TR01 International Travel Requirements
Subject Matter Expert:
Policy Steward:Office of the Corporate Controller>
- Use of the Travel Safety Network
- Emergency Preparedness Workshop- Students, Faculty Leading Student Groups
- Traveling with Technology
- Traveling to Countries on the Insurance Industry's List of Restricted Countries, and the U.S. State Department Warnings List
- University-Sponsored Student Group Trips
- Export Control and International Travel
- Who May Participate in University Affiliated Student Group International Travel
- Use of Tour Providers
- Further Information
- Cross References
All requirements of the Penn State Travel Policy apply for University-affiliated travel. This policy specifies additional practices and processes required for traveling internationally.
International travel affords unique educational, research and business opportunities to the members and affiliates of the Pennsylvania State University ("Penn State" or "University") community. While supporting these opportunities, the University must manage the risks associated with them, balancing safety obligations to its participants while honoring restrictions placed upon the University by applicable laws and/or University academic, research or business partners.
This policy applies to all University employees, students, authorized volunteers and guests of the University while travelling as part of any University Affiliated International Travel, regardless of the funding source, including individuals and groups of students participating in for-credit academic study-abroad experiences.
University Affiliated International Travel - Any travel by University employees, students, authorized volunteers and guests to an international destination which is for educational, research, or business purposes tied to the traveler’s affiliation with the University. This includes travel by groups affiliated with the University, such as Recognized Student Organizations and travel to professional conferences/meetings regardless of the funding source including if the University travelers’ costs are paid by an outside organization.
University Affiliated Student Group International Travel – All international travel outlined in Policy FN20 as well as international travel by Recognized Student Organizations which includes at least two students. This includes travel to professional conferences/meetings even if paid by an outside organization.
Members and Affiliates of the University Community - University employees, undergraduate students, graduate students, authorized volunteers and guests travelling as part of any kind of University Affiliated International Travel. For purposes of this Policy, Graduate Assistants traveling in their work capacity will follow the same requirements and guidance as faculty and staff. For programs sponsored by Education Abroad, "students" includes recent graduates who enrolled in the University Affiliated International Travel while still a student even though the travel takes place after graduation.
Authorized Volunteers - Individuals who are not included in the definition of Members and Affiliates of the University Community, who accompany a University group at the request of the group leader with the support of the College or Campus executive, for the purpose of enhancing the group's experience based on their subject matter, linguistic skill, or geographical knowledge. Notification and approval by the Vice Provost of Global Programs is required.
The Travel Safety Network (TSN) at Penn State is a database and network of resources to support international engagement across the institution and enhance the safety and security of University travelers. Global Programs oversees the TSN. Global Programs staff monitor events (e.g., political unrest, infectious outbreaks, natural disasters, etc.) that may impact travel. The TSN enables Penn State to more quickly and efficiently provide travelers with emergency assistance (e.g., medical or security), in the event of an emergency or crisis overseas. As part of this network, Global Programs works with University Risk Management, Student Activities, Export Compliance, and others across the University.
All students traveling on University Affiliated International Travel must record the trip with the TSN prior to travel, if their travel is not part of a University-affiliated group trip which has already been recorded. Employees must enroll their University Affiliated International Travel prior to travel in order to be compliant with AD89, University Export Compliance Policy (see "Export Control and International Travel," below). Students and employees traveling internationally on an Education Abroad program will have their travel recorded by Education Abroad and do not need to complete a TSN record for these programs. Complete travel enrollment information must be submitted not less than 30 days prior to individual travel or as soon as possible if the decision to travel is made less than 30 days prior to departure. For group travel, all individual and group enrollment information must be submitted and receive final approval 30 days prior to travel. TSN data should be updated as the traveler’s itinerary changes by contacting TSN@psu.edu. Enrollment of all faculty, staff, and student travel in advance of the trip shall be mandatory as a predicate to the individual being reimbursed for their travel expenses.
All students who are traveling abroad on University Affiliated International Travel must participate in an Emergency Preparedness or pre-departure orientation session offered by the Global Programs prior to departure. Students must attend a session once every two years as a condition of participating in University Affiliated International Travel.
Faculty and/or staff traveling with a group of students internationally are also required to participate in an emergency preparedness session for leaders offered by Global Programs prior to departure. Faculty and staff operating in this capacity must attend a session once every two years from their last workshop participation as a condition of participating in University Affiliated International Travel with students.
