Sponsored Travel Guidance

There are specific rules relating to travel charged to Federal Awards; please review this guidance in addition to the Harvard University Travel Policy (including Appendix G) and the Sponsored Expenditures Guidelines.

Travel expenses relating to meals, lodging, or ground transportation that directly support the sponsored project may be charged on an actual expense basis, on a per diem or mileage basis in lieu of actual expenses incurred, or on a combination of the two (e.g. per diem for meals and actual costs for lodging), provided the method of reimbursement used for each type of expense is applied to an entire trip and not to selected days of the trip. For example, you cannot request per diem for meals during day one of the trip and then request actual costs for day two. (See FAQs #5 and 7)

In order to charge expenses on a federal award, an itemized receipt should be presented even if the total amount of the bill is less than $75. If an itemized receipt is not available, submit a Missing Receipt Affidavit (MRA), and make note of the following if applicable:

• If a meal(s) did not include alcohol, the traveler must attest in writing that no alcohol was charged, and the entire amount can be charged to the appropriate federal award.
• If the meal(s) did include alcohol and the traveler can attest in writing the alcohol cost, then the alcohol portion of the meal costs, along with the applicable tax and tip, must be charged to a non- sponsored account (using object code 8450). The remainder of the meal costs can be charged to the appropriate federal award.
• If alcohol was included and the traveler CANNOT attest to the alcohol cost, then no portion of the meal costs can be charged to a federal award.

Before booking air travel on a federal award, consider the following requirements (See FAQs #8-15):

• Lowest Economy Fare Class: Booking the lowest economy airfare
• Fly America Act: Requires travelers funded by federal awards to use U.S. Flag Air Carriers or codeshare partners, unless it meets an exception.
• Open Skies Agreement: Allows the use of foreign carriers under specific conditions

Lowest Economy Class Airfare

Federal regulations (2 CFR §200.475.e(1)) require travelers to incur the lowest economy class fare available to the federal award; in most circumstances, this is a non-refundable (restricted) economy class airfare. Harvard defines lowest economy class airfare (sometimes called coach, standard economy fare class, or base airfare) to include a reserved seat, one personal item, one carry-on bag, and one checked bag.

Airfare costs in excess of the lowest economy fare class (e.g., business class or economy upgrades) are unallowable on federal awards or cost sharing accounts except when the lowest economy class airfare would:

• Require circuitous routing;
• Require travel during unreasonable hours;
• Excessively prolong travel;
• Result in additional costs that would offset the transportation savings; or
• Offer accommodations not reasonably adequate for the traveler's medical needs.

If one or more of these criteria are met, the traveler must justify and document the exception for the use of business class or upgraded economy airfare to be allowable on a federal award or cost share companion accounts. The Federal Lowest Economy Airfare Travel Reimbursement Exception Form must be completed and signed by an authorized signer and submitted with the travel reimbursement documentation.

If business class travel or upgraded economy is allowed under the Harvard Travel Policy but cannot be charged to the federal award, the traveler may still fly business class or upgraded economy, however, the difference in fare between the least expensive economy fare class and the business class fare must be charged to a non-sponsored account. Business class airfare can only be charged to a federal award if one of the federal exceptions noted above is met. There are no exceptions to this rule.

To document the fare difference between economy and an upgraded class, please reference FAQs #15. If the traveler does not obtain written documentation of the lowest available economy fare for the same itinerary within three business days of booking the flight, then NO portion of the fare may be charged to the federal award. Post-booking quotes are not allowed as substitute documentation.

Authorized Approvers for the Federal Lowest Economy Airfare Travel Reimbursement Exception Form

• HMS – Sheila Doyle
• SPH – Judy Lo
• FAS – Jimmy Matejek-Morris
• SEAS – Pamela Baker-Webber
• GSE – Jane Eaton
• HKS – Sarah Svenson
• HLS – Devin Advani

Fly America Act Overview

The Fly America Act is a federal regulation that states that any foreign air travel that is financed by federal funds must be booked on U.S. flag air carriers, regardless of cost or convenience when compared to foreign air carriers. This regulation must be followed by all Harvard and non-Harvard personnel, students, trainees, consultants and collaborators who are reimbursed for air travel using Harvard federally-funded sponsored awards and federal cost sharing companion accounts.

