Hosting Conferences/Meetings by Rice University Sponsored Programs
This document is intended to serve as formal guidance for Rice University regarding the use of funds from sponsored programs for conference costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored programs are allowable, reasonable, and allocable to a particular sponsored award, as defined by U.S. Office of Management and Budget’s Uniform Guidance (2 CFR §200.403-405); are in compliance with sponsor requirements; and are administered consistently across the campus for all sponsored programs. Procedural statements support the Rice University Cost Principles Procedure by providing definitions and processes for meeting those standards in like circumstances.
Conferences and conference costs are defined and described as allowable in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR §200.432 as:
A conference is defined as a meeting, retreat, seminar, symposium, workshop or event whose primary purpose is the dissemination of technical information beyond the non-Federal entity (Rice University) and is necessary and reasonable for successful performance under the Federal award.
When the non-Federal entity (Rice University) is a sponsor or host of a conference or meeting, the following items may be charged to the sponsored program as allowable costs: rental of facilities, speakers’ fees, costs of meals and refreshments, local transportation, and other items incidental to such conferences, unless further restricted by the terms and conditions of the awarding sponsor. Some sponsors provide conference funding in the form of participant support. 2 CFR §200.432 allows for the awarding sponsor to authorize exceptions where appropriate for programs including Indian tribes, children, and the elderly.
The costs of all meals must be reasonable for the circumstances. Breakfast and lunch costs should not exceed $30 per person and dinner costs should not exceed $75 per person. These limits are established in the Travel, Business Meeting, and Entertainment Procedures of Rice University.
Appropriate Documentation for Allowable Costs
In order to be compliant with the Uniform Guidance definition of a conference, documentation must be maintained by the department and should substantiate that the primary purpose was to disseminate technical information beyond Rice University.
Documentation should include, but is not limited to, the following:
- A detailed explanation of the primary purpose of the conference, which must be the dissemination of technical information beyond the Rice University and must have a programmatic purpose that is necessary and reasonable to the successful performance of the award.
- A copy of the conference agenda to substantiate the primary purpose.
- A list of all registered attendees, both university and non-university.
- If the conference was a public event not requiring registration, proof of advertising beyond Rice University.
- Actual cost per meal for each guest.
- The Business Meals and Entertainment Expenses form should be used for documentation.
- Costs associated with intra-campus and interdepartmental meetings are unallowable as a conference cost.
- Uniform Guidance defines conferences as having a primary purpose of disseminating technical information beyond the non-federal entity (Rice University and the related program team, even if located at different institutions or campuses).
- Lunch meetings with collaborators and departmental retreats are unallowable as a conference cost, as they do not satisfy the definition of disseminating technical information beyond the Rice University and the related program team, even if located at different institutions.
- Alcohol costs are unallowable when paid for through sponsored program funding.
- Meal costs in excess of established meal allowances are unallowable.
- Locally available dependent-care resources for travel to conferences is allowed only if there is an institution-wide Procedure that these costs are allowed. The Rice University does not currently have a Procedure that provides this benefit to faculty and staff. Therefore, it is not allowable to charge dependent care costs to a sponsored program.
Section 2 CFR 200.403(c) of the Uniform Guidance requires that we apply our policies and procedures uniformly to both federally-financed and other activities of the university. Therefore, the Rice University’ Cost Principles Procedure, and related procedural statements, are also applicable to non-Federal awards. The basic criteria for charging conference costs are similar for non-Federal sponsored programs, but it is also important to be familiar with the particular requirements or restrictions of each non-Federal sponsor. When allowed by the non-Federal sponsor, a written justification for the inclusion of conference costs should be provided in order to explain why these are necessary to fulfill the objective of the program, and to ensure that the cost directly benefits the program being charged, even when the non-Federal sponsor may follow more flexible spending guidelines.
The conference cost should be identified in the proposal budget justification and justified as to why it is necessary and allocable to the performance of the award. Inclusion in the budget justification is intended to enable the sponsor to review and concur with the need for the cost. Written justification and/or approval is meant to prevent questions regarding the allowability of costs in the event of an audit.
After an Award is Funded
In the event that an unbudgeted conference cost is required after an award is funded, the Principle Investigator should review proposed conference costs for allowability and reasonableness and be able to explain the benefit of this cost. The Principle Investigator should then work with SPARC to obtain prior approval from the awarding sponsor. The written sponsor approval as well as the justification explaining the purpose and benefit of the conference to the specific program will be retained in the file for the award in Cayuse. Supporting documentation should include the items listed in the Allowable Costs section above and should be retained by the department for future reference should the expenditure be questioned at a later date.
If there are significant changes to the proposed conference between proposal and implementation, the costs may become unallowable, the conference costs will need to be re-reviewed by the Research Accountant, and additional justification will be required. Examples of what might constitute a significant change include changes to the purpose or scope of the conference, or a change to the composition or numbers in the attendee list.