RSA Town Hall Meeting

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RSA Town Hall Meeting

• Thursday, October 15, 2009
• 130-330 pm
• HSW-300(Parnassus) w/ live broadcast to Rock Hall
  102 (Mission Bay) and Fresno Campus

Controllers Office
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CAS Guidelines on the Allowability of Meals on
Sponsored Project Awards
Controllers Office

• Debbie Caulfield, Manager, Compliance, Internal
  Controls

October 15, 2009
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2 CFR Part 22032. Meals and Conferences(Also
known as OMB A-21)

• Costs of meetings and conferences, the primary
  purpose of which is the dissemination of
  technical information, are allowable. This
  includes costs of meals, transportation, rental
  of facilities, speakers fees, and other items
  incidental to such meetings or conferences.
• AT UCSF, the meal guidance has now been
  formalized.

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CAS Appendix C Allowability of Meals on
Sponsored Awards

• When charging meals (other than those allowed
  under award terms for patients or subject
  participants) the following principles must be
  adhered to at UCSF

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Meals on Sponsored Awards(continued)

• The cost of meals provided for meetings for the
  express purpose of the dissemination of
  scientific project-related information must be
• included in the proposal budget and budget
  justification,
• and subsequently be approved by the awarding
  agency.
• Note If an agency disallows meals during the
  proposal review process, then the costs should
  not be charged to the award.

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Meals on Sponsored Awards(continued)

• Meals are not allowable for routine internal
  business meetings such as scientific and/or
  administrative meetings (weekly/monthly)

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Meals on Sponsored Awards(Continued)

• All meal charges must follow basic principles of
  reasonableness. Accordingly, meals must not
  exceed the then-current reimbursable cost of the
  applicable meal under the UCSF Travel Policy at
  the time of the meeting, and the items expensed
  must be allowable under federal cost principles.
• These guidelines must be consistently applied on
  all awards at UCSF, federally funded or
  otherwise.

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Meals on Sponsored Awards(continued)

• In rare instances, it may be allowable to hold an
  emergency project meeting and charge a sponsored
  project award for meals.

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Meals on Sponsored Awards(continued)

• For example, meals may be allowable in the case
  of an emergency meeting for the purpose of
  training nurses/coordinators working on a
  clinical study on the adverse impacts of a drug
  under study, or on a project where there are
  imminent human safety concerns that must be
  addressed.

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Meals on Sponsored Awards(continued)

• In these rare instances, you may be able to
  utilize rebudgeting authority to accommodate the
  cost provided there are no restrictions
  applicable to the particular award.
• Proper documentation of the reason for the
  emergency meeting should be maintained for audit
  purposes.

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Meals on Sponsored Awards(continued)

• Meals are allowable when project staff travel to
  outside scientific conferences (such as an annual
  AIDS Conference) as approved under grant terms
  and in conformance with the UCSF Travel Policy.

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Meals on Sponsored Awards(continued)

• Allowable cost for conference travel include the
  cost of meals, transportation, registration fees,
  or other items incidental to such travel.
• However, under federal regulations, travel costs
  are only allowable when the site is a minimum
  driving distance of 50 miles, by the most direct
  route, from an employees office/permanent duty
  station.

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Meals on Sponsored Awards(Continued)

• Examples of Unallowable Meal Expenses
• 1. Journal Club meetings
• 2. Routine meetings, such as weekly/monthly staff
  meetings.
• 3. Entertainment such as parties or social
  gatherings.
• 4. Meal expenses unallowable under UCSF Travel
  Policy such as alcohol.

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Meals on Sponsored Awards(Continued)

• Examples of Meal Expenses which may be allowable
  (always include in the proposal!)
• 1. An annual all day meeting of scientists,
  including subcontractor, scientific staff, to
  disseminate scientific results produced under a
  project.
• 2. Meal costs for project staff and outside site
  visitors for a site visit requested by a federal
  agency.
• 3. A meeting held for the purpose of training
  clinical coordinators/nurses on a particular
  clinical protocol to be performed under a
  multicenter research project.

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Question 1.

• My PI would like to charge her federal grant for
  pizza and beer. She states that these
  refreshments will be for a monthly meeting of
  postdocs working on the award. Is this allowable
  under the policy for charging meals to Sponsored
  Project Awards?

