Policy – Purchasing Food and Business Related Entertainment

This policy and the related procedures conform to Board of Regents of the University System of Georgia policies. These policies clarify instances when food may be purchased for consumption by students, potential students, volunteers and employees using institutional funds. As stated in the Board of Regents manual, institutional funds include all funds held in University accounts.  The policy also addresses instances when food for employees may be purchased or food expenses may be reimbursed other than provisions under the state travel policy when employees are on travel status.

The sections of this policy include:

1.0 General Information

2.0 Food for Students

3.0 Food for Volunteers

4.0 Food for Employees

5.0 Conference and Workshops

6.0 Meals Purchased for Business Related Entertainment

Food includes meals, beverages, snacks, etc. but specifically excludes alcohol as an allowable food expense.

Certain auxiliary units (e.g. Georgia Center and Food Services) purchase food for resale to the general public. This is the only instance where use of institutional funds for the purchase of alcohol, for resale in the normal course of business, is authorized.

The purchase of food is authorized in those circumstances where the use of food is integral and necessary to the organization’s mission. Examples include the McPhaul Center, a daycare facility, which purchases food to provide meals to the children enrolled in the daycare center, and 4-H Centers that purchase food for dining facilities at the 4-H locations which serve attendees.

Food purchased by outside organizations for employees does not fall under the scope of this policy. However, employees must comply with the provisions of the Gratuity Policy at: http://askuga.uga.edu/default.asp?SID=&Lang=1&SID=&Lang=&id=972&Lang=1&SID= 

Food purchased by either the Arch Foundation or the UGA Foundation is governed by the policies and procedures of those entities. For information on Foundation funded travel expenses and food purchases, please see Section VIII.D.1 and VII.J of Foundation policies at www.uga.edu/archfoundation and www.ugafoundation.org.

Food purchased for Study Abroad Programs is not addressed in this policy. Refer to:

(http://www.uga.edu/oie/docs/sa/director/financial/Financial_Administration_Procedures.doc) for financial policies and procedures for Student Abroad Programs.

An individual may be subject to different rules depending on the capacity in which they are participating in an event. For example, volunteers might include employees or students if the individual is operating in a capacity separate from their employee or student role. An employee or volunteer attending a student event in the capacity of a student would be considered a student. A student worker participating in an event while being paid would be considered an employee. Employees working additional hours in their own area, using work time to provide volunteer service, or otherwise participating in activities expected of employees, are not volunteers for the purposes of this policy.

The funding source used to purchase food should generally match the supported program and participants. For example, student activity fees would be an appropriate funding source to purchase beverages for a volunteer event sponsored by a student group. In this instance, students, volunteers, and employees would presumably consume the beverages. However, student activity fees would not be an appropriate funding source to purchase water or other hydration products for employees conducting activities as part of their normal job, e.g., groundskeepers. The budget for the groundskeeping department is the appropriate funding source in this instance.

Employees with responsibility for administering institutional funds and employees requesting reimbursement from institutional funds should ensure that funds are spent only for legitimate public purposes and not for the personal benefit of the employee or other individuals. All expenses and supporting documentation are open to public records. Noncompliance with these requirements can result in audit findings, loss of funds, and adverse publicity. The misuse of institutional funds may result in both employment termination and various civil and criminal penalties.

The chart included in Appendix A outlines the funding sources that may be used when making food purchases and provides some broad examples of allowable purchases. This chart is intended to provide guidance on allowable food purchases. It should be specifically noted that the use of P-Cards to purchase food is only allowable for:

• student food, 
• food for instructional uses, 
• food for official research,
• employee group meals as outlined in section 4.1 of this policy,
• conferences/workshops, and
• food for resale

• sanctioned student events - events and travel sponsored by recognized student groups and other campus events open to the general student body and designed to further the development and education of students;
• classroom and academic programs - in those instances where food is an integral part of the instructional methodology. (Examples: food could be purchased for students in a food appreciation, cooking, or foods and nutrition course, including a continuing education course);
• student recruiting events - potential students and their parents/guardians may be provided food at an event designed to encourage the student to attend the institution;
• volunteer events – events where students participate as volunteers along with other non-students.

The Board of Regents policy specifies that while participants are not necessarily in a travel status, the state travel per diem limits should apply to food purchased for consumption by students at these type events. Food purchased at a restaurant or on a per person basis should include a list of participant names and their relationship to the University using the form at:(http://www.busfin.uga.edu/forms/entertainment.pdf).   In the event that an employee expends funds in excess of the authorized per diem, the amount spent in excess is the responsibility of the employee making such expenditure.

