The University of Vermont (UVM) affirms the importance of global engagement in education, research, and service. This policy exists to enable safe and responsible participation in international activities while safeguarding the well-being of travelers and institutional integrity.   UVM encourages global engagement of its students, employees, and affiliates through international and U.S. territory travel. Recognizing the benefits of such travel, UVM also acknowledges both its duty of care to safeguard the health, safety, and well-being of all university-related travelers and its regulatory compliance requirements. This policy establishes requirements and guidelines to responsibly manage the risks associated with international and U.S. territory travel, ensure compliance with relevant regulations, and provide travelers with resources for safe, secure, and successful international travel.

This policy is to be read in conjunction with the UVM Travel Policy, which outlines institutional procedures for travel expenses such as transportation, lodging, meals, receipt requirements and authorizations, which are needed for travel cash advances. Where specific requirements exist for international travel, this policy supplements and extends those provisions.

UVM recognizes that international travel is necessary and of value for learning, research, and University business. Through this policy, the University aims to manage and reduce risk, including regulatory and safety risk, and provide helpful resources for safe, secure, and successful international travel.

This policy applies to: university-related international travel and UVM international travelers as defined below. This includes sponsored travelers who are not UVM employees or students and whose travel fits the definition below. This policy governs all international and U.S. Territory travel that is sponsored, supported, and/or facilitated by extramural sources, or is supervised or facilitated by the University of Vermont (UVM). It applies to employees (including faculty, staff, and others as defined below), students, and other UVM affiliates, including guests of UVM who engage in university-related international travel and travel to U.S. territories, defined by the policy, with specific provisions for travel involving students. Non-UVM travel is excluded. International travel also includes travel to U.S. territories. For international travel that involves both university-related and non-UVM travel, the traveler should follow this policy for the university-related portion of the travel.

Activities with Elevated Risk: Activities that are not simple and routinely accomplished, and which hold an increased possibility of injury, illness, structural damage, or financial loss. Examples include but are not limited to:  travel to elevated-risk destinations, attendance at mass gatherings, camping and wilderness travel, entering deep or near moving water, interaction with animals, rock or ice climbing, using explosive materials, driving long distances, or the use of power tools.

Direct Supervisor: The person who has direct oversight over the employee’s workload allocation. For many faculty this would be their chair, but this is not always the case. For staff, this would be their director-level supervisor in most cases. 

Elevated Risk Regions: Includes Foreign Countries of Particular Concern, and areas identified by federal agencies such as the U.S. Department of State, the U.S. Centers for Disease Control, the U.S. Office of Foreign Assets Control, as well as UVM’s international travel and medical assistance provider.

Employee: Any person employed by UVM in any capacity, including, but not limited to, part-time and full-time faculty, staff, and temporary employees. This also includes individuals based internationally and employed by UVM, either part-time or full-time. For faculty holding dual appointments with external entities, this policy applies when the travel is considered University-Related International Travel, whereby UVM requires, supports, supervises, controls, facilitates, or manages the travel.

Students who are also employees are defined as students for the purpose of this policy unless they are employed by UVM in a capacity unrelated to their studies and are traveling related to their role as an employee.

Foreign Countries of Concern: Countries identified under the CHIPS and Science Act as presenting heightened security or compliance risks. 

Independent Student Travelers: Any UVM student who is not traveling on an established education abroad experience (study abroad, travel study, or UVM GO), but whose travel is facilitated or supported by the University in some way. This includes international and U.S. territory travel sponsored by UVM by way of financial support, academic credit, or affiliation. Examples include Recognized Student Organization travel, participation in a professional conference, conducting research, internships, and medical rotations abroad or in a U.S. territory.  

International Travel Advisory Group (ITAG): A body with three charges related to travel with students or by a student:

• Evaluate and approve university-related international travel requests from students or involving students, including graduate student travel and sponsored travelers who are students at other institutions, as delegated by the Provost
• Evaluate requests and forward recommendations involving international travel to elevated-risk destinations and/or high-risk activities to the Provost for final review and decision-making  
• Coordinate emergency response, as appropriate, for international incidents involving travel with students, including work with the University’s Emergency Operations Group 

International Travel Emergency Team: A body with two charges related to faculty and staff travel and travel emergencies:

• When faculty or staff travel is anticipated to pose enhanced risk, this group provides assessment and feedback to the traveler, Chair, Dean, or other leaders.
• Act as an extension of the Emergency Operations Group if a serious incident, defined in the Emergency Operations Plan International Travel Emergency Annex, occurs. 

