Food on Projects
The following SHARPI provides information on the subject of food being charged to a sponsored project account. This was originally distributed to the campus via email on September 12, 2008
The Office of Sponsored Programs is responsible for maintenance and review of this Guideline.
CREATED AND DISTRIBUTED TO CAMPUS SEPTEMBER 12, 2008
Recently, there have been several occurrences of expenditure documents presented for reimbursement on federal sponsored projects that included the cost of food. I thought it would be good time to review Stevens' position (which reflects "traditional" project oversight for federal awards, Circular A-21 requirements, professional experience, and audit advice and opinions as practiced and shared at professional society meetings).
I understand this may represent a departure from what may have been a historical practice at our Institute but it is not new within the realm of sponsored project administration. Additionally, I understand the review process and application engaged by OSP regarding this matter may have been uneven in the past. For these reasons...and more, I thought it best to share this on a wider scale with the research community as soon as I detected the need. You CAN be reimbursed for food, but normally not on a sponsored project. There are a few circumstances where this is possible and they are narrowly described.
I am currently engaged in presenting training on many, many items associated with sponsored research and the responsibilities associated with the receipt of federal money. The first presentation is scheduled for September 17 and concerns "Cost Related Issues." Thus far I know of one person (outside of the central business functions who HAVE to attend) who indicated they are interested in attending.
Please feel free to call me at x8762 or email me at firstname.lastname@example.org in order to vent your frustrations and I will be glad to talk to people inpidually, or attend any group conversations you might want to put together, or feel would be productive. My staff, who consider themselves a part of every PI's research team, are sympathetic to your plight but I ask that you direct any complaints to me. I do not want them taking the heat for something that falls in my court and for which I am paid.
The following section is excerpted from the "Sponsored Projects Reference Manual" that was distributed in the Fall of 2007.
Food and Beverages
"Meals while traveling for a sponsored project are allowable; however, on-campus meals eaten at a local business are rarely allowed on federally sponsored projects. Food and beverage expenses are allowable if they are explicitly identified in the approved budget.
The one circumstance in which local business meals might be directly charged is described in OMB A-21 under the heading "Meetings and Conferences." This section (J.32) states:
"Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, and other items incidental to such meetings or conferences. But see section J. 17 'Entertainment Costs'."
Expenses for food and beverages must include documentation substantiating the business purpose of the meal. This would typically include the description of the nature of the discussion, and relationship to the sponsored project if applicable, an agenda, a list of attendees, etc.
Auditors routinely question local food costs, and unless they find adequate documentation to show that the costs were associated with a bona fide technical conference or meetings, they may be disallowed. It is important to document how the food charges specifically benefit the project. If the research administrator knows in advance that a conference or meeting on campus with food service is necessary, then the expense should be included as part of the proposal submission so that it may be approved by the sponsor.
When United States government officials visit campus, the research administrator should avoid directly charging costs for their meals. Typically, government officials are restricted from accepting meals and other benefits from recipients of federal funding. Most of Stevens' federal sponsors who visit campus understand this rule, so they usually offer to pay for meals on campus, and it is appropriate to accept their payment."