Business Policies and Procedures Manual
Chapter 95: Travel
International Travel Policy
BPPM 95.53
For more information contact:
Risk Management Services
509-335-6893 / compliance.risk@wsu.edu
International Programs
509-335-2541 / ip.admin@wsu.edu
Payment Services
509-335-2038 / travel@wsu.edu
Office of Research Support and Operations
509-335-0890 / orso@wsu.edu
Contents
- 1.0 Policy and Purpose
- 2.0 Applicability
- 3.0 Definitions
- 4.0 Faculty, Staff, and Authorized Volunteer Travel
- 5.0 Student Travel
- 6.0 Travel by Federally Funded Researchers (Foreign Travel Security Program)
- 7.0 Faculty-Led Study Abroad Programs
- 8.0 International Travel Registry
- 9.0 Travel to High-Risk Destinations
- 10.0 Related Policies
Policy and Purpose
It is the policy of WSU to support international travel for research and educational activities, while taking reasonable steps to mitigate risk to students, faculty, staff, and the institution. State and federal laws impose specific requirements which may vary depending on the types of travel. Example: Individuals engaged in federally-funded research traveling for research-related or other professional purposes must adhere to federal foreign travel security requirements. See Section 6.0.
This policy consolidates and links to various requirements and resources available to assist members of the University community engaging in international travel.
2.0 Applicability
This policy applies to faculty, staff, volunteers, and students travelling internationally for University-related purposes.
3.0 Definitions
High-Risk Destination: A high-risk destination is any country, region and/or city with a Level 3 or Level 4 travel advisory rating issued by the U.S. Department of State, Travel Advisories. WSU may also consider as a high-risk destination any location that poses a health, safety, or security risk, as indicated by other agencies such as the Center for Disease Control.
International Travel: International travel is travel to any non-U.S. location outside of the 50 states (including Hawaii, Alaska, and District of Columbia) and outside of the U.S territories (Puerto Rico, Guam, U.S Virgin Islands, Northern Mariana Islands, American Samoa, and Swains Island). The term “international travel” is used interchangeably with “foreign travel” in this policy.
Student: For purposes of this policy, a student is defined as any person who is enrolled in at least one undergraduate, graduate, or professional studies course, including during their time abroad or during an adjacent term at WSU.
4.0 Faculty, Staff, and Authorized Volunteer Travel
4.1 Criteria
Faculty, staff, and volunteers may request authorization for international travel for University-related business, which includes, but is not limited to, the following:
- To allow active participation in research projects or creative activities
- To teach
- To make use of unique library or similar resources
- To allow participation in a significant international professional meeting
- To develop international education, research, and/or training projects
4.2 Approval
All international travel requires prior approval by an authorized University official, regardless of whether the travel is being paid for by a University account or by a third party. All international travelers are to initiate a Spend Authorization in Workday to request approval for foreign travel. (See BPPM 95.01 and the Workday Create Spend Authorization reference guide.) The Spend Authorization requires international travelers to list:
- Each country to which they are traveling,
- The dates of the travel, and
- The general purpose of the travel.
Contact Risk Management for assistance with obtaining Spend Authorization approval in Workday for individuals whose travel is fully funded by third parties and who are not on the WSU payroll (e.g., visiting scholars, volunteers, and unpaid students working on research grants). Such individuals are processed as “external committee members” in Workday (see BPPM 95.21).
Any faculty or staff member who is on an employment-based visa sponsored by WSU and processed by International Programs (IP)-International Student and Scholar Services (ISSS) should check in with IP-ISSS far in advance of international travel to ensure maintenance of visa status.
4.3 Food and Lodging
Foreign travel food and lodging rates are available from Travel Services, as well as the U.S. Department of State Foreign Per Diem Rates website. These are the maximum amounts that may be reimbursed. (See also BPPM 95.19.)
