As a general rule, food is a personal expense for which appropriated funds may not be used without specific authorization, which includes review by OGC and approval by the proper official.
Note that the following types of NASA-sponsored events do not qualify:
As an occasional exception to the general rule, food may be purchased with appropriated funds, when otherwise authorized, only if all of the following criteria are met:
Food is normally considered a personal expense for which NASA cannot pay. This questionnaire is to assist in providing facts and justifications for one of the limited exceptions to the prohibition on paying for food with NASA's appropriated funds. Please fill in the background information and any part that you think applies to your event. Completing the questionnaire alone does not mean the event may use appropriated funds for food or refreshments!
- Do you plan on paying for the food and refreshments with appropriated funds?
- What is the title of the event?
- What NASA office is holding/sponsoring the event?
- How does the event fulfill a mission of the sponsoring office and/or of NASA?
- Does the event deal with primarily internal NASA matters?
- Has this or a similar event been sponsored by NASA in the past? When? Were food or refreshments purchased with appropriated funds previously?
- Who is the official who has approved or will approve the conference?
- Who is the certifying official for the expenditure of appropriated funds?
- Please provide a copy of the agenda or draft agenda that specifies topics and speakers.
- What are the dates for the event?
- What is the place of the event?
- What percentage or number of attendees are on Government travel orders?
- Where are most of the out-of-town [?] attendees expected to obtain lodging (i.e., at the conference site or nearby)?
- How many people are invited?
- Please indicate the types (and number of attendees if known) in each of the following categories:
- (____) Civil servants from other Federal Agencies,
- (____) NASA contractors,
- (____) Other Federal agency contractors,
- (____) Representatives from non-profit groups and/or institutions of higher learning,
- (____) Congressmen and staffers,
- (____) Representatives from local government,
- (____) Representatives from foreign governments,
- (____) Media, press,
- (____) the public, and
- (____) other (please specify).
- What meals and refreshments would you like to serve and when?
- What are the approximate values of each?
- What is the cost break-down per day for each person per refreshment/meal service?
- Will any other entity supply food or refreshments? If so, what is that entity?
- Are you employing a conference organizer? If so, please specify the company and provide the name and contact information for the NASA employee who is in charge of the contract or task order.
- Are there any reasonable cost-avoidance or cost-savings made by using appropriated funds to obtain meals and/or refreshments? If so, specify.
A. Is the Event a "Formal" conference? Questions:
1. Is the event a formal conference or a routine meeting?
2. Is there a topical matter of interest? If so, please specify what it is.
3. Will there be the participation of multiple agencies and/or nongovernmental participants?
4. Will there be registration?
5. Is there a published substantive agenda? Please attach the published agenda or a draft.
6. Will there be scheduled speakers or discussion panels?
7. Is the purpose of the conference to discuss matters internal to NASA (e.g., focused on NASA, its issues, projects, and activities) or matters of interest to a wide audience outside of NASA?
8. Are the food and refreshments incidental to the rest of the event?
9. Is attendance at the meals and during the refreshments important for NASA to ensure the full participation of attendees in essential discussions, lectures, or speeches concerning the purpose of the conference? (For example, are you having a speaker during lunch?)
10. Are substantial conference functions occurring separately from when the food is served?
B. Is this Event "Training?"
Endorsement from the cognizant training office that the event is training should be attached. Questions:
1. What is the subject matter of the training?
2. What is the goal of the training?
3. Is this meeting something other than a day-to-day or routine business meeting?
4. How does the event meet the definition of training above? Explain how.
5. Have you checked with the NASA training office to see if this event meets the criteria for NASA training? (If not, we recommend that you do so.)
6. Is the provision of food and/or refreshments necessary to achieve the goals of the training? If so, how?
7. Attach a copy of the agenda or draft agenda.
C. Is this Event an Awards Ceremony?
The Government Employees Incentive Awards Act allows the Government to use appropriated funds for awards to Federal employees. The Act also allows the Government to "incur necessary expense" for the honorary recognition of those employees, which GAO has interpreted as allowing the purchase of food and refreshments. In addition, the event must include presentation of the awards in front of an audience of more than awardees. The Agency must also make a determination that the food and refreshments will materially enhance the ceremony. Finally, the food and refreshments must be appropriate for the given circumstances. Questions:
1. Will there be an award ceremony?
2. What awards will be given and who will receive them?
3. Will there be an audience of more than the attendees?
4. Will the food and refreshments materially enhance the ceremony?
5. Are the food and refreshments appropriate for the type of award ceremony?
6. Will the food be served in conjunction with the awards ceremony?