.. Policy: Business Expense Policy and Procedure Apl>roved By: Vice President for Finance and Administration History: New Policy Issued - December I, 20 II Revised - November 5, 2012 Responsible Office: Finanee and Administration, Budget and Business Operations Additional References: Alcohol Policy, Awards and Prizes Policy, Gift Policy, Moving Policy Purchasing Policy, P-Card Policy, Recruitment Policy, Travel Policy I.
PURPOSE This policy sets forth requirements to be followed by employees, associates, affiliates, and other individuals (including students) and provides guidance for the appropriateness of expenses made using university funds and includes additional guidance for specific sensitive or reportable expenses.
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POLICY
STATEMENT
A. Processing Expenses All expenses made using university found in this policy (Item Ill).
funds must comply with the Tests of Propriety
B. Funding Restrictions on Expenses if more than one regulation or policy applies to a particular transaction, the more restrictive one must be followed. For example, a principal investigator cannot authorize the purchase of first-class airline tickets on a research project because federal/state fiscal regulations policy prohibit first-class air travel but the University would allow under special circumstances. C. Approving Expenses As indicated in the Purchasing Policy, all expenses over $1,000 made using university funds must involve at least two difTerent employees: a requestor and an approver. Both of these individuals must have sufficient knowledge to evaluate the transaction, and the authority to challenge or seek further approvals for questionable transactions. Approvers may not approve their own transactions, such as personal reimbursement, travel expenses; nor are approvers perm itted to approve transactions that provide personal reimbursement for their supervisor.
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Personal Responsibility 1. Individuals involved in a transaction may be held personally liable for a transaction that is made in violation of policies, laws, regulations, and rules or contract, grant and donor restrictions, regardless of when the approval occurred.
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1 2. Employees, associates, atliliates and other individuals (including students) responsible for making expenses using university funds have an obligation to stay current in their knowledge about, and act in compliance with, applicable policies, laws, regulations and rules, and contracts, grants, and donor restrictions, regardless of when the approval occurred. III. TESTS OF PROPRIETY These procedures are used to evaluate whether or not an expenditure is an appropriate use of university funds. The procedural statement below contains questions designed to test the propriety of expenses policy by forming an evaluation framework. An expenditure of university funds will be considered proper only ifit meets all of the tests of propriety. A. Procedural Statemcut All of the questions that follow must be answered prior to making an expenditure using university funds. In order for expenditures to be considered an appropriate use of university funds, the answer to cach of the questions must bc "yes." Is the transaction I. for official university business? 2. in the best interests of the University? 3. the most effective and rcasonable way to accomplish official university business? Meaning that, without the expenses, would programmatic objectives be difficult or otherwise more costly to achieve? Or would the impact, level, or quality of the achievement be reduced? 4. in compliance with applicable policies, laws, regulations, and rules; and contracts, grants, and donor restrictions including having the required approvals and authorizations? 5. within the available resources of the responsible unit, taking into consideration all outstanding commitments and encumbrances? 6. directly beneficial to the responsible unit where it is bcing charged? 7. in compliance with university conflict of interest provisions? !fan employee derives private gain, or appears to derive private gain. as a result of the transaction. then the transaction violates the conj7ict of interest po/iGY.
hit p:/Iwww.trinitv.edu/gtanner/ConflictoflnterestPolicv.htm hit p:1Iwww.trin itv .edu!de part mcntsl fisca I a filii rsl fapo IicvICon flict%2 00 1%20 intere st% 20Policv/BOT%20COI Policv 2009l.pdf If any of these qucstions receives a "no". then the transaction is not appropriate for university funds. Evaluating the propriety of university expenses requires a high degree of judgment and discernment. Therefore, consider the following when deciding whether or not a particular transaction is a proper use of university funds.
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Would a university outsider, such as the general public or auditor, consider the expenditure to be a reasonable and necessary expense of university funds? Would you want others such as the media knowing and reporting about what you have decided?
B. Tests of Propriety and Immediate Family Members Generally, family members are covered when it's appropriate to conduct University business, but not covered otherwise. Reimbursements for family members require the approval Ii'om the appropriate vice president or the president. C. Official Function An official function is a meeting, meal, by a department, attended by guests official university business. OtTicial program objectives and shall be limited
training activity or other function that is hosted and/or associates or employees, and held for functions shall be held to achieve University to reasonable and actual costs.
