In its pursuit of excellence and global impact, Washington University strives equally for high-quality research management and compliance with regulations governing international research.
Resources below provide WU researchers with guides, resources, and best practices for managing awards across international boundaries.
Table of Contents
Disclosure, Compliance & Export Controls
International Subrecipient Monitoring
International Travel
Visiting Scholars
Managing Foreign Funds and Sites
Resources
Disclosure, Compliance & Export Controls
Given the significance of research topics and rising need for international collaboration, one can imagine that such partnerships occur amidst increasingly complex relationships and regulatory environments.
Learn about compliance and export control issues that may shape your international project.
Visit the International Disclosures, Compliance & Export Control page.
International Subrecipient Monitoring
A subrecipient is a third-party legal entity performing a portion of a University sponsored project or program (e.g. institution of higher education, hospitals, other non-profit entities, for-profit corporations and international organizations / institutions). The terms of the relationship are documented in a subaward/subcontract.
Relationships with international subawardees require particular attention and monitoring to ensure compliance between different research environments. International subrecipients are deemed “high-risk” subawardees and come with additional monitoring and reporting requirements.
For more information about best practices for monitoring your international subawardee, access the following resources
Start Here: Subrecipient Monitoring Guidelines
Visit the guide by Sponsored Projects Accounting.
International Travel
Travel on Sponsored Funds Guide
Guidance from WU Sponsored Projects Accounting for best practices in charging travel to external funding.
WU Global Travel Resources
Resources, policies, and travel registry information for WU international travelers.
Export Control and International Travel
United States export control laws may place restrictions on WHAT travelers send overseas (both shipped or hand carried), WHERE they travel to, WHO they meet, and the END USE of items exported.
- Are you bringing equipment, materials (e.g. biologicals) or technology on your international travel (other than laptop and cell phone)? Are you shipping items ahead?
- In order to avoid travel delays and possible export violations, if you are bringing items (other than a laptop and cell phone) with you or shipping items ahead to a foreign country, contact the Export Controls Office.
- Visit the following site for more details about export control and international travel.
Other considerations for travel on sponsored funds
US flag air carriers must be utilized for foreign travel on federal grants and contracts unless the flight qualifies as an exception under the Fly America Act. When using non-federal funds, US Flag Air carriers do not have to be used. (Sponsored Expenditures Guide – WUSTL SPA)
- If a foreign air carrier must be utilized for the trip, please refer to the Fly America Act, Open Skies Agreements or the sponsoring agency’s guidelines to determine if/when this is allowable. Contact SPA prior to booking the airfare if there is any question about this issue. Additional guidance on the Fly America Act and Open Skies can be found on the SPA website.
- Open Skies Agreements provide an exception to the Fly America Act. Please refer to Open Skies Guidance information on the SPA website.
- Foreign exchange rates must be clearly documented by including a copy of a print screen showing the average exchange rate for the period (can be obtained from www.oanda.com) or by including a credit card statement that shows actual conversion rates. All receipts must be clearly labeled in English (i.e. hotel, rental car, taxi, food).
Foreign exchange rates must be clearly documented by including a copy of a print screen showing the average exchange rate for the period (can be obtained from www.oanda.com) or by including a credit card statement that shows actual conversion rates. All receipts must be clearly labeled in English (i.e. hotel, rental car, taxi, food).
When traveling outside of the USA and Canada it is recommended that WU travelers purchase the rental car insurance. International rental car insurance is allowable to charge on a sponsored fund.
Visiting Scholars
Washington University researchers may invite faculty or other qualified individuals, who are employed or appointed at another institution or organization, to visit WU for an extended period in order to advance a collaborative research activity.
An international scholar is usually considered to be an individual not enrolled in a formal degree program, who holds a temporary non-immigrant visa and who engages in scholarly activities including teaching, research and/or training at a university, research institute or hospital. At WU, international scholars may be faculty members, research associates, postdoctoral research fellows, visiting scholars or physicians.
Learn more about bringing Visiting Scholars to your lab.
Managing Foreign Funds or Research Sites
Washington University in St. Louis has numerous sponsored projects which are performed at off-campus facilities. In order to identify and properly segregate the expenditures related to off-campus activities in proposals and awards, the offices of Sponsored Projects Accounting (SPA) and Office of Sponsored Research Services (OSRS) have developed the policies and procedures to guide these activities.
For information about conditions in which the off-campus rate applies, visit the Off-Campus Guide.
Awards from foreign sponsors may come with financial and compliance regulations that are specific to the country or region of origin.
For examples visit the International Disclosures, Export Controls, & Compliance webpage.
Expense increases for fluctuations in exchange rates can be treated as a direct expense when existing funding is available to cover the difference. Prior approval by the federal awarding agency is only required when the change results in the need for additional funding or a change in scope.
Visit the Sponsored Project Expenditures Guide.
- Indirect cost rate in proposal budgets for foreign subawardees: The deminmus rate of 10% should be provided to all subrecipients that do not have a federally negotiated indirect cost (IDC) rate. NIH has received a deviation from this policy and will continue to cap IDC rates 8% for international subrecipients. Concerns or questions with regards to implementing this should be directed to SPA.
- WU budget indirect cost rate for off-campus activities: The term “off-campus” is defined in the university’s current Facilities and Administrative Cost Rate Agreement as a project performed in facilities that are not owned by the university and not on the Medical Center campus. The Rate Agreement requires the university to apply the off-campus F&A rate when all or a portion of the project is performed at an off-campus location. Actual costs must be apportioned between the on-campus and off-campus components, and each will bear the appropriate rate. The current off-campus F&A rate is 26% MTDC (modified total direct costs) for organized research and other sponsored activities, 24% MTDC for instruction, and 11.5% (MTDC) for the Genome Center, which represents the administrative portion of the on-campus rate. For more information, visit SPA’s Off-Campus Guide.
Wire transfers may be required to transfer funds to international partners.
Visit the Financial Services website regarding the process for wire transfers.
Resource List
Prepare for International Travel (Export Controls)
Tip sheet: export control and technology issues for international travel
Subaward Admin Process – OSRS
Administrative process: distribution of outgoing subawards by the Office of Sponsored Research Services
Subrecipient Risk Assessment
OVCR Risk Assessment Table showing level of risk assigned to WU subrecipients
Travel on Sponsored Funds
Charging travel costs to external funds
- Traveling on Sponsored Funds
- See “Travel and Related Expenses” section of the Sponsored Expenditures Guidelines
- Registry – Mandatory for international trips