University researchers and travelers often need to pay for goods or services to support projects occurring in a foreign country. Payments which may be common in the United States can be more complex in international locations. The purpose of this guidance is to provide researchers and departments with an overview of options for in-country payments, payments to research subjects in an international location, tax reporting issues, and payments for traveler expenses.

Payments made by the University in a foreign country are subject to compliance with the Foreign Corrupt Practices Act (FCPA) and other applicable local anti-bribery laws. For guidance on the FCPA, researchers and departments should review the University’s FCPA Guidance.

For questions regarding allowable costs on sponsored projects, researchers and departments should review the University’s guidance on Federal Award Compliance, Budgets, and Subawards [Link], or contact their grants or department administrator.

 

Payments for Expenses Incurred Outside the United States

There are various options available to researchers and departments for paying for University business expenses that arise from international research or projects. Options below are listed in order of strong preference, with PCard and Direct University Payment being the most preferred options.

• PCard: UR’s PCard program is a valuable tool for quickly and efficiently managing resources by concentrating low-dollar, low-risk purchases in a less paper-intensive process. University PCards should be used for any business expense that complies with the University PCard Policy. Common approved expenses that may occur in an internation location include office supplies or supplies for research, group meals (but not an individual meal) or groceries for a group, and taxi or public transportation charges. More information can be found at the University PCard

In rare cases, where payment by PCard to a payee is feasible but is prohibited by the terms of the PCard Policy, and other options below are impractical or impossible, departments may request an exception to the PCard Policy by completing the PCard Transaction Exception Form process described in the PCard Policy.

• Direct University Payment: Once a payee is set up as a Supplier in Workday, the University can issue payment to the payee via ACH to a bank account in the United States or electronic funds transfer (EFT) to a bank account in a foreign country (and if needed, in foreign currency). Payees can be set up us a Supplier in Workday in the following ways:
  • Completion of the Supplier Qualification Process through University Procurement and issuance of a Purchase Order; or
  • For certain “low-risk” Suppliers, through the Supplier Invoice Request (SIR) process through Accounts Payable.

University Procurement will determine whether a potential supplier should complete the Supplier Qualification Process or whether the supplier can be paid by SIR. For international projects, researchers and departments can contact University Procurement directly, or they can contact the Office of Global Engagement for consultation, who can work with departments and University Procurement on payment issues.

For example, researchers and departments should follow University Procurement’s processes to arrangements with independent contractors that will support a research project in a foreign country. Depending on the potential risk of the arrangement, the University will issue a Purchase Order to pay the independent contractor, or the University may be able to pay the independent contractor through the SIR process.

Where the University establishes a Purchase Order or pays by SIR, the University will pay by Direct University Payment, and not by cash, PCard, Credit Card, or any other payment type.

For more information on contracting for services, research, and goods in a foreign location, see the University’s guidance on Contracts for Services, Research, and Goods in International Research Projects. [Link]

• Work with established local partner: Researchers are encouraged to explore partnership opportunities with local institutions that can assist with payment needs. Trusted local partners (such as collaborating research institutions) are sometimes able to help fulfill various project responsibilities that may be challenging for the University to perform. This includes assistance with local payments or local procurement needs. Local partners may be able to make payments in a foreign country on the University’s behalf, and then invoice the University. A local collaborator may have previously established connections with some of the suppliers/payees with which a researcher plans to engage with their project.

To potentially initiate this option, researchers and departments should first contact the Office of Global Engagement for consultation on the potential arrangement. The Office of Global Engagement can coordinate with other stakeholder University offices on establishing an agreement with the partner and setting up the partner to receive payments in Workday. In these cases, the University will issue payments to the local partner via ACH to a bank account in the United States or EFT to a bank account in the foreign country (and if needed, in foreign currency).

Can researchers pay in cash (Cash Advance or Personal Funds) or use personal credit for project payments?

Generally, faculty, staff, and students should not pay for local services (including independent contractors) in cash, or use personal funds or credit for local procurement of supplies or equipment, unless it is unavoidable and has been approved in advance by Accounts Payable. Further, managing large sums of cash when abroad may present a personal security risk and should be avoided if possible. To initiate a request for cash payments, departments and researchers should contact Accounts Payable in advance to discuss cash needs. If approved in advance, one or more of the following options will be available:

• Cash Advance Cash may be advanced for international research trips subject to the Business Expense and Travel Reimbursement Policy. For detailed guidance on how to request a cash advance, review the Cash Advance reference guide which includes the Cash Advance Request Checklist. Funds may be used for ordinary and reasonable business-related expenses. If the expense will be paid for by grant funds, researchers should know the details of which costs are allowed on those grants.
• Personal Funds/Credit Card: Faculty and staff should the Business Expense and Travel Reimbursement Policy before spending personal funds/credit for business travel or other expenses.

Where Cash Advance or Personal Funds/Credit Card are used, an Expense Report is required to be submitted for the expenses paid in cash. Individuals should take care to log/track those cash expenses in detail so that the amount can be allowed as a business expense for posting to the grant or other University FAO.

Payments to Research Participants

The Paying Research Study Participants guide provides several traditional and non-traditional payment methods for payments to research subjects. The guide lists payment options, an order of preference, reference information, contacts for questions, and other guidance for when and how to use each. For research occurring in remote locations, payment options that include Flywire, low dollar cash, and gifts may be useful where other preferred options are not available.

Note the following important restrictions:

• Under no circumstances should researchers or departments utilize Venmo, PayPal, or other cash applications to pay research participants.
• Researchers and departments should not transmit University funds (received via petty cash or advance) to Venmo, PayPal, or other cash applications to research participants.

Before engaging in human subjects research in a foreign country, researchers and departments should consult the Guideline for Conducting International Research published the Office of Human Subject Protection (OHSP), and ensure that all OHSP and Research Subject Review Board (RSRB) requirements are met.

 

Tax Reporting

The University is not required to report payments to the IRS if the payee is a foreign entity or nonresident alien (as defined by the IRS) and all services are performed outside of the United States. This generally includes payments made to research subjects for research that occur in a foreign country. Subject to the monetary thresholds set forth in the Research Subjects Payments Policy, all U.S. citizens and permanent residents must have their payments for services reported (even if they are paid as a human subject in research occurring outside of the U.S.). Nonresident aliens performing services in the U.S. require tax reporting, and tax withholding is most likely required. If you have questions about whether payments made in connection with an international research collaboration will require tax reporting, contact Accounts Payable.

Paying for Travel Expenses for International Research

The Accounts Payable Reimbursement website contains policy and procedure information, as well as detailed guidance, on paying for University travel expenses.  The Accounts Payable guidance includes orders of preference for paying travel expenses, how and when to use each option, and links to more information and who to contact with further questions.