International Travelers: All UVM-affiliated individuals, including employees, students, and sponsored travelers engaging in university-related international travel.

Sponsored Traveler: Any non-UVM person whose travel is being funded by UVM or by funds flowing through UVM (e.g., gift, grant, award, research agreement/contract). 

Student: Any individual enrolled in a UVM academic program (degree or non-degree), credit or non-credit, graduate or undergraduate, including online or distance, certificate, professional, and executive education programs. Graduate teaching assistant, graduate research assistant, graduate assistant, pre-doctoral trainees, pre-doctoral trainees/fellows are considered students for purposes of this policy. 

University-Related International Travel: Travel by students, including independent student travelers, employees, or sponsored travelers to an international or U.S. territory destination that UVM requires, supports, supervises, controls, facilitates, or manages. This includes travel supported by external grants (e.g., from federal agencies or private foundations) made to UVM. Personal travel, along with travel that is not authorized, sponsored, facilitated, or controlled by UVM is excluded from the definition of university-related international travel.

U.S. Territories: U.S. territories include American Samoa, Guam, Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands.

UVM Sponsoring Employee: A UVM employee overseeing the program for which a sponsored traveler’s travel is authorized, sponsored, facilitated, or controlled.

1. International Travel and Medical Assistance Provider Registration

   Registering with UVM’s International Travel and Medical Assistance provider is required and essential to ensure that travelers receive pertinent information and updates from UVM’s international travel and medical assistance provider and have access to their emergency services. Travelers can register either by setting up a login and password on their phone or online by following the details provided at the above link, which details how to access the provider. 

2. Compliance

   Failure to comply with the requirements listed herein may result in denial of reimbursement for travel expenses, suspension of travel privileges, and/or the imposition of disciplinary action, in accordance with applicable University policies, handbooks, codes of conduct, and collective bargaining agreements. Additionally, travelers are personally liable for any violations of federal or international civil or criminal laws that occur during travel, whether authorized or unauthorized.

Before purchasing a ticket for international or U.S. Territory travel, all students, employees, and responsible UVM agents arranging for sponsored travelers must follow the procedures outlined below.

1. Students: Students traveling through UVM-run and UVM-approved education abroad opportunities, including study abroad programs, travel study, as well as Independent Student Travelers, must be registered and approved in UVM’s GoAbroad system following Office of International Education protocols and deadlines. Among other important things, this ensures that travelers are covered by UVM travel insurance policies. 

2. Employees: Employees planning university-related international travel to countries or regions with a U.S. Department of State Travel Advisory level of 3, 4 or “other” must seek prior approval by their direct supervisor and engage with the International Travel Emergency Team (risk.management@uvm.edu) for review, as specified in UVM’s International Travel Pre-Approval and Review Procedures.  
   
   For countries with a travel advisory level of 1 or 2 can proceed with travel bookings after following any departmental or unit protocols from their home appointment unit.

   All employee university-related international flights must be booked through UVM's designated travel management company, as specified by University Financial Services, except when the travel is arranged by approved partner institutions, subrecipients, or hosts under existing agreements (for example if a foundation or industry partner books and pays for the travel). Travelers should refer to the UVM Travel Arrangements page for current vendor information and booking procedures. Among other important things, this ensures that travelers are covered by UVM travel insurance policies and ensures the University's fulfillment of its duty of care.

3. Sponsoring Employee and Sponsored Travelers: The UVM sponsoring employee must disclose with their pre-travel registration as detailed above that they are planning on taking a non-UVM person whose travel is being funded by UVM or by funds flowing through UVM (e.g., gift, grant, award, research agreement/contract). 

Certain destinations are classified as elevated risk regions due to health, safety, security, or environmental concerns. UVM mandates that any university-related international travel to elevated-risk regions receive additional review by the International Travel Emergency Team and/or ITAG, as appropriate. 

1. Students: Review of student international travel starts with the student’s GoAbroad registration detailed above and ends with the Provost’s final determination about the allowability of travel. After review and in case of denial, a student may request a reconsideration by ITAG by bringing additional information to be considered.

2. Employees: Before employee travel can be approved, the employee must notify the direct supervisor of intended travel.  If there are multiple supervisors, all of them must be informed, but consultation occurs with the supervisor of the area related to their travel. The direct supervisor must e-mail Risk Management (risk.management@uvm.edu) at least six weeks in advance of departure with a draft itinerary of the trip that includes the sites to be visited, means of in-country transportation, whether others will be traveling, and any other trip information that will help Risk Management assess risks and identify mitigation strategies. 
   
   When employee travel to the same destination recurs for ongoing collaborations or fieldwork, and there is no change in the U.S. Department of State advisory level or substantive change in the in-country risk conditions, a standing or “umbrella” approval may be granted. Such approval remains valid for one year unless risk conditions change. Prior to each subsequent trip, the employee shall confirm that travel circumstances remain consistent with those described in the most recent approval. 

   Multiple employees associated with the same project or site may be covered under a single bundled approval request. 

   After review and in case of a denial, an employee may request reconsideration by bringing additional information to be considered.

   Additional information and steps are detailed in UVM’s International Travel Pre-Approval and Review Procedures (outlined below). 

Emergency assistance is coordinated through the University’s designated international travel and medical assistance provider. 

UVM retains discretion to rescind travel approval, cancel travel, or recall travelers based on safety or security assessments, including for student conduct issues that arise during travel. Decisions to rescind travel approval, cancel travel, or recall travelers are issued by the UVM Provost and must be adhered to by employees, students, and sponsored travelers. Such decisions are informed by the international travel emergency team and the University’s international medical and emergency assistance provider and are arrived at in consultation with the responsible faculty member and/or a hosting partner institution, in the case of education abroad experiences. In the instance of research collaborations, such decisions will be made in consultation with the Principal Investigator when feasible to ensure that research or field activities are safely and appropriately concluded. 

1. Students: Students participating in university-related international travel, including travel to U.S. territories must:
   1. Follow all Office of International Education registration processes and approvals in GoAbroad
   2. Comply with UVM’s Code of Student Conduct while abroad
   3. Attend any mandatory pre-departure orientations or health/safety briefings coordinated by the sponsoring unit, Office of International Education (OIE), or Risk Management
   4. Download the international travel and medical assistance app to their phone (Information available at UVM’s Risk Management website)
   5. Enroll in the U.S. State Department STEP Program, if a U.S. citizen, or their home country’s equivalent of a State Department registration, if not a U.S. citizen
   6. Understand that they are subject to the laws of the country/countries to which they are traveling.
2. Employees: Employees participating in university-related international travel, including travel to U.S. territories, must:
   1. Follow all departmental or unit protocols for their home appointment unit, including obtaining approval to travel
   2. Book their travel through UVM’s designated travel management company
   3. Download and set up the international travel and medical assistance app to their phone (Information available through UVM’s Risk Management website). In keeping with the University’s commitment to academic freedom and the protection of individuals involved in scholarly activities, travelers may temporarily restrict or disable location tracking when participating in sensitive research, meeting with vulnerable communities, or when local laws or conditions could place them or others at risk. Travelers should reactivate location services as soon as it is safe to do so to ensure access to emergency support. 
   4. Enroll in the U.S. State Department STEP Program, if a U.S. citizen, or their home country’s equivalent of a State Department registration, if not a U.S. citizen
   5. Register with UVM’s designated international travel and medical assistance provider
   6. Follow protocols outlined in the Section on Travel to Elevated-Risk Destinations if traveling to an elevated-risk area 
   7. Understand that they are subject to the laws of the country/countries to which they are traveling.

3. Faculty/Staff Leading Student International Travel: Faculty and staff planning to lead students abroad bear primary responsibility for ensuring a safe experience that is compliant with relevant policies and regulations. Therefore, they must do all the following:

   1. If involved in education abroad (UVM GO, Study Abroad or Travel Study), begin planning early and work with OIE or UVM GO to meet all requirements on timelines, logistics, budget, vendor contracts, pre-departure trainings, and travel support
   2. If involved in team or club travel, register group leader travel through GoAbroad and ensure student travelers complete their OIE obligations
   3. Secure written approval from their department/unit head, sponsoring Dean, Vice President, Vice Provost, or Chief Officer, and the International Travel Advisory Group
   4. Ensure all travel is registered and compliant with UVM policies, federal, and host country laws
   5. Download the international travel and medical assistance app to their phone (Available through UVM’s Risk Managementwebsite)
   6. Enroll in the U.S. State Department STEP Program and review safety and security advisories with Students

   In the event of an emergency, the faculty or staff leader must coordinate with UVM’s international travel and medical assistance provider to communicate available emergency services. Faculty and/or staff are expected to act as trip leaders and support students in adhering to UVM standards, policies and laws of the host country throughout the program.

UVM does not assume responsibility for non-affiliated individuals (e.g., family members) who travel in conjunction with UVM travelers. These individuals are not eligible for UVM travel benefits or insurance.

Sponsored student travelers, those who are not students at UVM but are students at another institution, are expected to register or be registered by the sponsoring employee in GoAbroad and follow the procedures for student travel.

Sponsored travelers, those who are neither a UVM student nor a student at another institution, are required to have their tickets arranged and purchased in the designated travel management system by the UVM sponsoring employee. Sponsored travelers must:

• Follow protocols outlined in the Section on Travel to Elevated-Risk Destinations if traveling to an elevated-risk area 
• Follow the laws of the host country 
• Follow the recommendations of the UVM sponsor 
• Reimbursement for international collaborators or sponsored travelers is permitted when their travel arrangements comply with UVM procurement requirements and can be reimbursed when booked outside of UVM's designated travel management company. 

1. Insurance: Travelers must maintain health insurance that covers them during international travel. All international travelers, as defined by this policy, engaged in university-related international travel are covered under UVM’s emergency medical insurance and its international travel and medical assistance provider coverage. Further information about the policy and coverage is maintained by UVM Risk Management.

   Utilizing the University's designated travel vendor and/or registering through GoAbroad for students ensures that travelers are covered under UVM's travel insurance policies. Booking through unauthorized channels may result in a lack of coverage and non-reimbursement of expenses.

2. Foreign Travel Security Training: As defined in the CHIPS and Science Act of 2022, all employees who are engaged in university-related international travel that includes teaching, conference attendance or research, or personal travel if that personal travel involves federally funded equipment, data with periodic training on foreign travel security, must comply with the federal government’s foreign travel security training requirement. This training must begin within one year after a federal agency provides a foreign travel security training resource, and then at least once every six years. This policy will be updated when that training has been released.

3. Export Control Compliance: All travel must comply with U.S. export control laws and regulations, as well as the University of Vermont’s Export Controls Policy. 

   Travelers are responsible for identifying export-controlled items (equipment, technology or software) and activities, as well as complying with any restrictions related to the transfer of such item to a foreign person (including obtaining necessary approvals, adhering to technical control plans and completing required trainings). The UVM supervisor of the traveler is available to provide assistance in identifying such restrictions and compliance requirements. The UVM supervisor may reach out to the Office of the Vice President for Research for additional resources.

   For detailed guidance and procedures, refer to UVM’s Export Controls Policy.

4. Data and Device Security: Travelers are responsible for safeguarding University data and devices. To reduce the risk of data loss, theft, or compromise, all travelers must follow UVM’s Information Security Policy and related procedures. Consult UVM’s Information Security Travel Guidance before travel. This guidance includes best practices on the use of secure devices, avoiding public Wi-Fi, limiting access to sensitive data, and incident reporting requirements. Data developed in whole or in part under a federally funded sponsored project may not be exported to foreign “countries of concern” without a prior review with the UVM export control officer.

   Basic Windows 11 laptops are available for short-term loan when traveling internationally.  Travelers should start by reaching out to the Information Security Office at iso@uvm.edu to let them know of the travel plans. The ISO group will provide additional instructions. Details can be found at International Loaner Laptop Guidelines.

5. Sponsored Project Administration (SPA) and International Travel: Where sponsored project funding will be used to cover international travel costs, it is the responsibility of the Principal Investigator or their designee to check with the unit’s SPA specialist or SPA to ensure international travel is allowed under grants and contracts or for assistance with a rebudgeting action or a request for prior approval from the sponsor, where needed.

University travelers must promptly report any significant incident that occurs during university-related international travel. Reporting is not optional. This includes but is not limited to medical emergencies, injuries, arrests, threats to safety, loss of UVM documents or equipment, discrimination, harassment, sexual misconduct, and other violations of University policy or local law.

• Emergency and Safety Incidents: In emergencies, all travelers notify UVM's international travel and medical assistance provider to initiate contact with UVM and other emergency supports. If the incident is a political or diplomatic incident, US travelers should contact the nearest US consulate/embassy as needed for support; whereas, non-U.S. travelers should contact their home country consulate/embassy in the host country. 
• The International Travel Emergency Response Team may convene to provide assistance and follow the Emergency Operations Plan International Travel Emergency Annex procedures.
• Incidents such as injury, illness, theft, or arrest must be reported to UVM Risk Management within three business days: Risk Management Reporting Procedures
• UVM faculty/staff leading students on international travel must report incidents to the Office of International Education following established emergency protocols.
• Certain international program sites and university-sponsored locations may fall under Clery crime reporting requirements. If you are unsure whether an incident qualifies, report it to UVM’s Clery Act Coordinator for evaluation. Refer to UVM Reporters Guidance.

1. Discrimination, Harassment, and Sexual Misconduct: Incidents of alleged discrimination, harassment, or sexual misconduct involving International Travelers must be reported to the Office of Equal Opportunity (EO). Refer to UVM Reporters Guidance.
2. Missing Persons Abroad: If an International Traveler is believed to be missing while abroad, report the situation immediately to UVM Police Services. For students, also report to the student’s UVM travel international program leader or OIE contact, and for others, report to the supervisor/director.

Training/education related to this policy is as follows:

Additional required training will be provided on an as-needed basis as determined by the Approval Authority or the Responsible Official.

Questions concerning the daily operational interpretation of this policy should be directed to the following (in accordance with the policy elaboration and procedures):

1. Students and Student Groups: Proposals must be submitted through the Office of International Education (OIE) at least six weeks in advance of travel and prior to the purchase of a ticket to that destination. The International Travel Advisory Group will evaluate the risks associated with the travel.
2. Employee: Determine Travel Advisory Level. If Level 1 or 2, additional approvals are not required. If Level 3, 4, or “Other”, the employee notifies via e-mail their department chair or director-level supervisor at least six (6) weeks prior to travel. Exceptions to the six-week review notification will be granted, if the international travel is expressly for emergency and/or humanitarian response work.
3. Sponsored Travelers:
   1. The UVM Sponsoring Employee determines Travel Advisory Level.
   2. If Level 1 or 2, the UVM Sponsoring Employee verifies, in writing, that the travel is university-related travel as defined in the Policy.
   3. If Level 3, 4, or “Other”, the UVM Sponsoring Employee notifies their direct supervisor via e-mail at least six (6) weeks prior to travel. The direct supervisor is responsible for contacting Risk Management. Exceptions to the six-week review notification will be granted, if the travel is expressly for emergency and/or humanitarian response work.

1. Upon providing notification of the intent to travel to the Department Chair and before travel can be approved, the department chair or director-level supervisor will e-mail International Travel Emergency Team via Risk.Management@uvm.edu with a draft itinerary of the trip that includes:
   1. sites to be visited
   2. means of in-country transportation
   3. whether others will be traveling
   4. other trip information that will help Risk Management assess risks and identify mitigation strategies in preparation for the meeting described in step I.C.

2. Within ten (10) days of receiving the department chair/director notification, the International Travel Emergency Team will meet with the traveler and direct supervisor, engage Healix International, and consult with the University’s insurance carriers or others as necessary. 

   Within seven (7) days of the meeting, the International Travel Emergency Team will provide written recommendations summarizing risks and mitigation strategies related to the travel.

3. After the employee and chair/director review the written recommendations about travel risks and actions that can be taken to mitigate those risks, the chair/director will make a determination. Chairs or directors may consult with their dean or supervisor.

   Chair/Director notifies employee of the decision, including any recommendations. Chair/Director may consult with their Dean or supervisor.

1. Students and Student Groups: The International Travel Advisory Group will refer international travel risk assessments deemed to be to a region with an elevated risk or including activities associated with elevated risk to the Provost, who makes the final decision on the allowability of travel.
2. Employees: Travelers must follow departmental protocols and consult with Risk Management if planning travel to elevated-risk regions. Approval from the sponsoring Dean, Vice President, or Chief Officer is required in addition to general travel authorization.
   1. Advance Notification: Employees must inform their department chair or director-level supervisor of planned travel to elevated-risk areas as soon as possible, and prior to the purchase of a ticket to that destination.
   2. Risk Management Engagement: The department chair or director must notify Risk Management, providing a draft itinerary and relevant trip details to assess risks and identify mitigation strategies. Risk Management may engage the International Travel Emergency Team to provide feedback.
   3. Risk Assessment Meeting: Within five business days of notification, Risk Management will meet with the traveler and chair/director, engage the international travel and medical assistance provider, and consult with the University’s insurance carriers or others as necessary.
   4. Written Recommendations: Within seven days of the meeting, Risk Management will provide written recommendations summarizing risks and mitigation strategies related to the travel.

Final Approval: After reviewing the recommendations, the department chair or director will make the final decision regarding travel approval, potentially consulting with their dean or supervisor.  In the case of multi-departmental collaborations and travel, both unit heads must be engaged and reach a consensus regarding the final decision.