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Answer 1.

• No.
• This would not be an allowable charge as the cost
  of meals or refreshments is not allowable for
  routine meetings such as weekly/monthly
  scientific or administrative staff meetings.
• Additionally, the cost of alcoholic beverages for
  entertainment purposes is never allowable on
  federal grants under A-21. When allowable, the
  costs of alcoholic beverages must be approved in
  the budget upon submission and review of the
  proposal and must play a role in the scientific
  research.

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Question 2.

• My PI has decided that he would like to charge
  the cost of meals for an annual all day meeting
  of project scientists, whereby, information on
  the most recent findings on his NIH project will
  be disseminated. His NIH grant is currently in
  year 02 of the Project Period but I do not see
  this on the original budget proposal. Can this
  charge be included?

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Answer 2.

• No.
• This charge would only be allowable if the PI
  included this request in his proposal budget and
  budget justification, and it was approved by the
  sponsoring agency at the time of the award.

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Question 3.

• An emergency has come up in which there has been
  an adverse reaction to a drug that is under study
  under an approved protocol funded under a
  sponsored project award.

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Question 3 (Continued.)

• We will need to hold a special training meeting
  for project nurses and clinicians who are
  providing services either directly on the grants,
  or under sub-awards which are paid under the
  grant award, in order to provide specialized
  training in order to minimize adverse drug
  reactions for human subjects under study. Is
  this an allowable charge?

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Answer 3.

• Yes.
• In rare cases it may be allowable to hold an
  emergency meeting and charge a sponsored project
  award for meals, provided that the principles
  under UCSF CAS Appendix C Allowability of Meals
  on Sponsored Awards are adhered to. When there is
  an imminent human safety concern that must be
  addressed, meals for a training meeting may be
  allowable. In some cases, such as on an NIH
  award, rebudgeting authority may be used to
  accommodate the cost.

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Answer 3 - Continued

• NOTE The grant rules for the particular
  sponsored project award should always be reviewed
  to determine whether or not prior approval from
  the granting agency is required.
• Proper documentation of the reason for the
  emergency meeting should be maintained for audit
  purposes.

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Question 4.

• My PI has an award from the American Heart
  Association. Since this is not considered
  federal funding and the A-21 rules do not apply,
  we will be having a special dinner this week for
  all project staff working on the award to
  celebrate the receipt of supplemental funding on
  this award. The PI also states that she will be
  talking about recent findings from the grant
  award on heart disease and French fries at the
  dinner. Is the cost of the meals allowable?

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Answer 4.

• No.
• Celebrations of supplemental funding would not be
  considered a reasonable use of sponsored project
  funds.
• Additionally, meals are only allowable if they
  are requested in a grant proposal and approved by
  the awarding agency.
• Note that the UCSF CAS Appendix C Allowability
  of Meals on Sponsored Awards must be applied
  consistently on all sponsored project awards,
  regardless of whether the fund source is federal,
  non-profit, or from other sources.

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Question 5

• A PI is traveling to a local conference (20 miles
  from her campus office) to attend a conference
  which has been approved under NIH grant award
  terms. Can the cost of travel and meals be
  charged to the award?

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Answer 5.

• No.
• Only the cost of the conference itself
  (registration) can be charged to the award, as
  under federal regulations travel costs are only
  allowable when the site is a minimum of 50 miles,
  by the most direct route, from an employees
  office/permanent duty station. Therefore, meals
  (unless already covered in the conference fee),
  transportation, and other items incidental to the
  travel are not allowable.

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Further Information

• Information on UCSF Cost Accounting Standards
  Guidelines in on the Controllers Office Website
  at
• www.acctg.ucsf.edu/extramural_funds/policies/
• This information includes
• UCSF Cost Accounting Standards Guidelines
• Charging Practices for Sponsored Projects
• Appendix A Unallowable Costs
• Appendix B Frequently Asked Questions
• Appendix C Allowability of Meals on Sponsored
  Project Awards

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Whom to Call?

• Debbie Caulfield, Compliance Manager
• [phone] Debbie.Caulfield_at_ucsf.edu

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Any Questions?