CCCS Guidance on Adequate Justification of Food for Meetings/Conferences

In May of 2013 the United States Department of Education released a new FAQ relative to providing food at meetings and conferences. The document, which is attached, alerts grant recipients to the heightened level of justification needed when using federal funds to provide food at a meeting or conference (for specifics see question 6.)

After reviewing this guidance CCCS recognizes a need to help clarify where providing food would be considered “reasonable and necessary.” Please note that this information is not meant to cover all situations but is intended to provide a base from which to make decisions.

1. Normal travel rules are not affected by this guidance.

2. Meals provided at a meeting or training should be at or below State per diem to be considered “reasonable.” Additional justification will be necessary for meals going beyond the established per diem amount.

For a lunch to be considered “necessary” the meeting or training must be at least 6 hrs in duration and span the lunch hour. Providing breakfast or dinner will require additional justification as to why that specific meeting time and providing food were required.

An example of this situation may include: Advisory Committee meetings that need to meet before or after the business day. In addition, since it would be unreasonable to require students attending career fairs to leave and obtain their own meal, it could be allowable to fund a lunch for a career fair that features CTE programs. For privacy, sign-in sheets listing student names will not be required, however there should be documentation of the career fair agenda and a record of the numbers of students attending (i.e., expected numbers attending per teacher per school.)

3. Documentation that may be requested for any reimbursement of food costs includes but is not limited to: Agendas (noting technical information being provided), Sign-in Sheets, Receipts, RSVP lists, and/or advisory committee meeting minutes.

July 30, 2013 4. If exceptions to the above guidance are needed, a compelling case must be provided. For example, if the meal cost is above State per diem, a menu illustrating all the meal choices and costs must be saved as documentation and may be requested. Similarly, if a meal is provided for a meeting that lasts less than 6 hours, a compelling justification must be provided specifically explaining the reasons the meal had to be provided for a short meeting.

5. Food should not be a Perkins expense for short, in-house staff meetings.

July 30, 2013