Policy Details Page

Regulation 6240R
Management Support

Purchase of Meals and Light Refreshments for Students, Staff and Non-Employees

Generally, District employees are expected to pay for and furnish their own meals. There are some situations where providing meals and light refreshments are in the District’s best interest. The cost of meals and light refreshments, if provided, shall be reasonable, necessary, and not exceed the District's benefit. Care should be exercised to ensure that employees are not in violation of the Internal Revenue Service (IRS) taxable fringe benefit rules and the Washington State Constitution, Article VIII, Section 5 “gift of public funds.”

Principals/Administrators shall not schedule meetings or training during normal meal periods provide a meal customarily provided by the staff member.

A. Meals and Light Refreshments

1. Meals - Defined as food and beverage items commonly served for breakfast, lunch, or dinner consumed during a normal mealtime period. The cost per meal shall not exceed the District’s approved per diem regulations.

2. Light Refreshments – Defined as items commonly served between meals, but not intended to substitute for meals, such as coffee, tea, soft drinks, cookies, pastries, fruit, cheese, etc. Items in this category shall be reasonable and shall not constitute a meal as described above.

B. Premises

1. Meals for the convenience of the employer and that serve a public purpose must be on the premises.

2. Premises are defined by the IRS as “The place where employees perform a significant portion of their duties.” Not “near” premises, but within perimeter of business (i.e., PDC).

3. May include temporary work sites, such as a rented hotel conference room, or educational service district if business is conducted there.

4. Public restaurants and outside eating establishments do not qualify as premises for employers' convenience.

C. Formal Meeting and Training

1. Formal Training – Defined as a structured methodology in which a formal curriculum is presented in accordance with laws and norms. It entails following a carefully planned and regulated course outline. This educational strategy is well thought out, well-defined, and has a set timeline (3.5 hours or more).

2. Formal Meeting – Defined as a pre-planned gathering of several people who have assembled for the purpose of achieving a common goal through verbal interaction. It has a structured schedule (3.5 hours or more), agenda with set protocols, an official notetaker, and other clearly defined roles of the members.

D. Non-Allowable Meal and Light Refreshment Purchases

1. Meals and light refreshments associated with usual, routine, and customary informal meetings (i.e., breakfast, lunch, or dinner meetings with a limited or small number of staff members in attendance, incurred in the normal course of the employee’s job, including consultations with external parties, subordinates or between employees, which may be perceived as dining at public expense) are not permitted.

2. Breakfast during the regularly scheduled workday is not permitted. District funds shall not be used to provide breakfast to staff unless there is community participation (i.e., parent advisory) or if breakfast is a requirement (i.e., under certain Federal or other specified programs). The IRS states that employers are not obligated to furnish breakfast to staff during the regularly scheduled workday. Staff members are expected to furnish their own breakfast before arriving at work.

Funding Source	Activity as related to Breakfast	Allowed
Federal Grant/Program	Breakfast required	YES
Grant Program	Training – Breakfast allowed	YES
General Funds	Superintendent’s Advisory Breakfast with Community	YES
General Funds	Training of Staff on Saturday	NO
General Funds	Training of Staff during week	NO

3. Meetings of a social nature for the sole purpose of networking, promoting goodwill, improving morale, or boosting energy.

4. In-service days or Data Days when staff are working in their assigned building and/or with cohort peers (social workers, counselors, health services, teacher librarians, specialists, Head Start, ECEAP, CTE, ESA’s), when students are not in attendance.

5. Entertaining, promotional hosting, influencing an election campaign or ballot proposition, or any other actions contrary to state law.

6. Meals purchased separately, when a meal is included in the registration cost of a formal class or training.

7. Alcoholic beverages.

8. Gratuities over 18%.

9. Meal consumed while in official overnight travel status. Such meals should be included with other overnight travel status related expenditures.

10. Meal furnished to paid consultants except as noted below.

E. Allowable Meal and Light Refreshment Purchases

1. Formal Staff Meetings and Trainings – Reasonable light refreshments and meal purchases are permitted. Meals consumed by staff during the regularly scheduled workday may be reimbursed when:

a.   Participants remain on-site and/or on task.
b.   The meeting/training occurs during the employee’s normal mealtime.
c.   The meeting/training lasts at least 3.5 hours.

2. Light refreshments may be reimbursed when all or most of the participants are required to be in attendance or when held outside the workday for a special project involving a considerable number of students, parents, or volunteers.

3. School board retreats, regular board meetings and study sessions – Meals and light refreshments are allowed in connection with these meetings.4. Collective bargaining events – Meals and light refreshments are allowed in connection with these meetings.

5. Non-Student Days – Security, Nutrition Services, Maintenance, or Custodial department training with an agenda, last all day (7.5 hours), require attendance, and the training or meeting meet the definitions listed above in Section C.