While the per diem limits also apply to group events where food is purchased on a group basis (pizza parties, etc.), departments are not required to document the actual numbers or names of participants. However, departments must provide documentation to substantiate how the appropriate per diem guidelines were followed.

Section 3.0 Food for Volunteers

Volunteers include individuals that provide benefits to the institution (serving on an advisory board, student mentors, etc.) without receiving compensation. Institutional funds may be used to purchase food for volunteers in those instances where a quid pro quo relationship exists. For example, an academic unit might form a volunteer advisory board for the purpose of obtaining advice, support, and expertise from members of the community as it relates to an academic program. It would be allowable to provide food to those volunteers as part of the advisory board meeting.  However, food purchased solely in connection with volunteer appreciation or volunteer recognition events would not be allowable using institutional funds under this policy, but may be purchased using Foundation funds.

The Board of Regents policy specifies that while these participants are not necessarily in a travel status, the state travel per diem limits should apply to food purchased for consumption at these type events. Food purchased at a restaurant or on a per person basis should include a list of participant names and their relationship to the University using the form at:(http://www.busfin.uga.edu/forms/entertainment.pdf). In the event that an employee expends funds in excess of the authorized per diem, the amount spent in excess is the responsibility of the employee making such expenditure.

While the per diem limits also apply to group events where food is purchased on a group basis (pizza, etc.), departments are not required to document the actual numbers or names of participants. However, departments must provide documentation to substantiate how the appropriate per diem guidelines were followed.

Section 4.0 Food for Employees

Employees include temporary, part-time, and full-time staff, faculty, administrators, resident assistants (RAs), graduate assistants, and other student workers. The employee’s participation must be required, essential, and in furtherance of an official institutional program.

In general, employees in travel status are subject to the state travel regulations (http://askuga.uga.edu/default.asp?SID=&Lang=1&SID=&Lang=&id=1619&Lang=1&SID=) and employees in a group meal status (see sections 4.1 and 4.2 of this policy) are subject to those applicable policies.  Otherwise, the following guidelines should be applied:

• Safety. Water or other hydration products may be purchased insofar as these products are required by OSHA or are necessary to prevent serious harm to an employee.
• Academic Programs, Student Events, and Educational or Business Meetings Involving Predominantly Non-Employees. When conducting a program, event or meeting involving predominantly non-employees (of any institution of the Board of Regents) where attendance by the employee is essential and in furtherance of an official institutional program, and the meal is an integral part of the meeting, an employee can partake in the meal and be reimbursed for his or her actual meal cost up to the per diem limits established by state travel policy. An employee may not be paid a reimbursement unless the employee actually incurs a cost.

Specific instances of allowable reimbursement include: 

Student recruiting. An employee may be reimbursed for food purchased at a meeting whose primary purpose is the recruitment of an individual to attend the institution. The employee’s participation in this meeting should be required as part of his or her job performance, and the institution should maintain control over the numbers of individuals necessary to attend a given recruitment meeting. 

A prior/existing contractual or grant arrangement, which must be quid pro quo, not gratuitous. For example, an external organization may award funds to the institution with the specific proviso that these funds may be used for employee food expenses as it relates to grant activities or meetings. In this instance, food could be purchased within the grant guidelines.

However, federal grant funds should NOT be used to purchase food for employees unless the federal grantor agency, in writing, authorizes this expenditure and certifies that this waiver is not a violation of applicable federal regulations.

The business purpose should be clearly stated and should accompany any invoices submitted for payment. Additionally, the state travel policy per diem limits apply to food purchased for consumption by employees participating in a program, event, or meeting or otherwise reimbursed to the employee by the institution. Per Diem limits apply only to food purchased with institutional funds. Food purchased by outside organizations does not fall under the scope of this policy. However, employees must comply with the provisions of the Gratuity policy (http://askuga.uga.edu/default.asp?SID=&Lang=1&SID=&Lang=&id=972&Lang=1&SID=) as it pertains to receiving gifts.

Section 4.1 UGA Employee Group Meals

This policy is in accordance with Board of Regents Procedures and the policy of the State Accounting Office and Office of Planning and Budget. This policy provides guidance regarding situations in which an employer might purchase meals for a group of employees when such employees may not be on travel status or otherwise eligible for payment of meals.

