Proposal Guide

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					                                                                          Smithsonian Astrophysical Observatory
                                                                  GUIDELINES FOR REIMBURSEMENT OF MEALS COSTS


     These guidelines address our ability, at SAO, to incur the cost of non-travel-related meals and other food, required approvals and requests for reimbursement
     when incurred by individuals. The source of funding for the specific scientific, administrative or social activity dictates allowability. The prevailing regulations and
     policies related to each funding source outlined below are not new. For specific, detailed requirements please refer to the applicable regulations and policies
     referenced herein. Links to relevant documents are also provided.




        Fund                   Description of Fund                     DsgCd                                   Prevailing Regulation or Policy

     Meals and Other Food

     The guiding principle is "Funds used for representational and special event expenses should be truly discretionary, such as honoraria, royalties, and other
     unrestricted non-allocated income. Restricted non-allocated funds, such as gifts and grants, may only be used for such purposes in included in the conditions of
     the gift or grant." See Note 2 .


                                                                                  "As a general rule, and absent statutory authority, Federal appropriations are not
                                                                                  available to feed federal employees at their official duty station. This is because
                                                                                  appropriations of public funds are enacted to finance public purposes, not the personal
                                                                                  expenses of employees. An employee is expected to bear the cost of personal expenses,
                                                                                  such as meals and light refreshments, from his or her own salary."             See Note 3.


                                                                                  Employee awards and recognition ceremonies
                                                                                  1. Smithsonian funds can be used to purchase light refreshments for receptions incident
                                                                                  to award ceremonies.
      000-120                        Federal                            All
                                                                                  2. Smithsonian funds can be used to purchase meals (breakfast, lunch and dinner) when
                                                                                  each of the following conditions is met:
                                                                                  a. The Unit has a formal incentive awards program (in writing) that has been approved by
                                                                                  the Director and the Office of Human Resources, and this program justifies the provision
                                                                                  of meals to recognize employee performance and achievements for specific situations.
                                                                                  b. The meal expenses do not exceed $20 per person.
                                                                                  c. The Unit Director approves and justifies, in writing and in advance, how the proposed
                                                                                  use of funds complies with the Unit’s incentive awards program.
                                                                                  Federal funds can be used only when the person(s) being honored is a Federal
                                                                                  employee. See Note 3.




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        Fund                   Description of Fund                DsgCd                                   Prevailing Regulation or Policy

                                                                            For SAO employees: Food is not an allowable expense unless it is related to SAO-wide
                                                                            activities that are a matter of SI/SAO's "established practice or custom for the
                                                                            improvement of working conditions, employer-employee relations, employee morale, and
         401         Trust Overhead                               040101
                                                                            employee performance…” Such activities must be approved by the Deputy Director of
                                                                            Operations and Finance prior to incurring the expense. Please note: public relations
                                                                            costs are not allowable using these funds. See Note 4.

                                                                            1. Food is not an allowable expense unless explicitly requested in the proposal and
                                                                            subsequently approved for funding and meets the criteria below under "Independent
                                                                            Research & Development" and "Proposal Preparation."
                                                                            2. The cost of food /meals may be allowable with regard to meetings and conferences,
                                                                            "the primary purpose of which is the dissemination of technical information... This
                                                                            includes costs of meals...and other costs incidental to such meetings..." However, "costs
                                                                            of entertainment, including...social activities and any costs directly associated with such
                                                                            costs (such as...meals...) are unallowable." Participant support costs, i.e., direct
                                                                            costs...such as stipends or subsistence allowances...paid to or on behalf of participants
                     Trust Overhead--IR&D and                     040105,
         401                                                                or trainees (but not employees) in connection with meetings, [etc.]...are allowable with
                     Proposal Prep                                040106
                                                                            the prior approval of the IR&D and Proposal Prep Committee.
                                                                            See Note 5.

                                                                            Independent Research & Development : costs neither sponsored by a grant nor required
                                                                            in the performance of a contract, AND which fall into any of the following areas: (i) basic
                                                                            and applied research; (ii) development, and (iii systems and other formulation studies.

                                                                            Proposal Preparation : costs incurred in preparing, submitting or supporting any bid or
                                                                            proposal effort which is neither sponsored by a grant nor required in the performance of
                                                                            a contract.
         401         SI Central Trust--Library                    040104    Food is not an allowable expense.

                                                                            1. Food purchase must directly support an approved development activity that meets
                                                                            specific criteria, including donor cultivation or recognition where at least one or
                                                                            prospective donor is present; the expense is financed with unrestricted trust funds
                                                                            (unless allowed by a gift, endowment or grant), and employee attendance and the type,
         401         SI Central Trust--Fundraising                1016xx    amount and cost of food & refreshments is reasonable, appropriate and consistent with
                                                                            SI practices and guidelines.
                                                                            2. Meals/light refreshments are allowed for individuals other than Smithsonian
                                                                            employees when a component of a development/fundraising activity.
                                                                            See Note 6.




