Janet and all,
We recently grappled with a similar situation. We had invited a federal
agency employee to give a talk about his agency's programs and to learn
about our research interests. His travel was to be paid by his agency.
But at the last minute, his agency said they didn't have the travel
funds for him. Since the presentation was already scheduled, one of our
people asked if he could still come if we paid his travel, and he said
yes. So he came, did his talk, learned about our research, went back
home, and then sent an invoice for his travel expenses. When the invoice
hit the system, it was flagged because everyone here, including me,
thought that paying for the travel was absolutely forbidden. Everyone
was in a tizzy about how we would make good on our offer to cover this
guy's expenses so they wouldn't have to come out of his personal pocket.
So I did a little research and determined that, contrary to what many of
us have always heard/believed, the FTRs do allow payment of federal
employees' travel expenses from non-federal sources. There are some
preapprovals required and some special conditions, but if all these are
met, it appears to be okay to pay. (See Chapter 304 of the FTR at
<http://www.gsa.gov/Portal/gsa/ep/programView.do?programId=8953&programPage=%2Fep%2Fprogram%2FgsaOverview.jsp&P=MTT&pageTypeId=8199&ooid=14161&channelId=-14863>
(long URL; if it doesn't work, just Google "Federal Travel
Regulations.") After assuring ourselves that our federal guest had met
all the special conditions, including pre-approval, we issued a check.
Note that the check went to his agency, not him personally, and it was
for actual travel expenses only. Janet, I think if the program officer
is willing to follow the FTRs and have everything pre-approved through
his agency as required (and note that he/she will need an official
written invitation from Radford), then I think, if the visit is for show
and tell, perhaps by both parties, you have nothing to worry about. If
your program officer isn't willing to follow the FTRs (like doing this
on vacation time), I would steer very clear. This all makes me wonder
how widely known Chapter 304 is in the federal circles. I had several
people here who are past NSF program officers who said we absolutely,
positively, never ever ever can pay travel expenses for a federal
employee. Maybe that was an internal NSF rule, and you may be dealing
with an internal agency policy in your case. But you might try gently
pointing the program officer to Chapter 304. Good luck!
Barbara

http://www.gsa.gov/Portal/gsa/ep/channelView.do?pageTypeId=8199&channelId=-16527&specialContentType=FTR&file=FTR/Chapter304p003.html#wp1135954

Hahn, Janet M wrote:

> I thought I knew that federal program officers only come to a campus
> on federal travel funds to avoid conflicts of interest, lobbying
> issues, etc.
>
> Today a PI said that the department would love to show the program
> officer what they have done with their instructional/service grant,
> but in speaking with the program officer, they have learned that if he
> comes to campus on federal money, he must conduct a site visit. While
> the PIs are delighted to show off the project, they would rather not
> deal with a site visit, perhaps because they people usual equate them
> with voluntarily submitting to surgery and perhaps because they will
> be in the midst of hosting a conference.
>
> According to the PI, the program officer is interested in
> visiting/getting out of DC, but if he is not conducting a site visit,
> he would do it on his annual leave and believes that it would be best
> if we paid for everything. He feels that if he gets reimbursed, it may
> be perceived as a bribe.
>
> I have NEVER known a program officer who was willing to have us to pay
> for anything (other than perhaps meals) and this makes me exceedingly
> suspicious. Before I tell the PI, “absolutely forbidden,” I thought
> I’d ask if ANYONE has agreed to such a situation.
>
> So the question is, have you ever had a current federal agency program
> officer visit your campus and university funds paid for any of the
> following?
>
> - car rental
>
> - airplane ticket
>
> - campus or off-campus lodgings at a rate below the federal travel
> reimbursement level
>
> - food
>
> - speaking fee? Not mentioned by the PI, but I figured I’d through
> that in, too.
>
> (Of course, my reaction was to wonder why a university would be
> willing to spend money for this and could come up with no legal answer).
>
> Janet
>
> *****
>
> Janet M. Hahn, C.R.A
>
> Exec Dir, Sponsored Programs & Grants Management
>
> Radford University
>
> Radford, VA 24142-6926
>
> tel: 540-831-5479
>
> fax: 540-831-6636
>
> xxxxxx@radford.edu
>
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--
Barbara H. Gray
Director of Sponsored Research
Desert Research Institute
2215 Raggio Parkway
Reno, Nevada  89512-1095
Telephone:	775-673-7381
Fax:		775-673-7459
E-mail:	xxxxxx@dri.edu
www.dri.edu

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