Official functions do not include events designed to sustain ordinary residential life activities, such as resident hall advisory meetings and resident hall events or activities related to external summer conferences. The following describc the most common types of official functions. This list is intended as a guide. ff an activity is not included on the list, it may still be an acceptable activity. •
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Training functions are held to enhance staff knowledge or to educate employees, associates. or other individuals that arc affected by the university's operations or regulations. Note: Training functions should have a written agenda, study materials, and be led by an identified presenter(s). Community relation functions are hosted on behalf of external entities, or are activities directly related to the educational, research, or public service mission of the university. Appreciation and employee recognition filllctions that may include meals are held for tbe purpose of acknowledging, appreciating, or honoring employees as a means of providing an encouraging and supportive work environment. Multi-department functions are infrequent events or meetings involving associates or employees from more than one department. The primary purpose of the function is to conduct University business and where the specific business purpose is noted on the receipt. Recruitment functions are held to enlist students, new employees, including faculty or post/pre-doctorates and prospective summer conferees. Retirement functions are held to honor departing or retiring faculty or staff members for their university service. Student functions are hosted for students and arc directly related to student or educational development. Examples include student recognition, student recruitment, and student programs.
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Events designed to generate alumni, donor, and business or community support for University programs where food and beverages migbt be catered at on or off campus locations. Department or division retreats. Occasional (not daily, weekly, or monthly) lunch meetings of only employees and/or official gucsts of the University. The primary purpose of the meeting is to conduct University business and where the specific business purpose is noted on the receipt.
The lollowing describe some that are not considered official functions. •
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Meals while working overtime (unless staff is required to stay in the office during a meal time, i.e. registration. open enrollment, all day Admission's Committee meetings. NCAA sporting events, summer conferences.) Lunch meetings (when such meetings can be done during the work day.) Lunches, dinners, receptions and other gatherings where the primary purpose is lor University personnel (faculty. staff and students) to informally gather for social or personal purposes and not to further specific Univcrsity program objectives. This includes birthdays, weddings, engagements, going away receptions or other "special days" such as birth or adoption of a child. An alternative to personal gatherings can be to take a collection and make unlimited gifts to colleagues for personal celebratory gatherings.
D. Sensitive Items - Additional Guidclincs The following table servcs as a quick rcference to specific sensitive or reportable expenses that departments frequcntly inquire about. Relatcd policies and/or conditions are identified to provide additional information and clarification.
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Expense Category
Permissible
1. Alcoholic Beverages
Related Policy /Conditions Alcohol Policy
a.
For official functions
Yes
b.
For employees in travel status (with meals only)
Yes
c.
For resale by a licensed establishment
No
d.
For research purposes and for purposes that do not include personal consumption (e.g., using alcohol as an ingredient used in experiments or for cleaning costumes)
Yes
e.
Grants and contracts
No
Refer to grant guidelines
2. Automobile-Related
Propriety of Expenses Policy, Section III. C Travel Policy
Expenses
a.
University owned vehicle expenses
Yes
Transportation: (1) University Autos
b.
Commercial vehicle rental, trip fares, or taxi/shuttle service
Yes
Transportation: (3) Rental Cars
C.
Private vehicle mileage reimbursement
Yes
Transportation:
(2) Private Cars
d. Airport parking fees
Yes
Transportation:
(2) Private Cars
e.
No
Transportation:
(2) Private Cars
Yes
Propriety of Expenses Policy
No
Propriety of Expenses Policy
Insurance
3. Break Room Equipment Expenses a.
Basic equipment for taking meals or snacks within the workpiace, such as simple refrigerators,
microwaves,
stoves, coffee pots, toasters, water filtration b.
Equipment for employee entertainment, such as televisions, stereo, VCRs, DVD players, HD converters
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Expense Category
4.
Departmental
Book Purchases
Permissible
Related Policy /Conditions
Yes
Books purchased with University department funds are property of the University.
5. Flowers, Fruit Baskets, and Greeting Cards a.
For decorative purposes associated with an official function
Yes
Propriety of Expenses Policy
b.
For expressing holiday, birthday or congratulation wishes
No
Gifts to Employees, Students and Others and Propriety of Expenses Policy
c.
For community relations support/indications of good. will or esteem, restricted to individuals or organizations who have, or may have, connections to the University
Yes
Propriety of Expenses Policy
d.
For expressing condolences upon the death of current students
Yes
Gifts to Employees, Students and Others and Propriety of Expenses Policy
e, For all major life events for
Yes
Gifts to Employees, Students and Others and Propriety of Expenses Policy
Yes
Travel Policy, Recruitment Policy
the employee or immediate family member of the employee (Note that major
life events, as considered by this pracedural statement, are birth, death, and significant illnesses) 6. Food, Meals and Related Consumables a,
Food and related consumable items during travel status, when conducting official university business or associated with an official function,
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Expense Category
Permissible
b.
Consumable items necessary to maintain the cleanliness of employee break room such as paper towel, dish detergent, and sponges.
Yes
c.
Beverage service (coffee/tea) available in general public or reception area of an organizational unit
Yes
d.
