- Burden of Proof
- Food Approval Flags/Food Approval Form
- Object Codes
- Food Purchase Documentation
- Hosting a Meeting or Conference
- Receptions, Networking Events, or Employee Appreciation Meals
- Federal Regulations
- Purchase of Alcohol or Meals Over Per Diem
There is a very high burden of proof to show that paying for food/meals and beverages with sponsored funds is necessary to meet the goals and objectives of the award. Departments have to make a compelling case that the unique circumstances they have identified would justify the purchase of food as reasonable and necessary.
As always, all food expenditures must be in compliance with the four Cost Principles.
Sponsored award budgets no longer use food approval flags. The application of approval flags was discontinued as its usage was inconsistent. Older Awards may have a food approval flag; the presence of such a flag or the food approval form does not replace the requirement to have appropriate approval documentation for the purchase of food on file.
The Food Approval Form is not required for Sponsored awards. Departments may establish more restrictive policies and procedures concerning food purchases on Sponsored Awards.
For Awards in the budget type 05 category that are not funded by a sponsored agreement (Clinical Practice, Royalty Income, etc.) departments should establish appropriate internal controls to detect and prevent fraud, waste and abuse of these funds.
See Financial Management's Food Policy for more information on both the Food Approval Flag and Form.
Use the appropriate Object Code that identifies the purchase as Food. There are a number of different Object Codes for food purchases; use the one that most closely describes the purchase. Object Code 05-01 “Food” provides information on the different Object Codes available for food purchases.
Do not use another Object Code that does not clearly identify the purchase as food (e.g., 05-99 Miscellaneous Consumables). Food purchases can typically be easily identified by the vendor name or other identifying information in the financial system.
Even if food is already approved by the sponsor, full documented justification for the purchase of the food by should be included. As food is a high risk purchase, food transactions are likely to be reviewed in an audit. Full documentation includes:
- The reason why food was being provided; explain how the purchase of food was necessary to obtain the objectives of the award;
- Copy of the sponsor’s approval (either in the proposal budget or post-award written approval);
- The cost per person (the total cost of the food, including taxes and applicable service charges, and the number of people that the food was served to); AND
- Proof that the cost per person is within the per diem allocation for the meal in question. Meal amounts above the per diem limit are not an allowable expenses (see “Meals over Per Diem” below). The per diem amount for each meal based on location can be found at the UW Travel website.
When hosting a meeting/conference, the department should structure the agenda so there is time for participants to purchase their own food, beverages, and snacks. Departments should consider a location in which participants have easy access to food and beverages.
Provision of a Meal
If a department is hosting a meeting or conference, grant funds may not be used to pay for food for conference attendees unless doing so is necessary to accomplish legitimate meeting or conference business. Remember that federal grant funds may only be used for expenses that are reasonable and necessary.
A working lunch is an example of a cost for food that may be allowable under a federal award if attendance at the lunch is needed to ensure the full participation by conference attendees in essential discussions and speeches concerning the purpose of the conference and to achieve the goals and objectives of the award.
If a meal is provided, be sure to:
- Follow the documentation requirements in “Food Purchase Documentation”.
- Make sure that for any participants who are receiving per diem, their per diem is reduced by the amount allocated for that meal. The per diem amount for each meal based on location can be found at the UW Travel website.
Meals over Per Diem
If a meal is provided and the cost per person exceeds per diem amount, the amount over the per diem is not an allowable expense. The per diem amount for each meal based on location can be found at the UW Travel website.
Facility Invoicing & Documentation
In planning a meeting/conference, ensure that the vendor will itemize any food purchases separately from other costs. If the vendor embeds food and beverage costs into the total cost of the meeting space, the department should work with the vendor to have the food and beverage costs identified separately. The fact that food and beverages are embedded in a contract for meeting space does not mean that the food and beverages are being provided at no cost.
Conference facilities sometimes include “complimentary” beverages (e.g., coffee, tea) as part of the facility rental. Departments have an obligation to confirm that the beverages are truly complimentary and will not be reflected as a charge in another area. It is not acceptable for a vendor to embed the cost of beverages in other costs, such as meeting space.
Using sponsored funds for these events is typically not justified as participation in such activities is rarely considered to be a reasonable expense and necessary to achieve the purpose of the award.
The following federal regulations address the purchase of food, conference and associated costs:
2 CFR 200.432 - Conferences
2 CFR 200.438 – Entertainment Costs
As with all expenditures, department should ensure that they are in compliance with the terms of the Award and any agency-specific regulations. (e.g., NIH Conference Grants strictly prohibit the purchase of food.)
On very rare occassions, sponsored awards allow for the purchase of alcohol. In this case a discretionary sub-budget must be set up. For more information on this process click here.