Traveling on Sponsored Projects

Northwestern University's Policy and Procedures for Sponsored Program Travel is detailed in the Northwestern University Travel Policies and Procedures manual.

The regulations below concerning the use of foreign air carriers on federal funds must be followed by all Northwestern University personnel, students, trainees, consultants and collaborators who are reimbursed for air travel with federally primed or federal pass through funds.

It is the Principal Investigator’s (PI) or his/her designee’s responsibility to ensure that all air travel charged to federally primed or federal pass through awards are in compliance with this regulation. 

Contacts

For issues related to sponsored program travel, please contact Jany Raskina, ASRSP Expenditure Audit Coordinator, at 847 491-4697 on the Evanston campus. For the Chicago campus, please contact Rosanna Sian, Senior Accounting Representative, at 312 503-0835.

Use of Foreign Air Carriers on Federal Funds – Fly America Act

What is the Fly America Act?

The Federal Fly America Act mandates that travel sponsored by the Federal government must be on U.S. airlines or a foreign air carrier that code shares with a U.S. Flag carrier on the flight taken. This includes flights within the U.S. If there is no U.S. carrier to your destination, you must travel on a U.S. carrier as far as possible. By law, additional cost for U.S. carrier flights is not sufficient justification to fly on foreign carriers. Please note that the same rules apply to a foreign visitor’s flights.

How do I know if my grant is subject to the Fly America Act?

The fund number in the chartstring indicates whether you have federal funding:

  • Fund 610 = federal
  • Fund 611 = ARRA federal
  • Fund 620 = federal flow-through  (a subcontract from an institution who has a federal  award.)
  • Fund 621 = ARRA federal flow-through
  • Funds 191, 192, or 193 when affiliated with federal funding = cost-sharing chartstrings on federal awards

What is the Code Sharing?

If you are scheduling international travel that is federally funded, you are allowed to schedule international travel on foreign air carriers that code share with a U.S. Flag carrier. Code sharing occurs when two or more airlines “code” the same flight as if it were their own. In other words, a U.S. airline may sell a seat on the plane of a foreign airline carrier; this seat is considered the same as one on a plane operated by a U.S. flag carrier. Compliance with the Fly America Act is satisfied when the U.S. flag air carrier’s designator code is present in the area next to the flight numbers on the airline ticket, boarding pass, or on the documentation for an electronic ticket (passenger receipt).

For example, Delta has a code share agreement with Air France to Paris, France. If the boarding pass (flight coupon) or e-ticket identifies a flight as DL##, the requirements of the Federal Travel Regulations would be met, even if the flight was on an Air France airplane. If however, the boarding pass (flight coupon) or e-ticket identifies the flight as an AF ###, then the requirements of the Federal Travel Regulations would not be met.

What are the generally permitted exceptions?

  • No U.S. flag air carrier provides service on a particular leg of the route. (Travelers may use foreign air carriers to or from the nearest interchange point with a U.S. Carrier).
  • Use of a foreign air carrier is necessary for medical reasons (additional supporting documentation required)
  • Use of foreign air carrier is required to avoid unreasonable risk to traveler’s safety. (see 41 CFR 301-10.138 (b)(2) for required supporting evidence).
  • Service on a foreign air carrier is 3 hours or less and the use of a U.S. flag air carrier doubles time enroute.
  • Air Travel is between U.S. and another country and use of a U.S. carrier on a non-stop flight extends travel time by 24 hours or more.
  • Use of a U.S. carrier would increase the number of aircraft changes outside of the U.S. by 2 or more.
  • Use of a U.S. carrier extends travel time by 6 hours or more.
  • Use of a U.S. carrier requires a connecting time of 4 hours or more at an overseas interchange point.
  • Use of foreign air carrier is permissible under the Open Skies Agreement. See: Foreign Travel Flowchart 

What documentation is necessary when an exception applies?

  • All travel for University business must be detailed in an expense report and routed through NU Financials, even if any or all of the expenses have been directly billed to an NU chartstring or paid for by an external source. See Northwestern University Travel Policies and Procedures manual.
  • A Foreign Air Carrier Exception Form, completed and signed by the traveler, must be attached to the expense report whenever a waiver from the Fly America Act is being sought.
  • Documentation that supports the exception as detailed on the exception form just also be attached to the expense report.

What is an Open Skies Agreement?

The Federal Fly America Act mandates that travel sponsored by the Federal government must be on U.S. airlines. One exception to this requirement is transportation provided under a bilateral or multilateral air transport agreement called “Open Skies Agreements.” There are currently four Open Skies Agreements that permit traveling on a European Union, Norwegian, Icelandic, Australian, Swiss or Japanese carrier under specific circumstances. See: Foreign Travel Flowchart (PDF).

Though the Federal Open Skies policies allow use of foreign airlines, the easiest and safest way to comply with Federal air travel regulations is to continue to book flights only on U.S. airlines. 

The use of a U.S. air carrier is required on Department of Defense awards even when there is an Open Skies Agreement in place.

How do I know if the grant chartstring is funded by the Department of Defense? 

The Open Skies exception is not applicable for awards given to NU directly from a Department of Defense (DoD) agency or for awards given to another institution from the DoD, and then passed through to NU. The safest way to determine if the award is from a DoD agency is to look up the Catalog of Federal Domestic Assistance (CFDA) number in NU Financials or review the Project Account Summary. See Guide to Determining Department of Defense Sponsorship 

Is there a recommended way to book foreign travel on the grant chartstring?

Though the Federal Open Skies policies allow use of foreign airlines, the easiest and safest way to comply with Federal air travel regulations is to continue to book flights only on U.S. airlines. For Federally-funded travel, use of U.S. airlines is always in policy and there is no need to submit the exception form or special documentation that is required for trips including Open Skies flights. However, if booking flights on the foreign airlines is desired, use of Orbitz for Business or contacting one of NU’s other preferred travel agencies (see University Services Preferred Vendors) will provide air policy guidance in selecting allowable flights.

What is the City Pair Program?

The City Pair Program is administered by U.S. General Services Administration (GSA) and offers discounted air fares to federal government travelers. When a GSA contracted airfare is available for the route, the Open Skies Agreements are often nullified. Even though NU employees cannot book travel at the GSA contracted rate, the Open Skies Agreements are still nullified.

For travel between the US and Switzerland, Australia or Japan on a foreign airline, a GSA Airline City Pairs Search must be performed to determine if Swiss, Australian or Japanese airlines are allowable for the specific trip.  The search requires entry of the trip’s origin and destination and clicking on the correct button for the trip’s date (within the Federal fiscal year of October 1 – September 30). For more information, see GSA Airline City Pairs Search and documentation showing screenshots of results

What countries are within the European Union?

To determine which countries are current members of the European Union, please see the European Union website.