For travel supported by sponsored projects, travelers are responsible for applying the sponsor’s procedures as detailed in the agreement and/or regulations when appropriate. If a sponsor specifies a different per diem rate, the lower of the two rates applies. State of Washington and WSU procedures supersede a sponsor’s procedures when the sponsor is less restrictive. For long-term travel, some sponsors’ agreements and/or regulations may provide for additional specified travel and residence expenditures. However, travelers are not to be reimbursed for more than the actual expenses of travel except for meals that can be reimbursed on an allowance basis. See BPPM 95.16 and 95.19.
See BPPM 95.06 for reimbursement procedures.
4.4 Air Carriers
University travelers generally are required to use U.S.-flag air carriers for international air transportation, with some exceptions. If a foreign carrier is used, the traveler is to justify the use of the foreign carrier on a Spend Authorization or Expense Report in Workday. The state of Washington considers economy to be the primary criteria to apply when making travel decisions.
International travel supported by federal funds is subject to the Fly America Act, which requires the use of U.S. carriers regardless of cost or convenience (see BPPM 95.45).
4.5 International Travel Supported by Sponsored Projects
Before undertaking international travel, travelers are to ascertain that the planned travel is allowable under the sponsor’s current regulations and the terms of the agreement. In addition, some sponsors require that international travel be itemized in the proposal and award agreement budgets.
4.6 Export Controls and Restricted Travel
All WSU employees are expected to comply with export controls and restrictions on travel to Office of Foreign Assets Control (OFAC) sanctioned countries or countries identified in 22 CFR 126.1 (Prohibited exports, imports, and sales to or from certain countries).
The Office of Research Assurances (ORA) publishes comprehensive guidelines regarding export controls, including an export control decision tree to help WSU employees determine whether and to what extent export controls apply. Federally funded researchers are required to contact ORA for a mandatory security briefing prior to traveling to countries identified above (see Section 6.0).
5.0 Student Travel
WSU’s Office of International Programs facilitates and coordinates student travel for purposes of study abroad and other international travel related to their WSU experience. Detailed information about programs and requirements is available on the International Programs website.
Students travelling for research-related purposes may be subject to federal regulations, including those in Section 6.0. Students are to work with their advisor(s) and the Office of Research Support and Operations (ORSO) to ensure compliance.
International students on a visa should check with IP-ISSS far in advance of international travel to ensure maintenance of visa status.
All WSU students travelling internationally for WSU purposes are required to register with WSU’s International Travel Registry (see Section 8.0).
6.0 Travel by Federally Funded Researchers (Foreign Travel Security Program)
As a covered research organization, WSU is required to maintain international travel policies for covered individuals engaged in federally funded research and development who are travelling internationally for research or other professional purposes. As required by National Security Presidential Memorandum NSPM-33, WSU’s policies regarding foreign travel security for researchers include the following:
6.1 Required Records of International Travel
WSU must maintain an organizational record of covered international travel by covered individuals engaged in federally funded research and development:
- Section 4.2 of this policy requires all international travelers to obtain advanced approval from an authorized University official (as defined in BPPM 95.01) prior to international travel.
- The completion and approval of the Workday Spend Authorization creates an organizational record of the international travel and its purpose that is maintained for the retention period required by state law.
The offices of Risk Management Services and International Programs can create reports in Workday of all University-related international travel by employees. (See also BPPM 30.07.)
6.2 Advance Disclosure and Authorization
WSU must implement a disclosure and authorization requirement in advance of international travel:
- All international travel must be disclosed and approved in advance by an authorized University official. See Section 4.2.
- Travelers who receive funding from a Public Health Service (PHS) entity or other entity that has adopted PHS regulations also must submit a significant financial interest disclosure form prior to travel through WSU’s MyResearch portal. The Workday Spend Authorization form includes a prominent notice of this requirement.
6.3 Mandatory Notifications
WSU must provide the following notifications:
- Mandatory applicable security briefings; and
- Advice regarding electronic device security prior to covered international travel; or
- Security advice prior to travel including electronic devices used for federally-funded research and development or purchased with federal funding.