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        Fund                   Description of Fund                DsgCd                                  Prevailing Regulation or Policy

                                                                           These funds may be used to purchase food for Smithsonian employees working in
                                                                           their local commuting area under one of the following conditions when approved in
                                                                           advance and in writing :
                                                                           1. For official Smithsonian events, such as employee recognition events (Director
                                                                           approves);
                                                                           2. When the expense is related to a compelling mission need that involves both
                                                                           Smithsonian employees and outside participants (Director approves);
                                                                           3. When SAO requests to host a working lunch that involves only Smithsonian
                                                                           employees (Secretary, Under Secs, Dir of External Affairs approve);

                                                                           4. When the cost of food is included at no extra charge in the fee for conference/meeting
                                                                           space when an outside facility is deemed essential by the Director (for other than routine
                                                                           staff meetings);
         402                 Director's Discretionary              All     5. When food is required to sustain employees working during unanticipated emergency
                                                                           situations;
                                                                           6. When the purchase of food directly supports an approved development activity that
                                                                           meets specific criteria.
                                                                           See Note 7.
                                                                           These funds may be used to purchase food for non-Smithsonian employees under the
                                                                           following conditions when approved in advance and in writing :
                                                                           1. When a component of an official fundraising activity;
                                                                           2. For official Smithsonian events, such as employee recognition events;
                                                                           3. For a Unit-sponsored event (advisory board activities, public lectures/seminars, press
                                                                           previews, receptions to recognize scientific achievement, receptions that promote an
                                                                           element of the Smithsonian's mission);
                                                                           See Note 8.
                                                                           Allowable in conjunction with Smithsonian activities and events only when award
         6xx         Endowment                                     All
                                                                           explicitly authorizes this use of these funds. See Note 9.
                                                                           Allowable in conjunction with Smithsonian activities and events only when award
         801         Gifts                                         All
                                                                           explicitly authorizes this use of these funds. See Note 10.
                     Non-government Contracts &                            Allowable in conjunction with Smithsonian activities and events only when the award
         802                                                      5xxxxx
                     Grants                                                explicitly authorizes this use of these funds. See Note 11.




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        Fund                   Description of Fund                  DsgCd                                    Prevailing Regulation or Policy


                                                                               1. Food is not an allowable expense unless related to travel or conferences and was
                                                                               explicitly requested in a proposal to a government sponsor which is subsequently
                                                                               funded. When requesting reimbursement for food purchased using such funds
                                                                               please include the cover and budget pages from the funded proposal.
                                                                               2. Food is allowable as an element of meetings and conferences, "the primary purpose
                     Government Contracts & Grants--              6xxxxx and   of which is the dissemination of technical information... This includes costs of meals...and
         803
                     Not RSAs                                       7xxxxx     other costs incidental to such meetings..." However, "costs of entertainment,
                                                                               including...social activities and any costs directly associated with such costs (such
                                                                               as...meals...) are unallowable." With regard to participant support costs, i.e., direct
                                                                               costs...such as stipends or subsistence allowances...paid to or on behalf of participants
                                                                               or trainees (but not employees) in connection with meetings, [etc.]...are allowable with
                                                                               the prior approval of the awarding agency. See Note 12.


                                                                               While the requirements of RSAs are less stringent, the funds are not discretionary. Also,
                                                                               we are required to keep our financial practices consistent. Therefore only costs directly
                     Government Contracts & Grants--              6xxxxx and   related to the RSA’s statement of work can be reimbursed. When requesting
         803
                     RSAs only                                      7xxxxx     reimbursement for food purchases please note on the form that they are RSA
                                                                               funds and indicate that the food/meal is specifically related to the scope of work .
                                                                               See Note 13.

     Alcoholic Beverages
      000-120        Federal                                         All       Alcoholic Beverages are not an allowable expense.

                                                                               At SAO alcoholic beverages are not an allowable expense to Trust Overhead but may be
         All         Trust
                                                                               purchased with other trust funds under the following circumstances only :

         401         SI Central Trust--Fundraising                 1016xx      1. As a component of an official fundraising activity;

                                                                               2. For a Unit-sponsored event (advisory board activities, public lectures/seminars, press
      6xx, 801       Endowment, Gifts, Government                              previews, receptions to recognize scientific achievement, receptions that promote an
        and          and Non-government Contracts &                  All       element of the Smithsonian's mission) use 6xx endowment, 801 gift, 802/803
      802/803        Grants                                                    government/non-government contracts & grant funds when explicitly allowed for the
                                                                               purchase of alcoholic beverages.