Meals for employees required to be at certain university events (i.e. registration In Focus admission events, NCAA playoffs, athletic preseason events, evening duty for summer conference activities)
Yes
Related Policy /Conditions
Propriety of Expenses Policy, Section III. C
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7. Internet Connections from a personal location
No
8. License Fees, Membership or Dues Fees paid to maintain a professional license or professional organization dues required by the employer are considered ordinary business expenses.
Yes
Propriety of Expenses Policy
9. Moving Expense Reimbursement
Yes
Employee Moving Policy
10. Parking Ticket violations (received either on or off campus)
No
b. University parking permits
No
c.
Yes
Reimbursable if incurred while conducting business for Trinity.
Yes
Mobile Technology Policy (forthcoming)
a.
Off campus parking fees
11. Mobile Technology Devices
a. Cellular phones - for authorized users
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Expense Category b.
Other mobile device - for
Permissible Yes
authorized users
12. Political Expenses (cash or in-kind contributions to campaigns involving
Related Policy /Conditions Mobile Technology Policy (forthcoming)
No
the nomination, retention, or election
of any person to any public office, or to urge voters to vote in favor of or against a ballot initiative) 14. Recognition, Gifts and Tokens Awards, rewards, and prizes
Yes
Income Tax on Awards and Prizes
b. Appreciation meals (where the approved meal is the award and no separate awards are given); such as departmental holiday events.
Yes
Propriety of Expenses Policy
c.
Employee recognition events
Yes
d.
For employees, associates and other individuals (including students) in the form of cash or non-cash
Yes
Gifts to Employees. Students and Others and Propriety of Expenses Policy Gifts to Employees. Students and Others and Propriety of Expenses Policy
a.
items
e.
For supporting organizations as an indication of goodwill or esteem or event-related advertisement
Yes
Gifts to Employees, Students and Others and Propriety of Expenses Policy
f.
Department donations to other non -profit organizations
No
g.
Outright purchases of clothing or other special
No
Ail requests for cash, check or purchase of charitable table event donations to other entities must be coordinated through the Vice President for External Affairs Propriety of Expenses Policy
accommodations
to non-
Trinity individuals (i.e., loss of luggage, clothing, use of University vehicle) h.
Retirement Parties
Yes
Expense Category
15. Recruiting Costs for Prospective Employees/Students
Permissible
Related Policy /Conditions
Yes
Recruiting Policy. NCAA rules must be adhered to when recruiting student athletes.
16. Tickets to events a.
Admission tickets to event purchased by University
Yes
If used for business related purposes. If used for personal consumption. tickets are considered remuneration by the IRSthus taxable to employee.
b.
For group events
No
Purchase for personal use is prohibited. See P-Card Procedural Statement
Yes
Reasonable tips are allowed (up to a maximum of 20% of actual service or good charge)
17. Tips
18. Training / Team Building Functions
a.
Work related functions or activities and their related costs, such as team-building exercises focused on the workplace, and supplies/materials
Yes
Propriety of Expenses Policy
b.
Non-work related activities and their related costs, such as non- univerSity sporting league registrations/fees and team uniforms
No
Propriety of Expenses Policy
Yes
Clothing allowances not required by the University and if approved by department are considered remuneration by the IRSthus taxable to employee. Property and Expense Policy
19. Uniforms, Work Clothes, Special Spirit Clothing (e.g., provided by campus police, facilities services, ath letics, for use at work, or by a department for use at a conference, student recruitment or other university event, i.e. TU Move In Day)
Expense Category 20. Visas, Green Cards, and/or Immigration Feesfor entry into U.S. Feesfor permits/documents as required by scholars, researchers, or employees in orderto conduct necessary university study/work and where there is a direct employment requirement by the U.S. Department of Homeland Security to obtain the permit/document (to include fees for passport/visa photos, foreign country exit fees, costs of birth/health/identity certificates, charges for inoculations ...not to include ancillary costs such as medical exams)
21. Miscellaneous, Other Clarifications. Earning frequent flyer or other reward points for airline, hotel and/or similar program expenses. a. Expenditures incurred for the employee traveling on Trinity business. b.
Expenditures incurred for group travel and other group activities.
Permissible Yes
Related Policy /Conditions Departments share in the cost of HI B visa fees. Green card labor portion of expenses paid by University as required by law. For all remaining costs, the employee is responsible for 50% of the remaining expense up to a maximum of $2,500.
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Yes
Propriety of Expense Policy, see Section A 7.
No
Propriety of Expense Policy, see Section A 7.
IV. CONTACTS The Associate Vice President for Budget and Business Operations will respond to questions and provide guidance regarding interpretation of this policy. Any exceptions to this policy must be approved by the Vice President for Finance and Administration.