There are specific rules relating to travel charged to Federal Awards; please review the applicable section in the Sponsored Expenditures Guidelines and Appendix G of the University Travel Policy, revision effective as of 3/1/16. To view the policy, please click here: Travel Policy
Airfare other than lowest economy (ex. business or economy upgrade) is not allowable on Federally Sponsored Funds unless an exception is met and documented. Federal regulations (2 CFR §200.474.3(d)) require that airfare costs in excess of the lowest economy fare class are unallowable except when the latter 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.
Exceptions for business-class or upgraded economy airfare must meet one of these criteria and be justified and documented to be allowable on a federal award. These exceptions require documentation and written approval by a designated school official via the Federal Lowest Economy Airfare Travel Reimbursement Exception Form.
Reasonable judgment should be exercised to determine the appropriate fare choices on a case by case basis considering all of the costs included or excluded in a particular air class.
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. Please utilize the Lowest Economy Airfare Split Coding Job Aid to assist you in allocating the cost between federal and non-federal accounts.
Authorized Approvers for the Federal Lowest Economy Airfare Travel Reimbursement Exception Form
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. This regulation must be followed by all Harvard University 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.
Harvard University generally requires travelers who will be reimbursed from federal grants or contracts to use U.S. flag air carrier service, consistent with the Fly America Act. Long-term exceptions to the Fly America Act are:
- When the use of U.S. 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; and
- When U.S. carriers do not offer nonstop or direct service between origin and destination.
However, a U.S. 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
- Require a connecting time of four hours or more at an overseas interchange point
Note that U.S. carriers must be used even if foreign carriers offer tickets at a lower price, offer preferred routing, are more convenient. Additionally, exceptions should be documented via the Fly America Travel Reimbursement Exception Form.
Exceptions to Fly America must meet one of the exception criteria and be justified and documented to be allowable on a federal award. These exceptions require documentation and written approval by a designated school official via the Fly America Travel Reimbursement Exception Form.
An additional exception to Fly America occurs when an Open Skies agreement is in place between the United States (U.S.) government and the government of a foreign country. There are currently four Open Skies agreements - with the European Union, Australia, Switzerland and Japan. It should be noted that there are limitations to the use of non-US carriers under an Open Skies agreement notably that the current Open Skies agreements do not apply to Department of Defense-supported activities and there is a prohibition against non-US carriers if a City Pairs agreement exists. For more information on Open Skies please refer to our Open Skies Document.
Please note that code-sharing agreements with foreign air carriers, whereby American carriers purchase or have the right to sell a block of tickets on a foreign carrier, comply with the Fly America Act Regulations. The ticket, or documentation for an electronic ticket, must identify the U.S. carrier's designator code and flight number. However, some funding sources may not recognize code-sharing as being compliant with Fly America Act regulations. When the specific funding source policy is more restrictive than the Fly America Act, the more restrictive policy applies. Please follow these hyperlinks for code-share examples of situations that are in compliance and not in compliance with the Fly America Act.
- Harvard University Travel Policy
- Sponsored Expenditures Guidelines
- General Services Administration (GSA) website on Federal Travel Regulations
- Online Federal Travel Regulations tutorial
- Online Travel and Reimbursement Overview course (currently under revision)
- Fly America – Open Skies Decision Tree
- Lowest Economy Airfare Split Coding Job Aid
- Federal Travel Policy Update brochure
- Open Skies Document
- Federal Travel Exception Forms:
- Travel and Expense Reporting
- Roseann Luongo, Associate Director, Training & Compliance, Office for Sponsored Programs
- Min Xiao, Compliance, Outreach, and Cash Manager, Office for Sponsored Programs
- Stacey Clifton, Strategic Sourcing Manager, Office of Procurement
Q: What is meant by “lowest economy airfare” when referenced in the federal guidance? Must the traveler choose the least expensive airline?
A: “Lowest economy airfare” refers to the least expensive fare class offered by the traveler’s preferred airline for the itinerary he/she has chosen. If an airline offers upgrades with designations such as “economy comfort” or “exit row seating upgrade,” these options do not qualify as the lowest economy class. However, a traveler is not required to choose the least expensive airline if several similar options are available. He/she may choose any reasonable option (see Fly America Act FAQs below for international flights).
Q: I want to book a flight with an airline that doesn't have a class called "economy". They have many different class options--how do I know which one I can book?
A: Many airlines have air travel class options that are not called "economy." In this case, you should select the lowest cost class that results in the lowest overall travel costs. For example, a class above the lowest cost may include 1 free checked bag, which would result in a lower cost than selecting the lowest class and also paying for a checked bag.
Q: 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?
A: Yes. 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.
