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Office of Sponsored Projects

Hinman Box 6210
11 Rope Ferry Road #6210
Hanover, NH 03755
Phone: 603-646-3007
Fax: 603-646-3670
Email: sponsored.projects@dartmouth.edu

Travel, Meals & Entertainment Expenses Related to Sponsored Research Awards

The primary responsibility for adherence to these policies rests with the departments and supervisors who are authorizing travel and approving expense reimbursements. Travelers should also bear in mind that government agencies and other observers may perceive certain expenditures as being either excessive or inappropriate in the context of a regulatory audit, an IRS audit, or other similar review of College activities. Thus, moderation and discretion should guide travelers' decisions to incur expenses on the College's behalf.

One category of costs that should receive special attention are entertainment and meals expenses. In general, entertainment expenses are not allowable on sponsored project awards. The allowability of entertainment expenses on non-federal sponsored project awards depends upon the guidelines of the specific sponsor. Entertainment has been loosely defined by the Uniform Guidance as "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 following guidelines should be used in determining the allowability and categorizing of expenses for meals, lodging and social activities on sponsored project awards:

Alcoholic Beverages are not allowable on sponsored project awards unless specifically authorized in the approved budget and consistent with the purpose of the award. The instances where alcohol is approved in the budget are extremely rare. Unless allowed by the sponsor, Alcohol purchased during meals, travel, conferences or meetings should be deducted from the amount to be charged to a sponsored project award, a department GL Account should be charged for the Alcohol in this instance. When Alcohol is allowed on a sponsored project award by the sponsor, the alcohol charge should initially be charged to a GL account, then a cost transfer should be completed transferring the expense from the GL account to the PTA account. For audit purposes we have found by doing the cost transfer, it provides a detailed justification as to why these transactions are appropriate as a direct cost on that specific sponsored project award.

Reasonable and actual out-of-pocket expenses incurred while traveling to a scheduled meeting are allowable when the travel will provide direct benefit to the award. Allowable expenses related to travel include meals for the individual. Guest meals are not allowable and should be not be charged to the sponsored project award. Travel expenses should be charged to the appropriate travel Expenditure Type.

Meals for subjects and patients under study are allowable when included in the approved budget. Meals for research subjects should be charged to the appropriate Expenditure Type.

Certain meals that are an integral and necessary part of a conference (i.e. working meal where business is transacted) and are associated with a sponsored project award that has been designated as a Conference Grant by the sponsor is allowable. Meals that are provided to key participants during an all day scheduled meeting with an agenda are allowable. A conference is generally defined as "A symposium, seminar, workshop, or any other organized and formal meeting lasting 1 or more days where persons assemble to exchange information or clarify a defined subject. Meals for guests not attending the conference are unallowable. Allowable expenses for "working" meals associated with an all day conference should be charged to the appropriate Expenditure Type.

Costs associated with recruitment of personnel generally are allowable, but you should confirm with your Sponsored Research Manager for that specific sponsored project award. These allowable recruitment costs include help wanted advertising costs, travel costs to pre-employment interviews incurred by applicants, and travel costs of employees while engaged in recruiting personnel. Guest (other than the applicant and Principal Investigator) expenses are unallowable.

IMPORTANT NOTE:

Sponsored project awards may be used to cover the costs associated with travel and entertainment, i.e. transportation, meals, and lodging. However, there are a number of factors that enter into approval of sponsored project awards to cover travel and entertainment expenses, here are those factors:

  • The awarded proposal must have explicitly stated an amount and justification for the travel, this will translate into a budget category for travel when the sponsored project PTA Account is established.
  • The expenses incurred related to travel and entertainment must be fully documented and explicitly stated in the Dartmouth College Travel Policy.
  • The expenses incurred related to travel and entertainment on a federally sponsored project award must conform to federal regulations.

Sponsors may have more explicit policies covering reimbursement of these expenses. The Department Grant Manager and Principal Investigator are advised to study the sponsor's travel policy as well as the full Dartmouth College Travel Policy. For further clarification of these policies, please contact your Sponsored Research Manager.

In addition to insuring the allowability of expenses on sponsored project awards, it is very important that those persons responsible for departmental accounts insure that expenses are properly classified into the correct Expenditure Types. Important audit information is derived from all accounts (both GL Accounts and PTA Accounts).

