Travelers are required to exercise the same care in incurring expenses that a prudent person would exercise if traveling on personal business when making official travel arrangements, and therefore, should consider the least expensive class of travel that meets their needs. The lowest other than coach class airline accommodations may only be used when the sponsoring agency specifically authorizes/approves in advance of the trip, see FTR 301-10.123.
Compliance with the Fly America Act is met when we can present proof of a U.S. flag air carrier’s designator code (IATA airline designator) for all legs of a trip. IATA codes are used for the identification of an airline. The designator code is typically listed in the area next to the flight numbers on the airline ticket, boarding pass, or E-ticket (passenger receipt). IATA provides an airline and airport search engine which is helpful for researching IATA codes.
In some instances, a non-U.S. flag air carrier may be used if one or more of the exception criteria listed FTR 301-10.135-138 are met. Detailed flight information showing airline designator codes and flight numbers for all flights being reimbursed must be provided. When we use a non-U.S flag air carrier for travel funded by a Federal grant, the UMass Fly America Travel Reimbursement Exception Form, along with any other relevant supporting documentation, must be completed and submitted with the expense report, bank card statement, or PO/Invoice for reimbursement. The exception form must list all flights taken on a non-U.S. flag air carrier.
Per FTR 301-10.142 travelers must complete a certification when foreign carriers are used. The UMass Fly America Travel Reimbursement Exception Form helps us to meet the certification requirements.
Code-sharing
Code sharing agreements with foreign air carriers comply with the Fly America Act Regulations, see FTR 301.10.134. The ticket, or documentation for an electronic ticket, must identify the U.S. carrier's designator code and flight number generally stated as “U.S. Air Carrier flight XXXX operated by Foreign Air Carrier.”
For example:
- Allowable: American Airlines (AA) 1234 operated by Quantas Airways (QF) 4321
- Unallowable: QF 4321 operated by AA 1234
Open Skies
The most well-known exception to the Fly America act is when travel meets GSA’s Open Skies agreement. UMass travelers supported by Federal funds may travel on EU airlines as well as U.S. flag air carriers. There are also open skies agreements with Australia, Switzerland, and Japan. There are four bilateral/multilateral “open skies agreements” in effect:
- U.S. Government and the EU
- U.S. Government and Australia
- U.S. Government and Switzerland
- U.S. Government and Japan
Please Note: Travelers being reimbursed with Department of Defense funding cannot claim an open skies exception.
The City Pair Program (CPP)
The city pair program offers fares considerably lower than comparable commercial fares, saving the federal government billions of dollars annually. A city pair check is required between any point in the U.S. to any point in an open sky non –EU member state (Australia, Switzerland, and Japan). Airline City Pairs can be found using the CPP Search Tool. A U.S. flag carrier must be used (unless an Exception other than open skies can be claimed) when a City Pair fair is found.
Even though these city pairs are likely not available to UMass travelers, this is a requirement of the open skies agreements with these members, so we must follow this rule.
Canadian Travel
Canadian based airlines (Air Canada, WestJet) do not qualify for an exception under open skies. Another Fly America exception must be claimed.
Additional Exceptions
There are some other strictly limited circumstances in which an exception may be allowed. All allowable exceptions are listed on the UMass Fly America Travel Reimbursement Exception Form:
- A U.S. flag air carrier does not provide service on a particular leg of your trip
- A U.S. flag air carrier will unreasonable delay your travel time
- A U.S. flag air carrier involuntarily reroutes your travel
- Medical/safety reasons
If a valid exception cannot be claimed, the traveler must choose an American Airline or have the travel funded from a non-federal source.
Risk of Non-Compliance/Audit
Non-Compliance with the Fly America Act is one of the top employee reimbursement audit findings. Travel costs can be disallowed and reputational risks are good reasons to achieve compliance with this regulation.