I. Procedural Statement
This document is intended to serve as formal guidance for CU Boulder regarding the use of funds from sponsored projects for entertainment costs in like circumstances. The university is committed to ensuring costs incurred in support of sponsored research 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 research. Procedural statements support the CU Boulder Cost Principles Policy by providing definitions and processes for meeting those standards in like circumstances.
II. Definitions
Entertainment costs are defined in the U.S. Office of Management and Budget’s Uniform Guidance, 2 CFR 200.438 as:
Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities).
III. Procedures
A. Federal Awards
Under the guidelines imposed by the Uniform Guidance, entertainment costs are considered unallowable direct charges, 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.
B. Non-Federal Awards
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, CU Boulder’s Cost Principles Policy and related procedural statements are also applicable to non-federal awards. The basic criteria for charging entertainment costs are similar for non-federal sponsored projects, 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 entertainment costs should be provided in order to explain why these are necessary to fulfill the research objective of the project, and to ensure that the cost directly benefits the project being charged, even when the non-federal sponsor may follow more flexible spending guidelines.
C. Process
At Proposal
Entertainment costs that have a programmatic purpose for a specific research objective must be identified in the proposal budget justification, and justified as to why they are 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, and is required by federal agencies. For non-federal sponsors, written justification and/or approval are meant to prevent questions regarding the allowability of costs in the event of an audit.
After an Award is Funded
In the event unbudgeted entertainment costs are required after an award is funded, the PI must work directly with their OCG grant or contract officer to explain either their programmatic purpose for federal awards, or the benefit of this cost for non-federal awards. Based on sponsor prior approval requirements and the specific benefit, OCG will contact the sponsor for allowability. The written sponsor approval, as well as the justification explaining the purpose and benefit of the entertainment cost to the specific project, will be retained in Boulder eRA (BeRA) for future reference should the expenditure be questioned at a later date.