To meet these requirements, WSU’s Spend Authorization includes the following prominent notices to travelers:
- Notice to federally-funded researchers of mandatory security briefings by WSU’s Office of Research Assurances prior to travel to Office of Foreign Assets Control (OFAC) sanctioned countries or countries identified in 22 CFR 126.1 (Prohibited exports, imports, and sales to or from certain countries)
- Notice to all travelers of WSU’s Office of Research Support and Operations (ORSO) guidelines for international travel, including detailed Electronic Device Security Tips for International Travel compiled by WSU’s Information Technology Services (ITS)
- Notice informing all travelers of the federal resources available at the U.S. Department of State’s Travel.State.Gov website, which provides travel advisories, safety and security information, and other important travel regulations and guidelines
7.0 Faculty-Led Study Abroad Programs
A faculty-led program is a study abroad experience in which WSU faculty/staff facilitate an international educational experience. Faculty-led programs typically are credit-bearing; however, faculty may lead students on non-credit-bearing experiences, which also fall within the purview of the Office of International Programs–Global Learning Department (IP-GL). Faculty-led programs are offered during the fall, winter break, spring, spring break, or summer semesters.
All faculty-led programs are to be led by at least two program leaders with exceptions made by IP-GL in scenarios in which the host institution is capable of providing program leadership and teaching in the event that the faculty member becomes incapable of leading the program. For large faculty-led programs, it is suggested that program leadership increase by one faculty member per 10-12 students participating but is negotiable based on program design.
Participants may include students with WSU ID numbers and faculty or staff program leaders. With the notification to a college dean or designee, program leaders may have an accompanying individual, limited to a spouse or legal partner, travel adjacent to the faculty-led program. This individual and the faculty member must sign an assumption of risk, statement of understanding, and release of claims and liability document indicating they understand that:
- WSU assumes no responsibility for the accompanying individual,
- The accompanying individual may not participate in program activities; and
- The accompanying individual must submit a background check, at their own expense.
Minor children of faculty may not participate in program activities. If they are in the country at the same time, they must have 24-hour care by a provider other than the program leader during the program. All costs incurred by any accompanying individual and/or minor child must be borne by the program leader. The University is not responsible for injury, illness, property damage, or any other occurrence related to these individuals, nor are they covered by WSU’s international travel insurance. Other non-WSU individuals are not permitted to participate.
7.1 Administration
IP-GL administers and coordinates all faculty-led study abroad programs for the University.
IP-GL works with sponsoring units to develop and monitor all faculty-led study abroad programs. To develop a faculty-led program, a sponsoring unit may contact IP-GL for assistance. Units may refer to the IP-GL development process website for more information.
7.2 International Agreements
International agreements (IAs) are processed in accordance with procedures in BPPM 10.42. In addition to applicable procedures in that section, individuals and departments initiating faculty-led study abroad programs are responsible for applying the following procedures.
7.3 Agreement Requirements
International Programs (IP) is responsible for agreement development for faculty-led study abroad programs. Any faculty-led study abroad program involving a third-party provider and/or educational institution requires an IA. (See BPPM 10.42.) These agreements define all aspects of faculty-led programs between WSU sponsoring units and third-party providers and/or educational institutions in the United States and/or in foreign countries.
Faculty-led program IAs must contain details pertaining to the parties’ contractual relationship including, but not limited to:
- Program description
- Duties of each party
- Costs, billing, refund and payment procedures
- Dates of service
- Scope of service
- Insurance and liability
7.4 Procedures
Procedures for faculty-led study abroad program development are outlined briefly below:
- The sponsoring unit develops a faculty-led program proposal and itinerary. The sponsoring unit must submit the proposal to IP-GL 12 to 18 months in advance of departure. (Online proposal forms and deadlines are available on the IP-GL development process website.)
- IP-GL assesses faculty-led program itineraries and contractors for risk. The International Safety, Health, and Security Committee reviews itineraries and contractors with potential risk factors and recommends approvals or revisions.
- IP develops and manages a program budget in collaboration with the sponsoring unit. The program budget determines income to be collected through program fees and tuition.
- IP bills and collects faculty-led program fees from student participants. Program fees are held in agency accounts managed by IP. Tuition goes to the departments owning courses. Tuition and/or agency funds may be used to support faculty-led program expenses, not including program leader compensation. Program fees may not be used to pay faculty/leader salary.
