Procedure TR2001 International Travel Approval, Compliance, and Reimbursement

Process Owner: Central Procurement - Travel and Expense Team

Policy Steward facilitating procedure: Associate Vice President for Procurement, Contracts, and Accounts Payable/Chief Procurement Officer

Subject Matter Expert: Penn State Global

Purpose

This procedure operationalizes the requirements of Policy TR01 International Travel Safety and Requirements by establishing required steps for planning, approving, conducting, and reimbursing University-affiliated international travel.

This procedure defines:

Pre-travel approval and compliance requirements
During-travel compliance expectations
Post-travel reimbursement and financial processing requirements
Roles, responsibilities, and internal control points

For a detailed mapping of policy requirements to procedural steps, see Exhibit A Policy-Procedure Crosswalk.

Scope

This procedure applies to all international Business Travel.

Business Travel is any of 1) university-affiliated travel; 2) activities conducted in accord with Policy AC80 Faculty Outside Professional Activities and Conflict of Commitment; and 3) any Third Party Paid Travel (aka Sponsored or Reimbursed Travel).

Source of funding does not preempt this procedure.

Travel conducted under the Applied Research Laboratory (ARL) must also comply with ARL security registration procedures in addition to this procedure and Policy TR01 International Travel Safety and Requirements.

Definitions

All defined terms applicable to this procedure are set forth in Policy TR01 International Travel Safety and Requirements. This procedure does not create, modify, or interpret definitions.

In the event of any inconsistency, ambiguity, or conflict between this procedure and policy, Policy TR01 International Travel Safety and Requirements shall prevail. Nothing in this procedure is intended to supersede or modify the requirements established in Policy TR01 International Travel Safety and Requirements.

Roles and Responsibilities

The following roles are responsible for ensuring compliance with this procedure:

Traveler

Initiates Global Safety Network registration
Completes required training
Ensures compliance with export control, OFAC, and funding requirements
Submits complete and timely expense reports

Penn State Global (Global Safety)

Reviews and approves GSN submissions
Conducts restricted travel assessments
Issues GSN Travel Receipt

University Export Compliance Office

Conducts export control reviews
Determines licensing requirements for OFAC-Sanctioned destinations

Financial Approver

Review expense reports for allowability and compliance
Verifies supporting documentation
Approves or denies reimbursement

Central Procurement - Travel and Expenses Team

Provides oversight of travel compliance
Supports audit and monitoring activities

Vice Provost for Global

Approves, denies, or revokes international travel

PROCEDURE:

The steps below correspond directly to the requirements established in Policy TR01 International Travel Safety and Requirements. Refer to Exhibit A Policy-Procedure Crosswalk for alignment of each procedural step to its governing policy requirement.

Before Travel

Travelers will confirm travel is University International Business Travel, which is any of the following:

University Affiliated Travel

Research, teaching, administrative, or service activities conducted under the auspices of Penn State;
Participation in university led or university supported programs, partnerships, or projects including study abroad, recognized student organization travel, alternative Spring Break to international destinations, etc.;
Conferences, workshops, and professional development activities representing or furthering university interests;
Consulting, outside teaching, or other professional activities that arise from or are connected to the traveler's university affiliation;
Sabbaticals;
Research related travel conducted to advance scholarly or institutional goals;
Travel funded, reimbursed, coordinated, or otherwise facilitated by Penn State, Sponsored Research funds, hosting institutions, agencies, or self-funding linked to university duties or programs.

AC80 Related Activities

For activities conducted under the auspices of university Policy AC80 Faculty Outside Professional Activities and Conflict of Commitment that include international travel, such international travel must be recorded in GSN. AC80 related activities are:

Outside Professional Activities - Entrepreneurial or professional services, paid or unpaid, that are in the general area of expertise for which the faculty member is employed by the university, but are beyond the scope of the individual's university employment responsibilities.
Outside Teaching - A type of Outside Professional Activity that includes all semester length or equivalent teaching engagements, both within and outside of a faculty member's general area of expertise, at a postsecondary institution of higher education other than the Pennsylvania State University.
Research. Systematic investigation, study, or experiment designed to develop or contribute to general knowledge.

