International Travel and Activities
Chapter 3120
Issued February 24, 2021
Revised January 4, 2024
.010 Purpose
.020 Scope
.030 Definitions
.040 Employees and Students International Travel Registration
.050 Travel to Elevated Risk Locations
.060 Employees Traveling with or Facilitating Travel for Students
.070 International Accident and Health Insurance and Travel Health Consultations for Employees and Students Traveling Internationally
.080 Export Controls
.090 Information Technology Security While Traveling
.100 Foreign Corrupt Practices Act and State Ethics Rules
.110 International Contracts, Agreements, Collaborations
.120 Training
.130 Resources and Related Policies
.140 Questions
.010 Purpose
Kansas State University recognizes the need, benefits and opportunities presented for its employees and students to travel and conduct activities abroad on official university business. This policy is designed to encourage responsible international engagement and aid university employees and students in the planning of their international travel and activities when they are conducted on behalf of the university or as part of a university program.
.020 Scope
This policy applies to all Kansas State University employees and students while traveling on university-sponsored international travel, regardless of the funding source. This policy sets forth the requirements that employees and students must meet before and during university-sponsored international travel. This policy does not apply to personal international travel when it is neither on behalf of the university nor as a participant in a university-sponsored program.
.030 Definitions
- Elevated Risk Location: A country or region identified by the university as presenting elevated risk for international travel, based upon information from the U.S. Department of State and the Centers for Disease Control and Prevention.
- Export: The actual shipment or transmission of items out of the United States. It also refers to the release of technology or source code (“technology”) to a foreign national within the U.S. or abroad, commonly referred to as “Deemed Export.”
- Deemed Export: Technology released to a foreign national regardless of location. Technology is released when it is made available to a foreign person in the form of visual inspection such as reading technical specifications, plans, blueprints, etc., verbal or oral exchange, or by practice or application under guidance of a person with knowledge of the technology. This transfer of information is an export because it is ‘deemed’ to have been exported to the person’s country or countries of origin.
- International travel and/or activity: Any activity conducted abroad, or which otherwise involves an international collaboration, funding or other component, that is sponsored by the university, including for example:
- Conducting research through a university grant, or otherwise at the direction of the university, in a foreign country or otherwise involving persons, materials, or natural resources in a foreign country.
- Engaging in university work while residing in a foreign country.
- Traveling with students in a foreign country within the scope of a K-State employee’s job responsibilities.
- Setting up an office or leasing space in a foreign country.
- Contracting or otherwise collaborating with a foreign government or private entity.
- Making or receiving payments from a foreign entity.
- Training persons in foreign countries.
- Employee: Any person employed by the university in any capacity, including faculty and staff.
- Volunteer: Any person engaged by the university to provide services on a volunteer basis without compensation. Throughout this policy, “employee” requirements may encompass requirements of “volunteers” when participating in university-sponsored international travel or other international activity, where it is not focused on employee benefits or compensation. Any volunteer serving on the university’s behalf in university-sponsored international travel shall complete a written Volunteer Agreement Form.
- Student: Any person currently enrolled in an academic program of the university, including but not limited to degree programs, credit bearing non-degree programs, and professional certificate or executive education programs.
- University-sponsored: Any program or activity authorized by the university and/or supervised by a university employee within the context of employee’s university employment, regardless of funding source, including but not limited to those programs or activities hosted by a university office, department, departmental student organization or other university units. An employee traveling while on leave of any type is generally not university-sponsored. Questions about whether a particular activity or travel is university-sponsored should be directed to the employee’s supervisor, who may consult with Education Abroad, the Assistant Vice President for Risk and Compliance, and/or the Office of General Counsel, as needed.
.040 Employees and Students International Travel Registration
The university requires all employees and students engaged in university-sponsored international travel and/or activities to register their trips 14 days before departure. Travel registration is required and travelers who fail to register their travel may be subject to sanctions under applicable university policies, which may include, but are not limited to, written reprimand, their travel reimbursement not being approved, and in extreme cases, termination for cause.
For university-sponsored international travel, employees are required to book their airfare in Concur. Expections to booking airfare in Concur require approval from the Office of Risk and Compliance and are considered case-by-case.
Students participating in programs administered by the Education Abroad Office register their travel with the Education Abroad Office (see section .060). In the case of Education Abroad programs managed by the Education Abroad Office, such as faculty-led, university exchange, third-party provider or direct enroll, the faculty and/or student planning to travel must meet with an Education Abroad advisor prior to submitting their request for approval.
Employees traveling on official university business register in the international travel registration system located on the KSU travel website.
Students not participating in international travel administered by Education Abroad Office register their travel in the international travel registration system located on the KSU travel website.
In cases of group travel, the university department, school or administrative unit that is supporting the travel is responsible for complying with this policy and identifying an individual to complete the registration process on behalf of the group.
