Use of federal funds to provide food or beverages

Administrative Letter: 4
Policy Code: KLM
To: Superintendents of Schools, Business Managers, Directors of Special Education
From: William H. Beardsley, Acting Commissioner
Date: January 13, 2016
Re: Use of Federal Funds to Provide Food or Beverages

The Maine Department of Education has received a number of questions regarding the use of federal funds to provide food and beverages at meetings and conferences. Generally, the use of federal funds for food and beverages is discouraged. The documents posted at are the federal government’s advisory on this topic.

Please note that the June 2012 U.S. Department of Education Memorandum mentions a “working lunch” as being an example of an allowable use of federal grant funds to pay for food when hosting a conference or meeting. However, the Frequently Asked Questions document provides more restrictive language which says, “Generally, there is a very high burden of proof to show that paying for food and beverages with federal funds is necessary to meet the goals and objectives of a federal grant. When a grantee is hosting a meeting, the grantee should structure the agenda for the meeting so that there is time for participants to purchase their own food, beverages, and snacks. In addition, when planning a meeting, grantees may want to consider a location in which participants have easy access to food and beverages. While these determinations will be made on a case-by-case basis, and there may be some circumstances where the cost would be permissible, it is likely that those circumstances will be rare. Grantees, therefore, will have to make a compelling case that the unique circumstances that have identified would justify these costs as reasonable and necessary.”

For questions please contact Janice Breton, Director of Special Services at