- IP ensures that faculty-led program courses are posted with the appropriate course attributes related to the faculty led program coursework, though it is up to the academic unit offering the program to ensure that a course exists.
- The faculty-led program and budget are approved by IP, the faculty-led program director(s), and the sponsoring unit’s approving authority, fiscal representative, and other designees.
- Faculty-led program fees may not be increased once approved, marketed, and tuition is determined by the Board of Regents.
- IP drafts and routes IAs for approval.
- Student participants must submit applications for faculty-led programs through IP-GL by specified deadlines.
- After program deadlines, IP-GL totals the completed applications and compares the number of requests against the program budgets. IP-GL confirms or cancels programs in consultation with sponsoring units based on financial feasibility and sponsoring unit goals.
7.5 Additional Approvals
In addition to required approvals for any international agreement (see BPPM 10.42), these agreements require approval in the following order:
- Director of IP-GL
- College and academic unit leadership or designee
- Academic unit fiscal leader
- Vice President for International Programs or designee
8.0 Travel Registry and Insurance
8.1 Faculty, Staff, and Authorized Volunteers
WSU’s central administration covers the cost of international travel insurance and risk management resources for registered WSU employees and official volunteers. WSU employees, graduate students on paid assistantships and timeslip appointments, and volunteers are automatically registered for WSU’s Global Assistance and Insurance Program when their Workday Spend Authorization for international travel is approved.
Risk Management Services provides international travelers with a plan identification card that includes WSU’s policy number, a summary of the plan’s services and benefits, and contact information for assistance.
Plan services and benefits include access to the following international travel insurance and risk management resources:
- Emergency medical and security evacuation
- Repatriation of remains
- Some additional medical, travel, and security assistance
It is also recommended that individuals register their travel with the Consular Section of the U.S. Embassy through the State Department’s travel registration website by enrolling in the Smart Traveler Enrollment Program (STEP).
Insurance and other risk management resources are not provided to WSU employees and volunteers for personal travel or for family members. See BPPM 60.81 regarding the requirements for official University volunteers.
For further information, contact Compliance and Risk Management (CRM); e-mail compliance.risk@wsu.edu; telephone 509-335-6893; website CRM Who’s Who.
8.2 Travel Registry for Students
WSU requires all students participating in not-for-credit travel abroad for WSU-related activities to register with International Programs’ Global Learning International Travel Registry. This includes individual as well as group student travel.
8.2.a Applicability
The travel registry requirement pertains to all students traveling internationally as individuals or in groups, with or without University funding, for any WSU-sponsored, WSU-administered, or WSU-related not- for-credit activity or program. Activities and programs requiring registration include, but are not limited to:
- Research or creative activities
- Civic engagement
- Other educational, co-curricular, or business opportunities
Students planning to earn academic credit for their experience abroad are exempt from enrolling in the International Travel Registry and should refer to the application and documentation procedures for study abroad (including faculty-led programs, exchange, and third- party provider based programs. Contact International Programs’ Global Learning for guidance; e-mail ip.globallearning@wsu.edu.
8.2.b Goals and Services Provided
The goals of the International Travel Registry are as follows:
- Document all international travel by WSU students for not-for-credit WSU educational and/or business activities approved by department chairs, deans, and other unit authorities.
- Ensure the capability for timely communication between WSU and relevant parties in the event of an emergency or other unforeseen event.
- Assist travelers with the following preparations for a safe experience:
- Obtaining instructions on how to register with the U.S. Department of State (for U.S. citizens and permanent residents).
- Obtaining information about the Department of State’s Travel Warning and Travel Alert system.
- Purchasing health and travel insurance to ensure emergency medical and security evacuation and repatriation of remains services.
IP provides the following services to students who are registered for international travel:
- Instructs U.S. citizens and permanent residents on how to enroll in the U.S. Department of State’s Smart Traveler Enrollment Program (STEP).
- Alerts travelers to any unusual or significant circumstances related to the proposed destinations before departure, as well as while abroad.
- Notifies travelers to submit a Petition for Participation in a High Risk Area, if required.
