10 | P a g e J u n e 2 0 2 0
Other instances, when food may be purchased for employees or employees
may be reimbursed for food purchased. These instances are addressed using
the following general categories:
• 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.
• 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:
• 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 duties, and the institution should
strictly control the numbers of individuals who may receive reimbursement
for food purchased at a given recruitment meeting.
• 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 contract or
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.
The 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.