When traveling on non-federal awards, unless it is specifically prohibited in the terms and conditions of the award agreement, travelers may purchase business class airfare for trips with an in-air flight time over six hours, per the University Travel Policy. Travel on a non-federal award does not need to meet the Fly America Act requirement.
Q: If the traveler purchases the lowest economy class ticket on a federal award solely for business purposes, do they need to obtain comparison documentation (e.g., between airlines, non-stop versus multiple stops, etc.)?
A: No, a comparison is not required for the lowest economy class ticket purchased solely for business purposes. If a portion of the flight is used for personal travel, other rules apply.
Q: Can a traveler purchase a refundable ticket on a federal award?
A: Yes. In situations where there is a high likelihood that the itinerary may change or other extenuating circumstances, it is appropriate to purchase a refundable (unrestricted) ticket. Travelers must include the reason for purchasing a refundable ticket in the business purpose section of the reimbursement request.
Q: Can cancellation or change fees be charged to a sponsored award?
A: Cancellation fees may be an allowable expense under extenuating circumstances. Please consult with your School-level research administration office if you have questions.
Q: What does “circuitous routing” mean in relation to travel on federal awards?
A: Generally, circuitous routing involves flight options with multiple stops and/or stops at airports that significantly increase the travel time. A general rule is that two or more stops, or an increase in travel time of four hours, may be considered circuitous. Utilizing this exemption to allow for economy upgrade or business class travel on a federal award requires that the lowest economy class fare is not available for the shorter route.
Q: Do travelers still have to comply with the Fly America Act in the case of circuitous routing on federal awards?
A: Yes, travelers must still comply with the Fly America Act on federal awards.
Q: Can insurance on airfare be charged to a federal award?
A: It may be appropriate to charge travel insurance to a federal award if the travel plans are uncertain. Travelers, reviewers, and approvers need to consider the circumstances and make a reasonable determination about insurance. It is the responsibility of the person booking the travel to review the rules and obtain verification that the cost is reasonable. Additionally, review of the specific insurance coverage is important, as some policies have very limited coverage.
Q: Are economy upgrades on a federal award allowable?
A: Generally not, unless you meet one of the exceptions specified in the federal regulations and Harvard Travel Policy (see Exception Documentation below). Harvard does allow the upgraded portion of an upgraded economy ticket to be charged to a non-federal discretionary account when such resources are available.
Q: Are no-cost or free upgrades allowable?
A: Yes. Please be sure that the ticket clearly states that the traveler was only charged the lowest economy fare.
Q: Are Harvard travelers applying travel costs on federal awards subject to the Federal Travel Regulations (FTRs)?
A: No, Harvard is not subject to the FTRs.
FEDERAL EXCEPTION DOCUMENTATION
Q: Which form do I need to complete when requesting reimbursement for an economy plus or business class airfare that meets an exception to charging the lowest economy fare on a federal award?
A: You must complete the Federal Lowest Economy Airfare Travel Reimbursement Exception Form and have it signed by a school authorized approver/official prior to submitting the travel reimbursement request.
Q: 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?
A: Yes, but only if you obtain the comparable flight documentation for the economy rate versus the economy plus or business rate within 1 business day of booking and submit the documentation with the travel reimbursement request.
Q: If the medical exception applies, should a medical note accompany the Federal Lowest Economy Airfare Travel Reimbursement Exception Form for reimbursement processing?
A: Yes, the Federal Lowest Economy Airfare Travel Reimbursement Exception Form must accompany the reimbursement request. The medical note should be secured locally per local/school procedures. Please consult with your local HR office and/or local Finance office for local/school procedures.
Q: How frequently should medical notes be reviewed?
A: Please consult with your local Human Resources Office, the University Disability Services Office, and/or your local Finance office for guidance on the medical note exception process..
Q: Who is responsible for retaining any exception documentation, such as the Federal Lowest Economy Airfare Travel Reimbursement Exception Form and backup justification?
A: The local unit that requests the payment or reimbursement for the travel must retain the documentation. For the medical note documentation, please consult with your local Human Resources Office, the University Disability Services Office, and/or your local Finance office for further guidance.
Q: Which form do I need to complete if I have only a Fly America exception?
A: You must complete the Fly America Travel Reimbursement Exception Form (FATREF).
Q: What happens if the comparable flight documentation for economy versus economy plus or business is not obtained within 1 business day of booking?
A: The entire fare must be charged to a non-sponsored account.
Q: What if there is no date stamp on the comparable flight documentation for economy versus economy plus or business?
A: If there is no date noted on your documentation, attach a note or an email to the documentation that states the date the comparable documentation was pulled.
Q: What details should be included in comparable flight documentation for economy versus economy plus or business flight information?