If using federal funds, it is strongly recommended that you book your international travel through one of the Harvard University Preferred Travel Agencies. Our preferred agencies have agents that are well versed in the Fly America Act. Please inform them that your trip is federally funded. Any improper use of foreign air carrier service may result in violations of the Fly America Act, and any transportation cost on the foreign carrier will not be payable under federal government funds.

It is the Principal Investigator’s (PI) or PI designee’s responsibility to ensure that all air travel charged to Harvard federally-funded sponsored awards is in compliance with this regulation. Harvard requires travelers who will be reimbursed from federal awards to use a U.S. flag air carrier, consistent with the Fly America Act. Exceptions to the Fly America Act include:

• When the use of U.S. flag air carrier service would extend travel time (including delay at origin) by 24 hours or more;
• When the costs of transportation are reimbursed in full by a third party, such as a foreign government or an international agency; or
• When U.S. flag air carriers do not offer nonstop or direct service between origin and destination.

However, a U.S. flag air carrier must be used on every portion of the route where it provides service unless, when compared to using a foreign air carrier, such use would:

• Increase the number of aircraft changes outside the United States by two or more;
• Extend travel time by at least six hours or more; or
• Require a connecting time of four hours or more at an overseas interchange point.

Exceptions to the Fly America Act must meet one of the exception criteria and be justified and documented to be allowable on a federal award. These exceptions require completion and submission of the Fly America Travel Reimbursement Exception Form (FATREF), along with supporting documentation and approval by an authorized reimbursement approver at a department/local level managing unit or by a designated school/tub official in accordance with school/tub’s policy. Signed forms and supporting documentation must be included in the reimbursement request.

Table 1: Authorized Approvers for the Fly America Travel Reimbursement Exception Form (FATREF)

Open Skies

The Fly America Act requires that federal grant funds be used to purchase air travel on U.S. flag carriers or codeshare flights operated by foreign carriers under a U.S. airline's flight number. Open Skies Agreements are an exception to this Fly America Act requirement and allows travelers to fly on airlines from travel on foreign carriers in certain cases, if a FATREF is completed/approved.

While there are over 100 Open Skies Agreements which the Department of State has negotiated between those countries, currently, the four Open Skies Agreements with the U.S. that meet the requirements of the Fly America Act are with Switzerland, Australia, Japan, and European Union. The key factor in the four agreements is the statement “for U.S. Government Procured Transportation" in either the Article or Annex 3 of the agreement which explains what is allowed.

Note: Open Skies Agreements do not apply to Department of Defense-supported activities.

Codesharing

Under the Fly America Act, a traveler may use a foreign airline if it is part of a codeshare agreement with a U.S. carrier. A codeshare agreement allows two airlines to share the same flight, meaning a ticket purchased from the U.S. carrier may be operated by a foreign airline. To comply with Fly America regulations, the airline ticket, boarding pass, or on the electronic ticket documentation (passenger receipt) must identify the U.S. carrier's designator code and flight number.

Look for the U.S. carrier's designator code on your ticket (e.g., “DL” for Delta,"AA" for American Airlines, "UA" for United Airlines) to ensure compliance. For example, Delta has a codeshare agreement with Air France to Paris, France. If the 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 (example of Compliant Code-Share Situation). 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 (example of Non-Compliant Code-Share Situation).

Some funding sources may not recognize codesharing as being compliant with Fly America Act. When the specific funding source policy is more restrictive than the Fly America Act, the more restrictive policy applies.

The purpose of this chart is to provide common examples of travel charges and whether they are allowable on federal or non-federal sponsored funds or cost-share funds. Allowability within this chart is determined by general Travel Policy, sponsor restrictions, practices, and regulations. You must review the terms and conditions of all funding to determine allowability. Allowed with restrictions may require additional documentation and/or approvals. Find more information on restrictions in the FAQs. Individual schools may have more restrictions. If this information conflicts with another University policy or term the more restrictive provision will apply.

Note: Please reference OSP’s Sponsored Travel FAQs for specific examples that may not be included in this chart. Schools or units may have additional restrictions. Contact your local sponsored research office or finance office for guidance.

General

1. My PI has funding from both federal and non-federal sponsors. Are there rules relating to travel costs charged to federal awards that are different than those for non-federal awards?

Yes. Any travel costs charged to federal awards must comply with federal regulations and Harvard’s Travel Policy, including the requirement to book the lowest economy airfare and comply with the Fly America Act. When traveling on non-federal awards we must adhere to the sponsor’s terms and conditions and Harvard’s Travel Policy. Some sponsors may be more stringent (DoD) than others, please check terms and conditions.

