Charging Food/Meals to Federally Sponsored
(and Federal Flow-Down) Projects
(Go to FAQs)
Purpose: This guidance provides the Institutional position on the direct charging of food/meals while not in travel status to sponsored projects.
**Note: UVA policies may permit spending other types of funds for food/meal expenses, but they may not be allowable on sponsored projects. Absence of a scenario from the FAQ’s below does not necessarily mean the costs are allowable. You should always consult (1) the University position, (2) project terms and conditions and (3) sponsor guidelines when making these types of costing decisions.
Institutional Position: The cost of food/meals while not in travel status will normally not be allowed as a direct charge on federally sponsored (or federal flow-down) projects, as these costs are typically considered a personal expense.
The institution is cognizant that occasionally there are events and meetings where food/meal costs may be an allowable charge to a federally sponsored project. The applicable criteria for determining allowability are:
- The cost must be not be expressly disallowed by the institution, both under federal and sponsor regulations, AND under the terms of a specific project.
- The cost must be allocable, that is, the project which pays the expense must benefit from the event or meeting that includes the food/meals. More specifically, the food /meals must be integrated into a project-related event.
- The cost must be reasonable, that is, must reflect the action a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. Food /meal costs per person should not exceed UVA per diem rates (as published on UVA’s Procurement and Supplier Diversity Services website).
- Participants/employees typically should not be solely UVA employees. There should be speakers/attendees from other employers/institutions.
- All documentation requirements must be met as outlined below.
- The event or food/meals could not be perceived as entertainment, hospitality or otherwise unnecessary to achievement of project goals. The food/meal costs are integral to delivery of project goals.
Meals, Business Expenditure Type:
“Meals, Business”, should ONLY be used for meals in NON-travel status. Travel-related meals should be expensed using the appropriate “Travel, Subsist & Lodging” expenditure type.
- Dated agenda or other written document that clearly demonstrates the purpose of the meeting/event in furthering project goals/aims.
- Roster of people attending, including the name of each participant’s institution/employer.
- Technical role/affiliation with the project of each attendee.
- Approved Federal Costing Exception Request Form (See Costing Principles and Guidance for additional information regarding the federal costing exception process).
The Code of Federal Regulations 2 CFR 220 (OMB Circular A-21)
Section J-32: 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, speakers' fees, and other items incidental to such meetings or conferences. But see section J.17 of this Appendix, Entertainment costs.
Section J-17: Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities) are unallowable.