Sponsored Travel Policy FAQs


What is the Fly America Act?

The Fly America Act is a federal regulation that requires that any foreign air travel funded by the federal government be booked with U.S. flag air carriers, regardless of cost and convenience.

My PI has funding from both federal and non-federal sponsors. Are there rules relating to travel costs charged to federal awards that are different than those for non-federal awards?

Yes. Any travel costs charged to federal awards must comply with federal regulations, including the requirement to book the lowest economy airfare and comply with the Fly America Act. Travel on a non-federal award does not need to meet the Fly America Act requirement.

What is a U.S. flag air carrier?

In general, all airlines based in the United States qualify. Specifically, a U.S. flag air carrier is one that holds a certificate under Section 401 of the Federal Aviation Act of 1958. If you have questions on where a particular airline is based, you can search this airline database.

In addition, travelers are allowed to fly on code share flights operated by foreign carriers. A flight qualifies if a ticket is purchased from a U.S. flag carrier but the aircraft is operated by a foreign airline. Your ticket will identify the U.S. carrier in this case. For example: “AA 1234 operated by SAA 567” (AA = American Airlines, SAA = South African Airways).

What is a code share flight?

The traveler is considered to be on a code share flight if he/she purchases a ticket from one carrier but flies on an aircraft owned by another airline. This would be a ticket that is issued by a U.S. air carrier that states “U.S. air carrier flight XXXX operated by foreign air carrier.” There may be a list of code share partners on the U.S. air carrier’s website; however, not all flights on those partner airlines are operated under code share agreements. Only code share flights booked properly through the U.S. carrier are allowable.

Allowable:  AA 1234 operated by QF 4321
Unallowable: QF 4321 operated by AA 1234
(AA = American Airlines, QF = Qantas Airways)

How do I determine whether a flight is a code share flight?

Tickets/electronic receipts include the information necessary to determine if a flight is a qualifying code share. Tickets must be issued by the U.S. flag air carrier and the flight number must use the code of a U.S. carrier (e.g. UA, AA).

If you have questions before purchasing a ticket, you can contact the airline, which is required by law to answer questions related to code share flights.

Where can I find the airline designator codes?

If you are trying to determine the country of origin of an airline, visit The Airline Codes Website.
You can search for any airline and see the country associated with the airline on the Airline Code Search Results page.

What if I’m flying within a foreign country or between two foreign countries?

Even when traveling between two foreign locations, a traveler must abide by the Fly America Act regulations. Certain exceptions may apply.

What if there are no U.S. flights available?

You must use a U.S. flag air carrier for all legs of your route on which a U.S. flag air carrier is an option. If a U.S. flag air carrier does not travel to your final destination or does not provide service on a portion of your route, you may use a foreign air carrier only on the leg(s) for which U.S. service is unavailable. If a Fly America Act exception exists, it is the traveler’s responsibility to obtain the supporting documentation at the time of purchase to substantiate the allowable exception.

My PI is planning an international trip that is approved under his/her federal award. What issues do I need to consider when booking the airfare?

The Fly America Act states that when using federal funds you must use U.S. flag air carriers or flights operated under a U.S. code share agreement to travel to the foreign destination. The easiest way to ensure that you are flying on a U.S. Flag Air Carrier is to book your travel directly through the U.S. flag air carrier. Using a travel website such as Kayak, Expedia, Travelocity, etc. can cause confusion, as these websites are designed to find the lowest fares regardless of air carrier.

Do trainees, students, consultants or other non-Brown University personnel have to follow the Fly America Act?

Yes, the Fly America Act must be utilized by all individuals who are seeking reimbursement for travel costs on federal awards. If trainees, students, consultants, collaborators, or other non-Brown personnel book travel on foreign air carriers, they will not be eligible for reimbursement from federal sources.

In addition, international collaborators and consultants must also follow this regulation. Please make sure to work with international consultants before they make flight arrangements to ensure that they are aware of U.S. air carrier restrictions.

In researching available flights, we discovered that booking a flight on a foreign air carrier costs substantially less than booking a flight on a U.S. air carrier. We want to save the award funding for other research-related purposes. Is this an allowable exception to the Fly America Act?

No, the Fly America Act specifically states that the decision to use a foreign air carrier service must not be made solely based on the cost of the ticket.

My PI has already purchased a ticket to a foreign destination. The receipt includes portions of the flight that are booked on U.S. flag air carriers and portions booked on non-U.S. flag air carriers. Can the portions booked on the U.S. flag air carriers be charged to the grant?

