Doc. T22-066, as amended
Passed by the Board of Trustees on April 12, 2023

Purpose

The Policy provides systemwide uniformity for addressing safety, security, and compliance during University Travel (as defined below). It also establishes additional requirements for travel to high-risk destinations. This Policy applies to all University Travel and all University Travelers as defined in this policy, regardless of funding source.

Introduction

The University of Massachusetts (UMass or University) recognizes the import and necessity of travel for educational, research and business purposes in furtherance of the University’s mission. In supporting these opportunities, the University must manage the associated travel risks and liabilities while promoting the health, safety, and security of all members of the UMass community.

The University establishes this Policy pursuant to the authority granted in M.G.L. c. 75, § 32 to set requirements and expectations for University Travel. All University Travelers must comply with this Policy, associated Presidential Standards, and applicable campus guidelines.

I. Definitions

  1. Approver: Duly Authorized university representative with authority to approve travel for budgetary and programmatic purposes.
  2. Campus: Individual academic institution of the University of Massachusetts system (Amherst, Boston, Dartmouth, Lowell, Chan Medical School). For purposes of this policy, the President’s Office is also considered to be a campus component.
  3. Campus Travel Risk Review Committee: Committee authorized by each campus or the UMass President’s Office (UMPO) to review requests by prospective Traveler(s) from the respective campus/UMPO for University Travel to High-Risk Destinations and to make recommendations to the Travel Risk Approver.
  4. Comprehensively Sanctioned Destination: Countries and geographic regions subject to comprehensive U.S. trade, economic restrictions, or embargo.
  5. Domestic Travel Destination: Any travel destination that is a state or territory of the United States.
  6. Duly Authorized: With the authority of the University per Policy, Standard, or campus procedures.
  7. Elevated Cyber Security Risk Destination: Any International Travel Destination designated by the Systemwide Travel Risk Management Advisory Committee or the campus as posing substantive cybersecurity risk to a University Traveler and/or the University.
  8. High-Risk Destination(s): Any Comprehensively Sanctioned Destination(s); any country, region, province or city, including Domestic Travel Destinations and International Travel Destinations, designated by the Systemwide Travel Risk Management Advisory Committee or the campus as posing substantive health, safety, security risk to a University Traveler and/or the University.
  9. High-Risk Travel Destination Request Review Protocol: The pre-departure process for identifying, reviewing, and approving or denying proposed University Travel to High-Risk Destinations.
  10. International Travel Destination: Any travel destination that is not a state or territory of the United States.
  11. Personal Side Trip: Personal Travel made by a University Traveler while on approved University Travel.
  12. Personal Travel: Travel that is not University Travel including any Personal Side Trips.
  13. Travel Risk Approver: Duly Authorized University representative(s) designated by the campus or UMPO with authority to approve or deny Travel to High-Risk Destinations, generally after evaluating recommendations of the Campus Travel Risk Review Committee.
  14. Travel Risk Management Advisory Committee (TARMAC): Systemwide, five-campus and the UMass President’s Office (UMPO) advisory committee established per Section II(G) of this Policy and authorized to designate and periodically review the University’s systemwide High-Risk Destinations and advise on travel compliance and management protocols.
  15. Unauthorized Travel: Any travel that has been denied or is unapproved by the Campus as University Travel.
  16. University Business: Any activity, practice, commerce, trade, service, research, education, etc. in furtherance of the University’s mission and functions.
  17. University Device(s): Electronic devices such as laptops/computers, tablets, mobile phones, smartphones, and the like which are owned by the University and used to collect, store, access, transmit, carry, use, or hold University Data whether during or outside of normal working hours and whether it is used at a normal place of work or not.
  18. University Data: Data created, received, maintained or transmitted by or on behalf of the University through the course of its academic, administrative, research, or outreach activities.
  19. University Property: University-owned equipment, specimens and/or materials.
  20. University Travel (“Travel”): Any travel by Travelers for University Business regardless of funding source. University Travel includes, but is not limited to:
    1. Travel in the course and scope of the Traveler’s employment at the University.
    2. Travel financed, in full or part, through university funding, grants, scholarship, or sponsorship.
    3. Travel sponsored, arranged, endorsed, promoted, or administered by the University, or by university faculty or staff members.
    4. Travel that is credit-bearing, or necessary for meeting a course or degree requirement, including graduate research at the University.
    5. Travel that involves the physical transport of University Property regardless of funding source for such travel.
    6. Travel directly related to a university-sponsored grant or contract.
    7. Travel to an International Travel Destination when the Traveler will be performing any university-related work remotely on a regular basis.
  21. University Traveler(s) (“Traveler”): Duly Authorized employee, student, recognized student group or organization, trustee and Special State Employee as defined in MGL Chapter 268A, or non-employee (e.g., speaker, lecturer, student, visiting professor, candidate for university employment, guest etc.) on University Travel.
  22. University Travel Registry: Platform for maintaining critical travel information of University Travelers for safety and security purposes.

