International Research Administration
The following information provides resources for faculty and staff to plan and implement international research activities in a manner that is compliant with applicable sponsor and federal regulations. Duke University is committed to supporting these activities, from long-term projects with a physical footprint to the management of foreign subrecipients. The following guidelines, contacts, and forms are meant to assist the Grant Manager (GM) and Principle Investigator (PI) with pre- and post-award issues and considerations for projects with a foreign component.
These activities may vary in location, nature and circumstances from those research activities conducted on Duke’s campus; therefore, it is important for GMs and PIs to verify the appropriate regulations applicable to their awards. Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency.
Federal awards should be managed in accordance with 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance). These guidelines pertain to federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-Federal sponsor’s policies and/or procedures.
For information on Duke’s Global activities, including service and scholarship, visit the Duke Global website.
Originating authority: 2 CFR 200.412-200.413 Classification of costs; Direct Costs.
When developing proposal budgets for projects that will incur costs in an international environment (whether in the form of a long-term research site, short-term travel or other circumstances), PIs and GMs should consult with their respective pre-award offices to determine the allowability of direct costs typically not found in domestic proposals. International environments are unlike those circumstances that exist on Duke’s campus or other domestically-based projects, and therefore costs such as security, administrative, payroll and other fees incurred in the process of conducting research may be allowable if they otherwise meet AAR requirements and are costs that are specifically identifiable to a project.
The pre-award offices, in consultation with appropriate central office personnel will review award documents and applicable regulations to provide the PI and GM with an assessment of the costing environment. Note that expenses are still subject to the standards of GAP 200.320, Direct Costing on Sponsored Projects.
If expenses are not included in the application or proposal, but occur during the life of the award they may still be allowable, but appropriate documentation will be required and these expenses will likely reduce available funding in other direct cost budget categories.
Originating authority: 2 CFR 200.431 Compensation – fringe benefits.
Applicability: Hiring in international settings.
In accordance with federal regulations and Duke University Human Resources Policies, Duke provides “adequate” support for fringe benefits for individuals performing duties and responsibilities relating to University business or sponsored projects executed by an agent of the University in an international setting. The level of support for benefits will be dependent on the type of work being performed, the provisions of the employee contract, and the local laws and environment as these may create unlike circumstances for employees.
The scope of benefit support will be dependent on the specifics of the situation being considered including employment status, duration of the assignment, and geographic location.
Fringe benefits for individuals working in an international setting consist of health care, leave, and benefits required by the laws and regulations of the locality where the work is being performed (which may include, but are not limited to, national workers comp, a thirteenth month, or pensions). Where appropriate, this support may also include benefits which are customary in the locality where the work is being performed. Where it is not practical for certain benefits such as health care to be purchased by Duke on behalf of an individual, the benefit may be provided via a Duke-supported mechanism, to be determined in consultation with pre-award, financial services, and human resources representatives.
When developing a budget for a project that will engage individuals in an international setting, the Principal Investigator should consult with Financial Services and with their respective pre-award research offices to review the circumstances and determine the appropriate method for providing fringe benefits. Note: When charging fringe benefits to a federal grant, determinations of scope and costs should adhere to definition of reasonable costs as stated in 2 CFR 200.404.
Originating authority: 2 CFR 200.440 Exchange rates.
Applicability: Spending Project Funds; International Activity
Cost increases for goods and services due to fluctuations in exchange rates are allowable costs, subject to the availability of funding. PIs may rebudget funds as necessary, with documentation; however, unless the terms of the award state otherwise, the PI must receive prior approval if the cost increases result in the need for additional funding from the sponsor. Communication with the sponsor must be coordinated with the respective pre-award office. Requests must be made prior to the expiration date of the Federal award and must be properly documented. The Grant Manager and PI are responsible for monitoring the amount of remaining funds in USD and local currency.
The Office of Sponsored Projects (OSP) generally prepares invoices submitted to a foreign sponsor. Duke’s preference is to receive contracts in USD. However, in the event these invoices requirement payment in a currency that is not USD, OSP uses the OANDA currency calculator to determine the exchange rate at time of invoice submission.
Originating authority: 2 CFR 200.473 Transportation costs.
Applicability: Sending money to a bank external to the U.S.; Spending Project Funds
Fees associated with wire transfers of funds to foreign recipients are an allowable expense and can be direct charged to a project. Adequate documentation must be provided to confirm the expense is specifically identifiable to the project being charged. In addition, PIs and GMs should consult award documents to ensure wire fees are not specifically unallowable on the award. Wire fees to pay subrecipient invoices should be allocated to the parent code.
Originating authority: 2 CFR 200.474 (e); 49 U.S.C. 40118
Applicability: Air travel funded by federal awards
Please note that air travel funded by federal awards is subject to the Fly America Act. This Act requires that all flights charged to federally-funded projects must use U.S. flag air carriers or foreign air carriers that code share with a U.S. flag carrier. This includes flights within the U.S., flights between the U.S. and an international destination or between international destinations. There are exceptions to this requirement, including Open Skies Agreements and City Pairs Programs.
Please note that any individual planning to charge travel (domestic or international) to a federal award is responsible for knowing and adhering to the Fly America Act requirements.
Originating authority: Foreign Corrupt Practices Act of 1977 (FCPA) 15 U.S.C 78dd-1, et seq.)
Applicability: International activity
The Duke University Compliance Program, through the Office of Export Controls, maintains and implements the Duke University Anti-Corruption Policy. Any individual employed by or acting on behalf of Duke, including faculty members serving as PI’s, research associates, and administrative staff must comply with the Foreign Corrupt Practices Act (FCPA), United Kingdom Bribery Act (UKBA) and other applicable anti-bribery and anti-corruption law and regulations when engaging in activity around the world. Individuals may not give or promise a bribe (anything of value) to a foreign official or an employee, representative or agent of the same with the intent to gain a business advantage.
The following materials were developed for the International Research Administration Symposium, hosted by Research Costing & Compliance on August 9, 2017.
- Resource Guide to Supporting International Research. A matrix of activities occurring in International Research and Duke University offices involved in supporting these activities.
- Decision tree for escalating questions regarding international research.