Meals provided to participants of an all day conference or working meeting should include the following documentation:

  • List names of the attendees
  • Include a statement that specifies the nature of the business conducted during the meal, why the meal was a necessary part of the conference and explain how it directly benefited the sponsored research award
  • Attach a copy of the conference agenda

Examples of Entertainment and Meals Situations

The following are examples of common situations that arise on sponsored project awards. These examples are intended as a guideline for determining the classification and allowability of expenses. We realize that the guidelines are subject to interpretation on a case-by-case basis. Please call OSP for questions regarding a specific case.

  1. The institution invites a renowned scientist to deliver a paper directly related to a sponsored project award. The Department of Pathology provides coffee and cookies during a break before a related question and answer session. The cost of the refreshments are not entertainment and should be allowable on a sponsored project award, so long as they are reasonable. They are associated with a meeting where the predominant purpose is the delivery of information regarding a related sponsored project award.
  2. After the meeting, the dean of the Medical School holds a reception for the scientist where beer, wine and hors d'oeuvres are served. These costs are considered entertainment and generally unallowable on a sponsored project award.
  3. Instead, the dean takes the scientist and his department chair out for dinner. Alcohol is served. This is also considered entertainment, and is not generally allowable on a sponsored project award.
  4. The College puts this scientist up at a local inn after the talk. The costs of subsistence would be allowable on a sponsored project award where the principal purpose of the meeting like this, was dissemination of technical information.
  5. The President, Provost, and Vice-Presidents hold a retreat off campus to discuss a 3-year financial plan. There is a continental breakfast, and lunch served. The participants go to a local restaurant for dinner. Since the primary purpose of the meeting is a technical discussion, and there is an agenda (the 3-year plan), the costs of travel, housing, breakfast, and lunch would not be considered entertainment. It would probably be hard to argue that the primary purpose carried over to dinner, however. In fact, it probably makes sense to exclude on this basis all meals where alcohol is served, except where on travel & meals are being reimbursed as part of travel reimbursement policy.
  6. The Physics Department receives a sponsored project award to hold a symposium for leading scientists to discuss a new particle. In its sponsored project proposal, the Department listed the activities it planned to conduct, and the sponsored project proposal specifically provided for a working dinner the night before. This would be allowable on the sponsored project award since there was such a specific provision.
  7. From time to time, the Chemistry Department Chairman holds lunches for the members of her Department at the faculty club to discuss academic and research issues. Unless the primary purpose of the lunch is dissemination of technical information, as evidenced by a formal agenda, the sponsor would probably contend that the primary purpose was the meal, not the discussion (which could presumably have been held without the expenses); so the cost of lunch would be considered entertainment and generally not be allowed on a sponsored project award.
  8. The provost travels to Cleveland to recruit a department chair. The reasonable cost of travel and subsistence (less alcohol, of course) would not be considered entertainment. Presumably this would include the costs of lunch or dinner with the recruit, assuming that it was inappropriate to meet at the recruit's place of business. Similarly, the reasonable cost of the recruit's travel to your institution would not be considered entertainment.
  9. The President holds a reception in honor of the Medical School's 100th anniversary. This is entertainment. Presumably the exclusion would also run to any glossy publications that were produced on or after the affair.

Travel on Grants

Travel and other expense reimbursements charged to sponsored project awards are managed under the policy and procedures outlined on the Controller's Office website and the Finance Center websites.   

Please familiarize yourself with the policies and procedures below:

Fly America Act

The Federal Travel Regulations requires international flights be on U.S. flag air carriers whenever possible, which is accomplished when code sharing is present. Code sharing occurs when two or more airlines “code” the same flight as if it was their own.  Therefore, international flight may be on a foreign air carrier’s plane, but is considered the same as one operated by an U.S. flag air carrier.

Compliance with the Fly America Act is satisfied when the U.S. flag air carrier’s designator code is present in the area next to the flight numbers on the airline ticket, boarding pass, or on the documentation for an electronic ticket (passenger receipt).

If foreign travel is required and it was not originally stated in the sponsored project proposal, in most instances, the PI will need receive prior approval from the sponsor to be able to do foreign travel on that sponsored project award. The PI would need to type up a letter requesting foreign travel on that sponsored project award. The letter request would need to be signed by both the PI and OSP. The fully signed letter request would be emailed to the sponsor by OSP.

Open Skies Agreement

Qualifying travelers, whose travel is supported by federal funds, may travel on U.S. Flag Air Carriers, or European Union airlines as long as they touch down in an EU country. Travelers with DoD funding are not allowed to take advantage of this agreement.  List of current member countries: http://europa.eu/about-eu/countries/index_en.htm Please noteTravelers with DoD funding are not allowed to take advantage of the “Open Skies” agreement.

 

 

 

Last Updated: 3/13/17