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Using NSF grant money to attend SIGCSE TS in Toronto Wed 13 Jul 2022

From Paul Tyman, NSF Program Director Division of Undergraduate Education on March 10, 2022.

If you are not a PI on an NSF award, and/or do not plan to use NSF money in conjunction with the SIGCSE Technical Symposium next year, you can stop reading now.

You are probably aware that for the first time the SIGCSE Technical Symposium will be held outside of the United States. Some of you may be planning on using NSF money to attend the symposium and/or to hold dissemination events at the conference and may be wondering if there are any issues using NSF money to do so.

The NSF does not require any notification or request to move funds from “domestic” travel to “international” travel. This is like any other form of line-item re-budgeting. Except for a few types of re-budgeting (e.g., movement of funds out of Participant Support, addition of travel support for dependents, movement of funds to Construction), NSF approval is not required unless the budgetary change also reflects a “change in objectives or scope” (i.e., a major change in the project). The grantee institution is responsible for documenting and approving internally, according to its usual procedures, the justification for any re-budgeting that is done. The NSF does not get involved unless the re-budgeting is one of the few types that requires prior NSF approval.

There is, however, one issue that you need to be aware of. Foreign travel is subject to the “Fly America Act” requirement described in Article 14 (Travel), Sections c and d, of the NSF-specific Research Terms & Conditions (RTC) here: https://www.nsf.gov/bfa/dias/policy/fedrtc/agencyspecifics/nsf_1021.pdf. In a nutshell, if you decide to fly on a non-US carrier, the ticket must be a code-share ticket bought through a U.S. carrier. So, for example if you decide to fly on an Air Canada plane, the ticket must be a code-share ticket bought through a U.S. carrier such as United (one of Air Canada’s codeshare partners).

Finally, if you are planning on holding a workshop or other activity that has a cost associated with it, paying the Canadian companies for the normal services associated with hosting an event at the site will probably not pose a problem. You must always follow the procurement policies and procedures of your institution. But if you are paying the hotel, the AV company, the computer rental company, etc., for typical logistical costs associated with the workshop (room rental, food, A/V, etc.), those are small procurements (from budget line G6, “Other Direct Costs: Other,” in your grant budget) and will probably not raise a flag. Of course, I am referring to the situation in which such a workshop or other activity was part of your NSF proposal that was funded.

In case you are interested, or need to look up specifics, here are the sections/documents that provide the current policy related to travel and post-award requests:

PAPPG, “Travel” in proposals: https://www.nsf.gov/pubs/policydocs/pappg22_1/pappg_2.jsp#IIC2giv PAPPG, “Prior Written Approvals” (requirements): https://www.nsf.gov/pubs/policydocs/pappg22_1/pappg_10.jsp#XA3 Research Terms & Conditions Prior-Approval Requirements Matrix for Awards; see “NSF” column: https://www.nsf.gov/bfa/dias/policy/fedrtc/appendix_a.pdf NSF’s Agency-Specific Terms & Conditions for Awards, Article 14 (“Travel”): https://www.nsf.gov/bfa/dias/policy/fedrtc/agencyspecifics/nsf_1021.pdf Uniform Grant Guidance (UGG), “Travel Costs” (2 CFR § 200.475): https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-E/subject-group-ECFRed1f39f9b3d4e72/section-200.475 “Fly America Act” requirement, GSA: https://www.gsa.gov/policy-regulations/policy/travel-management-policy/fly-america-act GSA’s FAQs on the “Fly America Act”: https://procurement.vcu.edu/media/procurement/pdf/document-library/FlyAmericaAct_Printable_Combined.pdf – Paul Tymann Program Director Division of Undergraduate Education 703.292.2832 (office)