Travel registration provides the university with the information it needs to conduct risk assessments, export controls compliance review, locate travelers and provide information or assistance in the event of a crisis or emergency. Available services to registered travelers may include emergency medical support, embassy information, repatriation and medical evacuation.
Any questions related to travel registration can be directed to the Office of Risk and Compliance at risk@k-state.edu.
.050 Travel to Elevated Risk Locations
The university disfavors employees or students participating in university-sponsored international travel to any locations categorized as Level 3 or Level 4 by the U.S. Department of State or classified as Warning Level 3 by the Center for Disease Control and Prevention.
Employees and students traveling to elevated risk locations will be prompted to identify risk mitigation strategies during the trip registration process. Travelers may request health, safety and security briefings from Lafene Health Center, the Export Controls Office, the Research Security Officer and the Office of Risk and Compliance.
The U.S. Department of State has a website which provides travel advisories, as well as safety and security information, for every country in the world. Each traveler will be prompted to review the State department and Centers for Disease Control (CDC) travel advisories during the registration process. K-State strongly recommends each traveler register on the website or download the mobile app to gain access to real-time information.
.060 Employees Traveling with or Facilitating Travel for Students
Any employee arranging or otherwise facilitating university-sponsored international travel for students must register the university travel and/or activities through the university Education Abroad Office. The employee may do so by emailing abroad@ksu.edu for additional guidance. The purpose of this is to ensure all students participating in university-sponsored international travel register their travel in advance through K-State Education Abroad for risk management, international health insurance, international liability insurance and emergency support purposes.
Additionally, Education Abroad is responsible for facilitating contracts for any services, lodging and other arrangements for student international travel that is managed by Education Abroad; all such contracts should first be reviewed by the unit, then submitted to Education Abroad for review, which will forward them to the Office of General Counsel, Assistant Vice President for Research Compliance and the Office of Risk and Compliance for review. (See PPM 3070).
.070 International Accident and Health Insurance and Travel Health Consultations for Employees and Students Traveling Internationally
The university provides international travelers on university travel with accident and sickness insurance coverage while traveling abroad, available from the Office of Risk and Compliance. Employees, students, volunteers and guests traveling outside of the United States are covered under a blanket accident and sickness insurance policy that covers costs that could be incurred while traveling abroad, including emergency medical evacuation, repatriation of remains, a family assistance benefit, a bereavement reunion benefit, a security evacuation benefit, and worldwide travel assistance. Individual travelers or departments are financially responsible for costs that are not covered by the policy.
Travel Consult
The university strongly encourages all travelers to participate in a travel consult from Lafene Immunization Clinic or from their primary care physician prior to their departure. This will help travelers avoid the risk of contracting a vaccine-preventable disease in the country that they are visiting. Without proper health preparedness before traveling, the traveler risks becoming ill and having to seek medical care which might be substandard depending upon their location. The university also recognizes that certainly faculty who frequently travel abroad and are familiar with the country or countries that they visit may not need to repeat a travel consult prior to each foreign travel visit.
A travel consult is available at the Lafene Immunization Clinic to assist employees and students who are traveling internationally. Reasonably in advance of traveling, schedule a travel consultation, which will include:
- Individual review of vaccination requirements for the region being visited.
- Travel recommendations for the region based on current health and safety precautions.
- Worksheet completion listing requirements and recommendations.
- Referral to a physician for any medications, health assessment, or needed instruction.
- Available vaccinations, which may be initiated at the time of the initial consult.
Information about health risks and suggested preventative measures is based on recommendations by the Centers for Disease Control and Prevention and the U.S. Department of State. Appointments should be scheduled well in advance (2-3 months) of the desired travel date because some vaccination requirements may take several months to be completed. This will help ensure that you have the opportunity to receive any vaccinations, anti-malaria treatment (if indicated), medications, and other protective measures in advance to provide adequate protection by your departure date. More information about travel consults is available on Lafene's Travel Clinic website.
.080 Export Controls
Employees and students engaged in university-sponsored international travel and/or traveling with university property are responsible for complying with export control laws and regulations. An export control review of the proposed trip is mandatory for all travelers prior to departure.
Export control regulations may restrict or prohibit some travel related activities or destinations, and/or may require licenses for others. The University Research Compliance Office (URCO) can help travelers assess what export control requirements apply to ensure institutional and individual compliance. Advance consultation with URCO — before the proposed international travel and/or activity — helps ensure compliance with export control regulations. Information provided on the international travel registration form is reviewed for compliance with export control regulations: the traveler will be contacted by URCO if export conrol concerns are found or when additional information is required.
Any questions on export controls requirements, travel to embargoed countries, travel with equipment and materials, or any other questions can be directed to exportcontrols@ksu.edu. In certain instances when the projected travel will be to an elevated risk destination or an embargoed or sanctioned destination, URCO will coordinate with the traveler and recommend a pre-travel briefing from the K-State Research and Facility Security Officer.