6. Grant-approved programs – Meal purchase(s) must be itemized in the grant award or approved in writing by the grantor.

7. Gratuities up to 18%

8. Outside groups/supporters/sponsors – The District may furnish a meal during the normal meal period when there is a direct benefit to the District. Meal and light refreshments are allowed in connection with an event or meeting where many outside groups (non-staff) are working with District staff on a specific task or project. These include the following: volunteers, advisory groups or panels, parent involvement, and community partners.

9. Celebrations, Dedications and Open Houses – Light refreshments are allowed. Examples of these would include opening of a new school, retiree district wide celebration, dedication of a school or name change.

10. Consultants – As indicated under the Non-Allowable Meal and Light Refreshment Purchases section above, paid consultants are expected to furnish or pay for their own meals. Exceptions to this rule may occur when the consultant is an integral part of a formal training, and it would be difficult to separate out the cost of a meal or refreshment provided.

11. Meetings Held Outside the District, i.e., Off-site Conferences and Training – Meal expenses may be reimbursed if an employee is required to work through normal breakfast, lunch, or dinner periods while attending “formal” meetings, trainings, workshops, and conferences that are held outside the district and include a considerable number of participants who are not district employees.

12. Instructional Curricular Food Purchases

a.   Classroom Supplies: Such as food purchased for home economics or foreign language instruction, etc.
b.   Student Incentives/Rewards: Food purchases less than $25.00 per student and district/school approved student incentive program such as attendance, academic achievement, etc. This is allowed only when documented as an integral and necessary part of the students’ educational program.
c.   Lesson Plan: Food purchased as part of a lesson plan/curriculum that is prepared in the classroom
d.   Testing Periods: Instructional or educational purposes where it can clearly be shown to be of an educational benefit to the student.
e.   Associated Student Body: ASB funds can be used to pay for meals for parents and/or staff that participate as required chaperones and supervisors if approved by the ASB. Light refreshments for celebration events that meet ASB criteria shall be allowed. (A non-travel food and light refreshment K12 form not needed for ASB)
f.   Snack or beverage supplies for school nurse office; Such as water and crackers. A non-travel food and beverage form is required for these purchases.

F. Authorization and Documentation

1. A Non–Travel Meal and Light Refreshment Consumption Form (NTMLRCF) – Must be filled out seven (7) days before making the purchase. The form is available on the Business and Finance website under Finance Forms.

2. Advance Spending Approval – All NTMLRCF requests, regardless of the amount, must be preapproved by the administrator with BRC authority and Purchasing Director or Designee.

3. Nutrition Services must be first given the opportunity to cater the event prior to seeking outside meals or refreshments from other vendors.

4. Agenda and Sign-In Sheets – Event and/or meeting agenda and a list of individuals who consumed meal or light refreshment items shall be attached to the NTMLRCF for audit purposes.

5. Procurement Card (P-Card) Purchases – When using P-Cards, original itemized receipt(s) reflecting food items purchased and the NTMLRCF approved form must be maintained on site for audit purposes. When reconciling the P-Card, comments related to the event shall be noted in the P-Card comment field.

6. Classroom Food Curriculum Purchases – Purchases of food items for curricular purposes shall be processed in accordance with regular requisitioning approvals. Food items for use in the classroom curriculum do not require the Non-Travel Meal and Light Refreshment Consumption Form.

7. Multiple Event Dates – Events exceeding one day require a separate computation form showing each date and relevant costs. The Non-Travel Meal and Light Refreshment Consumption Event Data Computation Sheet may be found on the finance website under forms.

8. Grant Funds – When using grant funds to pay for food purchases, written authorization in the form of a grant award which clearly identified food purchases or a written correspondence from the grantor must be obtained. This form must be attached to the P-Card use form when using the P-Card to purchase.

G. Funding/Payment

1. An approved NTMLRCF, meeting agenda, and sign-in sheet (if applicable) shall accompany an Informed K12 P-Card Use Form.

2. Non-Travel Meal and Light Refreshments must be charged to accounting code 5610.

3. Group activities (where business is being conducted) involving a commercial facility must be authorized before the activity by completing a contractual services form.

4. When ordering from the District’s Nutrition Services Department, a copy of the approved Non-Travel Meal and Light Refreshment Consumption form must be submitted. Events catered by the Nutrition Services Department will be charged to the individual BRC/programs by an internal fund transfer.

5. P-Cards may be used to purchase meals and light refreshments if preapproved by the administrator with BRC authority.

6. When attending an outside meeting or training, a NTMLRCF is required. Payment shall be through the applicable process, noted above. Information required for reimbursement shall include original receipts, date, time, location, and meeting agenda.

H. Spending Threshold

1. The cost of light refreshments per person shall not exceed 40% of the District’s approved breakfast per diem regulations (excluding tax). Per diem rates may be found on the Business and Finance website

I. Compliance

1. Unallowable or undocumented meal transactions will be personally reimbursed by the administrator/BRC authority approving the event.

2. Meals and light refreshments provided for a meeting or training that did not receive approval through the established approval process will not be reimbursed and will be the responsibility of the person providing those.

Approval Date: 9/7/2010

Revised Date: 1/29/2013, 6/11/2024