Under certain infrequent circumstances, employees may be required to remain at the work site during mealtime. Those circumstances include emergency situations, such as natural disasters and crisis operations, but may also include intra-departmental meetings or training sessions, where the meeting or training session continues during the meal and the employees are not permitted to leave the premises of the meeting site.

Under these similar circumstances, organizations may purchase meals for the affected employees using the following standards:

• Group meals should be held only to facilitate the effective and efficient operation of the departments involved. For example, it may be that scheduling an intra-departmental meeting or training session is the most effective and efficient use of employees’ time given teaching schedules, other meeting commitments, etc. In this instance, requiring employee to participate in a meeting which continues during the lunch hour may be the best means available to get the required participants in the same place for the period of time required.
• Group meals should only be provided in those instances where the meeting lasts for at least four (4) hours. A meeting for less than four hours could generally be scheduled prior to or after a normal meal without significantly impacting employees on different work schedules.
• Group meals held at the start and/or finish of a meeting are not eligible for payment under this policy. Purchase of a group meal is authorized solely as a convenience to the employer and in those instances where employees may not leave for a normal meal due to the time constraints associated with the meeting or training session. Those events not starting until the normal meal time should be delayed until after the normal meal time or employees may bring employee-purchased food (“brown-bag”) to the meeting.
• Group meals for a “lunch meeting”, in which the meal and the meeting are one and the same, are prohibited for payment under this policy.
• Such expenditures are limited to the purchase of meals only (this does not include snacks), and meal limits outlined in the Statewide Travel Regulations must be adhered to. Set up and delivery costs associated with the group meal shall not be included in the meal limit calculation.
• Purchase of such meals must be approved by the Dean or Vice President prior to the date of the event (for non-emergency situations). Prior approval must include:
  • The purpose of the meeting or event,
  • A formal written agenda including session times,
  • A list of attendees (UGA and non-UGA personnel) with their associated departments/entities, and
  • The expected cost of the meal per person.

Requests for approval of group meals should utilize the “Employee Group Meals” Request Form available at:  http://www.busfin.uga.edu/forms/group_meals.pdf and have attached the required documentation as noted above. Employee Group Meal expenditures will be charged to object code 72770.  All of the documents that are required for the prior approval process should be submitted with the payment request along with signed approval. All documents will be retained for audit purposes.  These expenditures are subject to special audit scrutiny, to insure that uses of funds for this purpose are infrequent rather than routine.

Section 4.2 Employee Group Meals Involving Multiple Institutions

Efficient and effective administration of University System of Georgia (USG) Institutions may require instances when various groups of university officials such as Presidents, Executive officers, or employees representing functional areas such as student activities, academic affairs, business affairs, etc. may be required to meet. The purpose of these meetings must support the official business purpose of the institutions represented. These events are often sponsored by a USG institution or by the University System Office and are supported through the use of registration fees charged to participants. Registration fees may be reimbursed by the participant’s home institution and may be used for expenses such as speaker fees, room rentals, equipment charges, food for meals and breaks, and items directly related to the purpose of the meeting. For policy and procedure relating to Group Meals Involving Multiple Institutions, please reference the Board of Regents Procedure Manual, Section 19.7.2 at: http://www.usg.edu/fiscal_affairs/bpm_acct/bpm-sect19.pdf.

Section 5.0 Food Purchased for Conferences and Workshops

UGA units hosting and coordinating conferences and workshops collect registration fees that may be used for food for meals and breaks which are an official and integral component of the conference or workshop. In general, departments should contract with a caterer to provide the necessary meals and breaks. Non-catered food purchases (i.e. individual items purchased from grocery stores) must be accompanied by a written justification as to why the food was purchased outside of a catering arrangement. This justification is necessary to substantiate that there has not been personal use of food purchased. As noted in section 1.0 of this policy, employees with responsibility for administering funds should ensure that funds are spent only for legitimate public purposes and not for the personal benefit of the employee or other individuals.

Per Board of Regents policy, institutional funds, which include conference and workshop accounts, cannot pay for alcohol. In those instances where alcohol is needed at a reception or dinner associated with a conference or workshop, a cash bar should be utilized. Registration fees may be used to pay for bartender services.

Section 6.0 Meals Purchased for Business Related Entertainment
University related entertainment charges/meals purchased for business related entertainment include business related breakfast, lunch or dinner, catered business-related meeting, fund-raising or alumni event, etc. Alcohol cannot be purchased using any University account. Any purchases of alcohol must be made directly from a Foundation account.

