This page explains the University of Iowa's Temporary Overseas Remote Work Arrangement (TORWA) policy, which explains the approval request process for eligible employees to work outside the United States for up to 180 days.

Working while in other countries presents potential risk to the UI that depends on a number of factors, including but not limited to:

• Location
• Duration of stay
• Nature of the work
• UI systems access
• Data access
• Local collaboration
• Nature of your grants and contracts

For example, India has unique tax and labor laws that could result in significant liability for the UI depending on the nature of your work and duration of your stay. In other circumstances, accessing research data from other countries can risk penalties from funding agencies, accessing university systems can compromise security, and accessing student or records can implicate FERPA, HIPAA, or other privacy laws.  

For these reasons and more, the UI needs your cooperation to assess these risks and help you prepare for travel and possible work activities before you go in order to minimize potential liability.

International Remote Work Guidelines

Prior to completing any work while traveling internationally, review the guidelines below. Remember that remote work is a benefit that is offered by the UI when it helps to meet a significant business need. Remote work, temporary or otherwise, is subject to UI discretion and need. Faculty and staff should not expect to have continuous access to the UI systems in foreign jurisdictions and must plan for potential disruptions.

Eligibility for International Remote Work

Not all employees are eligible to work outside the United States. Employee groups not eligible for international remote work include:

• Student employees (including undergraduate, graduate, and professional students)
• Any appointment that is less than 50% FTE
• Teaching faculty (including clinical faculty who have scheduled instruction with students, residents, or fellows)
• Faculty and staff employed less than 12 months with the university
• Complimentary appointments
• Employees whose work involves items restricted by International Traffic in Arms Regulations (ITAR) or Export Administration Regulations (EAR)
• Any employee whose work would risk the UI establishing a legal presence or tax presence in another country in the UI's sole discretion

Travel to High-Risk Destinations

Due to regulatory, tax, privacy, legal, and IT security risks, the UI restricts employee work in certain countries. 

Even if working from high-risk countries is technically possible, access to University of Iowa systems, data, and information is prohibited from high-risk countries. This includes Office365, MAUI, Workflow, ICON, Epic, research shared drives, etc.

The current list of high-risk countries for prohibited University of Iowa systems or data access includes:

Russia, China (including Hong Kong and Taiwan), Cuba, Iran, North Korea, Sudan, Syria, and the Crimea Region of the Ukraine.

This list is subject to change. Other countries may be deemed ineligible for international work due to Level 4 Travel Advisories, as determined by the U.S. Department of State. 

If an employee intends to visit high-risk countries for university-sponsored or personal travel, they must notify their HR representative and local IT support as early as possible. Working from these countries may be prohibited, especially during personal travel.

Working in the Republic of India

India’s tax laws make it a high-risk country for remote university-related work. In addition, remote access to University of Iowa systems, data, and information necessary for accomplishing work may implicate regulatory, legal, and security issues and may not be permitted. As a result, travel to India requires thorough, fact-specific review and may not be approved in all cases. 

Temporary Overseas Remote Work Arrangement (TORWA)

Review the information above and the ITS International Travel Guidelines prior to completing any work while traveling internationally.

The Temporary Overseas Remote Work Arrangement (TORWA) form must be submitted by faculty and staff who want to work from an international location:

• For any period of time (even 1 day or less) from a security high-risk country: Russia, China (including Hong Kong and Taiwan), Cuba, Iran, North Korea, Sudan, Syria, and the Crimea Region of the Ukraine. 
• For any period of time (even 1 day or less) from a country under a U.S. Department of State Level 4 Travel Advisory.
• For any period of time (even 1 day or less) from a tax high-risk country (India).
• For 14 consecutive business days or more for countries not designated as high-risk or subject to a Level 4 Travel Advisory. 

TORWA applies when the nature of the work does not require the employee’s presence in the foreign country. This may be requested for personal reasons (including personal travel) or other professional travel, like a conference. 

If international travel does not meet the 14 consecutive working days requirement and is a low-risk country, approval from ITS and a local Human Resources representative is appropriate, rather than submitting a TORWA. If you will access research data from a low-risk country, you also must contact DSP and the Research Security Office in OVPR to ensure you are compliant with grant and contract disclosures for international work. 

A different process is applicable when the nature of the work requires the employee to work internationally. Examples of work that requires the employee to work internationally include where the university-related work can only be performed at a physical location in that country. You should contact Erin Litton if this applies to your request for international work.