Frequently Asked Questions

Middlebury College’s legal or official address is 9 Old Chapel Road, Middlebury, VT 05753. The address listed on W2, or 990 forms, is the Controller’s Office.

Middlebury has a $5,000 limit for hiring independent contractors without undergoing the formal engagement process. Though the IRS or any other external entity does not mandate it, the finance department set this limit. It serves as a streamlined approach for smaller projects and expenses. To learn more about procurement policies and procedures at Middlebury College, please visit the Middlebury Purchasing and Payment website.

Assessing the tax consequences for both the expert and Middlebury is crucial when bringing international experts to campus.

If the expert is a noncitizen on a visa and we can pay them, we would need to withhold taxes for work performed within the U.S. Work performed outside of the U.S. by a non-resident is not taxable.

To comply with tax laws and regulations, it is advisable to seek guidance from Middlebury’s tax office or legal counsel. For information on tax compliance and international tax matters, you can visit the Middlebury Tax Office.

Middlebury makes honorarium payments to foreign nationals for presentation-oriented events, such as guest lectures or invitational events. Foreign nationals in B-1, B-2, VWB (Visa Waiver Business), and VWT (Visa Waiver Tourist) status can accept honorariums and have their travel expenses reimbursed under the Honorarium Rule (“9/5/6” Rule) as long as they meet certain conditions. These conditions include the following:

• The activity must be a “usual academic activity or activities” (i.e. non-professional services).
• The stay at Middlebury College/Institute must be 9 days or fewer.
• The individual cannot have accepted payment from over 5 educational or research institutions (including Middlebury College/Institute) in the previous 6-month period.”

Please note that consultation on the curriculum is not eligible for payment under an honorarium, as it is considered a professional service and not offered to students or the public. When paying an honorarium to a foreign national, the honorarium is subject to a 30% federal withholding and applicable state withholding (around 8.1% for VT), unless the person can claim a tax treaty benefit. Withholding is not applicable to travel reimbursement, since it is not considered income.

For more information on tax compliance and payment procedures, please visit the Middlebury Tax Office

The 183-day tax rule is used to determine an individual’s tax residency based on the number of days spent in a specific tax jurisdiction. It is important to note that this rule is not universally applicable and is typically included in bilateral tax treaties between countries. Before considering whether this rule applies, it is essential to check if a tax treaty exists between the country of residence and the country of employment. You can visit the IRS website to see if a treaty applies and what it entails.

If an employee works overseas for a short period of time (generally less than 183 days within a tax year), they may still be considered a resident of their home country for tax purposes. However, the exact definition of “short period of time” can vary depending on specific tax treaties and local regulations. However, once the place of employment shifts to a different country, the payroll laws of that country will apply. To learn more about tax residency and international tax matters, we recommend consulting with Middlebury’s tax office or legal counsel. You can also visit the Middlebury Tax Office website for guidance.

Mauve Group is a leading provider of global HR, employment, and expansion services, helping companies expand their operations to new markets in over 150 countries. Middlebury uses Mauve Group’s services for hiring in situations where Middlebury’s existing overseas legal entities cannot hire individuals. If such a situation arises, the department concerned should reach out to Human Resources to ensure compliance with legal requirements and facilitate the hiring process through Mauve Group.

Middlebury offers comprehensive insurance coverage for both U.S.-based and non-U.S.-based faculty and staff when traveling abroad. 

Non-U.S.based staff: Middlebury provides CIGNA MBA insurance coverage, which includes comprehensive health insurance benefits for non-U.S. citizens traveling outside their country of residence for work related travel. This coverage applies to Middlebury’s Schools Abroad directors and employees of the Vienna Center for Disarmament and Non- Proliferation (VCDNP), among others.

U.S.-based staff: Employees on the standard U.S. benefits program are covered by several options:

• CIGNA: The standard U.S. medical plan (CIGNA) will pay for covered services incurred outside of the U.S., however in almost all cases the participant will need to pay for the claims directly and then file for reimbursement from CIGNA.
• CIGNA MBA insurance coverage: Middlebury provides CIGNA MBA insurance coverage, which includes comprehensive health insurance benefits for Benefits Eligible U.S. citizens traveling outside their country of residence for work related travel.
• Assist America worldwide travel assistance program offered through UNUM. This benefit provides pre-trip assistance and immediate 24/7 attention for emergencies, including medical evacuation, legal services, and more.

For details on health insurance coverage for international employees, please refer to the health and safety section at Middlebury Health and Safety.