2. Are no cost or free upgrades allowable?

Yes. Please be sure that the documentation clearly states that the traveler was only charged the lowest economy fare. See Appendix A, Section 2 of the Harvard Travel Policy for guidance.

3. Can change fees, cancellation fees, or trip cancellation insurance be charged to sponsored funds?

Change fees, cancellation fees or trip cancellation insurance may be an allowable expense on non-federal awards under extenuating circumstances provided there is a compelling and valid reason such as a canceled conference or medical emergency; as referenced in the Appendix A, Section 2 of the Harvard Travel Policy. Authorized approvers must ensure any change or cancellation fees charged to non-federal sponsored funds are allowable and follow local policies. Generally, cancellation insurance requires preapproval (this is often an exception request through the Financial Dean or designee) and includes the insurance with the travel reimbursement.

4. Which is better, to charge to a sponsored award refundable airfare or cancellation fees? What about change fees or trip cancellation insurance?

Cancellation fees, change fees and trip cancellation insurance are not allowed on federal awards but may be allowable on non-federal awards. Please review the terms and conditions of your award for allowability and check local policy.

Refundable airfare is allowed on sponsored awards when there is a likelihood that the trip may need to be changed. Purchases for refundable airfare should be justified in the reimbursement request. If you believe there’s a likelihood that a trip may be changed or cancelled, it is better to buy refundable airfare.

5. What are the benefits of using Harvard Preferred Vendors?

The preferred and most convenient way to book your travel is through one of Harvard’s preferred agencies.  Although they charge a booking fee, using one of our preferred agencies will enable you to take advantage of University discounts and benefits negotiated with preferred travel partners and will provide you with an added level of support. Additionally, international reservations made though our preferred agencies are automatically registered with International SOS MyTrips.

Our preferred agencies are familiar with Harvard Travel policies and restrictions, including the Fly America Act and Open Skies Agreements, just let the agent know ahead of time that you are traveling on Federal funds. Furthermore, Egencia has added a Fly America Act indicator on flight searches.

For travel occurring within 72 hours, call your agent instead of e-mailing for any urgent needs (changes, cancellations, and/or rebooking), unless otherwise instructed by your agent.

For more information about our preferred agencies and vendors visit the travel website.

6. Can a traveler request reimbursement using per diems or are itemized receipts required?

Depending on school/tub policy, travelers can choose to request per diems for meals hotel and incidentals in lieu of actual receipts. The Department of State (DOS) per diem rates should be used for international travel, and the General Services Administration (GSA) per diem rates for domestic travel. Additionally, the GSA states that if your trip includes meals that are already paid for by the government (such as through a registration fee for a conference), you will need to deduct those meals from your reimbursement request.

Transportation

7. May travelers book business class rail fare or must a traveler book the lowest economy class fare available?

Rail travel is expected to be at the lowest fare that offers reserved seating. In some cases, this may be designated as business class or first-class and is considered allowable on federal funds. See “Booking Rail Travel” on the Harvard Travel Website.

8. Is using a private (non-luxury) sedan service for transportation pickup allowed on sponsored funds?

Travelers are expected to use the most economical mode of transportation appropriate for their needs. Private transportation should only be used when valid business reasons prevent the use of more economical options, such as Uber, Zipcar, or taxi services. Please provide backup documentation demonstrating that standard transportation was unavailable. See Appendix B of the Harvard Travel Policy for detailed guidance.

Meals

9. What information is required for reimbursement for meals?

Meals may be charged to a sponsored award in one of two ways:

1. Per Diem: Meals may be charged to a sponsored award in alignment with Harvard Policy for reimbursement at per diem rates. Harvard will reimburse travelers up to the federal per diem rates. On the first and last travel days of a trip, travelers are only eligible for 75% of the total meals and incidental expenses rate for their travel location.
2. Itemized reimbursement: For expenses equal to or greater than $75, an itemized receipt is required. Schools can require receipts for all expenses regardless of amount. Refer to your school's policy. A Missing Receipt Affidavit (MRA) may be used.

When claiming reimbursement for a trip, the traveler may choose either Per Diem or Itemized reimbursement for the trip and apply it to the entire trip. You cannot select per diem for the first day of a trip and then itemized reimbursement for the second day of a trip. 

All costs charged to sponsored awards must follow cost principles and be allowable and allocable to that award.

