Hosting a Conference Funded by University of Arkansas Sponsored Programs
This document is intended to serve as formal guidance for University of Arkansas 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 University of Arkansas Cost Principles Policy 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 (University of Arkansas) and is necessary and reasonable for successful performance under the Federal award.
When the non-Federal entity (University of Arkansas) is a sponsor or host of a conference, 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.
For meal costs, the established limit for breakfast is $20, lunch $25, and dinner $45 per person. In extraordinary cases where meal costs per person exceed these limits for the conference location, provide justification with official function form.
Non-Federal Sponsored Program 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 sponsored activities of the university. Therefore, the University of Arkansas’ Cost Principles Policy, and related procedural statements, are also applicable to non-Federal sponsored program awards. The basic criteria for charging conference costs are similar for non-Federal sponsored programs, but specific restrictions given by each non-Federal sponsor will be the overruling factor in determining cost allowability for non-Federal sponsored projects. Even when specific costs are allowed by a 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.
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 the University of Arkansas.
Documentation may include, but is not limited to, the following:
- A detailed explanation of the business purpose of the conference, which must include the dissemination of technical information beyond the University of Arkansas 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, including company or institution.
- If the conference was a public event not requiring registration, proof of advertising beyond the University of Arkansas.
- Actual cost per meal for each guest.
- 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 (University of Arkansas 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 University of Arkansas and the related program team, even if located at different institutions.
- Alcohol costs are unallowable through sponsored program funding.
- Meal costs in excess of established limits are generally unallowable through sponsored program funding. The business unit may choose to cover costs beyond the established limits using alternate sources of funding, as allowable by University Policy.
- Locally available dependent-care resources for travel to conferences is allowed only if there is an institution-wide policy that these costs are allowed. The University of Arkansas does not currently have a policy that provides this benefit to faculty and staff. Therefore, it is not allowable to charge dependent care costs to a sponsored program.
Conferences Included in Proposals
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.
Adding Conference Spending Post-Award
In the event that an unbudgeted conference cost is required after an award is funded, the Principal Investigator should review proposed conference costs for allowability and reasonableness and be able to explain the business benefit of this cost. The Principal Investigator should then work with RSSP 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 Razorgrant. 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 of or numbers on the attendee list.
Purchasing Approval Procedures
Prior to the event the budgetary unit hosting the conference should complete the official function form, including as much information about attendees as possible, and submit this form for approval. Research accountants will review these forms for allowability under applicable federal, sponsor, and project guidelines. If additional expenses for a conference are incurred, they must be approved through this process before they can be applied to the sponsored program.