(Last Modified on December 20, 2019)

The purpose of this section is to clarify those instances when food may be purchased for consumption by students, potential students, volunteers and employees using institutional funds. This policy addresses instances when food may be purchased or food expenses may be reimbursed that are not otherwise addressed in BPM Sections 4.0 and 19.7.

Food includes meals, beverages, snacks, etc., but specifically excludes alcohol as an allowable food expense. The purchase of food for resale in connection with the auxiliary operations of an institution is allowable, and is not addressed in this policy.

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.

Note: 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.

Institutional funds include all funds to which an institution holds title, such as student fees, auxiliary revenues, state appropriated funds, etc. Purchases of food using institutional funds should still be recorded using the proper account as designated in BPM Section 2.0 and should be made using the appropriate fund source as outlined below. This policy does not address use of affiliated organization funds to provide food to employees, students, or volunteers. Also note that this policy does not address any potential tax implications associated with the purchase and consumption of food for individuals.

The chart on the following pages outlines the funding sources that may be used when making food purchases and provides some broad examples of allowable purchases.

Note: This chart is intended to provide guidance on allowable food purchases. This chart should be used in conjunction with the relevant BPM sections referenced. Please note, however, that the method of payment via P-Cards is only allowable as described in BPM Section 3.3.1.2.

The funding source should generally be matched to the supported program and participants. For example, student activity fees might be used to purchase water for a volunteer event sponsored by a student group. In this instance, students, volunteers, and employees would presumably consume the water. However, student activity fees should not be used to purchase water for employees conducting outside activities as part of their normal job, e.g., groundskeepers. Please refer to BPM Section 2.0 for more information on the appropriate uses of various fund sources.

Activity	Allowable Participants	Potential Funding Source(s)	Notes
Sanctioned Student Events (excluding athletic events)	• Students • Volunteers • Employees whose participation is required	• Custodial Funds if authorized by fund agreement • Auxiliary Funds • Endowment funds where authorized by fund agreement • Grants or Contract Funds as authorized by fund provider • Student Activity Fees	• See BPM Sections 19.8.1, 19.8.2, and 19.8.3 • Per diem limits apply
Athletic Events & Recruiting	• Students • Potential students & parents/guardians • Volunteers • Employees whose participation is required	• Athletic Auxiliary Funds • Endowment funds where authorized by fund agreement • Student Athletic Fees	• See BPM Sections 19.8.1, 19.8.2, and 19.8.3 • Per diem limits apply • Applicable athletic conference rules shall also be followed
Classroom & Academic Programs	• Students • Employees whose participation is required	• Sales & Service Revenue • State appropriated funds for use only in for credit courses • Tuition & Fee Revenue	• See BPM Sections 19.8.1 and 19.8.2
Student Recruiting Events	• Students • Potential students & parents/guardians • Volunteers • Employees whose participation is required	• Auxiliary Funds • Student Activity Fees	• See BPM Sections 19.8.1, 19.8.2, and 19.8.3 • Per diem limits apply
Volunteer Events	• Students • Volunteers • Employees whose participation is required	• Non-appropriated funds, Custodial funds if allowed by fund agreement • Recognized “executive” program tuition revenue may be used to purchase food for volunteer events	• See BPM Sections 19.8.2 and 19.8.3 • Per diem limits apply • Volunteer events with sole purpose of recognition or appreciation for past services may not be paid using any fund source except for Foundation funds
Safety Products	• Students • Volunteers • Employees at risk due to environmental or workplace conditions	• Auxiliary funds • Sales and service revenue • State appropriated funds • Student Activity Fees • Tuition & Fee Revenue	• See BPM Section 19.8.3 • Expenses should be paid using the departmental budget of the assigned employees
Educational or Business Meetings	• Students • Volunteers • Employees whose participation is required	• Auxiliary funds • Sales and service revenue • State appropriated funds	• See BPM Section 19.8.3 • Meeting must consist of predominantly non-employees • Per diem limits apply

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. The misuse of institutional funds may result in both employment termination and various civil and criminal penalties.

19.8.1 Food for Students

(Last Modified on July 3, 2019)

Students include individuals enrolled to take classes at an institution, including students enrolled in Continuing Education, and individuals being recruited as potential students.

Institutional funds may be used to purchase food for students at sanctioned student events. Sanctioned student events include events and travel sponsored by recognized student groups, athletic team events, and other campus events open to the general student body and designed to further the development and education of students. Additionally, food may be purchased for a class in those instances where food is an integral part of the instructional methodology. For example, food could be purchased for students in a food appreciation or cooking class offered by a Continuing Education unit. While not necessarily in a travel status, the per diem limits in BPM Section 4.4 should apply to food purchased for consumption by students participating in sanctioned student events.

Potential students and their guardians may be provided food at an event designed to encourage the student to attend the institution. Food for athletic recruits may be purchased subject to the rules and regulations of the athletic conference of which the institution is a member.

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19.8.2 Food for Volunteers

(Last Modified on July 3, 2019)

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 under this policy. While not necessarily in a travel status, the per diem limits in BPM Section 4.4 should apply to food purchased for volunteers.

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19.8.3 Food for Employees

(Last Modified on July 3, 2019)

Employees include temporary, part-time, and full-time staff, faculty, administrators, Resident Assistants (RAs), student assistants, and other student workers.

Employees in a travel status are subject to the employee travel regulations as contained in BPM Sections 4.0. Employees in a group meal status are subject to the guidance contained in BPM Section 19.7. However, there are instances not addressed in BPM Sections 4.0 and 19.7 when food may be purchased for employees or employees may be reimbursed for food purchased. Those instances shall be addressed using the following general categories: Safety, and Academic Programs, Student Events, and Educational or Business Meetings Involving Predominantly Non-Employees.

1. 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.

2. 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 in BPM Section 4.4. An employee may not be paid a reimbursement unless the employee actually incurs a cost.

Clarification of specific instances of allowable reimbursement include:

1. Athletic 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 strictly control the numbers of individuals who may receive reimbursement for food purchased at a given recruitment meeting.

2. 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.

Business purpose should be clearly indicated on any invoices submitted for payment. Additionally, the per diem limits of BPM Section 4.4 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 Section 8.2.13 of the BoR Policy Manual as it pertains to receiving gifts.

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19.8.4 Documentation Requirements and Enforcement of Per Diem Limits at Group Events

(Last Modified on July 3, 2019)

Nothing in this policy shall be construed as requiring an institution to provide food to employees for events or to reimburse employees for participation in events. Institutions should establish the appropriate procedures to ensure that funds for employee food are not spent without the appropriate supervisory review and approval.

Appropriate procedures shall include 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.

In the event that an employee expends funds in excess of the authorized per diem contained in BPM Section 4.4, then the amount spent in excess should be 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.), institutions are not required to document the actual numbers or names of participants. However, institutions should require employees expending institutional funds for those events to certify that the appropriate per diem limits were followed.

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