Airfare

10. What is the Fly America Act and what qualifies as a U.S. flag air carrier?

The Fly America Act states that when using federal funds you must use U.S. flag air carriers or flights operated under a U.S. code share agreement to travel to any destination, including international destinations, regardless of the cost comparison with a foreign air carrier. It is recommended to use a Harvard preferred travel vendor and inform them that federal funds are being used to purchase the flight.

11. Are there any exceptions to the Fly America Act?

Yes. There are a few exceptions to the Fly America Act. All exceptions must be documented and approved using Harvard’s Fly America Act Exception Form (FATREF). Exceptions are listed on the FATREF. The most common exceptions are the Open Skies Agreements. Currently there are four Open Skies Agreements with the U.S – Switzerland, Australia, Japan, and European Union that meet the requirements of the Fly America Act. The key factor in the four agreements is the statement “for U.S. Government Procured Transportation" in either the Article or Annex 3 of the agreement which explains what is allowed.

A list of the 29 countries under the EU Open Skies Agreement is below:

• Austria
• Belgium
• Bulgaria
• Croatia
• Cyprus
• Czech Republic
• Denmark
• Estonia
• Finland
• France
• Germany
• Greece
• Hungary
• Iceland (ECAA member)
• Ireland
• Italy
• Latvia
• Lithuania
• Luxembourg
• Malta
• Netherlands
• Norway (ECAA member)
• Poland
• Portugal
• Romania
• Slovakia
• Slovenia
• Spain
• Sweden

12. How should I document exceptions to the Fly America Act?

To document exceptions, you will need to complete the FATREF form and retain relevant backup to support and document the exception. Documentation should be saved along with the reimbursement support.

Per the General Services Administration Fly America Act website, you must include the following information in your travel reimbursement:

• A completed and signed internal agency Fly America exception form.
• A detailed travel itinerary from a travel agent or online travel service (i.e. Egencia, Sanditz, Orbitz or Expedia).
• The search results performed at the time of booking from an online travel service that document all available flights and the existence of the Fly America exception identified on the Fly America exception form, if applicable.

13. Can I use open skies as an exception to the Fly America Act for all federal awards?

No. Open Skies agreements cannot be used as an exception to the Fly America Act for Department of Defense funding. You must review the terms and conditions of your federal awards for restrictions on use of Open Skies.

14. Can I use a non-commercial flight for travel and charge the cost to a sponsored award?

Harvard discourages the use of non-commercial flights due to safety concerns. If you have to use a chartered or private aircraft, please see Appendix A of the Travel Policy for more details. Sponsors may have restrictions on travel and allowable costs. Make sure you get the proper approvals from the sponsor and within Harvard as necessary to book a non-commercial flight.

15. How should I document flight comparisons to evidence Fly America Act exceptions or lowest costs of airfare being charged to the sponsored award?

Forms must be completed and submitted along with the documentation outlined below at time of reimbursement.

• For exceptions to the Fly America Act, complete the FATREF
• For exceptions to lowest economy airfare, complete Federal Lowest Economy Airfare Travel Reimbursement Exception Form

Below are criteria for documenting flight comparisons. Please note that costs in excess of the lowest comparable flight flown cannot be charged to sponsored awards.

All airfare price comparisons must be:

• Generated with the same characteristics as the actual travel (i.e., class of service and refundable vs. non-refundable ticket).
• Based on the travel dates of the business-only itinerary.
• Clearly show the price as well as the date on which the comparison fare was generated.
• Attached to the reimbursement as supporting documentation.

Travelers are advised to work with Harvard preferred travel agencies to book flight reservations. These agencies can assist travelers by providing comparison airfares as part of the booking process. Comparison flight information must be captured within 3 business days of booking.

When choosing to book travel outside of Havard’s preferred agencies, travelers themselves must obtain the airfare price comparisons. The steps below ensure that travelers capture airfare comparisons with appropriate date stamp to evidence meeting the three business days timeframe requirement:

1. Search for flights that represent the business-only itinerary (i.e., use the dates and destinations of the business-only trip that does not include any element of personal travel).
2. Save a PDF of at least one business-only itinerary. The date of capture must be visible on the PDF. To save a webpage as a PDF with visible capture date:
   1. Open the print menu by pressing Ctrl+P
   2. Under the printer drop down menu, select “Save as PDF”
   3. Under “More Settings” or “More Options,” ensure that the “Headers and Footers” checkbox is selected (the capture date will appear in either the header or footer)

This price comparison PDF with capture date must be attached to the Concur expense report.

