Guidance for Business Meals on Sponsored Projects
Business meals on sponsored projects are allowed to the extent they are allowable under the University of Massachusetts policies and those of the sponsor. Federal grants are also subject to allowability under the Office of Budget and Management (OMB) Circular A-21, Principles for Determining Costs Applicable to Grants, Contracts and Other Agreements with Educational Institutions.
Under OMB A-21 meals are allowed to the extent they are necessary to meet the objectives of the sponsored projects. Meals that are related to administrative functions such as food at a lab meeting are not allowable. Meals for entertainment purposes and alcohol are also not allowed. When meals are not necessary to the continuity of a meeting, they are considered entertainment and not allowed on sponsored projects. Meals that are for purposes of discussing future projects are also not allowed.
In order for business meals to be charged to a grant the following must be demonstrated:
- The meal must be part of a formal business meeting and integral to the continuity of conducting business
- The meeting must include external participant(s)
- The business discussed during the meal must be integral to the goals and objectives of the project
If a Business meeting is allowed on a grant, the following documentation is required:
- Date, location and description of the expenditure
- Itemized receipts of items ordered
- List of names of attendees with title, company or institution, affiliation and business relationship to the project
- Business purpose for incurring the expense; description of how the business conducted furthers the goal of the project. The need for such meals should be included in the proposal.
Following are brief excerpts from various agency websites:
NSF – Grant Proposal Guide Section C 2 g (xii) Unallowable Costs
(a) Entertainment
Costs of entertainment, amusement, diversion and social activities and any costs directly associated with such activities (such as tickets to shows or sporting events, meals, lodging, rentals, transportation and gratuities) are unallowable. Travel, meal and hotel expenses of grantee employees who are not on travel status are unallowable. Costs of employees on travel status are limited to those allowed under the governing cost principles for travel expenses.
(b) Meals and Coffee Breaks
No NSF funds may be spent on meals or coffee breaks for intramural meetings of an organization or any of its components, including, but not limited to, laboratories, departments and centers.
(c) Alcoholic Beverages
No NSF funds may be spent on alcoholic beverages.
NOAA - DOC Grants Manual Chapter 9
Costs. Eligible costs under a DOC financial assistance award must be in accordance with the applicable cost principles.
DOD - 32 CFR 32.27 - Allowable costs
8 (d) The allowability of costs incurred by institutions of higher education that may be recipients, subrecipients, or contractors is determined in accordance with the provisions of OMB Circular A21, Cost Principles for Educational Institutions.