Purpose: This IRM provides IRS policies and procedures for business units requesting approval to use appropriated funds to purchase meals or light refreshments for events that the IRS sponsors or hosts.

Audience: All business units

Policy Owner: CFO, Financial Management

Program Owner: CFO, Financial Management, Travel Management office, develops and maintains this IRM.

Primary Stakeholders: The primary stakeholders are IRS business units that host or sponsor events and use appropriated funds to purchase meals or light refreshments for event participants.

Program Goals: To track and monitor funds appropriated and used to purchase light refreshments at events that IRS sponsors or hosts. The IRS has a responsibility to act as a careful steward of taxpayer dollars, ensuring that federal funds are used for purposes that are appropriate, cost effective and important to the IRS’s core mission. Business units must exercise the same care in purchasing meals or light refreshments that a prudent person would exercise if incurring these expenses on personal business.

The Comptroller General has identified statutory authorities that permit the use of appropriated funds to pay for meals or light refreshments at IRS-sponsored events in the following circumstances:

Light refreshments include, but are not limited to, coffee, tea, milk, juice, soft drinks, ice cream, donuts, bagels, muffins, fruit, vegetable trays, cheese trays, pretzels, cookies and chips. Light refreshments must be provided in quantities that are not considered to be a meal.

Business units should exercise prudence when purchasing meals or light refreshments. The amount spent on meals or light refreshments must be reasonable in relation to the nature, size and overall cost of the event. If employees are in travel status, they do not need to reduce their meals and incidental expenses (M&IE) allowance for any light refreshments provided.

When holding an event in a hotel or similar facility, a business unit cannot contract to pay for meals or light refreshments and allow the facility to provide the conference rooms or support at no cost to the government. In other words, the hotel is not allowed to provide a free conference room (″comp″ a room) in exchange for the IRS purchasing meals or light refreshments.

The IRS cannot use appropriated funds to pay for meals or light refreshments at preliminary or evening social gatherings or during breaks to merely facilitate social interaction or to improve the attendance of participants.

The IRS is generally prohibited from using appropriated funds to pay for meals or light refreshments at day-to-day internal business meetings.

The business unit hosting the event should first determine if the event meets the basic criteria for training, awards ceremonies or special emphasis programs as explained in this IRM. If not, the business unit should determine if it fits the criteria for a formal meeting or conference.

To determine if meals or light refreshments are authorized, the business units may consult with General Legal Services, HCO or with the CFO Travel Policy and Review office for advice on the nature of an event.

Event coordinators/hosts are responsible for obtaining the appropriate approval and ensuring the event is properly documented (for example, invitation letters, registration forms, sign-in agendas) and must have these records available for inspection by TIGTA or other interested parties for a period of six years.

Generally, only items classified as light refreshments are appropriate at an award ceremony. The light refreshments must enhance the recognition of the award recipients as determined by the appropriate IRS official. Business units must exercise prudence when using appropriated funds to purchase light refreshments for awards ceremonies.

The GEIAA permits agencies to incur necessary expenses for the honorary recognition of federal employees under established awards programs.

The GAO Comptroller General decisions have emphasized that the purposes of award ceremonies are to foster public recognition of employees’ meritorious performance and allow other employees to honor and congratulate their colleagues. In accordance with GEIAA, the event must meet all of the following criteria to be considered an award ceremony.

The GAO Comptroller General decisions do not authorize providing meals or light refreshments to recognize employees for their achievements in connection with an event or function that is primarily designed to achieve other agency objectives.

The IRS may be able to use appropriated funds to pay for meals or light refreshments at conferences, provided that the event meets the following requirements and condition.
 

The event:

In addition:

The quantity of the meals or light refreshments provided must be commensurate with the scale of the conference. Business units must exercise prudence when using appropriated funds to purchase meals or light refreshments for formal conferences. Generally, the cost per person may not exceed 25% of the per diem rate for applicable meals based on the geographic location of the conference.

The IRS may be able to use appropriated funds to pay for meals or light refreshments at training events. The GETA authorizes an agency to pay all or part of the necessary expenses of training. In accordance with 5 USC Section 4101, the event must meet all of the following criteria:

A determination must be made whether providing meals and light refreshments during a training session will be advantageous to the participants in receiving the intended objectives of the course.

The IRS may be able to use appropriated funds to pay for meals or light refreshments at special emphasis programs. The GAO Comptroller General decisions provide limited authority for agencies to use appropriated funds to purchase meals or light refreshments for special emphasis program when the event is:

These programs improve the workplace environment by promoting and fostering diversity in the workplace through awareness and by educating IRS employees and others to appreciate, value, understand and celebrate social and cultural similarities and differences.

The meals or light refreshments must consist of small samples of ethnic foods prepared and served during the event.

Requests to use appropriated funds to purchase meals or light refreshments must be approved in advance of the event by the:

To facilitate the request/approval process, Frequently Asked Questions have been developed and posted to the Manager’s Corner to assist business units with requesting approval to purchase meals or light refreshments.

Business units requesting approval to purchase meals or light refreshments should complete Form 14676, Meals and Light Refreshments Request, no later than 30 days before the event start date to allow enough time for approval by the appropriate Deputy Commissioner or by the CFO.

After the business unit Division Commissioner/Chief/Head of Office or Deputy has signed Form 14676, Meals and Light Refreshments Request, the request form should be forwarded to *CFO-FM-Travel Policy & Review. Travel Management will review the request and coordinate obtaining the signature of the appropriate Deputy Commissioner or the CFO.

Business units are responsible for obtaining the appropriate event spending and training event approvals through the Servicewide Training and Event Tracking System as published on HCO’s Servicewide Training & Event Management website.

Some hotel contracts include refreshments and/or lodging and require the acceptance of contractual terms and conditions that are subject to IRS procurement processes and procedures. For additional information about IRS policies on obtaining off-site facilities, reference Procurement Policy and Procedures Memorandum 70.24, Acquiring Training, Meeting, and Conference Services and Facilities/Spaces for Training, Meetings and Conferences at: Policy and Procedures Memorandum No. 70.24.

Business units should ensure that the event is properly documented with, for example, invitation letters, registration forms, sign-in agendas, and letters/memorandums documenting how much was spent for the event, including the actual costs incurred for any light refreshments or meals served. These records must be available for inspection by TIGTA or other interested parties for a period of six years.

In accordance with the FTR, when the IRS furnishes meals or light refreshments, an attendee in travel status must make the following adjustments for claimed M&IE:

FTR 41 CFR 301–11.17 through 11.19, provides additional information on this requirement, including exceptions.

Meals furnished by the IRS may be taxable to the employee when a trip is less than 24 hours without overnight lodging. Business units need to consider the potential tax implications of providing meals to employees at their official stations prior to providing such meals.

See IRS Publication 15-B, Employer's Tax Guide to Fringe Benefits, for guidance on the tax treatment of employer-provided meals and on the circumstances in which meals may be excluded from income.

The business unit event coordinator is responsible for reporting taxable meals furnished to IRS employees to Travel Management. The event coordinator can contact the Travel Operations help desk at *CFO BFC Help Desk.