16. What is required for a medical exception to charge additional related airfare costs to a sponsored award?

Confirmation that a medical exception is on file. Please consult with your school/tub HR office and/or Finance office for local procedures. If a flight in excess of economy is needed, a completed Federal Lowest Economy Airfare Travel Reimbursement Exception Form is required. The form must be signed by a school/tub authorized approver/official prior to submitting the travel reimbursement request in Concur or Buy-to-Pay.

17. Can I purchase an “Economy Plus” airfare ticket if it is less expensive than the recommended Lowest Economy Class airfare option?

If the “economy plus” costs less than the economy ticket after adding the personal item, carry-on and reserved seat, then yes, you can charge the “economy plus” airfare ticket to a sponsored award. Whenever you are charging above lowest cost airfare, you need to complete the Federal Lowest Economy Airfare Travel Reimbursement Exception Form and submit it with the reimbursement along with a screen shot of the comparison flight.

18. If my school’s authorized official determines that the airfare does not meet the exception criteria and does not approve my request, can I charge the lowest economy fare class amount to the federal award and charge the difference to a non-sponsored account?

Yes, but only if you obtain the comparable flight documentation for the economy rate versus the economy plus or business rate within 3 business days of booking. Documentation should be included with the travel reimbursement request. If the incremental cost of the upgrade is clearly itemized on the purchase receipt, an additional comparison is not required.

Lodging/Hotels

19. Is there specific guidelines or requirements for renting homestays through platforms like Airbnb or Vrbo for university-related travel, and what documentation is necessary to ensure compliance with price comparison policies, including any associated taxes and fees?

Yes, guidance can be found in Appendix C. Airbnb/Vrbo/Other Rental Accommodations (homestays) are allowable with comparable rates to a standard, single-occupancy room with the proper price comparison documentation reflecting a lower cost option was selected, including the related taxes, fees and cleaning fees. Note: If the sponsor terms are silent or unclear, allowability is at the discretion of the school/unit. However, Harvard does not endorse the use of homestays or vacation rentals.

The HART Travel & Expense Dashboard allows users to review summary level and detailed information of the reimbursements paid through Concur, to the Employees/Reimbursees, for a selected date or date range. Analysis and monitoring to ensure travel expenses are compliant with sponsored rules can also be performed by using this dashboard. Data analysis queries can be found in the table below.

Table: Federal Funds Data Analysis Recommendations

Related Policies and Guidelines

• Harvard University Travel Policy
• Sponsored Expenditures Guidelines
• Responsibilities of Purchasers, Preparers and Approvers
• General Services Administration (GSA) website on Federal Travel Regulations
• Definition of Receipts

Tools and Training Resources

• Harvard Federal Travel Regulations online course
• Harvard Travel and Reimbursement Overview online course
• Fly America Act and Open Skies Agreements Decision Tree (Digitally Accessible Version)
• Fly America Act and Open Skies Agreements Decision Tree
• Codeshare Examples:
  • Compliant Code-Share Situation
  • Non-Compliant Code-Share Situation
• Federal Travel Exception Forms:
  • Federal Lowest Economy Airfare Travel Reimbursement Exception Form
  • Fly America Travel Reimbursement Exception Form (FATREF)

Contacts

• Charlotte Gallant, Director, Cost Analysis, Office for Sponsored Programs
• Stacey Clifton, Strategic Sourcing Manager, Strategic Procurement
• fad_travelmgr@harvard.edu

July 2025

• Appendix G
  • Title changed from “Federal” to “Sponsored” Awards
  • Removed examples and added the info to newly created allowability charts (saved on the website)
• Website
  • Created and added Sponsored Travel Allowability Charts
  • Updated FAQs
  • Moved Travel & Reporting info to the website so that info isn’t scattered throughout multiple webpages/resources
• Comparison Documentation
  • Added an FAQ with detailed info comparing flights
  • Change: Comparison documentation should be obtained within three business days, instead of one
• FATREF
  • Clarified language and added sample documentation to the form
• Consolidated or archived webpages and resources
  • Lowest Economy Airfare Split Coding Job Aid was removed as a resources since allocation are in systems
  • Fly America Act Open Skies Agreements Overview content was consolidated with the OSP Travel Guidance webpage
  • Air Travel Guidelines at a Glance content was incorporated into Appendix G    
  • Flight Checklist when using Federal or Cost Share Funds content was incorporated into Appendix G and the OSP Travel Guidance webpage