BE A FI$CAL $.T.A.R. Allowable Costs. Management/Oversight. Presenters: Ron Petracca , Senior Counsel, Office of General Counsel (OGC) Sean Barrett, Financial Management Analyst, SMPID Fiscal Unit. Conferences, Meetings and Travel Expenditures. AGENDA.
Ron Petracca, Senior Counsel, Office of General Counsel (OGC)
Sean Barrett, Financial Management Analyst, SMPID Fiscal Unit
Conferences, Meetings and Travel Expenditures
Audit of expenses at DOJ law conferences (September, 2011)
OMB Memo on “Eliminating Excess Conference Spending and Promoting Efficiency in Government” (September, 2011)
Audit of GSA conference (April, 2012)
OMB Memo on “Promoting Efficient Spending to Support Agency Operations” (May, 2012)
Congressional Oversight Requests
Deputy Secretary’s memo (June, 2011)
Use the “reasonable and necessary” standard – Is this necessary? Can I prove this?
Are there alternative, more cost-effective ways to accomplish your objectives without sacrificing quality (e.g., location, webinars, video conferencing)?
If a determination is made that it is reasonable and necessary to use appropriated funds for food (i.e., working lunch):
If specific statutory authority exists to use appropriated funds for expenses of attendance at meetings, food may be considered as a reasonable and necessary expense, if it meets the following criteria (Four-part test):
Communicate requirements to groups early and often, especially if food/drink were previously provided.
Is there a way to structure the location or agenda to make acquiring food and drink easier?
Are there more cost-effective or efficient alternatives (i.e., different location, webinars, video conferencing) to provide the information?
Is the meeting and/or food consistent with the grantee’s funding agreement (contract, grant, etc.)?”
What are the state per diem rules?
How would the participant acquire food/drink if the activity were not occurring?
Follow statutory and regulatory requirements in determining whether costs are reasonable and necessary
When asked, could the grantee provide documentation necessary to justify the expenditure- including exploration of alternatives?
A working lunch is an example of a cost for food that might be allowable under a federal grant if attendance at the lunch is needed to ensure the full participation by attendees in essential discussions and speeches concerning the purpose of the meeting/conference and achieving the goals and objectives of the project.
Do not assume that allowability in one state automatically means allowability in another. State laws and regulations often differ; unknown details also may differ and result in a different interpretation. In making decisions in your agency about the appropriateness of providing food, be sure you have employed all the relevant tests – reasonableness, necessity for full participation, achieving the goals and objectives of the project.
Our SRC routinely meets in settings where participants can easily access food/water during planned breaks. As part of our outreach plan we are looking to have our next meeting in a very rural part of the state where it might not be possible to find a meeting location with good access to outside food/water. In this instance can we provide food/water with federal funds?
The purchase of food/water with federal funds would be allowable in this situation, if in fact the barriers associated with the rural location proved to be unavoidable (at this time they are potential, not actual barriers).
Our commission holds community forums to garner input which we use when creating State Plans. These typically occur over dinner, and we are afraid that without providing dinner, the community won’t attend, which will diminish our ability to write an effective plan. To avoid this we provide full buffet style dinners to all who attend.
No. Although all the aspects listed above would indicate this as an allowable activity, the “full buffet style dinner” appears to be an unreasonable method to complete the activity. Dramatically scaling back the food could make this activity allowable
Our SILC provides coffee in the morning and cookies in the afternoon. We have done so for 15 years and our members have come to expect this. Can we continue?
No. No facts were presented to indicate that providing these amenities for member is necessary to achieve the mandate functions. Furthermore, these amenities may be covered in per diem costs, which are already paid to the member. We recommend assuring agendas or other plans are structured to allow members time to acquire food/drinks on their own.
Our annual VR staff meeting typically awards a trip to Hawaii to high performers. We strongly believe this benefits morale and rewards high performers.
No. A trip to Hawaii would be an unreasonably expensive method to achieve the goal of improving morale.
Don’t hesitate to ask questions or raise concerns/issues.
Grantees are expected to take proactive steps to justify allowability of expenses.
RSA staff is available to provide support and advice.
Recipients of federal funds are responsible for proactively justifying expenses.
We all must be responsible stewards of taxpayer dollars.
MEMORANDUM TO ED GRANTEES REGARDING THE USE OF GRANT FUNDS FOR CONFERENCES AND MEETINGS