Hi everyone,

I am writing to inquire how your institutions handle travel on grants for personnel (students, staff, faculty, or outside colleagues) who do not report effort on a project. While my specific example below is in regards to travel on NSF grants, I would also appreciate feedback regarding this question in general as these questions have been raised on projects sponsored by other funders as well. I would like to stress that we are only talking about travel under the “Travel” category and not under “Consultants” or “Participant Support.”

In the NSF General Grant Conditions, it states:

Travel

a. Allowability of Travel Expenses

1. Expenses for transportation, lodging, subsistence and related items incurred by project personnel and by outside consultants employed on the project (see GPG Chapter II.C.2.g(iv)) who are in travel status on business related to an NSF-supported project are allowable as prescribed in the governing cost principles. Except as noted in paragraph b. below, the requirements for prior approval specified in 2 CFR § 200.474 are waived.

My question is regarding the term “project personnel.” Other than those noted within the grant budget and proposal, we have faculty who stress that GRAs or faculty not funded by the project may still be working on the project without reporting effort. Thus, they say they should be considered project personnel eligible to travel under that grant. Our concerns regarding allowing personnel not reporting effort to travel on these grants comes down to several issues. First, our internal rules stress that those working on a sponsored project should have an appropriate level of effort charged to the project (which is captured in our system by payroll charges). Second, we have located three OIG audits (including one from NSF) in which travel costs by individuals not charging effort to the project were questioned. Finally, there is a concern that demonstrating who is or is not project personnel puts a high burden of proof on the institution, and thus, the best way to document this is through effort reporting. Would your institution agree or disagree? Any thoughts or suggestions would be greatly appreciated.

Thank you!

Nicole Whetstine, MNM, CRA
Grant Administrator
Office of Sponsored Research Administration
Embry-Riddle Aeronautical University
(386) 226-6451
xxxxxx@erau.edu

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