A: The comparable flight documentation should identify the date of the comparison of the itinerary, as well as the airline, flight number, date, time, fare class and price for the economy ticket, and fare class and price for the ticket purchased.
Q: Can a preferred vendor/booking agent help with the flight comparison documentation?
A: Yes, our preferred vendors can assist you. Please be sure to let them know that you are using federal funds for your airfare.
Q: If a traveler does not use a preferred vendor to book an economy class flight, is a travel search engine screenshot adequate documentation to show that this was the least expensive economy flight?
A: Documentation is not required to prove that you have obtained the lowest price on your air fare. You are simply required to book the lowest economy class – i.e., not economy plus or business/first class. However, Harvard recommends utilizing the Harvard preferred travel vendors for all business-related travel.
Q: When combining airfare for personal travel with Harvard business, how do you determine the portion that is allowable and allocable to the federal award?
A: If you are booking a flight with more stops or a longer duration than required for the business trip due to personal travel, then you should provide as documentation a comparable itinerary (including price, dates, and air class) based on the business portion of the travel. The comparison must be obtained within one business day of booking. Only the allocable business portion of the travel should be charged to the federal award.
SPLIT CHARGING ECONOMY VERSUS ECONOMY PLUS OR BUSINESS CLASS AIRFARE
Q: Should we charge the portion of business class to be charged to an unrestricted account, on a companion account?
A: No, you should not charge the federally unallowable portion to a companion account. These expenses must be charged to a non-sponsored account. Note that unallowable costs should never be charged to cost sharing or companion account.
Q: What object code should we use to charge the unallowable portion of the business class airfare?
A: You should charge the federally unallowable portion of a business class flight to a non-sponsored account using the appropriate airfare object code.
NON-FEDERALLY SPONSORED TRAVEL
Q: Does a traveler using non-federal funds need to follow all the rules in Appendix G of the Harvard Travel Policy?
A: No. Appendix G only refers to travel expenses charged to a federal award.
Q: Can a traveler use a non-federal sponsored award to cover costs not covered by a federal award?
A: No. Only a non-sponsored account can be used to cover costs not covered by a federal award (e.g., the price difference between an economy class ticket and economy plus upgrade).
Q: The Harvard Travel policy states that business class is acceptable in limited circumstances when a trip has an in-air flight time of over six hours or under extenuating circumstances (e.g., medical reasons) and signed by the traveler’s Financial Dean or designated approver. Does this mean that the traveler can charge an approved business class flight on a non-federal sponsored award? If so, is there a form that needs to be filled out?
A: Yes, if approved by the Financial Dean or designated approver and there are no restrictions on the non-federal sponsored award terms and conditions, a business class flight can be charged. Exceptions to the University Travel policy are managed at the school level.
Q: Can the traveler charge economy class upgrades to non-federally sponsored funds?
A: Reasonable preferred economy upgrade fees may be appropriate to charge to a non-federal award according to University Policy as long as the award terms allow. It is the shared responsibility of the traveler and approver to use independent judgment to determine both what is reasonable and what is allowable on the sponsored award. If there is a disagreement between the traveler and the approver, the approver has final determination over whether or not a charge is reasonable and/or allowable, unless the School remands the issue using the sponsored expenditure escalation process as outlined in the Sponsored Expenditures Guidelines.
FEDERAL FLY AMERICA ACT + OPEN SKIES AGREEMENTS
Q: What is a U.S. flag air carrier?
A: In general, all airlines based in the United States 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 this airline database.
In addition, travelers are allowed to fly on code share 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).
Q: What is a code share flight?
A: The traveler is considered to be on a code share flight if he/she purchases a ticket from one carrier but flies 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 code share agreements. Only code share flights booked properly through the U.S. carrier are allowable.
Allowable: AA 1234 operated by QF 4321
Unallowable: QF 4321 operated by AA 1234
(AA = American Airlines, QF = Qantas Airways)
Q: How do I determine whether a flight is a code share flight?
A: 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 must use the code of a U.S. carrier (e.g., NWA, 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 code share flights.
Q: Where can I find the airline designator codes?
A: If you are trying to determine the country of origin of an airline, visit The Airline Codes Website.
You can search for any airline and see the country associated with the airline on the Airline Code Search Results page.
Q: What if I’m flying within a foreign country or between two foreign countries?
A: Even when traveling between two foreign locations, a traveler must abide by the Fly America Act regulations. Certain exceptions may apply per the Fly America Act Exception Form.
Q: What if there are no U.S. flights available?
A: You must use a U.S. flag air carrier for all legs of your route on which a U.S. flag air carrier is not 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.
Q: My PI is planning an international trip that is approved under his/her federal award. What issues do I need to consider when booking the airfare?