.090 Information Technology Security While Traveling
K-State Information Technology Services (ITS) provides recommendations for employees and students engaged in university-sponsored international travel and/or traveling with university property. Key recommendations include:
- Do not travel with any moderate or high-risk data.
- Use the virtual private network (VPN) when accessing any university systems.
- Avoid public Wi-Fi networks that do not require a login or password.
- Confirm with staff (at your hotel, conference center, host, etc.) the correct name of the network and exact login procedures to ensure that the network is legitimate.
- To prevent theft and unauthorized access or loss of sensitive information, never leave equipment — including any USB or external storage devices — unattended in a public place.
- Keep your devices secured in taxis, at airports, on airplanes and in your hotel room. Also be aware that government officials and hotel staff will likely have access to the safe in your hotel room.
- If you travel with a mobile phone, do not use the public charging kiosks; the connecting cable may open access to whatever you have stored on the phone.
IT Loaner Laptop Program
Traveling with a loaner laptop reduces the risk of data and identity theft and is critical to protecting university property. The university's Division of Information Technology has 10 laptops available to be checked out by employees engaged in university-sponsored international travel to high-risk countries. More information about that program can be found at the IT equipment checkout website. The loaner laptop program is free to employees, but the unit of the employee, or the employee borrowing the laptop, as applicable, will be responsible for replacement costs due to damage, loss, or theft. IT is not responsible for any lost data.
.100 Foreign Corrupt Practices Act and State Ethics Rules
State ethics rules govern what state employees can receive, and the Foreign Corrupt Practices Act (FCPA) is more focused on what can be given to foreign officials — who are quite broadly defined, to include such individuals as faculty members at public universities abroad. Employees traveling abroad must be familiar with these rules.
Accepting or requesting gifts, meals, entertainment and travel offered because of your official position is generally prohibited, with several very limited exceptions. The State Governmental Ethics Commission’s guidelines have different rules for each of those categories. All State of Kansas employees are subject to these rules, and violations can result in a civil fine of up to $5,000 and/or removal from state service. You must be familiar with the rules, know where to find answers, and adopt a practice of asking questions when in doubt. Compliance with these ethics rules are personal obligations and subject to fines and criminal penalties against the individual.
The FCPA prohibits the university and its employees (among others) from paying, authorizing, or promising to pay money or anything of value to a foreign official to influence the foreign official or to secure any improper advantage in order to assist in obtaining or retaining business. Foreign officials include an expansive group of people. Notably, foreign officials include employees and agents of government-owned and government-controlled universities and businesses, such as faculty, administrators and other employees (and their family members) at counterpart public universities around the globe.
There is no exception to the FCPA simply because the meal, entertainment, gift or other payment is small; rather, the focus of the FCPA remains on the purpose of the payment. Any plans to provide gifts, travel, meals or entertainment to any foreign official should be scrutinized closely for FCPA compliance by the employee and the employee’s supervisor. If the person to whom the payment or anything of value is going to is assisting you or the university in conducting or retaining business or other benefits (such as in association with a university contract) or relieving you or the university from a legal requirement, you should consult with the Assistant Vice President for Risk and Compliance and the Office of General Counsel prior to making any payment or gift, regardless of size. You can read more about the FCPA from the Department of Justice’s resource guide. See the Office of General Counsel's website for more information about accepting gifts.
.110 International Contracts, Agreements, Collaborations
Any business, research or other similar services received by or provided to the university (or its employees) while in country should be documented within a university contract prior to traveling. Requirements for university contracts are in PPM Chapter 3070, and time for review of international activities contracts generally is more extensive due to necessary coordination with local foreign counsel.
.120 Training
Employees and students are responsible for completing any required training prior to departure. Such training could include, but is not limited to, responsible conduct of research, IACUC, IRB, and/or IBC training, export controls, anti-discrimination/anti-harassment, FCPA, political activity, and state ethics. Employees shall consult with the University Research Compliance Office at comply@ksu.edu for training requirements related to research and export controls prior to travel. Other training questions can be directed to Human Capital Services at hr@ksu.edu.
.130 Resources and Related Policies
K-State Travel Website
University Handbook Appendix S: Kansas State University Policy on Conflict of Interest, Conflict of Time Commitment, Consulting and other Employment
University Research Compliance Office Export Controls Compliance Program
Department of State Travel website
Centers for Disease Control Travel website
Lafene Health Center Travel Clinic
Guidelines for State Employees Concerning Meals, Gifts, Entertainment, and Travel
The Foreign Corrupt Practices Act Guide
PPM Chapter 6401 Reimbursable Travel Expenses and Forms
.140 Questions
Please contact the Office of Risk and Compliance for questions related to travel to elevated risk countries, travel insurance and assistance, and general policy questions. Please contact the Export Controls Office for questions related to Export control review and guidance.
