Written by Justo Torres.
If you are a department of college grant manager or research administrator, you have probably encountered the scenario where a principal investigator asks the following question: “Can I travel internationally on my contract or grant?”
On one hand, if you say no, you may be limiting research and grant activity without a solid reason. On the other hand, if you say yes, you might be breaking some rule that you are not sure even exists. So, like any good research administrator, you say: “it depends.” While this is the correct answer, let’s take it a step further and see what this answer depends upon.
| Criteria | Question(s) | Answer |
|---|---|---|
| What (purpose) | ○ Does the trip align with the scope and goals of the contract or grant? ○ Does the PI need to meet in person? ○ Is the trip to attend a conference on the grant’s topic or will research results be presented? | If yes, you are off to a good start. |
| What (budget) | Is this specific international trip budgeted and proposed in the original proposal? | If not, you may need to seek pre-approval from your sponsor. Please note, this can take some time, so plan well in advance of your trip. |
| Where | ○ Is the travel destination a restricted country? ○ Are you taking scientific equipment or scientific knowledge that might be considered a deemed export and can be a violation of export control laws? | The travel destination can be critical. Foreign travel to certain nations can be restricted. Additionally, the taking of scientific equipment (even laptops) or scientific knowledge can be considered a deemed export and can be a violation of export control laws. Countries such as Cuba, North Korea, Iran, and Syria are restricted. Additionally, there are certain regions of the world that the State Department advises U.S. citizens not to travel to. These are typically regions that present a hazard to foreign individuals due to health, war, or other political tensions. |
| How | Does the travel comply with the Fly America Act? | International travel using federal funding requires compliance with the Fly America Act. In short, any international travel on a Federal contract or grant requires use of the U.S. flagged carrier. There are exceptions that can be found in the resource below. |
| Who | Are sponsor-specific rules around international travel followed? | Aside from the Uniform Guidance, there could be sponsor-specific rules around international travel that need to be followed. Check with your funding agency’s guidelines. |
Additional resources to help with these questions can be found on the links below.
- Export Control registrations: