When traveling on a federally funded award, please keep in mind that there must be a clearly defined relationship between the traveler and how they support the work of the project documented in the expense report. If the traveler is paid on the project, that provides sufficient documentation of the relationship. 

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 nonfederal award does not need to meet the Fly America Act requirement.

All travel costs must be allowable, allocable and reasonable. All expenses on the expense report must provide a direct benefit to the sponsored project. The benefit to the project must be clearly stated in the expense report memo heading.

For help navigating allowable travel expenses or exceptions to the Fly America Act, contact your department administrator or your grant and contract accountant in Sponsored Projects. 

Documenting Travel

If the sponsor's approval is required for the travel, the approval must be attached to the expenses as supporting documentation. If sponsor terms require a U.S. carrier for airfare and a foreign carrier is used, the exception to the Fly America Act must be documented in the expense report.

Using Brown’s Preferred Travel Agency

When using Brown’s preferred travel agency for foreign travel, complete the Request for Direct Payment of Airfare/Train Expense Form and have it signed by Sponsored Projects before submitting to Accounts Payable for approval. Accounts Payable will send a copy of the form to Brown’s preferred travel agency, so they'll know whether a foreign carrier is allowable.

When using a preferred vendor, it is 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.

Multipurpose Trips

Additional documentation is required for trips that have multiple purposes or include personal stays. If you are booking a flight with more stops or a longer duration than required for the business trip, due to personal travel, you must obtain a comparison quote at the time of booking to show the exact airfare for the sponsor-related portion of the trip (including price, dates and air class). That quote must be attached to the expense report in Workday.

If you are directly booking your flight with Brown’s preferred travel agency, the travel agent must also obtain the comparison quote at the time of booking. Multipurpose trips without a timely comparison quote cannot be reimbursed from sponsored project funds.

Travel Expenses

View a list of allowable and unallowable travel expenses on Sponsored Projects’ guide: Traveling for Brown University on a Federally Funded Award.

Guide: Traveling for Brown University on a Federally Funded Award

Meals

The traveler cannot claim both actual meal expenses and per diem during the same trip. Only one type of meal reimbursement may be chosen per trip.

For all sponsored projects, proposed per diem or subsistence allowances must be reasonable and limited to the days of attendance at the conference plus the actual travel time to reach the conference location by the most direct route. Where meals and/or lodgings are furnished without charge or at a nominal cost (e.g., as part of the registration fee), the proposed per diem or subsistence allowance must take this into consideration. 

GSA Meals and Incidentals Breakdowns

Lodging

Lodging rates are reimbursed at the University’s maximum daily rate, as outlined in the Controller’s Office’s annual spending guidelines, unless the award terms and conditions state otherwise or you are using the U.S. General Services Administration (GSA) lodging rates. 

When traveling for a conference, it is appropriate to stay at the hotel hosting the conference, even if the rate exceeds the University’s guidelines; however, the room must be booked at the conference rate.

Reimbursement for Hotel Expenses

Travel on federal awards requires an itemized hotel bill, with $0 balance due. A hotel booking agency receipt is a prepaid hotel 'reservation', however, the itemized hotel bill confirms the travel has taken place and details the full accommodation costs, travel dates and the payment confirmation. If necessary, a traveler should be able to request a copy of an itemized bill, even after the travel has taken place.

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. 

In general, all airlines based in the U.S. 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 the ALC Airline Codes database.

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 and Travelocity can cause confusion, as these websites are designed to find the lowest fares regardless of air carrier.

Using a foreign air carrier that costs substantially less than booking a flight on a U.S. air carrier is not an allowable exception to the Fly America Act, which specifically states that the decision to use a foreign service must not be made solely based on the cost of the ticket.

Codeshare Flights

Travelers are allowed to fly on codeshare 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).

The traveler is considered to be on a codeshare flight if they purchase a ticket from one carrier but fly 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 codeshare agreements. Only codeshare flights booked properly through the U.S. carrier are allowable.

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 in most cases has 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 codeshare flights.

Open Skies Exception

The biggest exception to the Fly America Act is the Open Skies Agreement, which allows for travel sponsored on federal awards to use foreign air carriers under certain circumstances. Currently, the U.S. has Open Skies agreements with the European Union (excluding the United Kingdom), Australia, Japan and Switzerland.

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.

Traveling Between Foreign Locations

A traveler must abide by the Fly America Act regulations even when traveling between two foreign locations. Certain exceptions may apply. U.S. flag air carriers must be used to the furthest point possible, and one should only switch to a foreign carrier for a portion of travel for which 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.

Students, Consultants and Non-Brown Personnel

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.

Reimbursement After Ticket Purchase

If a PI on a federally sponsored project has already purchased their ticket to a foreign destination and the receipt includes some U.S. flag air carriers but also portions booked on foreign air carriers, you may be able to charge the U.S. portions to the federal grant, depending on who issued the ticket or if there is a flight-specific codeshare 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 or receipt), 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 or 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 codeshare 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.

Lowest 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. 

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

Upgraded Airfare

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 or preferred coach seating options is generally a traveler's personal choice and therefore is at the traveler's personal expense. 

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.

Upgraded airfare costs may be allowable when the least expensive, unrestricted accommodation class is not reasonably adequate for the traveler's medical needs. This must be justified and the conditions documented. This will be reviewed on a case-by-case basis in order for the use of first-class or business-class airfare to be allowable in such cases.

Upgraded Airfare for Medical Needs

Upgraded airfare costs may be allowable when the least expensive, unrestricted accommodation class is not reasonably adequate for the traveler's medical needs. This must be justified and the conditions documented. This will be reviewed on a case-by-case basis in order for the use of first-class or business-class airfare to be allowable in such cases.

In order to document this exception, a doctor’s note should be obtained to identify the medical accommodation(s) being requested, such as extra leg room, etc. (Example: “John Smith is currently under my care and is advised to only book airfare with extra leg room to accommodate his medical needs.”) The note should not include any privileged medical information regarding the traveler’s medical condition. The traveler’s privacy must be maintained.

Refundable Tickets

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 canceled 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.

Many nonrefundable 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.