Units should not expend funds for business related entertainment from University restricted accounts which are specifically supported by the UGA Foundation or the Arch Foundation, but instead, should process payments directly with the appropriate Foundation.

Business related entertainment charges may only be processed on the UGA accounts listed below:

• UGARF Indirect Cost Return Accounts (900 Accounts),
• Sponsored accounts which specifically allow for business related entertainment,
• Royalty Revenue or Residual Balance Accounts (950 Accounts), and
• Other discretionary restricted accounts.

Invoices or receipts submitted for reimbursement, for alcohol cannot be paid through a UGA account. Such expenses should be paid directly from Foundation accounts.

All purchases should be submitted for reimbursement using a check request form pertinent to either UGA or a Foundation, as appropriate under this policy. All requests submitted on a UGA account must include the original/scanned receipt and the UGA Reimbursement of University Related Entertainment form available at: http://www.busfin.uga.edu/forms/entertainment.pdf.  For payments made directly from Foundation accounts, the following is required:

• Entertainment form with explanation of the business purpose, names and business relationships of people whose meals are being paid;
• Foundation check request and original receipts.
• For further information, please see Section VIII.D.2 of Foundation policies at www.uga.edu/archfoundation and www.ugafoundation.org.

For payments made on Sponsored accounts:

As the University must comply with federal cost accounting standards which require consistency in the treatment of costs, the University typically cannot use sponsored funds for business related entertainment since University state accounts do not specifically allow the purchase of business related entertainment. Therefore, discretion must be exercised when charging such expenses to sponsored restricted accounts. As such, the cost of purchased meals or food within fifty (50) miles of the University area will normally not be allowed as a direct charge to a sponsored restricted account because the UGA employee or trainee is not "traveling" and the cost is normally considered a personal expense. See below for special circumstances.

In special situations such as all day seminars or meetings when a food, beverage, or meal cost meets the three criteria of allowable, allocable and reasonable to the specified sponsored project, the faculty member may provide written justification of the business purpose of the expenditures and how they relate to the specific sponsored project including purpose of the meeting, list of attendees, a formal written agenda, and the beginning and end times of the meeting. To be allowable, the following items must be provided:

1. Meal or food expenses must be included in the budget and approved by the sponsor.
2. An agenda must be provided with the request
3. Must specify each participant on the entertainment form
4. Must be attended by non-UGA personnel. Meetings comprised of all UGA personnel are more often designated as a staff meeting where meals are not allowable. (Reference section 4.1 for information on UGA Employee Group Meals).

Additional guidance is provided by the following Federal Sponsors at the following web sites:

http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part12.htm#Meals

http://grants.nih.gov/grants/policy/nihgps_2003/NIHGPS_Part12.htm#Travel_222

Examples of allowable food charges:

• Lunch and refreshments provided for periodic all-day meeting of collaborators on a program project (with formal agenda and participants from different locations).
• A post-doc being recruited to fill an open position on a research grant. His/Her meal may be charged to the grant since they are on travel status.

Examples of unallowable food charges:
(While these expenses may not be allowable on sponsored restricted accounts, they may be reimbursed from discretionary type restricted accounts or directly from the Foundation.)

• Lab personnel meet weekly to discuss progress on the grant.
• PI has lunch/dinner with a colleague and discusses research

The National Science Foundation (NSF) GPG, Chapter II states:

(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.

Section 7.0 Documentation Requirements and Enforcement of Per Diem Limits at Group Events

Nothing in this policy shall be construed as requiring a department to provide food to employees for events or to reimburse employees for participation in events. When circumstances warrant the provision of funds for allowable food purchases, departments should follow normal procedures to ensure that funds for employee food are not spent without the appropriate supervisory review and approval.

Check requests must include original/scanned receipts and adequate documentation associated with the event and/or purchase. For example, food purchased for a group event should include a flyer, email, agenda, or other documentation substantiating that the event was an official event. Food purchased at a restaurant or on a per person basis should include a list of participants using the Reimbursement of University Related Entertainment form at: http://www.busfin.uga.edu/forms/entertainment.pdf.

In the event that an employee expends funds in excess of the authorized state travel policy per diem, then the amount spent in excess should be covered/reimbursed by the employee making that expenditure.

While the per diem limits also apply to group events where food is purchased on a group basis (pizza parties, etc.), departments are not required to document the actual numbers or names of participants. However, departments expending institutional funds for those events should certify on the supporting documentation that the appropriate per diem limits were followed.

Please refer to the following link to view Appendix A - Reference Chart for Food Purchases