From: Papier, Joel (NIH/OD) [E]
Sent: Monday, June 16, 2008 4:35 PM
To: List ICTRAVELPOC-L
Cc: NIH Executive Officers; Stith, Kenneth (NIH/OD) [E]; Miers, Kristy (NIH/OD) [E]; Howard, Florence (NIH/OD) [E]; Sieber, Anna (NIH/OD) [E]; Rogerson, Anne (NIH/NIAID) [C]; 'mbharlow@aol.com'; Chiacchierini, Kathy (NIH/NBS) [C]; Martin, Jennifer (NIH/OD) [E]
Subject: OFM Transmittal No. 333 - New HHS-348 Sponsored Travel Certification Checklist Form

Importance: High

Good afternoon,

As you may know, the recently issued 2008 Version of the HHS Travel Manual contained a revised HHS-348 Sponsored Travel Form, i.e., the Certification Checklist.  As such, this office was advised by a DHHS Ethics Official that the NIH has been using a format that is vastly different from the old HHS Manual form but that it incorporates all of the information required.  And, in this regard, our NIH Form also mirrors the information displayed on the 2008 revised HHS Form only that some of the questions in the HHS Form have been either, combined, condensed, or juxtaposed.  One question however, that does bring about a significant change is Question No. 1 on the NIH Form vs. Question No. 3 on the new HHS Form.  On the NIH Form, Question No. 1 reads, “Is the sponsoring organization using Federal Funds to defray the costs of this trip?  (If yes, reimbursement may NOT be accepted)”.  Conversely, on the 2008 HHS Form, under Question No. 3, it reads, “Is the sponsoring organization using Federal Funds to defray the costs of this trip?  (If yes, explain the source of the Federal grant or contract)”.  Please be advised that what this change is highlighting is the HHS policy change that took place in 2005 that does permit travel acceptance even though the non-federal source may be using Federal grant or contract monies to pay for said travel.  We want to emphasize that this change did not stem from a statutory or regulatory source and thus, does not present any corresponding legal impediment.  To reiterate, the HHS Form was revised simply to reflect the aforementioned 2005 policy change.

To accommodate this change, we will continue to use our current automatically generated Certification Checklist, however, should you have a scenario where you answer “Yes” to Question No. 1, a field will now open up on the form that will allow you to proceed to enter a justification for such acceptance.

Please be advised that once we migrate to GovTrip, we will begin to utilize the new HHS Certification Checklist Form as intended.  The appropriate DHHS staff persons are examining this requirement to ensure that the automated form will be programmed such that the OPDIV Ethics Officials will be able to address each ethics related question accordingly.

Please ensure that your respective IC Ethics Officials receive a copy of this guidance.

Thanks,

Joel