Notes on Travel Policy

Both 2 CFR 200 and USAID's standard provision on international travel refer to the recipient organization's written travel policy as determining the allowability of travel costs. Both of these sources refer to other federal regulations as providing the default conditions for cost allowability in the absence of a recipient's written policy.

Thus, although no regulation actually requires a recipient to do so, an organization may consider it to be in its best interest to maintain a written travel policy.

Key Points to Cover in your Travel Policy

Prior approval requirements

  • Although prior funder approvals are no longer a routine requirement for international travel, certain conditions still require such approval, and your policy should alert staff to any such conditions that they are likely to encounter and provide instructions for obtaining the necessary approvals.

Cost restrictions on commercial air travel

  • State your organization's understanding of "the basic least expensive unrestricted accommodations class." (Don't force your staff to figure this out for themselves.)
  • Establish rules for allowing and documenting deviations from "basic least expensive…" This may be guided by the conditions you typically encounter when traveling on organizational business.

Use of US-flag carriers

  • If travel cost is to be charged to a US federal award, require the use of US-flag carriers, if available.
  • Provide instructions on how the definition of "US-flag carrier" is expanded by the Open Skies agreements.
  • Provide guidelines and documentation standards for determining when a US-flag carrier is not available.

Cost restrictions on travel by privately owned vehicle

  • If your organization allows staff to travel in privately owned vehicles, adopt a mileage rate and define documentation standards.
  • Probably a good idea to establish safety standards too, like requiring wearing of seatbelts, etc.

Lodging standards and cost limitations

  • Establish minimum sanitation and safety standards for lodging when staff are in travel status, to assure personal safety of travelers.
  • Define reasonable maximum limits on travel lodging costs, to avoid unnecessarily costly accommodations.
  • Establish standards for reimbursement of costs, if staff are authorized to secure travel lodging on their own behalf. This might involve reimbursing only actual costs of lodging on the basis of written receipts and excluding ancillary services (though some services may reasonably be allowed as incidental costs).

Subsistence allowances and/or cost limitations

  • Establish basic allowances for meals and certain specific incidental expenses. It may be most efficient to do this through daily allowances, which may vary according to location, duration of travel, and whether or not the traveler is a resident of the country in which travel takes place.

See also:
About 2 CFR 200
Notes on ADS Series 300
About the Fly America rule
Olga Wall’s blog post of 03SEP14

Regulatory references

49 USC 40118 (the "Fly America rule")
2 CFR 200.474 Travel costs.
USAID Standard Provisions for US NGOs:

  • M17 Travel and International Air Transportation;
  • RAA4 Exchange Visitors and Participant Training; and
  • RAA13 Foreign Government Delegations to International Conferences

Good resources for guiding policy standards

DSSR (Department of State Standardized Regulations)
41 CFR 301, Parts 301-10 through 301-31 (Federal Travel Regulation, Chapter 301, Subchapter B — Allowable Travel Expenses)
48 CFR 31.205-46 (FAR cost principles on travel)

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