What is Sponsored Travel?
Sponsored Travel is any travel expense that has been paid directly for you by a third party or for which you have been reimbursed directly by a third party. This includes the travel expenses of your spouse and dependents if the travel is in conjunction with your professional activities.
Who must report Sponsored Travel?
Any principal investigator or any member of the key personnel on any project funded by the U.S. Public Health Service, e.g. NIH and CDC, and any principal investigator or member of the key personnel of any project that is a sub-award or subcontract under another entity’s PHS-funded project must report Sponsored Travel. Key personnel include individuals who are directly appointed and charged to the project and those whose effort is cost-shared. Individuals who anticipate receiving PHS-funded awards should also report Sponsored Travel that will occur in the next 12 months or that is related in any way to the proposed PHS-funded project.
Why must I report Sponsored Travel?
Reporting of reimbursed or sponsored travel related to a PHS-funded Investigator’s institutional responsibilities is required under 42 CFR Part 50 Subpart F.
42 CFR Part 50 Subpart F promotes objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct, and reporting of research funded under Public Health Service (PHS) grants or cooperative agreements will be free from bias resulting from Investigator financial conflicts of interest. [Commonly known as the Financial Conflict of Interest (FCOI) regulations].
The FCOI regulations require all PHS funded investigators to “disclose the occurrence of any reimbursed or sponsored travel (i.e., that which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to their institutional responsibilities…” 42 CFR §50.603.
What Sponsored Travel should be reported?
The following MUST be reported. This is not an exhaustive list and investigators should report any reimbursed or Sponsored Travel that would reasonably be interpreted to be related to their PHS-funded research.
• Travel that is reimbursed or paid directly by any person or entity for whom you are serving as a consultant except other universities and government agencies as described below
• Travel that is reimbursed or paid directly by the sponsor of your research except other universities and government agencies as described below
• Travel that is reimbursed or paid directly by any vendor, prime contractor, or any sponsor of a sub-award or subcontract except other universities and government agencies as described below
• Travel that is reimbursed or paid directly by any for-profit company or non-profit organization, other than another university as described below, for speaking or participation in meetings, conferences, proceedings, etc.
• Travel that is reimbursed or paid directly for services as an expert witness
• Travel that is reimbursed or paid directly by any entity in which you have a personal financial interest such as a start-up company, a licensee of intellectual property that you invented or created, consulting company, or other business
Is there Sponsored Travel that I do not have to report?
Sponsored Travel for participation in many scholarly activities such as serving as a grant reviewer for a government agency, or serving on a government task force or panel does not need to be reported. The Sponsored Travel that DOES NOT need to be reported includes the following items.
• Travel that is reimbursed or paid directly by a federal, state, or local government agency
• Travel that is reimbursed or paid directly by an institution of higher education as defined at 20 U.S.C. 1001(a)
• Travel that is reimbursed or paid directly by an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education
• Travel reimbursed or paid directly by Clemson University
• Travel reimbursed or paid directly for service on National Academies panels, committees, roundtables, task forces, or membership meetings• Travel reimbursed or paid directly by non-profit organizations in which Clemson University is a member institution and for which you are serving as a member of its governing board, a panel or a task force where such service has been approved by the Institute