º£½Ç¹Ù·½Ê×Ò³ Food and Business Meals Expense
VIII-99.00(A) | Financial Affairs | Approved February 4, 2014
Responsible VP/AVP: Dawn M. Rhodes, DBA, MBA
Applies to: Faculty, Staff
Revision History
Policy Effective: February 1, 2014, Revision of A&F Policy 3332
Required By: State of Maryland General Accounting Division Guidelines
Purpose
To describe and provide some examples of allowable and unallowable business meal reimbursements and food purchases using º£½Ç¹Ù·½Ê×Ò³ funds in order to meet:
1.Maryland General Accounting Division requirements
2.Internal Revenue Code accountable plan requirements
3.Federal cost regulations under OMB Circular A-21
Policy Statement
Expenditures for food must be in accordance with State requirements, reasonable, necessary, and part of a documented bona fide business function of the University of Maryland, Baltimore (º£½Ç¹Ù·½Ê×Ò³). Expenditures must not be for events considered to be routine meetings, gatherings that are primarily social in nature, or purchase of alcoholic beverages. Within these guidelines, the local hosting of an event and purchase of food/catering services or business meals in support of º£½Ç¹Ù·½Ê×Ò³ business may be allowable use of º£½Ç¹Ù·½Ê×Ò³ funds.
Department approvers have the right to reject all or part of the reimbursement requests at their discretion.
Allowable Expenses:
Using º£½Ç¹Ù·½Ê×Ò³ funds to pay for business meals or food/catering services may be appropriate in the following circumstances:
- Interviews of an applicant (and the applicant’s spouse, if invited) for employment by official º£½Ç¹Ù·½Ê×Ò³ host(s) for positions of Faculty, Department Heads, Directors, Deans, Vice Presidents and President.
- Meals with prospective students.
- Meals for visiting scholars and faculty.
- Meals for distinguished guest speakers/lecturers.
- Meetings with business leaders outside º£½Ç¹Ù·½Ê×Ò³ for the purpose of developing student interaction, future contributions to programs, or developing business relationships benefitting º£½Ç¹Ù·½Ê×Ò³.
- Meetings with colleagues from other universities to discuss university research, instruction, administrative functions, etc.
- Business meals where external consultants are participating in official º£½Ç¹Ù·½Ê×Ò³ business.
- Conferences, convocations, symposiums and other special events which are on behalf of or substantially involve personnel not employed by º£½Ç¹Ù·½Ê×Ò³.
- Events where participant fees are collected to offset the food cost (e.g., a conference).
- º£½Ç¹Ù·½Ê×Ò³-wide events coordinated through the Office of Communications and Public Affairs to promote or further º£½Ç¹Ù·½Ê×ҳ’s mission (e.g., commemoration of Dr. Martin Luther King Jr. during Black History Month).
- Student events and student related functions (note- postdoctoral fellows, residents, and trainees are not students).
- Food or meals for activities that are specified as allowable charges under a grant or contract.
- Donor cultivation events.
- Employee-only full or half-day workshops, seminars, conferences, retreats, etc., where the event overlaps routine meal times.
- º£½Ç¹Ù·½Ê×Ò³-wide employee awards/appreciation events coordinated through the Department of Human Resource Services (within º£½Ç¹Ù·½Ê×Ò³ University Operations).
- Meals during unusual hours or at unusual places of work for employee groups performing required º£½Ç¹Ù·½Ê×Ò³ services (e.g. weekend meetings or emergency-related activities).
- Meetings with affiliates for three or more hours where the offices of the attendees are more than 5 miles apart.
Unallowable Expenses:
Business meals or food/catering services are not appropriate in the following circumstances:
- Personal meals among º£½Ç¹Ù·½Ê×Ò³ employees.
- Routine (see definitions) meetings among º£½Ç¹Ù·½Ê×Ò³ employees (e.g. faculty and/or staff meetings).
- Meals during general discussion meetings among employees.
- Costs associated with social functions or activities such as (but not limited to) birthday parties, holiday parties, retirement parties, Administrative Professional’s Day events, etc.
- Expenses for food that are subsequently reimbursed by the º£½Ç¹Ù·½Ê×Ò³ Foundation or any affiliated entity.
- Purchase of alcoholic beverages (including related tax and tip).
- Functions where one or more students are present but the primary purpose of the meeting is not student related.
- Other expenses not listed under allowable expenses.
