Fly America Act checklist for grant-funded travel

The rule in one paragraph

The Act (49 U.S.C. 40118) and the Federal Travel Regulation (41 CFR 301-10.132 to 301-10.142) require travellers whose air travel is paid for by the federal government to use US flag airlines. GSA applies it to federal employees and their dependants, consultants, contractors and grant recipients. A flight operated by a foreign airline counts as US flag service when it is a codeshare ticketed under the US airline's designator code and flight number. Open Skies agreements and a list of exceptions allow foreign airlines in defined cases, each of which has to be documented.

Codeshares: which code is on the ticket

The same aircraft can be sold under two flight numbers. Which one is on your ticket decides whether it counts.

Flight numbers here are examples. Check the ticket or e-ticket receipt, not the booking site's summary: the receipt shows the carrier code and flight number that was sold.

Before booking

• Confirm how the trip is funded. The Act applies to air travel paid for with federal money, which includes travel by federal employees, contractors and grant recipients charged to a federal award.
• Read the award terms. Sponsors differ: some accept travel under an Open Skies agreement and some do not, and an agency's own rules can be stricter than the regulation.
• Book a US airline, or a codeshare sold under the US airline's code and flight number. A flight operated by a foreign airline counts as US flag service only when the ticket shows the US airline's designator code and flight number.
  In TripDesk365: Each flight keeps the airline whose code was sold and, when different, the airline that operates it, and the itinerary shows "operated by".
• Where a US airline offers nonstop or direct service on the route, use it unless doing so would add 24 hours or more to the journey, including waiting at the origin. The regulation has further rules for journeys with connections.
• If you are relying on an Open Skies agreement, check that it covers the route and the funding: see the table below.
• If no US airline can do the trip, write down which exception applies before booking, and get any written approval the exception needs.
• Record the award number on the trip, so every flight can be tied to the grant it was charged to.
  In TripDesk365: A grant or award number can be a required booking field, carried as a column in every export.

Open Skies agreements

The United States has Open Skies agreements that allow some government-funded travel on airlines of the other party. As GSA describes them:

None of these exceptions applies to travel funded by the Department of Defense. Grant recipients should also check whether their sponsor accepts Open Skies travel at all: some do and some do not.

The exceptions

The regulation allows a foreign airline when a US airline is available but cannot provide the transportation needed, or using it would not accomplish the mission. Section 301-10.135 lists reasons that count, including:

• medical reasons, such as reducing connections for someone who needs treatment;
• avoiding unreasonable risk to the traveller's safety, decided case by case with written approval;
• threats against US airlines, supported by a travel advisory from the FAA and the State Department;
• threats against the traveller, with evidence;
• no seat in the authorized class on the US airline when one is available on the foreign airline.

Cost and convenience are not on the list. Section 301-10.136 sets the rules for when US airline service counts as available on a journey between the United States and another country.

After the trip: the records to keep

• Keep the e-ticket receipt or ticket documentation showing each flight's carrier code and flight number. For a codeshare, it must show the US airline's code.
  In TripDesk365: The e-ticket receipt can be attached to the trip, stored encrypted, beside the flights it describes.
• Keep the detailed itinerary for the whole journey, connections included.
• Before the expense report, review every flight operated by a foreign airline and confirm it was sold under a US code or is covered by an exception.
  In TripDesk365: The flight-by-flight export has an "Operated by" column and a column for the award number, so every codeshare on a grant can be listed in one pass.
• Where an exception was used, complete the certification: the traveller's name, the travel dates, the origin and destination, a detailed itinerary, and how the exception applies or the written approval.
• Add what GSA asks agencies to keep for an exception: the agency's signed exception form, the detailed itinerary, and the search results showing the flights available and why the exception applied.
• Send the certification and documents to whoever your institution names, usually the sponsored programs or post-award office, before the cost is charged to the award.

Sources: 49 U.S.C. 40118; the Federal Travel Regulation, 41 CFR 301-10.132 to 301-10.142, on eCFR; GSA's Fly America Act page. Read 10/09/2026.

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