Policy | Guidelines for Reimbursement

The IRS imposes additional regulations that SIBCR must follow to maintain an Accountable Plan for reimbursement of foreign travel expenses. These regulations include severe limitations for adding personal days to a foreign trip.International travel may require approval from the sponsor. The SIBCR grant administrator should be advised and will work with you to get this approval from the sponsor before any international travel is scheduled.

Foreign travel reimbursements should be submitted within 30 days from return of travel. The traveler must submit original receipts on a Travel Reimbursement form certifying the travel claim purpose, accuracy and appropriateness of expenditures.

The responsible member or authorized designee reviews and approves the Travel Reimbursement form before forwarding to the SIBCR Accounting Department for payment.

Foreign Travel - Federal Grants

All foreign travel charged to federal grants must be approved by SIBCR prior to the purchase of airfare.

For foreign travel to be charged to a federal project, the Guidelines on the Fly America Act must be followed. Failure to comply with the Fly America Act will result in non-allowable expenditures on a federal grant. These charges cannot be reimbursed from the grant.

Again, if you are a VA employee, there are additional VA requirements for travel and especially for foreign travel.

Transportation – Federal Grants – Fly America Act

All flights charged to federal projects must be taken on U.S. flag air carriers or on foreign air carriers that code share with a U.S. flag carrier on the flight taken. This includes flights within the U.S. If there is no U.S. carrier to your destination, you must travel on a U.S. carrier as far as possible. By law, additional cost for U.S. carrier flights is not sufficient justification to fly on foreign carriers. Please note that the same rules apply to foreign visitor flights.

See list of U.S. Flag Air Carriers and Code Share Alliances


There are strictly limited circumstances in which an exception may be appropriate. For example:

  • a U.S. flag carrier does not provide service on a particular leg of your trip,
  • the use of a U.S. carrier will unreasonably delay your travel time as defined by GSA Regulations you are involuntarily rerouted, or
  • medical or safety reasons, per GSA Regulations

Use of the Fly America Act Waiver Checklist can help you identify legitimate exceptions for use of a non-U.S. carrier.

Open Skies Exceptions

The biggest exception to the Fly America Act is the Open Skies Agreement. On October 6, 2010, the United States and European Union (EU) "Open Skies" Air Transport Agreement was published by the U.S. General Services Administration providing full explanation of the multilateral agreement in place so that qualifying travelers, whose travel is supported by federal funds, may travel on European Union airlines as well as U.S. flag air carriers. A list of current member countries of the European Union is available at the Europa web site (plus Norway and Iceland). There are also Open Skies agreements with Australia, Switzerland and Japan.

What does the Open Skies Agreement mean to Travelers?

When air travel is supported by federal funds, travel to the following destinations must either be on a U.S. carrier or, for specific destinations, may be on a European Union (EU) (plus Norway and Iceland), Australian, Japanese, or Swiss airline.

Important Note: The Open Skies Agreements do not apply if travel is funded by the Department of Defense (DOD) or by a department of the U.S. Military. Travel funded by the DOD or by a US military department must be on a US flag air carrier.

Click on a destination area below for Open Skies Agreement specifics:

EUblock Astralia Japan Switz Other
Documentation of Compliance

To satisfy regulatory requirements for charges to a federally sponsored project, a U.S. flag carrier designator code must be present on documentation for a flight; for example, UA1776 for United Flight 1776 or AA1787 for American Flight 1787. If you believe that you were on a code share flight, but there is no documentation showing the U.S. flag carrier code and flight number, you cannot charge the flight to a federally sponsored project.

A paper ticket or documentation for an e-ticket normally provides this proof. However, in some code sharing situations, we have found that only the boarding pass shows the U.S. flag carrier code. In this case, the boarding pass should be retained for documentation.

If you are claiming an exception under the Act, GSA Regulations 301-10.141 and 301-10.142, you must document the reason for the exception by submitting a Certification of Exception to Fly America Act Form. Submitting this information with a reimbursement request will speed the payment process and is required prior to reimbursement.


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