M&E Policy

Think of entertainment expenses as business-driven hospitality expenses (instead of amusement-related) -this helps to make sense of the entertainment policy outlined in HBP 9.1.1. Below are key components of that policy.

Entertainment expenses should support the institutional mission and MUST serve a business purpose. Here's a list of the types of purposes UT identifies:

1. Recognition or promotion of achievement, scholarship, and/or service to the institution
2. Promotion or communication of intellectual ideas and/or exchange of administrative and operational information on the institution’s programs or activities
3. Support of institution-sponsored student events and activities
4. Recruitment of students, faculty, staff 
5. Unit or department morale building events (does not include individual awards) 
6. Assistance to The University of Texas Regents, accrediting agencies, officials from other institutions, etc. 
7. Support of a program of continuing education

 

The above purposes are further split into two types of events:

A. Official Occassions - think of these as events with departmental or college backing.

Receptions, luncheons, dinners, or similar events sponsored and funded by The University of Texas at Austin and often hosted by an administrative officer. These functions are normally associated with special programs, university guests, faculty, and staff recruitment. Examples include conferences, workshops, seminars, development events (donor receptions, fundraising activities, etc.), planned retreats, staff meetings, unit or department morale building events, and other similar activities.

B. Administrative/Business Meetings - these are the 'less arranged' instances on a more local level.

Meetings that involve two or more people, must include a university employee, are agenda driven, and directly concern university business. Business meeting expenses may be reimbursed if the meal or light refreshment is an integral part of the meeting (integral in this case means essential due to circumstances), not a matter of personal convenience, the meeting time encompasses a regular meal time and could not otherwise be scheduled during regular working hours. University funds cannot be used for social lunches between two or more university employees.

KEY CONCEPTS

Sticking with research administration and what's typical, the more local level type of meetings tend to be the ones that involve faculty members, students and university guests who meet for either faculty recruitment purposes, or research discussions and similar agendas.

Business Purpose #4 above: faculty recruitment, falls under A. Official Occasions. These types of occassions should be arranged in conjunction with department/unit leadership. Some depts/units set internal recruitment policy (that also conforms with CoLA policy). Consult dept/unit to confirm requirements.

Business Purpose #2, exchange of intellectual ideas and information, this one falls under B. Administrative / Business Meetings and occurs more often than other types. This includes research-related meetings/meals.

• The idea of having meals legislated throws some folks off, and often because they forget about what drives allowability of meals/entertainment expenses in the first place: the business purpose.
  
  This can't be emphasized enough: The main driver is the business reason for the meeting, and the meal is part of the meeting only because the meal time is/was the only time the meeting could take place. A meal is added to a meeting, as opposed to adding a meeting to a meal. <-- this is a helpful phrase for reminding faculty.
   

The university furnishes a comprehensive, regularly updated chart that serves as a matrix for types of costs associated with the entertainment policy and traces to the sources of policy for each type.

CoLA Business Affairs keeps several wiki pages devoted to CoLA Entertainment policy. They address a wide variety of scenarios. Below are sections pulled from CoLA's entertainment policy as it applies to research adminstration.

• Entertainment expenses involving only UT employees (faculty & staff) and for special/infrequent occasions, which may involve both employees and student employees (both graduate and undergrad): Should not exceed $35.00 per-person (including food, beverage, tax, and gratuity; tips/gratuity are reimbursable up to 20% of the pre-tax subtotal); frequency of special gatherings involving food/entertainment expenses should be limited to no more than three times yearly (e.g., start-of-year, holidays, end-of-year).
   
• Requests exceeding $1,000.00 in total cost must first be preapproved by the Assistant Dean for Finance & Administration, or the College Dean, when the Assistant Dean is not available.
   
• Events involving more than one vendor: Processing vendors on separate requests to avoid the pre-approval threshold is not allowable. All vendors associated with an event are to be represented on a single Official Occasion Entertainment Form to capture the cost of the entire event.
   
• Regularly recurring meetings, including faculty and staff meetings, should not include food/beverage.
   
• Generally, alcoholic beverages cannot be served on property and in buildings owned or controlled by The University of Texas System or UT Austin. See Board of Regents’ Rule 80102 for additional details.
   
• Alcohol expenses at dinner are reimbursable, if the meeting or event is for recruitment or a developmental purpose and donors or distinguished guests are in attendance.
   
• Alcohol will only be reimbursed up to 50% of the bill. Alcohol costs in excess of 50% of the bill will not be paid using UT funds.
   
• Alcohol is not reimbursable for business meetings conducted during breakfast or lunch.
   
• Companions: Reimbursements for meals are not permitted for companions of University employees, unless it is for a developmental related event and the donor/distinguished guest also brings a companion.
   
• Meals while traveling: When a university employee is in travel status and incurs costs for UT business-purpose meals involving more than one person, that meal cost converts into an entertainment expense and is processed in the same way that other entertainment expenses are processed - with an itemized receipt that shows proof of individual payment, number of guests, date, time, location, and other identifying details. 
  • In such cases, total per diem claimed for that travel status day should be prorated to reflect only the meals incured that do not include the entertainment meal.

Commonly found abbreviations for entertainment costs among sponsored projects are:

• E&I (Entertainment & Incidentals)
• M&E (Meals & Entertainment)
• M&IE (Meals & Incidental Expenditures)
  
  -None of which should be confused with per diem, which is a travel-specific type of cost that involves low-level travel-status expenses and food-related costs incurred during official travel status
  (see the Travel section for more on this).
   

By default (though exceptions do exist), the university extends these regulations to cover all sponsored awards, including from non-federal entities. 

§ 200.438 Entertainment costs

'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.'

• Entertainment costs that meet the definition of programmatic purpose are cases where, for example, an agreement has an outreach component to it, or specific events that have been included within the description of the award, such as training retreats or other similar events.
   
• There have been instances where a federally sponsored award has included a budget justification that mentioned entertainment expenses that are typically not allowable according to that sponsor's own guidelines.
   
  • The included entertainment expenditures still have to conform to the agency/sponsor rules, and in such instances, the budget justification does not expressly and automatically create exceptions to the agency/sponsor policy.
     
    • What we mean by this is: If the description of the entertainment costs doesn't comply with the exceptions the sponsor allows, then it falls into the 'oops' category
       
      • In such cases, it is recommended to write to the sponsor for additional clarification --sometimes something unallowable slips by, but that doesn't make it allowable. And your sponsor contact will likely lack the authority to grant an exception that doesn't meet the published exception criteria and essentially goes against their policy. <-- ping us if you need to talk through this, we know it's a bit... hairy.

 

• For non-federal sponsored awards, allowability of entertainment-associated costs needs to be included within the project or budget narrative, or written sponsor approval must be obtained to allow charges on the grant or award.
   

Disallowance of entertaiment expenses on a sponsored award does not impact the allowability of per diem costs associated with travel during university business that is included with sponsored research activity. These are very different things, despite often having food in common.

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