Charging Food on NIH Awards

Have you had a chance to read the latest from NIH regarding meal cost on NIH grants that primarily support conferences or scientific meetings (R13/U13)?  The new policy states that awards issued on or after January 27, 2012, will include the following special term and condition in the award notice:

“Direct charges for meals/food and beverages are unallowable charges to this project.”

For awards issued prior to 1/27/2012, the Notice of Award will not be revised, but NIH is strongly encouraging grantees to apply this rule broadly to all active R13/U13 Grants.

However, please note that research grants and other mechanisms that are not awarded to specifically support conferences are excluded from this new rule.

ORA has already spoken on multiple occasions with various NIH grants management staff members regarding the interpretation of the new rule, as some at the agency were disallowing food related costs on R01 awards solely based on the new rule.  However, that is NOT how the notice reads, so we have had to clarify with NIH directly in those instances.

If you receive an NOA with this term, or you are contacted by NIH on an existing award and are instructed to stop charging food costs, and you do not think it is appropriate, please contact ORA immediately.  Do NOT negotiate directly with NIH.

Continue to read your NOA and follow the A-21 governing principles to determine if food-related costs are a reasonable expenditure on your research award.  And always remember that the burden of proof falls on the department/institution to show that the costs are allocable, reasonable, allowable, and consistent.