Northwestern'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 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.
For issues related to sponsored program travel, please contact Jany Raskina, Expenditure Audit Coordinator, at 847.491.4697 on the Evanston campus. For the Chicago campus, please contact Rosanna Sian, Expenditure Audit Coordinator, at 312.503.0835.
Use of Foreign Air Carriers on Federal Funds – Fly America Act
What is the Fly America Act?
How do I know if my grant is subject to the Fly America Act?
- 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 chart strings on federal awards
What is the Code Sharing?
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 three hours or less and the use of a U.S. flag air carrier doubles time en route.
- 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 two or more.
- Use of a U.S. carrier extends travel time by six hours or more.
- Use of a U.S. carrier requires a connecting time of four 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 NUFinancials, even if any or all of the expenses have been directly billed to a University chart string or paid for by an external source.
- 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 the 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 (DoD) awards even when there is an Open Skies Agreement in place.
How do I know if the grant chart string is funded by the Department of Defense (DoD)?
Is there a recommended way to book international travel on the grant chart string?
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 Northwestern employees cannot book travel at the GSA contracted rate, the Open Skies Agreements are still nullified.
For travel between the U.S. 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