A: 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 the foreign destination. 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 Expedia, Travelocity, LowestFares.com, etc. can cause confusion, as these websites are designed to find the lowest fares regardless of air carrier.
Q: Do trainees, students, consultants or other non-Harvard University personnel have to follow the Fly America Act?
A: Yes, 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-Harvard 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.
Q: In researching available flights, we discovered that booking a flight on a foreign air carrier costs substantially less than booking a flight on a U.S. air carrier. We want to save the award funding for other research-related purposes. Is this an allowable exception to the Fly America Act?
A: No, the Fly America Act specifically states that the decision to use a foreign air carrier service must not be made solely based on the cost of the ticket.
Q: My PI has already purchased a ticket to a foreign destination. The receipt includes portions of the flight that are booked on U.S. flag air carriers and portions booked on non-U.S. flag air carriers. Can the portions booked on the U.S. flag air carriers be charged to the grant?
A: It depends on who issued the ticket or if there is a flight specific code share 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/receipt), then 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/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 code share process.
Q: My PI traveled to a foreign destination. The flights within the U.S. were on U.S. air carriers with tickets issued by the U.S. air carrier, and the flights to and/or within the foreign countries were on foreign carriers with tickets issued by the foreign carrier. Can the domestic flights be charged to the grant?
A: Yes, the domestic portions issued on tickets from U.S. air carriers can be charged to the federal grant. However, the tickets issued by the foreign carriers may not be charged unless there were no U.S. flag air carriers flying to that destination. Please note that U.S. flag air carriers must be used to the furthest point possible, and one should only switch to the foreign carrier for the portion where there is no U.S. flag air carrier available.
Q: My PI has a conference in Paris, and then he/she must travel to London for a collaborator meeting at a subrecipient institution. The flights between Paris and London were booked on British Airways. Can this be reimbursed from the federal award?
A: It depends. This flight could possibly be reimbursed by a federal award if it was booked on an EU or U.S. carrier under the Open Skies exception, unless you are using Department of Defense (DoD) funds. If you are using DoD funds, then this flight would not be eligible for reimbursement unless it met one of the other Fly America Act Exceptions per the Fly America Travel Reimbursement Exception Form (FATREF).
Q: If I book the airfare through Harvard’s preferred travel vendors, do I still need to check to confirm that the flight meets U.S. flag air carrier criteria?
A: Yes, it is still 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.
Q: We found an Air Mexico business class ticket that costs less than the economy ticket on a U.S. carrier. Can we book this flight?
A: No. You must adhere to the Fly America Act and fly a U.S. flag air carrier, unless you meet one of the exemptions allowed in the Fly America regulations.
Q: Why do I need to provide an itemized receipt for meals charged to federal awards?
A: Federal awards require an itemized receipt because of the need to attest that all costs charged are allowable, allocable, reasonable and consistent. For example, alcohol may not be charged to any federal award. An itemized receipt for a meal can serve to prove that no alcohol was charged.
Q: When I do not have an itemized receipt, why do I need to submit a Missing Receipt Affidavit (submit an MRA) and an attestation that on a federal award no alcohol was purchased?
A: If an itemized receipt is not available, a Missing Receipt Affidavit must be submitted so that the record is complete for audit purposes. Travelers must attest as to whether alcohol was purchased or not in order to meet federal guidelines for allowable costs. If you are using Concur, you can note that no alcohol was included as part of this meal.
Q: If the traveler consumed alcohol with a meal, but does not have an itemized receipt, what kind of information do we need to estimate the charge?
A: The traveler should be able to purchased estimate the amount of money per meal that was spent on alcohol. The estimated amount, plus estimated tax and tip, should be deducted from allowable meal costs. Tax and tip for alcohol can be estimated at 22% (including an average 7% meal and beverage tax and 15% tip).
Q: Can a traveler still request reimbursement using per diems?
A: Depending on school/local policy, travelers can choose to request per diems for business travel 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 should be used for domestic travel.
Hands-on training related to federally sponsored travel is available in the online Federal Travel Regulations tutorial. An additional online course providing a broad overview of Harvard's travel and reimbursement policy is currently under revision and will be available later in Spring 2016.
Concur is a system used by Harvard University to process employee expense reimbursements. Through 2017, University departments and schools will be migrating from Web Reimbursement to a best in class electronic Travel & Expense (T&E) system, Concur.
- Expense/Object Mapping File: this file will aid administrators in determining which Concur expense code should be used to correlate with the object (expense code) that will ultimately be charged to our general ledger.
- Concur Training & Job Aids: This page contains Concur training resources and job aids.
- 1/9/2017 - Added information about Concur.
- 7/12/2017 - Added an additional question and answer to the FAQ section.