Business-Related Hospitality and Entertainment Expenditures Guideline Changes
OVERVIEW Guideline Changes were made to: • Streamline requirements • Be responsive to issues raised by various individuals/divisions • Remove superfluous or confusing language • Clarify certain requirements
II. Authority • Added reference to Internal Revenue Service (IRS) III. University Guidelines • Allowable Expenditures • Expenditures must meet the IRS definition of directly-related or associated test
III. University Guidelines (continued) B. Allowable Expenditures(continued) • Administrative/Business Meeting – updated • Removed restriction that disallowed use of university funds to provide refreshments other than water or coffee • Replaced with: Light Refreshments may be appropriate for certain meetings (but not necessarily on a routine basis) • Light refreshments should not exceed the limit established for breakfast and lunch.
Allowable Expenditures (continued) • Spouse or Partner of a UTSA guest or UTSA host • Cost of meals may be reimbursed provided event serves a bona fide University business purpose • Official functions to which a spouse or partner are invited as matter of protocol or tradition may be considered a bona fide business related activity.
C. Student Oriented Special Programs • Renamed Special Events • To Student Oriented Special Programs and Events • Modified Eligibility and requirements • Allows for recurring special programs and events to complete a “Blanket” BEF for pre-authorization when the event is student focused. • Reduces the BEF paperwork for multiple reimbursements and/or ProCard charges • Blanket authorization • Completed BEF • Estimate of total expenditures • Anticipated dates of events (or range of dates for similar programs) • List of potential vendors or individuals to be reimbursed
E. Expenditure Limits • Flowers • Modified restriction that the expenditure limit will not exceed $100 per individual to • The expenditure limit generally will not exceed $100 per individual F. Disallowed Expenditures and Exceptions 8. Reimbursement for state sales tax • Tax exemption certificate should be provided to merchant/vendor for all cash purchases of goods or services; • Reimbursement may be allowed on supplies & related materials on an exception basis when individual was required to pay taxes; • Reimbursement of taxes on restaurant charges for meals are always allowed.
H. Reimbursement Procedures • Completed and approved BEF must be submitted within a reasonable period of time • Changed for consistency with IRS accountable plan requirements to review the circumstances surrounding untimely reimbursement requests. • UTSA has interpreted a reasonable period of time to be 90 days. • Past 90 days, must have an explanation based on facts and circumstances for the delay. • Requires approval by University Controller or designee. • Repeat offenders may require Vice Presidential approval.
H. Reimbursement Procedures (continued) • Allows one BEF for multiple receipts for multiple events to one individual • BEF is no longer required for advertising specialties and promotional products provided at training programs, seminars or institutional functions • If parking is the only expense incurred • Use the Mileage/Parking Log form
H. Reimbursement Procedures (continued) 3. Certifying the completed BEF Note: Only one event host and one administrator are required to certify each BEF – unless additional approval is required by guidelines A. Event Host: • An employee present at the event certifying expenditures are in accordance with guideline, or • Normally the individual who is requesting payment or reimbursement. However, that is not a requirement as often individuals within the department may purchase items for events to which they do not attend.
H. Reimbursement Procedures (continued) 3. Certifying the completed BEF (continued) • Administrator Approval • Designated approver of entertainment and hospitality expenses • Must be either a Assistant/Associate Dean, Assistant/Associate VP, VP or the President • Not the same as the account administrator • President or VP event host, then VPBA must approve
H. Reimbursement Procedures (continued) 3. Certifying the completed BEF (continued) C. Additional Approval is required 1. The maximum allowable per person limit is exceeded • Appropriate VP must approve • VP signs as administrator – no additional approvals are required, unless VP is event host 2. The total cost per single event exceeds $5,000 • Appropriate VP approval required • Additional approval is not required unless VP is event host
H. Reimbursement Procedures (continued) • 3. Certifying the completed BEF (continued) • C. Additional Approval is required • 3. When requesting other exceptions to policy • Appropriate VP approval required • Additional approval is not required unless VP is • event host • 4. Expenditures for Table Sponsorships • Vice President for University Advancement or • designee must approve
I. Accounting Object Codes • Object Code 1302 – Social Club Dues • Cost of President/Provost approved individual social memberships & business related club dues, such as Rotary • Object Code 1309 – Official Student Occasions • Cost of food, beverages, catering charges room rental and related expenditures associated with student official occasions
IV. Definitions • Per IRS regulations §1.274-2 (c) and (d) • Associated Test • Active conduct of the employer’s business and • Directly before or after a substantial business discussion • Directly Related Test • Main purpose is the active conduct of business • Business conducted during meal period and • General expectation of deriving income or specific benefit in the future
IV. Definitions (continued) • Light Refreshments • Non-alcoholic and edible items commonly served between meals, but not intended to substitute for meals, such as tea, coffee, soda, bottled water, doughnuts, cookies, fruit or similar items. • Buffet line, sandwich line, heavy hors d’oeuvres or similar fare is notconsidered to be light refreshments