Direct Costs: Travel & the Fly America Act

Travel costs, including costs of transportation, lodging, meals, and incidentals, are an allowable cost on Federal awards. Employees should be on travel status and on official business related to the Federal award (UG §200.475). The employee's travel should directly benefit the project goals. In most cases, this means an employee should be paid through the grant in order to charge travel to it. Documentation for travel costs charged to a Federal award must justify:

Participation of the individual is necessary to the Federal award
The costs are reasonable and consistent with UCI's travel policy

Airfare

When booking travel for Federal award or any other university business, only coach or economy-class tickets should be purchased. This policy applies to all travel regardless of the purpose or the fund source. Use of business or first-class may be authorized under the following circumstances:

Business or first-class is the only service offered between two points;
The use of coach class would be more expensive or time consuming, such as unduly long layover when making connections or an unnecessary hotel expense;
An itinerary involves overnight travel without an opportunity for normal rest before the commencement of working hours; or
The use of business or first-class travel is necessary to reasonably accommodate a disability or medical need of a traveler.

Exceptions should be justified, documented, and approved in advance by an administrator with an official Delegation of Authority granted by the Chancellor (usually a Dean, depending on the organizational structure of the unit).

Ancillary charges for airfare are sometimes allowable. Provided that the charges for these ancillary expenses are allowed by the funding source, the following airline charges may be reimbursable under UCI policy:

Checked and carry-on bag fees
Early check-in (i.e., Southwest Airlines Early Bird Check-in)
Economy-class seat selection fees

Exception to Open Skies Agreement

The rights given to airlines under the Open Skies Agreement don't apply to travel funded by the Secretary of Defense or the Secretary of a military department.

As a result of this additional restriction, the Department of Defense (DOD) requires that all foreign travel takes place on U.S. flag air carrier services, unless the traveler qualifies for an exception, as noted in FTR §301-10.135, sections (a), (d), (e), (f), and (g).

Foreign Travel - Fly America Act

Federal Travel Regulations require that U.S. flag air carriers are used for travel that is to be reimbursed from federal grants and contracts. This policy is called the Fly America Act.

Before making travel arrangements for air travel for university business, find out about the funding type and, if applicable, ensure the booking is in accordance with the Act. The following information is provided to help determine if the airfare expenses comply with the federal regulations:

Fly America Cheat Sheet provided by the U.S. General Services Administration.
List of Certified U.S. Flag Air Carriers.
Ticket cost and convenience are NOT exceptions to the Fly America Act.
Compliance with the Fly America Act is the responsibility of each department.
Authorized exceptions must include additional documentation, and may require pre-approval and a certification.

Exceptions to the Fly America Act

If a flight is a codeshare flight, customers will be informed of the airline that will operate the flight when making the reservation. In the example below, the codeshare flight from Washington, D.C., to Istanbul is operated by a non-U.S. flag air carrier, KLM, but is allowable because it includes the Delta flight number, DL9447.

Federal regulations would not be met if only the KLM flight identifier KLxxx was listed on the boarding pass or e-ticket and the Delta DLxxx code was not identified.

The United States currently has Open Skies Agreements with the European Union, Australia, Switzerland and Japan. These agreements meet the requirements of the Fly America Act and allow travelers to use foreign air carriers from these countries for government-funded travel.

The United Kingdom is no longer a member of the EU and the Open Skies Agreement with EU no longer applies to U.K.
Iceland and Norway are not EU members, but are members of the EU air treaty.
The exceptions provided by the Open Skies Agreements do not apply to travel funded by the Department of Defense (DoD).

When a U.S. air carrier is not available.
When using a U.S. carrier service would extend the travel time by 24 hours or more.
When a U.S. carrier does not offer a nonstop or direct flight between origin and destination, and using a U.S. carrier:
- Increases the number of aircraft changes outside the United States by two or more;
- Extends travel time by six hours or more; or
- Requires a connecting time of four hours or more at an overseas interchange point.
When the flight time from origin to destination is less than three hours and using a U.S. flag carrier doubles the flight time.

Responsibilities of Research Administrators

Have a good understanding of Federal regulations and institutional travel policies and procedures and stay up to date with changes to these policies
Know your institutional travel reimbursement systems and forms and complete required training.
Review the terms and conditions of the award and budget details for each project you manage to determine who is allowed to travel, when they may travel, and whether a sponsor’s prior approval is required.
Instruct the PI to obtain timely prior approval from the sponsor if required.
Ensure that all future travel is approved by the PI in writing or on an internal form before any travel arrangements are made.
Make sure that the person asking for a reimbursement works on the project and can be reimbursed for this type of travel, or that they were specified in the budget and budget justification in some other way as authorized to travel for the benefit of the project (i.e., participant support travel).
Ensure that all reimbursable travel costs are allowable, reasonable, and the institutional travel policy is consistently applied.
Ensure that the most economical mode of transportation is used and have a good understanding of when exceptions to coach or economy-class travel may be allowed under UCI policy.
Determine allowed amounts for lodging, subsistence, and other travel-related expenses, and type of allowed reimbursement (actual cost basis, per diem, or a combination of the two).
Carefully document the business purpose (i.e., conference schedule and agenda) and dates of each trip, including specifying personal days and their full exclusion from the travel reimbursement.
Advise travelers to not pay for each other during travel.
If there is a possibility that a part of a trip cost was covered by another institution, ensure that this is clearly specified and documented in the reimbursement, and not reimbursed a second time.