It depends on who issued the ticket or if there is a flight specific code share in place. If a U.S. flag carrier issued the ticket (i.e., it is printed on a U.S. air carrier ticket/boarding pass/receipt), then the expense will, in most cases, be eligible for reimbursement. If the ticket is issued by a foreign air carrier (i.e., the foreign airline is printed on the ticket/boarding pass/receipt), the ticket is not eligible for reimbursement on a federal award, even if there are portions of the flight that have a U.S. Air Carrier flight designator code. This is due to the fact that this ticket would have been booked incorrectly through the code share process. If a Fly America Act exception exists, it is the traveler’s responsibility to obtain the supporting documentation at the time of purchase to substantiate the allowable exception.

My PI traveled to a foreign destination. The flights within the U.S. were on U.S. air carriers with tickets issued by the U.S. air carrier, and the flights to and/or within the foreign countries were on foreign carriers with tickets issued by the foreign carrier. Can the domestic flights be charged to the grant?

Yes, the domestic portions issued on tickets from U.S. air carriers can be charged to the federal grant. However, the tickets issued by the foreign carriers may not be charged unless there were no U.S. flag air carriers flying to that destination. Please note that U.S. flag air carriers must be used to the furthest point possible, and one should only switch to the foreign carrier for the portion where there is no U.S. flag air carrier available. Travelers must make sure to attach to the Expense Report request in Workday the flight information at the time of purchase to substantiate that there was no U.S. flag air carrier available.

My PI has a conference in Paris, and then he/she must travel to London for a collaborator meeting at a subrecipient institution. The flights between Paris and London were booked on British Airways. Can this be reimbursed from the federal award?

It depends. This flight could possibly be reimbursed by a federal award if it was booked on an EU or U.S. carrier under the Open Skies exception, unless you are using Department of Defense (DOD) funds. If you are using DOD funds, then this flight would not be eligible for reimbursement unless it met one of the other Fly America Act exceptions.

If I book the airfare through Brown’s preferred travel vendor, do I still need to check to confirm that the flight meets U.S. flag air carrier criteria?

Yes, it is still your responsibility to ensure that the flight meets the U.S. flag air carrier criteria. However, you should inform the preferred vendor that the traveler is using federal funds.

We found an Air Canada ticket that costs less than the ticket on a U.S. carrier. Can we book this flight?

No. You must adhere to the Fly America Act and fly a U.S. flag air carrier, unless you meet one of the exemptions allowed in the Fly America regulations.

How do I verify that I have secured the lowest available commercial discount fare?

The traveler is expected to secure the lowest available commercial discount or coach airfare at the time of booking travel, whether through a travel agent or by booking travel themselves.  

When combining airfare for personal travel with business, how do you determine the portion that is allowable and allocable to the federal award?

If you are booking a flight with more stops or a longer duration than required for the business trip due to personal travel, then you should provide as documentation a comparable itinerary (including price, dates, and air class) based on the business portion of the travel. The comparison itinerary must be obtained at the time of purchase or within one business day of booking the flight. Only the allocable business portion of the travel can be charged to the federal award.  

The cost of premium economy airfare and other offers provided by airlines in excess of the base price for a coach ticket is unallowable on sponsored projects. The use of these upgraded/ preferred coach seating options is generally a traveler's personal choice and therefore is at the traveler's personal expense (see 41 CFR 301-10.124). The cost attributed to the upgraded service cannot be charged to a sponsored project and must be deducted from the total amount of the airfare requested for reimbursement. Comparable flight documentation should be provided with the reimbursement request. The comparable flight documentation provided should include the base price for the coach airfare at the time of booking. Failure to isolate the upgrade cost and provide comparable documentation will result in denial of the reimbursement of the entire airfare on a sponsored project.

What is the consequence if I do not travel under the lowest available discount fare?

If airfare is determined unreasonable and no comparable documentation provided, the flight cost will be disallowed and not be reimbursed on a sponsored project.

My trip may be canceled or rescheduled.  Can I purchase a fully refundable airline ticket?

No.  In most cases it is less expensive to pay the change fee for a rebooked ticket than to pay for a fully refundable ticket.  In cases where there is a high probability that the trip could be cancelled and the funds are not available for a future flight, the purchase of trip insurance is allowable if supporting documentation is thoroughly completed and justification is provided.

What should I do with my ticket if my trip is canceled? 

Many non-refundable tickets can be used for future travel after paying a change fee.  Confirm with the issuing agent or airline that the ticket can be used for future travel.  It is the responsibility of the traveler to track unused airline tickets for future business use.  If future travel is related to a sponsored project the usual sponsored project rules apply. 

Can I upgrade my ticket? 

An upgrade is an unallowable expense on sponsored projects and is not permitted and will not be reimbursed.  Free upgrades or upgrades paid by the traveler must be clearly documented when seeking reimbursement.  Extra cost beyond the base fare is considered an upgrade to the ticket and is not reimbursable by a sponsored project account.

What happens if I do not provide supporting documentation with my travel reimbursement?

If supporting documentation is not provided, the cost of foreign air carrier travel is unallowable on a sponsored project and must be reimbursed by non-sponsored (personal or departmental) funds.