Policy Library

Meals and Entertainment Expenses Guidance

PDF Version

The Office of Management and Budget states the costs of entertainment, including amusement, diversion, and social activities and any associated costs are unallowable, except where specific costs that might otherwise be considered entertainment have a programmatic purpose and are authorized either in the approved budget for the Federal award or with prior written approval of the Federal awarding agency. The allowability of entertainment expenses on non-federal sponsored research awards depends upon the guidelines of the specific sponsor. This guidance should be used in determining the allowability and categorizing of expenses for meals and social activities on sponsored awards.

Meals on Sponsored Awards

The cost of meals may be allowable as a direct charge to sponsored agreements, based on the facts and circumstances of the expense. Meals should be classified into one of the following categories to properly assess and determine the allowability of the charge.

Meals While Traveling

Meals while traveling are defined as meal expenses incurred when traveling on out-of-town business trips (conferences, meetings, workshops, etc.) for more than 50 miles. Travelers will be reimbursed for meal expenses provided they are documented, reasonable, and consistent with federal guidelines and University Policy 1202: Travel Policies and Procedures.

Food Charged as Part of Conferences Sponsored or Hosted by the University

A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the University and is necessary and reasonable for successful performance under the Federal award. Allowable conference costs paid by the University as a sponsor or host of the conference may include rental of facilities, speakers' fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences unless further restricted by the terms and conditions of the Federal award.

Therefore, meals may be directly charged to an award if they are associated with a formal conference that is specifically budgeted and approved by the sponsoring agency.

Business Meals

The cost of food/meals while not on travel status will normally not be allowed as a direct charge on sponsored projects, as these costs are considered personal expenses. However, meals while not on travel status may be allowable if:

  • The sponsor does not specifically disallow such costs AND
  • The meeting includes significant participation of external collaborators AND
  • The meal is served at a formal meeting being conducted in a business atmosphere where the meal serves to maintain the continuity of the meeting AND
  • The activity at which the meal is being served is integral to the goals of the project

Documentation to support these costs, as required by University policy and I.R.S. guidelines,must include all the following:

  • Specific business purpose of the meal, typically an agenda
  • Names and business relationship of the individuals attending

o If an individual is not a University employee, the name of the company or institution that the individual represents must be provided.

o If more than 10 people attend, they may be identified as a single body.

  • Business Meals are not to be charged to a grant or contract unless the terms specifically allow it. University Research Administration must approve and activate the sub account before you may charge a grant or contract.
  • Itemized receipt

Meal costs should not violate University policy nor should the cost per person exceed local per diem rates.

Meals that generally do not fall within this category as allowable include those associated with research team meetings (either scientific or administrative), working lunches, coffee breaks, staff meals, recurring meetings to discuss the progress on an award, or otherwise any other intramural meetings. If such expenses are incurred, they may be charged to a university account if University travel and expense guidelines are met.

Food for Research Subjects and Project Participants

The cost of food/meals for research subjects is allowable on a federal project, assuming all human subject compliance requirements are in place. IRB approval is required and if the method and amount of food/meals differs from what was originally approved by the IRB, any change must receive IRB approval. The cost of food/meals must have a programmatic purpose and are authorized either in the approved budget for the Federal award or with prior written approval of the Federal awarding agency.

Participant Support Meals

Food-related expenses associated with Participant Support costs are allowable only if the project includes an education or outreach component, and the food-related expenses are explicitly listed in the proposal budget and justified as part of the education or outreach components. Participant support costs are defined as direct costs for items such as stipends or subsistence allowances, travel allowances and registration fees paid to, or on behalf of, participants or trainees, not University employees, in connection with conferences or training projects.

Considerations for Charging Meals on Federal Awards

The following general considerations apply whenever food costs are being charged to a federal grant award:

  • When dealing with food costs, always keep in mind that “entertainment” costs may not be charged to federal grant awards.
  • The food costs should appear in the project budget that was approved by the awarding agency. If this is not the case, PIs and approvers should consult with University Research Administration before initiating or signing off on food-related expenses. Meals and Entertainment Expenses Guidance 3
  • The costs must clearly and directly benefit the award project to which they are being charged.
  • All food costs must be soundly documented in a manner that makes it possible for a third party to easily determine how the costs benefitted the project.
  • The costs must be reasonable, reflecting market value or below. Obtaining multiple price quotes for larger purchases, such as catering for an off-campus meeting, will help to ensure this.
  • The costs must be allowable by federal standards. For example, charging alcohol to federal grants is unallowable.
  • The costs must be consistent with University policy.