II. Policy

  1. Prior Approval: All University Travelers must obtain budgetary, programmatic and, as necessary, risk approvals for University Travel prior to departure.
  2. Registration of Travel: All University Travelers must register University Travel in the University Travel Registry and obtain associated approvals prior to departure.
  3. Travel Expenses: The Business and Travel Expense Policy (T92-031, Appendix C) governs expenses associated with all University Travel.
  4. Authority to Restrict Travel: The University reserves the right to restrict, deny, or postpone any University Travel in its sole discretion if the risks associated with the proposed travel outweigh the benefits to the professional or business purpose of the travel.
  5. Authority to Require Travelers to Evacuate: The University reserves the right to require Travelers to leave or evacuate a given location when, in its sole judgement and discretion, it determines that continued presence in that location may severely endanger health, safety or well-being of University Travelers or others.
    1. University Travelers who fail to heed University instruction to evacuate do so at their own risk and are on notice that the University may not be able to respond with assistance. Such Travelers may forfeit emergency travel assistance and insurance coverage, academic credit, tuition payments or expense reimbursement, and may be held responsible for additional expenses incurred by the University due to the Traveler’s refusal to follow policy. In addition, such Traveler(s) may be subject to local administrative requirements or law enforcement actions related to specific local conditions or restrictions.
  6. Compliance with Laws and Regulations: Travelers are required to comply with applicable state, federal and international laws, including but not limited to the anti-bribery provisions of the U.S. Foreign Corrupt Practices Act (“FCPA”), which prohibits bribery of foreign officials; 18 USC Section 201, which prohibits bribery of US officials; and MGL Chapter 268A, the MA conflict of interest law.
  7. Travel with University Devices and/or University Data.
    1. University Travelers traveling with University Devices, University Data, or by accessing University Data remotely shall not create data security or other confidentiality risks that cannot be effectively mitigated.
      1. Whether on University Travel or Personal Travel, Travelers traveling with University Device(s) and/or University Data must comply with cybersecurity, connectivity, telecommunication requirements as set forth in the Presidential, University Information Technology Services (UITS), and/or campus Information Security or Technology departmental standards and guidelines.
    2. University Travelers must not travel with University Devices and/or University Data to International Travel Destinations with elevated cyber security risks. For clarity, this extends to international Personal Travel.
      1. Campuses may grant authority to travel with University Devices and/or University Data when mitigation measures can effectively be achieved.
        1. Traveler must obtain such approval from their respective campus prior to Travel.
  8. University Travel to or Through High-Risk Destinations.
    1. This Policy establishes a University Travel Risk Management Advisory Committee (TARMAC) which is a systemwide advisory committee with representation from each campus and the President’s Office (UMPO). TARMAC is authorized and charged with assessing and monitoring travel-related risks, designating High-Risk Destinations or criteria for designating High-Risk Destinations, advising the system on travel compliance and management protocols, and periodically reviewing this Policy and the associated Presidential Standards.
      1. The composition of TARMAC is detailed in the Presidential Standards.
      2. Each Campus Travel Risk Review Committee maintains the authority to designate additional High-Risk Destinations for their campus.
      3. TARMAC will serve as a resource for the Campus Travel Risk Review Committees.
      4. Each Campus, through its Travel Risk Review Committee and Travel Risk Approver, has the authority to approve or deny Travel to a High-Risk Destination by their respective Traveler(s) [see Section II.(H)(ii) and II.(I)].
    2. Generally, University Travel to or through High-Risk Destinations is not allowed.
    3. The University recognizes that, on occasion, there may be a compelling reason to consider allowing University Travel to or through a High-Risk Destination. In such cases, and always prior to departure, Travel Risk Approvers must approve or deny all University Travel to, or through, a High-Risk Destination(s).
      1. Each Campus, through its Travel Risk Review Committee and Travel Risk Approver, has the authority to approve or deny Travel to a High-Risk Destination by their respective Traveler(s).
      2. The Travel Risk Approver is authorized to approve or deny requests to travel to or through High-Risk Destinations, generally after reviewing the recommendations of the Campus Travel Risk Review Committee.
