One category of costs that should receive special attention are entertainment and meals expenses. In general, entertainment expenses are not allowable on sponsored research awards. The allowability of entertainment expenses on non-federal sponsored research awards depends upon the guidelines of the specific sponsor. Entertainment has been loosely defined by OMB 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 research awards:
Alcoholic Beverages are not allowable on sponsored research 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 research award, a department GL Account should be charged for the Alcohol in this instance. When Alcohol is allowed on a sponsored research award by the sponsor, the designated Expenditure Type for this type of expense should be charged.
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 research 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 research 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 OSP Grant Manager for that particular sponsored research 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.
Sponsored research 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 research awards to cover travel and entertainment expenses, here are those factors:
Sponsors may have more explicit policies covering reimbursement of these expenses. The Department Grant Administrator and Principal Investigator are advised to study the sponsor's travel policy as well as the full Dartmouth College Travel Policy, if for further clarification of these policies you can contact your OSP Grant Manager.
In addition to insuring the allowability of expenses on sponsored research 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:
Examples of Entertainment and Meals Situations
The following are examples of common situations that arise on sponsored research 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.
Travel and other expense reimbursements charged to sponsored 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:
Business Expense Questions: http://www.dartmouth.edu/~fincenter/frequently_asked_questions/business_expense_questions.html
Dartmouth Business Expense Policy (available on the Controller's Office website). The BER policy covers topics such as documentation, cash advances, air travel, lodging, unallowable expenses, moving expenses and many other reimbursement topics.
Individuals using federal funds to fly on international air carriers must pay careful attention to restrictions on US Flag Carriers.
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).
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 note: Travelers with DoD funding are not allowed to take advantage of the “Open Skies” agreement.
Last Updated: 3/21/15