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When managing a grant from the U.S. Department of Education (ED), understanding the rules and guidelines around the use of federal funds is crucial to ensure compliance and maximize the impact of the grant. One area that often raises questions is the use of federal grant funds for food, beverages, and conference-related expenses. While these costs may sometimes be allowable, they are not automatically approved even if they are included in the grant budget. Instead, each expense must meet stringent criteria to be deemed reasonable, necessary, and directly related to the objectives of the grant. This summary provides detailed guidance on the conditions under which food and conference expenses may be approved, highlighting the importance of proper documentation and justification to align with federal regulations.

1. Using Federal ED Grant Funds for Food and Conferences

General Rules for Using Federal Grant Funds for Food

• Allowability: All expenses for food, beverages, or snacks must meet specific criteria to be considered allowable under Federal ED grant funds. These criteria include the expense being reasonable, necessary, and allocable to the grant, as well as compliant with the guidelines outlined in 2 CFR §§ 200.403-200.405.

Conditions for Food Expense Approval

• Not Automatically Approved: Budgeting food costs in a grant does not guarantee automatic approval. Each instance where food costs are proposed must be justified with a detailed rationale explaining why the expenditure is essential to achieving the specific goals and objectives of the grant. The justification must demonstrate that the food expense is reasonable and necessary to the project’s success.
• Required Documentation: Grantees must provide thorough documentation showing that the food costs are critical to meeting the grant's objectives. This includes evidence that alternatives, such as scheduling breaks for participants to procure their own food or selecting a venue with accessible food options, were considered but found inadequate.

Examples of Potentially Allowable Food Costs

• Family Engagement Events: Food expenses might be justified if providing food ensures higher attendance or engagement at a family engagement event crucial to the program. For example, if the event coincides with a typical mealtime and the absence of food would deter participation.
• Working Lunches: If a lunchtime session is necessary for the program and cannot be rescheduled, and participation is vital to the grant’s success, food costs might be approved. For example, during a day-long professional development session where attendees must work through lunch to cover essential topics.
• After-Hours Meetings: When meetings occur outside of regular working hours, and food provision is necessary to maintain participation, light refreshments may be allowable. This is contingent on proving that these meetings are critical to the grant’s objectives.
• Day-Long Training Sessions: If evidence supports that providing light snacks will improve participation and productivity in a day-long training session, these costs could be justified as necessary for the grant's success.

Examples of Non-Allowable Food Costs

• Networking Sessions: Food expenses for networking events, particularly those with a social focus, are typically not allowable since such activities are rarely essential to achieving the grant’s objectives.
• Regular Staff Meetings: Recurring staff meetings usually do not qualify for food-related expenses as they are generally considered part of routine operations, not directly tied to the specific goals of the grant.
• Remote Meetings: Food costs for remote meetings, such as sending meals to participants' homes, are generally not considered necessary and are unlikely to be approved.
• Entertainment and Alcohol: Costs related to entertainment, such as meals at social functions, or alcohol, are strictly unallowable under any circumstances.

2. Using Federal Grant Funds to Host Meetings or Conferences

General Rules for Hosting Meetings/Conferences

• Allowability: Federal grant funds can be used to host meetings or conferences if they are explicitly justified as necessary for achieving the grant's objectives. The expenditure must be consistent with the approved grant application and must serve a direct purpose relevant to the program's success.

Approval Conditions for Food at Conferences

• Case-by-Case Basis: Like other food expenses, the use of grant funds for food at meetings or conferences is not automatically approved, even if included in the budget. Each case must be evaluated individually, and the grantee must demonstrate that the food expenses are necessary for achieving the specific outcomes of the meeting or conference.
• Vendor Contracts: If a venue or hotel includes food costs as part of a contract for meeting space, grantees must ensure these costs are separated and justified as necessary. Any embedded costs must be identified and removed unless they meet the criteria for allowable expenses.

3. Attending External Conferences

Using Grant Funds for Attendee Costs

• Conditional Approval: Travel expenses for attending meetings or conferences can be covered by grant funds if attending is essential for the grant’s objectives. Grantees must justify the necessity of the conference for the grant’s success and provide a cost-benefit analysis to ensure the expenses are reasonable.

Evaluation Criteria for Travel Expenses

• Reasonableness and Necessity: Expenses must be reasonable and align with the grantee's policies. Federal grant funds should only cover the number of attendees and the length of attendance that are necessary for achieving the grant’s objectives.

Links to References

• FAQs on the Use of Federal ED Grant Funds
•  Additional information may be found at the Department's Laws, Regulations, and Guidance webpage at