University employees not supervising students but traveling internationally for research, conferences, or other University Affiliated International Travel reasons may participate in the emergency preparedness sessions for their own information, but it is not required.
Traveling with technology presents concerns and challenges. When travel involves crossing an international border, concerns center on the traveler’s safety and security, as well as securing data and devices, and safeguarding the integrity of Penn State systems and networks. Travelers should review Traveling with Technology on how to safeguard University equipment and devices as well as personally identifiable information.
TRAVELING TO COUNTRIES ON THE OFAC LIST OF RESTRICTED COUNTRIES, THE INSURANCE INDUSTRY’S LIST OF RESTRICTED COUNTRIES, AND THE U.S. STATE DEPARTMENT TRAVEL WARNING LIST:
The University is always concerned with the safety of all members of the University Community while traveling as part of any University Affiliated International Travel. Therefore, the following restrictions have been instituted:
FACULTY AND STAFF: The University does not by policy prohibit its faculty or staff from traveling to any country in the world. However, the U. S. Department of Treasury Office of Foreign Asset Control (OFAC) places travel restrictions on certain locations or activities. Further, the University's workers’ compensation insurance voices serious travel and safety concerns for travel to the countries on the Insurance Industry’s List of Restricted Countries. Travel to the countries on these lists must be reviewed and evaluated on a case-by-case basis.
Travel and security plans related to any of the countries identified on the Insurance Industry’s List of Restricted Countries must be reviewed in advance of departure by the International Restricted Travel Committee in order to engage resources to understand the specific risks, develop a safety plan to mitigate the likelihood of injury, and determine the best path forward. Travel to any of the countries identified on the Insurance Industry’s List of Restricted Countries cannot take place until approval is given concerning the identified risks. The review is initiated by completing a Restricted Travel petition as part of a TSN travel record for individual travel, or as part of the proposal phase for an Education Abroad program.
These requirements apply for all University Affiliated International Travel for faculty and staff, including when hosting or attending Student Group travel.
STUDENTS (INDIVIDUAL OR GROUP): Students on University Affiliated International Travel, including Recognized Student Organizations, are restricted from traveling to countries with a U.S. State Department Travel Warning or a country on the Insurance Industry's List of Restricted Countries, unless approved through completing an exception petition described below.
RESTRICTED TRAVEL PETITION: Travelers must utilize the following procedures which have been integrated into the TSN enrollment process or Education Abroad program proposal process:
- Employees planning travel to a country on the Insurance Industry’s List of Restricted Countries must complete a Restricted Travel Petition as part of creating a travel record in TSN.
- Students planning University Affiliated International Travel to a country with a U.S. State Department Travel Warning or a country on the Insurance Industry's List of Restricted Countries must complete a Restricted Travel Petition as part of creating a travel record in TSN or an Education Abroad program application.
- Faculty/Staff traveling with Students to a country with a U.S. State Department Travel Warning must complete a Restricted Travel Petition as part of creating a travel record in TSN or an Education Abroad program proposal.
- For Undergraduates who wish to travel on University Affiliated International Travel in countries subject to a Travel Warning issued by the U.S. State Department, see Undergraduate Policy R-7.
- Graduate Students shall refer to Graduate Student Policy for Travel to Countries on the U.S. State Department Warnings List.
- International travel by Recognized Student Organizations shall not be permitted to countries with a U.S. State Department Travel Warning or countries on the Insurance Industry's List of Restricted Countries without approval of a Restricted Travel Petition created as part of the group TSN record. Recognized Student Organizations should contact their campus Student Activities Office for instructions on this process.
Refer to Policy FN20 for the approval guidelines for any international travel by a student group sponsored by the University. As defined in policy FN20, student group travel refers to a group consisting of two or more students accompanied by a University employee with a purpose that is relevant to the University's mission. Groups of five (5) or more student participants that include undergraduate students must be accompanied by a minimum of two (2) University employees, and additional employees should be considered for large groups in consultation with Global Programs. The requirement for accompaniment is not applicable for travel involving exclusively graduate students, medical students, or law school students. In all cases, regardless of group size or student status as undergraduate or graduate, if the student group travel is part of an Education Abroad program, participants must be enrolled in credit-bearing course(s) at the University. No unenrolled participants may travel with the program as "students" or guests.