         402         Director's Discretionary                                  3. If funds described in #2 above are unavailable, unrestricted fund 402 must be used.

                                                                               See Note 1.



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        Fund                   Description of Fund                DsgCd                                    Prevailing Regulation or Policy
       ====================================
                     See Supplement to the Smithsonian Institution Trust Funding Policy for Gifts, Alcoholic Beverages and Food (GAF) and Related Expenses,
       Note 1
                     Revision 2, July 25, 2008, Alcoholic Beverages, 6.b.


       Note 2        See FY 2005 fund 401 Allocation Memo, Attachment 5, Use of Trust funds for Representational and Special Event Expenses.



       Note 3        See SI Use of Funds Handbook, January 2010.


                     See 2 CFR 230 Cost Principles for Non-Profit Organizations (OMB Circular A-122) Attachment B, Selected Items of Cost, Section 1. Advertising
       Note 4        and public relations costs, paragraphs d. and f., Section 13. Employee morale, health, and welfare costs, paragraph a., and Section 19. Goods or
                     services for personal use.


                     See FAR Appendix--Cost Accounting Standards Subpart 9904.420 Accounting for Independent Research and Development Costs and Bid and
       Note 5        Proposal Costs and 2 CFR 230 Cost Principles for non-Profit Organizations (OMB Circular A-122) Attachment A General Principles and Attachment
                     B, Selected Items of Cost, Section 14. Entertainment costs, Section 29. Meetings and conferences and Section 33. Participant support costs.


                     See Supplement to the Smithsonian Institution Trust Funding Policy for Gifts, Alcoholic Beverages and Food (GAF) and Related Expenses,
       Note 6
                     Revision 2, July 25, 2008, Meals and Light Refreshments, 8.g. and 9.


                     See Supplement to the Smithsonian Institution Trust Funding Policy for Gifts, Alcoholic Beverages and Food (GAF) and Related Expenses,
       Note 7
                     Revision 2, July 25, 2008, Meals and Light Refreshments, 8.a.i., c., d., e., f., g. and 9.

                     See Supplement to the Smithsonian Institution Trust Funding Policy for Gifts, Alcoholic Beverages and Food (GAF) and Related Expenses,
       Note 8
                     Revision 2, July 25, 2008, Meals and Light Refreshments, 9.

                     See Supplement to the Smithsonian Institution Trust Funding Policy for gifts, Alcoholic Beverages and Food (GAF) and Related Expenses, Revision
       Note 9
                     2, July 25, 2008, Meals and Light Refreshments, paragraph 11.

                     See Supplement to the Smithsonian Institution Trust Funding Policy for Gifts, Alcoholic Beverages and Food (GAF) and Related Expenses,
      Note 10
                     Revision 2, July 25, 2008, Meals and Light Refreshments, paragraph 11.

                     See Supplement to the Smithsonian Institution Trust Funding Policy for Gifts, Alcoholic Beverages and Food (GAF) and Related Expenses,
      Note 11
                     Revision 2, July 25, 2008, Meals and Light Refreshments, paragraph 11.




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        Fund                   Description of Fund                DsgCd                                   Prevailing Regulation or Policy
                     See 2 CFR 230 Cost Principles for Non-Profit Organizations (OMB Circular A-122) Attachment B, Selected Items of Cost, Section 14. Entertainment
                     costs, Section 29. Meetings and conferences and Section 33. Participant support costs AND NSF Award & Administration Guide, Chapter V
      Note 12        Allowability of Costs, C. Other Direct Costs, 5. Meetings and Conferences AND NSF Grant Proposal Guide NSF-10, January 2010, Chapter II
                     Proposal Preparation Instructions, C. Proposal Contents, 2. Sections of the Proposal, g. Budget, (xii) Unallowable Costs, (b) Meals and Coffee
                     Breaks.

                     See 2 CFR 230 Cost Principles for Non-Profit Organizations (OMB Circular A-122), Attachment A, General Principles, A. Basic Considerations,
      Note 13        paragraph 2.c. AND FAR Appendix Part 9904--Cost Accounting Standards, Subpart 9904.401--Consistency in Estimating, Accumulating and
                     Reporting Costs.




     Links to complete documents:

     http://prism.si.edu/ocfo/opmb/docs/FY_2005_401_Allocation%20Memo_Fund_Use_OPMB8.doc
     http://prism.si.edu/ocfo/opmb/docs/GAF_Revision_2__7-25-2008.pdf
     http://www.whitehouse.gov/omb/circulars/a122/a122_2004.pdf




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