Includes basic or applied research that may or may not be published in an article, book, or book chapter and product development (e.g., a diagnostic test or drug).
Includes, but is not limited to, any activity for which sponsored funding is available from a federal, state, or local government agency, or a public or private entity, through a grant, contract, or cooperative agreement (e.g., a research grant, career development award, center grant, individual fellowship award, infrastructure award, institutional training grant, program project, research resources award, training grant, or outreach award) or gift.
Research may or may not be funded or sponsored.

Scholarly Activities. Activities that are generally expected of a faculty member as part of their professional portfolio, whether compensated or uncompensated. Note: while policy AC80 does not require disclosure or prior approval for Scholarly Activities, international travel related to Scholarly Activities must be recorded in GSN.

Third-Party Paid Travel

Third-Party Paid Travel is travel for which any entity other than Penn State pays for or provides some or all the participation-related or travel-related costs incurred by a Penn State employee. Third-Party Paid Travel includes "Sponsored or Reimbursed Travel." Such travel must be recorded in GSN when the travel is:

Connected to the employee's university role, expertise, or professional standing; or
Connected to AC80 related activities; or
Sponsored, reimbursed, or facilitated by an outside organization (including corporations, nonprofits, governments, host institutions) that provides any portion of travel or participation related costs such as transportation, lodging, meals, per diem, registration fees, stipend, or honorarium, etc.

If yes, all relevant steps below are required.

Step 1: Register Travel in the Global Safety Network (GSN)

All international travel must be recorded in Global Safety Network (GSN) before departure. The GSN serves as the system of record for international travel approval and compliance validation.

GSN approval shall not be granted unless:

University international insurance enrollment is confirmed, and
Any required rider documentation is uploaded and verified

Education Abroad program participants, regardless of program duration or the presence of a Penn State program leader, are registered in the GSN by the Penn State Global Education Abroad office. Participants and leaders do not need to independently register this travel or petition for its approval directly in the GSN.

Submission Timelines

Non-Restricted Travel Destinations: Submit at least seven (7) business days before departure
Restricted Travel Destinations:

Initiate documentation in GSN at least 30 days before departure
Complete documentation in GSN no later than 14 business days before departure

Group Travel: Submit at least 30 business days before departure
GSN submission automatically initiates:

Restricted travel review (if applicable)
Export control review request

Travel may not proceed until all required approvals are completed in GSN
Non-refundable expenses incurred prior to approval are at the traveler's risk and may not be reimbursed

Penn State Global identifies restricted travel destinations at the Global Safety website.

Travel Authorization and University Authority

International travel is not authorized until all required approvals are granted through GSN and any required Restricted Travel review is complete.

The Vice Provost for Global has the authority to suspend, deny, or revoke approval, at any time, for international travel that presents unacceptable safety, legal, compliance, or reputational risk.

Failure to obtain required approval before departure may result in:

Cancellation or suspension of travel
Denial of reimbursement
Disciplinary action

Restricted Destination Determination

Submitting travel documentation initiates a review to determine whether the destination is subject to the university's Restricted Travel Petition process.

If subject to the university's Restricted Travel Petition process, travelers will be prompted to complete the petition.

Adjudication of the petition is required and will be provided before travel can commence.

Do not incur non-refundable expenses before approval.

War Risk Exclusion

In the event a Penn State student or employee seeks to conduct university business travel to a location identified as a war risk region, the traveler's academic college is required to either purchase an insurance rider to cover all non-covered expenses for injury or evacuation or assume financial responsibility for all such non-covered expenses should they occur. Proof of the rider or assumption of financial risk must be provided in writing as part of the travel documentation process.

Undergraduate student travel to destinations identified under the University's War Risk Exclusion is prohibited. No undergraduate student may participate in University International Business Travel to such locations, regardless of funding source or academic purpose.