- Enroll students in WSU International Health and Travel Insurance, which includes emergency medical and security evacuation and repatriation of remains services or ensures that equivalent coverage has been obtained.
- Provides predeparture orientation materials to ensure proper precautions are taken and resources are known and accessible to students.
8.2.c Registration Process
All students registered for international travel (for both credit and not-for-credit activities) are required to purchase WSU International Health and Travel Insurance, except for graduate students on paid assistantships and timeslip appointments during their time abroad.
The cost of the insurance is charged to the students’ accounts, which are accessed through myWSU. As part of their business decisions, academic units may opt to pay for the student insurance directly. Students who have comparable insurance that covers (at a minimum) emergency evacuation, repatriation of remains, injury, illness, and death while traveling internationally may request an exemption from purchasing WSU International Health and Travel Insurance. (RCW 28B.10.660(3)) Exemptions must be requested in advance and approved in writing by IP-GL prior to travel.
Students are required to register prior to departure in accordance with the procedures outlined below. WSU colleges, departments, faculty, and staff affiliated with such activities are responsible for ensuring that students document their travel plans through the online International Travel Registry.
Follow the steps below to complete the International Registry process.
8.2.c.i Log Into Registry
Log into the International Travel Registry.
8.2.c.ii Enter Required Information
The student traveler must provide all of the following information in the online registry:
- Travelers’ identification as it appears in their passport:
- Name
- Issuing country
- Passport number
- Expiration date
- Dates of travel
- Itinerary including location(s) and housing details, where known
- Contact information for the vendor providing support for the international experience.
- Traveler’s contact information while abroad
- Emergency contact information
- WSU mentor or sponsor’s contact information including:
- Name
- Title
- Department and/or program
- E-mail address
- Telephone (office and mobile)
- Additional information as requested by IP, e.g., travel to high risk areas as designated by the U.S. Department of State.
8.2.c.iii Complete Questionnaires
Complete the questionnaires and provide electronic authorization for the participation agreement, liability forms, and other documents, as required.
8.2.c.iv Review Orientation Materials
Review all predeparture orientation materials.
8.2.c.v Contact IP with Questions
Contact the Office of International Programs (IP) with any questions.
9.0 Travel to High-Risk Destinations
WSU’s Risk Management Executive Committee (RMEC) has authority to limit or prohibit travel to high-risk destinations (defined in Section 3.0) whenever it deems such travel to pose an unreasonable threat to health, safety, or security. See EP6 (Policy on Risk Management). Subject to this authority, general requirements and limitations related to travel to high-risk destinations are set forth below.
9.1 Students
Undergraduate students may not travel to destinations with a Level 4 or equivalent travel advisory rating. For destinations with a Level 3 or equivalent travel advisory rating, undergraduate students must request prior review and authorization from IP-GL for both the program locations and the program vendors.
Graduate and professional students may travel to destinations with a Level 3 or 4 travel advisory rating only upon prior review and authorization from IP-GL.
IP-GL requires all students traveling to high-risk destinations to complete and submit an assumption of risk and release of liability form. Contact IP-GL to obtain the form; e-mail ip.globallearning@wsu.edu.
9.2 Faculty, Staff, and Authorized Volunteers
Subject to the authority of RMEC, WSU does not generally impose restrictions on travel to high-risk destinations for faculty, staff, and authorized volunteers. All personnel are expected to be familiar with current U.S. Department of State travel advisories and to comply with export controls and restricted travel as set forth in Section 4.6. Federally-funded researchers must also comply with the requirements in Section 6.0.
IP-GL requires all faculty, staff, and authorized volunteers traveling to high-risk destinations with students to complete and submit an assumption of risk and release of liability form. Contact IP-GL to obtain the form; e-mail ip.globallearning@wsu.edu.
10.0 Related Policies
EP27: University Research Personnel Conflict of Interest, Technology Transfer, and State Ethics Requirements)
BPPM 10.42: International MOUs and Agreements
BPPM 95.01: Travel Management
BPPM 95.06: Meals and Lodging
BPPM 95.45: Fly America Act
_______________________
Revisions: November 2023 – new policy (Rev. 619).