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NSF Regulations on Domestic and Foreign Carriers

Federal government regulation contain strict rules regarding when public employees, which in this case means Fellows, are allowed to be reimbursed for travel on foreign airlines. Essentially, they require that you travel on a U.S.-flag carrier or on a U.S. carrier's code-shared flight to the greatest extent possible (see below for details on what "code-shared" means). If you plan to fly overseas, check these rules carefully before purchasing your ticket on a foreign airline. Heck, if it seems too complicated, you might just be better off finding conferences and collaborators in Hawaii. Remember not to scuba dive and climb volcanoes on consecutive days, and to wear plenty of sunscreen. Aloha!

Anyway, rules governing the use of foreign-flagged air carriers can be found in the NSF Grant Policy Manual (see Chapter VII, section 760). The text found here is effective as of July 1, 2005.

For the purposes of this discussion, travel on a U.S.-flag air carrier entails essentially the same regulations as travel under a “code-sharing” arrangement with a U.S.-flag carrier. A code-sharing arrangement means that the flight has both a foreign flight number and a domestic one (e.g., without any endorsement implied, the fictional example United Airlines Flight 9999/Lufthansa Flight 999).

Code-shared flights are only allowed if you purchase the ticket through the U.S.-flag carrier. DO NOT purchase the ticket for the code-shared leg from the foreign-flag carrier, or you are not allowed to use the grant to reimburse the cost!

Summarized, the NSF rules, which can be found in full below, state that:

  1. Domestic travel must take place on a U.S.-flag carrier.
  2. Roughly speaking, connecting legs within the U.S. should take place on a U.S.-flag carrier (see 761.2.d for the gory details).
  3. Stick to U.S.-flag carriers heading to/from/between foreign countries unless they add 24 hours to your time in transit, add at least two connections to a leg of your trip, or (when interchanging at a foreign airport) require a connection of longer than 4 hours or an additional six hours in transit (see 761.3 for the gorier details).

NSF Regulations from the Grant Policy Manual

761 Travel to Foreign Countries

761.1 Policy

  1. Expenses for transportation, lodging, subsistence and related items incurred by project personnel and by outside consultants employed on the project (GPM 614, "Travel Costs") who are on travel status on business related to an NSF-supported project are allowable as prescribed in the governing cost principles. The requirements for prior approval detailed in the governing cost principles are waived.
  2. Support for the foreign travel of an investigator’s dependents is allowable only under the conditions identified in GPM 614, "Travel Costs".

761.2 Use of U.S.-Flag Air Carriers

  1. The General Services Administration issued an amendment to the Federal Travel Regulations in the November 13, 1998 edition of the Federal Register (Vol. 63, No. 219). The amendment relates to the use of U.S. flag air carriers under the provisions of 49 U.S.C. 40118, which is commonly referred to as the Fly America Act.
  2. Any air transportation to, from, between or within a country other than the U.S. of persons or property, the expense of which will be assisted by NSF funding, must be performed by, or under a code-sharing arrangement with, a U.S.-flag air carrier if service provided by such a carrier is “available” (see Comp. Gen. Decision B-240956, dated September 25, 1991). Tickets (or documentation for electronic tickets) must identify the U.S.-flag air carrier’s designator code and flight number.
  3. For the purposes of this requirement, U.S.-flag air carrier service is considered “available” even though:
    1. comparable or a different kind of service can be provided at less cost by a foreign-flag air carrier;
    2. foreign-flag air carrier service is preferred by or is more convenient for NSF or traveler; or
    3. service by a foreign-flag air carrier can be paid for in excess foreign currency.
  4. The following rules apply unless their application would result in the first or last leg of travel from or to the U.S. being performed by a foreign-flag air carrier:
    1. a U.S.-flag air carrier shall be used to destination or, in the absence of direct or through service, to the farthest interchange point on a usually traveled route;
    2. if a U.S.-flag air carrier does not serve an origin or interchange point, a foreign-flag air carrier shall be used only to the nearest interchange point on a usually traveled route to connect with a U.S.-flag air carrier; or
    3. if a U.S.-flag air carrier involuntarily reroutes the traveler via a foreign-flag carrier, the foreign-flag air carrier may be used notwithstanding the availability of alternative U.S.-flag air carrier service.

761.3 Use of Foreign-Flag Air Carriers

  1. Travel To and From the U.S. Use of a foreign-flag air carrier is permissible if the airport abroad is:
    1. the traveler’s origin or destination airport, and use of U.S.-flag air carrier service would extend the time in a travel status by at least 24 hours more than travel by a foreign-flag carrier; or
    2. an interchange point, and use of U.S.-flag air carrier service would increase the number of aircraft changes the traveler must make outside of the U.S. by 2 or more, would require the traveler to wait four hours or more to make connections at that point, or would extend the time in a travel status by at least six hours more than travel by a foreign-flag air carrier.
  2. Travel Between Points Outside the U.S. Use of a foreign-flag air carrier is permissible if travel by a:
    1. foreign-flag air carrier would eliminate two or more aircraft changes en route;
    2. U.S.-flag air carrier would extend the time in a travel status by at least four hours more than travel by a foreign-flag air carrier and the travel is not part of the trip to or from the U.S.; or
    3. U.S.-flag air carrier would require a connecting time of four hours or more at an overseas interchange point.
  3. Short Distance Travel. For all short distance travel, regardless of origin and destination, use of a foreign-flag air carrier is permissible if the elapsed travel time on a scheduled flight from origin to destination airport by a foreign-flag air carrier is three hours or less and service by a U.S.-flag air carrier would double the travel time.
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