Step 2: Obtain GSN Travel Receipt

A GSN Travel Receipt is a required control document confirming that all pre-travel compliance and approval requirements have been met.

A valid GSN Travel Receipt is required for:

Travel authorization documentation
Reimbursement eligibility

Travel without a valid GSN Travel Receipt may be considered non-compliant and may result in denial of reimbursement.

Federal Funding Compliance Requirements

For federally funded travel:

Travel must comply with Uniform Guidance 2 CRF 200
Airfare compliance with the Fly America Act (49 U.S.C. 40118) must be verified during expense review
Any exceptions must include:

Written justification
Supporting documentation

Expense reports lacking required documentation will be denied or returned for correction.

Failure to meet federal funding requirements may result in cost disallowance and denial of reimbursement.

If required GSN registration deadlines are missed:

The travel may be marked non-compliant.
Reimbursement may be denied.
A written remediation request from the Dean, Chancellor, or Budget Executive of the traveler may be submitted to the Vice Provost for Global for review and determination whether to issue a travel receipt.

Travel expenses incurred before required approval are at the traveler's own risk.

Step 3: Complete Required Training:

Students

Complete required pre-departure orientation.
Education Abroad students must complete their pre-departure orientation for each program.

Group Leaders

Complete "Pre-Departure Orientation for Leaders."
Must attend at least once every two years.
Must complete training no later than 10 business days before departure.

Travel may not proceed if training is incomplete.

Student Group Planning Requirements

See Policy TR03 Student Group Travel for Student Group and Student Organization distinctions.

For student group travel, age verification must be documented prior to GSN approval. No participant under 18 may travel.

Group Leader to Student Ratios

1-4 students: minimum one (1) employee
5-20 students: minimum two (2) employees
21+ students: minimum two (2) employees plus one (1) additional employee or authorized volunteer per 10 students or fraction thereof (ex: 24 students require three (3) employees; 33 students requires four (4) employees, etc.)

Deviation requires written approval.

Group Leader Responsibilities

Group Leaders must:

Oversee academic activities
Supervise cultural and extracurricular events
Manage travel logistics
Monitor safety and conduct
Respond to emergencies
Support student welfare

External Participants Approval

Spouses, partners, children, or others may only participate if:

Approved in writing by VP, Global
Properly classified (e.g., authorized volunteer)
Allowable per host and/or third-party partner policy

Unapproved participants may not join any university international business travel including University-affiliated student group travel.

Export Compliance Review

Export compliance review is automatically triggered upon GSN submission.

Traveler must:

Disclose all equipment, data, and technology being transported
Obtain documented approval from UECO prior to departure

Required documentation:

Export clearance confirmation OR
Applicable export license documentation

Export approval documentation must be retained and attached to the expense report prior to reimbursement.

Travel may not proceed without export compliance clearance where required.

OFAC-Sanctioned Countries

For travel to OFAC-sanctioned countries:

University Export Compliance Office (UECO) must determine whether:

A general license applies, or
A specific license is required

If a specific license is required:

Written authorization from OFAC must be obtained prior to travel

Travel may not proceed without required OFAC authorization:

Documentation must be:

Uploaded in GSN
Retained per Policy AD35 University Archives and Records Management
Attached to the expense report

NSPM-33 Research Security Requirements

For federally funded research travel:

Required research security disclosures must be completed.
Required training must be current.
International collaborations must comply with federal security guidance.

Travel may not proceed if required research security obligations are unmet.

During Travel Compliance Requirements:

While traveling, the traveler must comply with Policy TR02 Penn State Travel including:

Retain itemized receipts for all expenses
Comply with:

Approved itinerary
Per diem and allowable expense limits

Safeguard:

University data
Devices and export-controlled information

Report:

Safety incidents to Penn State Global
Compliance issues to appropriate offices

Failure to comply may result in denial of reimbursement or disciplinary action.

After Travel Expense Reconciliation and Reimbursement

Financial reimbursement processing must comply with Policy TR02 Penn State Travel. This procedure establishes additional compliance requirements specific to international travel.

Upon completion of travel, the traveler must: