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Units are required to utilize the PEO and hire personnel working abroad as a ��������Ƶ Global Affiliate, rather than ��������Ƶ Employee,  in scenarios where a new hire has any of the following: 

• Lack of access to US Banking Account; or
• Working abroad for more than 4 months in a tax period; and
• Hiring an individual living internationally that will continue living internationally;
• Does not have any of the exceptions listed below.

Exceptions 

��������Ƶ Boulder employees would not be required to transition to a ��������Ƶ Global Affiliate position if they are working outside of the U.S. in certain activities or employment arrangements and have worked in the U.S. previously. Under the following activities or employment arrangements, ��������Ƶ Employees are excluded from the requirement to use the PEO: 

• Sabbaticals of any length
• Research fieldwork
• Fellowships
• Study Abroad programs
• Academic, Research, or Administrative activities that require travel abroad, including conference travel
• If a potential hire abroad is affiliated with an institution other than ��������Ƶ Boulder. For these individuals, the institutional payment method is the default method of payment and should be used whenever possible. 

   All tenured, tenure-track faculty, and instructors are excluded from the use of the PEO requirement. TTT faculty are expected to work on campus as ��������Ƶ Employees. In rare cases, a TTT faculty may be initially hired using a PEO during an initial transition period. 

   Graduate assistant, graduate teaching assistant, and graduate research assistant recruitment and hiring decisions are managed by the hiring unit in partnership with the Graduate School. Questions regarding global work arrangements should be directed to the hiring unit and/or Graduate School.

The use of a PEO on sponsored projects is allowable in the following situations:

• For key personnel who are ��������Ƶ Global Affiliates and will not be paid salary from the project (salary will be paid from non-sponsored project funds). PIs or Co-PIs must have an eligible ��������Ƶ Boulder appointment. 
• In rare cases, such as University personnel moving out of the country near the end of a project or transitioning to a ��������Ƶ appointment from another country, an individual may serve as key personnel (PI or Co-PI) on a sponsored project and temporarily be paid through the Global PEO with the agreement of the responsible ��������Ƶ Unit and eligible ��������Ƶ Boulder appointment (eg, Research Affiliate). Note that the exclusion of TTT faculty being paid through the Global PEO still applies.
• For non-key personnel who are ��������Ƶ Global Affiliates and receiving salary from the project if:

  • They are not current ��������Ƶ Employees (eg, not allowable for currently employed PIs, postdocs, researchers, GRAs) and do not knowingly intend to be ��������Ƶ Employees (eg, new or to be new hires), intend to work from another country, and do not have access to U.S. healthcare, a U.S. social security number, or a U.S. bank account. 

  • In rare cases, new ��������Ƶ Employee hires may be initially hired using a PEO during an initial transition period. Current ��������Ƶ Employees may be temporarily hired using a PEO if a visa expires or they are transitioning from ��������Ƶ to a new appointment in another country

  • The sponsor allows/does not disallow “Personal Service Contracts.”

Only salary and fringe benefits (social costs) of the PEO costs can be charged to a sponsored project unless the ��������Ƶ Global Affiliate working in another country is a requirement of the project. If working in another country is not required for the project work, the unit must pay non-salary and non-fringe costs related to affiliation with the PEO. Global PEO refundable deposits are an unallowable cost. 

For all allowable cases:

• The sponsor must allow or not disallow “Personal Service Contracts.” Costs of the Global PEO are charged as “Personal Service Contracts” and not salary and wages.
• Personnel paid on the Global PEO are not subject to ��������Ƶ’s effort reporting process.
• If working in another country is not required for the project work, the unit must pay non-salary and non-fringe costs related to affiliation with GPS.
• If working in another country is a requirement of the sponsored project, then salary and fringe benefits (social costs) as well as some GPS fees may be paid by the sponsored project (see exclusions in the next bullet).
• GPS refundable deposits and “Transition Fee” are an unallowable cost for all sponsored projects and must be paid from non-sponsored project funds.

Global Affiliate records will be reflected in HCM as active affiliates (HCM: contingent worker) with no compensation and no assigned FTE to maintain access and affiliation with the University, to receive campus communications, and to be provided relevant systems access (including those paid on sponsored projects).  This will allow ��������Ƶ Boulder to maintain the history, status, and tenure of individuals regardless of pay mechanism (HCM or PEO), for ��������Ƶ Global Affiliates to complete training and compliance requirements, and to initiate system provisioning.  

��������Ƶ units are responsible for:

• Initiation and management of the relationship with the PEO
• All costs associated with the use of the PEO, including any PEO fees, required payment of salary, and fringe costs that contribute to benefits and foreign country social costs
• Providing ��������Ƶ Global Affiliates with a global affiliate MOU
• Onboarding new affiliates and advising on required affiliate policies, procedures, and training
• Receiving approval officer level approval
• Supervisory oversight and management of ��������Ƶ Global Affiliate’s work with the University
• Determining annual salary increase. ��������Ƶ Global Affiliates will be part of the merit process.  It is recommended that any salary increase follow Central HR recommended ��������Ƶ parameters for that period (ie. performance review on file “meeting expectations'' or better and adhering to the merit pool limit)
• For sponsored projects, ensure the costs are allowable by the sponsor before engaging with Global PEO

Units incur risk when an employee of ��������Ƶ works abroad while being paid through ��������Ƶ and not the PEO.  This could be in the form of fines or penalties being assessed by a foreign government and this risk is mitigated by the usage of the PEO.  International assignments, new hires, or telecommuting arrangements require due diligence and may trigger the need for tax and legal consultation outside of the University. The assigning unit is responsible for all externally incurred costs as a result of engaging in a global affiliate relationship, including potential fines or penalties levied against the University.  The head of the department must approve each global PEO relationship.  

��������Ƶ Global Affiliates are not considered ��������Ƶ Employees. However, they must adhere to prescribed University policies and procedures to maintain University affiliation.

��������Ƶ Global Affiliates are expected to keep current on all mandatory University training and reporting required of their work with the University. Performance management completion in the annual performance cycle is at the discretion of the department and not required for Global Affiliates. While a ��������Ƶ Global Affiliate is employed through the PEO, all employment risk is assumed by the vendor and not ��������Ƶ.  When a ��������Ƶ Affiliate works abroad in a standard employee relationship through the PEO, there is some risk assumed by the individual. However uncommon, this may include potential fines or penalties levied against the individual.