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Office of Sponsored Programs (OSP)


DHHS Guidance on Food as an Unallowable Expense

Posted on February 8, 2012 at 10:05am

Dear Colleagues,


We are getting clarification on the new HHS mandates issued in January and have tried to summarize the policy. As always it does get confusing! We have also included an excerpt from the HHS Policy and the full Policy below.


·         The policy on food applies to grants, contracts and cooperative agreements.

·         No food can be purchased under a contract unless specifically allowed in writing by the contract officer

·         Food may not be purchased with HHS funds on conference grants. You would need to use program income from registration or UW or 3rd party cost sharing.

·         This policy does not further restrict paying for per diem costs of travel.

·         Routing purchase of food on grants and contracts may not be restricted but it is important to have approval from your grants officer so we recommend checking before you purchase food for meetings.



Lynne Chronister

Ted Mordhorst






2.2 Additional Exceptions and Clarifications

1.    Grants and Cooperative Agreements:  When a grantee conducts a conference as an ancillary effort under its grant or cooperative agreement, food-related costs may be considered allowable as prescribed in OMB Circular A-21 (cost principles applicable to educational institutions), OMB Circular A-122 (cost principles applicable to non-profits), HHS’ Awarding Agency Grants Administration Manual, and HHS’ Grants Policy Statement.  Such grants and cooperative agreements are not subject to the approval requirements below.  However, as a matter of Departmental policy, when the primary purpose of the grant or cooperative agreement is to conduct a conference, such as NIH’s Support for Conferences and Scientific Meetings R13/U13 grants and other similar grants, the requirements in Section 2.4 below apply.


Both OMB Circular A-21 and the HHS GPS and NIH GPS do allow reasonable expenditures for food for working lunches where grant related work is conducted.  One key thing auditors may look carefully at is the reasonableness of the expense in light of this new directive.


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