Code Sharing

Interpretation of the Fly America Act - Code Sharing, Relative to MIT International Travel Purchases

The VPF wishes to remind all MIT travelers that a condition of reimbursement of cost for all international travel (including North America) under federal awards is the traveler's compliance with the terms and conditions set forth in the Fly America Act. The act requires that all international travel being paid by the Federal Government utilize U.S.-certified airlines to the maximum extent possible. Any possible exceptions should be reviewed with your administrative or fiscal officer. With the advent of code-sharing, a mechanism by which a U.S.-certified carrier leases space on an aircraft of a foreign air carrier, and vice versa, the allowability of cost of international travel has become somewhat more complicated.

In order to clarify code-sharing arrangements, federal regulations have recently been revised to indicate that the ticket or documentation for an electronic ticket must identify the U.S.-flag air carrier's two letter designator code and flight number, which is located on the right hand section of the passenger receipt. This indicates that the flier is in a U.S.-flag carrier seat, regardless of the air carrier that owns the aircraft. The requirement that the ticket be issued by a U.S.-flag carrier, as shown in the upper left hand corner of the ticket, has been eliminated.

To assist you in verifying the allowability of code-share flights, below is a mock up of a ticket highlighting the appropriate areas to check.

Passenger Ticket and Baggage Check

The above ticket was issued by KLM, but the two letter designator code is NW (Northwest). This ticket is considered reimbursable under a government award.

If the air carriers were reversed, so that the issuing airline was Northwest and the designator code was KL, this ticket would not be reimbursable under a government award. However, it would be reimbursable, if allocable to a non-federal research award (WBS), a Cost Center or Fund (Internal Order). In this situation, the ticket expense will be charged to Cost Element 420071, Foreign Travel/ Foreign Carrier. Travel will ensure this accounting procedure.

The VPF continues to recommend that code-share flights be avoided whenever possible to avoid complications related to allowability of cost under federal awards. However, if you cannot avoid them, please use one of our three approved agencies, TQ3Navigant, OT & T Travel, and Travel Collaborative. They are knowledgeable of MIT's travel policies and will be responsible for ensuring appropriate ticketing on international flights.

Should you have any questions, contact Ellen Sico, 617-253-3547.