NCDPI Guidance on Using Race to the Top (RttT) Funds for Food at Conferences or Workshops The understanding of NCDPI about the use of RttT funds to pay for food at RttT related conferences and workshops has not changed from the beginning of the grant and is in line with the requirements of the Office of Management & Budget (OMB) Circular A-87. RttT funds may be used to provide food at a meeting or conference if: The purpose of the meeting or conference is to disseminate “technical information” related to the goals and objectives outlined in the state’s USED approved Detailed Scope of Work. Providing food is a reasonable support to facilitate accomplishing the objectives of the meeting or conference (e.g., it is an all-day meeting as opposed to a one hour meeting). Food is not a part of an activity that might be considered entertainment, such as (but not limited to) networking functions. The cost of the food provided is reasonable. These guidelines are based on two items in Part B of OMB Circular A-87 that provide guidance about using federal funds to pay for food at conferences or workshops: “14. Entertainment. Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such costs (such as tickets to shows or sports events, meals, lodging, rentals, transportation, and gratuities) are unallowable. […] 27. Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, and other items incidental to such meetings or conferences. But see Attachment B, section 14, Entertainment costs.” Section E-10 of the “Race to the Top Grantee Frequently Asked Questions” (January 31, 2011) provides clarification on how to interpret these items specifically for RttT funds: “Food is not an allowable expense if it is part of an activity that is considered to be entertainment… However, food may be an allowable cost if it is necessary to accomplish the objectives of the program, and is reasonable in cost.” NC RttT Program Management Office 1 6/7/2013 USED also recently clarified what might constitute “technical information” as described in Item 27 in Part B of OMB Circular A-87: “Examples of technical information include, but are not limited to, the following, each of which must be related to implementing the program or project funded by the grant: Specific programmatic, administrative, or fiscal accountability requirements; Best practices in a particular field; Theoretical, empirical, or methodological advances in a particular field; Effective methods of training or professional development; and Effective grant management and accountability.” However, it should be noted that while USED allows some discretion on the part of the states and LEAs about what is an appropriate use of federal funds for food at conferences or workshops, they also feel that “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.” Because of this preference, careful thought should be given as to whether to use RttT funds to provide food at a conference or meeting; the justification for such decisions should be clear, reasonable, and aligned with the criteria outlined in this document. NC RttT Program Management Office 2 6/7/2013