Since not all grant proposals are successfully funded, an International Activity Review form is not required at the time of proposal submission. However, once a project has been funded, and at least eight weeks prior to making travel arrangements, please complete and submit the form. Please visit the “International Activity Review Form” section on the Middlebury website for more details. We recommend you discuss unique circumstances with the Office of Grants and Sponsored Programs (OGSP) to ensure compliance.

Conducting research in the open sea, whether on a ship or research vessel, necessitates specific documentation. This includes getting research permits and adhering to maritime regulations.

For guidance on these matters, researchers should consult Natalie Steen at the Office of the General Counsel. She can provide an updated field trip release form and assist with any additional requirements, such as scuba diving or other high-risk activities, which may require specific wording in the form. Please provide a certificate of insurance or other proof of insurance from either the vessel operator or the institute commissioning the boat, along with a copy of the contract. Please send this to the Middlebury Office of the General Counsel, addressed to Natalie Steen, for review; she will facilitate the review process.

For students not taking part in Middlebury School Abroad programs, there are a few options available for travel insurance while overseas. If their parents’ insurance covers the student, they should check if it includes coverage for overseas travel.

Students at Middlebury and MIIS who are pursuing other abroad experiences supported by Middlebury have the option to purchase the GeoBlue insurance plan.

GeoBlue insurance costs about $100 per month, making it a worthwhile option for students without other coverage. However, it is worth mentioning that GeoBlue insurance excludes coverage in the student’s home country. Therefore, if the student is from Uganda, for example, they would not be eligible for this insurance in their home country. This limitation is often the case with travel insurance.

In the event of a program evacuation, Middlebury has contracted evacuation services to ensure the safe and effective evacuation of students. Middlebury’s coverage extends to program evacuations, but not to individual evacuations. The cost of an individual evacuation will be the responsibility of the student and their family, and it can vary depending on factors such as location, circumstances, and travel restrictions. For further details, please visit Global Rescue Advisory Services.

Assuming the student is on the college plan, Middlebury provides coverage for medical evacuation and repatriation through its student health insurance plan. 

For more detailed information, please consult the following webpages:

• Middlebury Student Health Insurance Plan
• Health and Safety Abroad

Middlebury only approves the use of licensed and insured transportation companies to ensure the safety and security of its students, faculty, and staff. This includes ensuring that transportation providers are properly licensed, verifying that they have adequate insurance coverage, and conducting a vetting process to meet safety and reliability standards. In addition, protocols are in place for handling emergencies during travel. While this may create some hurdles, Middlebury cannot take on the risk of individuals transporting their students or employees. While this may create some hurdles, Middlebury cannot take on the risk of individuals transporting their students or employees.

For specific risk-related questions, please contact the Enterprise Risk Management Specialist. For more information on procurement policies and procedures, please visit Enterprise Risk Management at Middlebury.

Organizers of trips where Middlebury has a contract (even if only an e-mail exchange) for space (i.e. accommodation, classroom, event) that will be used by students should submit a Clery Trip Form. 

Middlebury staff responsible for student trips must report trip information to the Middlebury College Department of Public Safety or the Director of Operations at the Middlebury Institute (for MIIS trips). We recommend filling out the form before the trip to avoid forgetting. For questions, visit the Clery Compliance webpage, or email ftorrey@middlebury.edu and dkirby@middlebury.edu.

The International Activity Review Form is required for any Middlebury/MIIS-sponsored programs or activities abroad. This form ensures that all international initiatives are reviewed and approved according to Middlebury’s guidelines. It helps in assessing the risk and planning new programs abroad. For more details, please visit the International Activity Review Form page.

The Travel Registration Form is mandatory for all Middlebury-affiliated individuals traveling abroad on a Middlebury-sponsored activity. This form helps Middlebury quickly account for the whereabouts of students, faculty, and staff abroad, allowing the institution to provide help in case of emergencies. For more information, please visit the Register My International Travel page.

Finance Record Retention Policy: At present, we do not have a direct link to the finance record retention policy. The finance record retention policy on our website requires updating. We recommend retaining financial data on a selected platform for at least six years. For further information, consult the Student Financial Services Handbook. 

Record Retention Policy for Middlebury-C.V. Starr Schools Abroad: Our record retention policy document has undergone no changes since its inception. Therefore, we can proceed with using the existing policy document. 

Data Loss Prevention (DLP) Policy: Middlebury has an established data loss prevention (DLP) policy, but we have yet to create a formal data retention policy. You can review the Data Classification Policy, which includes principles for data protection and may cover aspects of data loss prevention. 

If you need further help, please reach out directly to Middlebury’s Information Technology Services or the Office of Student Financial Services.