As specified in Policy AD89, the United States Government has established certain laws and implemented certain regulations and guidelines to restrict, prevent and/or inhibit access to or provision of certain information, materials, equipment, services and/or financial resources by, to, or for the benefit of unauthorized foreign nationals. These laws, regulations, and guidelines are often collectively referred to as "Export Controls."
All University employees must comply with all U.S. laws and regulations when traveling internationally on University Affiliated International Travel, including the complex set of U.S. laws and regulations governing the export of controlled materials, software, technology, data, financial resources and services. It is required under Policy AD89, therefore, that an export compliance review be obtained prior to commencement of any University Affiliated International Travel to evaluate the proposed international travel event against any applicable Export Control laws or regulations.
For the convenience of the international traveler and to streamline the processes in place at the University, as well as to satisfy federal record retention requirements under applicable Export Control laws and regulations, the required export compliance review for University Affiliated International Travel has been integrated into the TSN enrollment process. Notification of completed enrollments in the TSN will be provided automatically to the University Export Compliance Office. In the event any additional information about a travel event recorded in the TSN is necessary in order to complete the required AD89 export compliance review, the traveler will be contacted directly by a University Export Compliance Specialist for further follow-up. University employees who have completed the required TSN enrollment will have met the requirement of AD89 to obtain the prior export compliance review of the travel event. Additional documentation and guidance information about the application of Export Control laws and regulations to University Affiliated International Travel is available within the TSN system.
University Affiliated International Travel which cannot, for whatever reason, be recorded in the TSN, must be submitted directly to the University Export Compliance Office (UECO) for completion of the AD89 required export compliance review, subject to the same timing requirements outlined above for enrollments in the TSN (30 days prior to travel or as soon as travel plans are completed for travel arranged within 30 days of travel). Forms for submission of non-TSN eligible University Affiliated International Travel are available on the UECO website.
No export review is required for employees traveling internationally on personal vacation or attending conferences or other events solely at their own personal expense. However, a review is required if the University or any third party contributes to funding any costs associated with the travel, including, but not limited to, salary reimbursement, travel expenses or incidental expenses. If there is any doubt about whether a particular travel event is subject to the AD89 export compliance review requirement, it is recommended that the traveler simply submit such travel event for review via TSN enrollment or completion of the non-TSN eligible forms.
The failure to comply with any applicable U.S. Export Laws and Regulations may result in personal civil and/or criminal liabilities for the traveler, up to, and including, debarment, fines and/or imprisonment. More information about export compliance at the University is available in Policies AD89, ADG09, RA40, and RAG40, or at the UECO website.
Penn State employees leading academically-related international travel with a group of students are expected to devote their attention to the oversight of the students when involved in course activities, non-academic activities which they arrange and/or participate, and while traveling. All travelers are expected to comply with all relevant University Policies, local laws and applicable policies of host institutions; additionally, students are expected to adhere to the Penn State Student Code of Conduct. Spouses/domestic partners (except for a faculty/staff spouse/partner who is co-teaching the program’s academic content) and children of faculty and staff engaged in such a program may be permitted to accompany such travel with prior authorization as part of the program application process, to be granted by the Vice Provost for Global Programs, after consultation with the Risk Management Office and the program’s College Dean or Campus Chancellor.
Community members (including alumni, spouses and children of students) are not permitted to accompany University Affiliated Student Group International Travel. Rare exceptions may be made for community members serving as official University volunteers, and permission for such an exception may only be granted by the by the Vice Provost for Global Programs, after consultation with the Risk Management Office and the sponsoring unit’s Budget Executive, Dean or Chancellor.
For any University Affiliated Student Group International Travel programs, the Risk Management Office has established contractual requirements for tour service providers, and either Procurement Services or the Risk Management Office must process such agreements for authorized University signature in accordance with these contractual requirements.
For questions, additional detail, or to request changes to this policy, please contact the Office of Global Programs or the Risk Management Office.
AD89 – University Export Compliance Policy
ADG09 – Export Compliance Definitions, Procedures and Implementation Guidelines
FN20 - Student Group Travel Policy
RA40 - Compliance with Federal Export Regulations for Sponsored Research Efforts (Formerly RA18)
RAG40 - Guidelines for Ensuring Compliance with Export Control Policy RA40 (Formerly RAG11)
Most Recent Changes:
- January 4, 2018 - to modify the language around family members of faculty accompanying them on trips.
Revision History (and effective dates):
- May 16, 2016 - New policy.
Date Approved:January 19, 2018>
Date Published:January 19, 2018>