Managing Meal Caps at Offsite Dinners
When the Sunshine/Open Payments Act went into effect in 2013, life sciences companies implemented self-imposed meal caps to be compliant. Although the actual regulations in the U.S. require only that food and beverage (F&B) offered be “reasonable” or “modest” in price, concerns about compliance perception made those who set the budgets interpret “reasonable” more frugally than reality, especially in first-tier cities.
Since then, though, there have been a few developments that are making it somewhat easier to comply with meal spending caps. We find that more and more, companies are setting their own food cap limitations internally and sharing them with their HCPs (in the registration form) explaining amounts they will be spending on meals. In cases where HCPs may exceed the meal caps, they also offer other option where HCPs can then pay the difference or offer vouchers for use at food vendors within the meeting venue.
In order to stay on track and within meal cap budgets, it is important that meeting planners work closely with hotels and chefs (or designated food service providers) to help select local, seasonal foods that are cost effective yet still suitable for attendee preferences and any particular dietary restrictions. The best venue partners will often help design and create custom menus branded to your event needs—particularly when it comes to meal caps.
Additionally, coordinating menu choices to mirror those of other groups in-house helps in meeting meal cap budgets. Food costs, staff services, taxes, and gratuity all contribute to the decreasing amount available for the actual food products. So, it is important that your meal caps are reasonable.
To maintain a meeting planner’s sanity, the best rule of thumb is to stick to your guns. Don’t bend the basic meal cap rules you have set in place. Although it may be the source of frustration for some who may want to “go out” privately for dinner, assuring compliance is important.
Another tip would be to ask that the venue not allow attendees to upgrade their meals for a separate fee. Any time you move money around, you are make yourself at risk for documentation problems. You can count on venues to allocate spending into the appropriate categories (such as catering) once your program is over, so it’s best to keep things in order from the get-go. If an audit reveals that the actual spend on F&B was not accurately reported, it could be construed as a violation (of spending caps).