    4. Each campus and the UMPO shall designate a Travel Risk Approver with the authority and responsibility to approve or deny travel requests from their respective campus/UMPO for any Travel to or through High-Risk Destinations.
    5. Each campus and the President’s Office shall appoint a Campus Travel Risk Review Committee responsible for reviewing travel requests from their respective Travelers to High-Risk Destinations and making recommendations to the respective Travel Risk Approver.
  9. High-Risk Travel Destination Request Review Protocol.
    1. Each campus and UMPO must develop and implement a pre-departure High-Risk Travel Destination Request Review Protocol for identifying and reviewing all anticipated University Travel to or through High-Risk Destinations for the respective campus or UMPO.
      1. High-Risk Travel Destination Request Review Protocol must be compliant with this Policy, associated Presidential Standards and associated campus guidelines.
    2. University Travelers seeking to travel to or through a High-Risk Destination must request and obtain travel authorization in accordance with High-Risk Travel Destination Request Review Protocol.
      1. Approval of Travel to High-Risk Destination.
        1. University Traveler authorized to travel to a High-Risk Destination must comply with all pre-departure requirements which may include, but are not limited to:
          1. Enrollment with the U.S. Department of State, “Smart Traveler Enrollment Program” (STEP) or the equivalent citizen service of the University Traveler’s country of citizenship.
          2. Registration with the University’s international emergency travel assistance provider.
          3. Obtaining a required license from the U.S. Department of Treasury Office of Foreign Assets Control for travel to a Comprehensively Sanctioned Destination, if applicable.
          4. Completing and acknowledging completion of a safety, cybersecurity and security training or briefing.
    3. Denial of Travel to High-Risk Destination.
      1. If the Travel Risk Approver denies a request to travel to a High-Risk Destination, the travel shall not be considered University Travel and shall not be supported with University funds. Any Traveler who makes the personal decision to travel to a High-Risk Destination despite the denial does so as a private individual and without university support. The University has no obligation(s) or liability in connection with such unauthorized travel, and such travel may not be eligible for support through the University emergency travel assistance program or University insurance coverage.
  10. Export Control Requirements for Travel to International Travel Destinations.
    1. When traveling to any International Travel Destination, University Travelers are considered “exporters” of any tangible items and technical information they take with them and/or share abroad. Therefore, all University Travelers traveling to International Travel Destination(s) on University Travel shall comply with all established laws, regulations and requirements specific to Export Control, including requirements for the proper handling, transfer, access, storage, control, and release of export-controlled commodities, hardware, software, information, technology, and technical data.
      1. Campuses shall implement an export control review process for University Travel to International Travel Destination(s).
  11. International Emergency Travel Assistance and Insurance Program.
    1. The University international emergency travel assistance and international travel accident and sickness insurance program provides risk management and emergency support and services for Travelers on approved international University Travel.
    2. Travelers are responsible for reviewing all materials relating to University international travel assistance and international travel accident and sickness insurance program and for cooperating with the University in the event that any claim needs to be filed.

III. Responsibilities

  1. Each campus is responsible for designating responsibility for compliance with this Policy and applicable state and federal law.
  2. Each campus is responsible for designating responsibility for compliance oversight of the U.S. export control and economic sanctions requirements for the University.
  3. The Travel Risk Management Advisory Committee (TARMAC) is responsible for designating, monitoring, and periodically updating the University’s designation of High-Risk Travel Destinations as well as advising the system on travel compliance and management protocols. TARMAC is also responsible for periodically reviewing this Policy and the associated Presidential Standards.
  4. Each campus is responsible for reviewing and approving or denying individual requests received from University Travelers from their respective campus for travel to or through High-Risk Travel Destinations.

IV. Standards

The President, in consultation with the Chancellors and the Vice President for Administration & Finance and Chancellors, will issue administrative standards to implement this policy.

V. Related Policies