Federally Funded Air Travel: Fly America Act and Open Skies Guidance 

Air travel charged to a federal grant or contract, including a federal flow-through award, must comply with the Fly America Act and any applicable Open Skies Agreement. Compliance is the responsibility of the department and Principal Investigator. Before purchasing airfare, confirm that every flight segment uses an eligible U.S.-flag carrier or qualifying codeshare, or that the itinerary meets the requirements for an allowable exception. Travel that does not comply with the Fly America Act cannot be charged to the federal award and may require a non-federal funding source.

• Before Booking Airfare

  Before purchasing airfare for travel charged to a federal or federal flow-through award:

  1. Confirm the funding source. Determine whether the trip will be charged, in whole or in part, to a federal or federal flow-through award.
  2. Review every flight segment. Review connections and return flights, not only the longest segment. Confirm the ticketed airline designator and flight number for each segment.
  3. Review the award terms. Sponsor-specific or award-specific requirements may be more restrictive than the general Fly America Act requirements.
  4. Resolve exceptions before purchasing. If a foreign carrier may be necessary, determine whether an allowable exception applies and retain the supporting flight searches available at the time of booking.

  Travelers must use a U.S.-flag carrier or qualifying U.S.-carrier codeshare unless the itinerary meets the requirements for an allowable exception.

• Codeshares and Multi-Segment Itineraries

  Codeshares and Multi-Segment Itineraries

  For a codeshare flight, the airline designator and flight number shown on the ticket determine Fly America Act compliance.

  A flight may qualify when a foreign airline operates the aircraft, provided the ticket displays a U.S. carrier’s designator and flight number. A U.S. codeshare available on the same aircraft does not make the traveler’s ticket compliant if the purchased ticket displays the foreign carrier’s designator.

  For itineraries containing multiple flights, review every ticketed segment separately. One compliant segment does not make the entire itinerary compliant.

  

   

   

   

   

   

   

   

   

   

  Example: Each segment must be evaluated using the airline designator and flight number shown on the traveler’s ticket.

  Segment	Ticketed flight	Operating carrier	Result
  Los Angeles to Frankfurt	UA 945	Lufthansa	Compliant U.S.-carrier codeshare
  Frankfurt to Munich	LH 122	Lufthansa	Foreign-carrier flight number; review for an allowable exception
  Munich to Los Angeles	UA 8860	Lufthansa	Compliant U.S.-carrier codeshare

• Allowable Exceptions

  When an Exception May Apply

  Federal guidance recognizes limited circumstances in which a foreign carrier may be used, including:

  • No U.S.-flag carrier service is available.
  • Using a U.S.-flag carrier would extend the total travel time by 24 hours or more.
  • A U.S.-flag carrier does not provide nonstop or direct service, and using available U.S.-carrier service would:
    • Increase aircraft changes outside the United States by two or more;
    • Extend travel time by six hours or more; or
    • Require a connection of four hours or more at an overseas interchange point.
  • The scheduled flight time is less than three hours and using a U.S.-flag carrier would at least double the travel time.
  • An applicable Open Skies Agreement permits the use of the foreign carrier.

  A lower ticket price, traveler preference, or convenience alone does not qualify as an exception. Award-specific requirements may also be more restrictive than the general federal rules.

  When an exception applies, complete and sign the Fly America Act Exception Form. Attach the form and all supporting documentation to the Concur Expense Report.

  Completing the form does not, by itself, make a noncompliant itinerary allowable. The selected exception must be supported by the itinerary and booking-time documentation.

• Open Skies Agreements

  An Open Skies Agreement may permit the use of an eligible foreign carrier for certain federally funded international travel. An agreement does not automatically make every foreign-carrier flight allowable.

  Before relying on an Open Skies Agreement:

  • Confirm that the route and foreign carrier qualify under an applicable agreement.
  • Determine whether a GSA City Pair fare applies to the origin and destination.
  • Confirm that the travel is not funded by the Department of Defense or a military department.
  • Review the award terms for additional sponsor restrictions.
  • Retain the City Pair search and other flight-search results available at the time of booking.

  Complete the Fly America Act Exception Form and identify the applicable Open Skies exception.

  Review the GSA Fly America Act and Open Skies guidance and the GSA City Pair Search before purchasing the ticket.

• Required Documentation and Review

  Retain documentation that identifies the complete itinerary and supports compliance for every flight segment.

  For federally funded foreign travel, include the following with the Concur Expense Report, as applicable:

  • A detailed itinerary showing every flight segment, flight number, and ticketed and operating carrier;
  • The booking confirmation and airfare receipt;
  • Boarding passes or other carrier documentation when the booking record does not contain sufficient detail;
  • Booking-time flight-search results supporting the selected exception;
  • GSA City Pair search results when relying on an Open Skies Agreement;
  • The completed and traveler-signed Fly America Act Exception Form, when applicable;
  • Lodging receipts;
  • Meal receipts when claimed expenses exceed the approved per diem rates; and
  • Receipts for other reimbursable costs, such as visa fees, ground transportation, and parking.

  A general Expedia or Anthony Travel confirmation is not sufficient when it does not identify every segment, flight number, and applicable carrier. Provide a detailed itinerary from the carrier, travel agent, or online booking service, or boarding passes covering the entire trip.

  Extramural Funds reviews federally funded foreign travel documentation before Accounts Payable completes the reimbursement. The department may be contacted if additional information is needed.

  Review the Foreign Travel Documentation Requirements for Federally Funded Awards.

• Common Questions and Resources

  Common Questions

  What if the foreign-carrier flight is less expensive?
  A lower price, by itself, does not qualify as an exception.

  What if a foreign airline operates the aircraft?
  Check the ticketed airline designator and flight number. A U.S.-carrier flight number may qualify even when a foreign airline operates the aircraft.

  What if the airfare has already been purchased?
  Determine whether an allowable exception applies. Completing an exception form after purchasing the ticket does not correct noncompliance when no valid exception exists.

  What if the airline changes the flight involuntarily?
  Retain the original compliant itinerary, cancellation or change notice, and revised booking. Document the circumstances and determine whether an exception applies.

  What happens if the airfare does not comply?
  The airfare cannot be charged to the federal award. The department must identify an appropriate non-federal funding source.

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  Resources

  • Fly America Act Exception Form
  • GSA Fly America Act and Open Skies Guidance
  • GSA City Pair Search
  • Foreign Travel Documentation Requirements for Federally Funded Awards
  • UC Business and Finance Bulletin G-28: Travel Regulations