Dollar Limitation Guidelines:
The following guidelines are provided to assist faculty and staff in determining what food costs are reasonable within the broad array of events and situations that arise in the course of campus business.
1.Individuals must apply a prudent and reasonable approach to business meals. The reasonableness of an expense depends upon many relevant factors, including the business purpose of the event and the location. The maximum amount of expense allowable for business and catered meals for one person in one day (including tax and tip) is one and one half (1 ½) times the maximum per diem rate set by the federal government (US General Services Administration). Refreshment or snack expenses are set at the breakfast rate. Click HERE for the current Business Meal Rates.
2.Departments have the authority to limit or prohibit reimbursement or payments based on availability of funds, availability of lower cost alternatives, specific requirements of funding sources, or reasonableness. Established meal rates are maximums and should not be considered entitlements.
3.Amounts in excess of these guidelines may be permitted based upon circumstances including location. Expenditures that exceed these guidelines must be justified by the department and approved in writing by the President or his/her designee.
Definitions
Affiliated Entity- An entity that has a relationship with º£½Ç¹Ù·½Ê×Ò³ authorized by the Board of Regents or by law, e.g., faculty practice plan organizations, º£½Ç¹Ù·½Ê×Ò³ Foundation and other affiliated foundations, recognized incorporated alumni associations, affiliated business entities, the University of Maryland Medical System/University of Maryland Medical Center, and other University System of Maryland institutions.
Business Meal- A meal, generally occurring off campus, involving one or more non-º£½Ç¹Ù·½Ê×Ò³ employees where the business purpose for the expense is clearly identified.
Employees- Includes all º£½Ç¹Ù·½Ê×Ò³ employees (staff, faculty, residents, and postdoctoral fellows; regular, contingent I and contingent II), trainees, and employees of Affiliated Entities.
Food/Catering Services- The purchase of meals or refreshments served on º£½Ç¹Ù·½Ê×Ò³ property or at an off-campus location for a group of people.
IRS Accountable Plan- An accountable plan is a method for reimbursing employees for business expenses that complies with IRS regulations. If the IRS rules for an accountable plan are maintained, reimbursement paid to employees is not required to be treated as taxable income.
Routine- In the context of frequency or types of meetings- a meeting is routine when it is regularly scheduled or recurring on a periodic basis (i.e. weekly, bi-weekly, monthly, quarterly, annually, etc.) for the same group of people.
º£½Ç¹Ù·½Ê×Ò³ funds – All funds administered by º£½Ç¹Ù·½Ê×Ò³, regardless of fund source. º£½Ç¹Ù·½Ê×Ò³ funds include State Appropriations, Auxiliary funds, Revolving/Discretionary funds, Designated Research Initiative Funds, Contracts or Grants, and Other Restricted funds.
Scope and Exceptions
Scope:
This policy applies to all food and business meal purchases with º£½Ç¹Ù·½Ê×Ò³ funds. The requirements stated in this policy apply when reimbursement or payment is being requested directly from º£½Ç¹Ù·½Ê×Ò³. The policy also applies when reimbursement or payment is being requested from an affiliated entity and subsequently reimbursed by º£½Ç¹Ù·½Ê×Ò³.
Limitations:
1.This policy does not apply to food/meal purchases during travel that are covered under º£½Ç¹Ù·½Ê×Ò³ Policy VIII-11.00 (A) – º£½Ç¹Ù·½Ê×Ò³ Policy on Travel.
2.This policy does not apply to personal meal purchases related to employee relocations.
3.This policy does not apply to food that is purchased for resale by º£½Ç¹Ù·½Ê×Ò³ (e.g. Donaldson Brown Center).
Exceptions:
Exceptions to this policy must be approved in writing by the CAFO. All requests should be in the form of a memo to the CAFO signed by the Dean/Vice President or the Dean/Vice President’s designee (e.g., an appropriate Associate Dean or Associate Vice President).
Roles and Responsibilities
The º£½Ç¹Ù·½Ê×Ò³ employee responsible for an event or meal involving food cost reimbursement must:
Submit all appropriate supporting documentation for food purchase or meal reimbursement.
Ensure that all food purchases and meal reimbursements are appropriate and in compliance with campus policy and Financial Services procedures.
Obtain appropriate approvals for food or meal reimbursements.
The Department of Financial Services under the direction of the Chief Administrative and Finance Officer (CAFO) is responsible for establishing procedures to promote compliance with this policy and adhere to IRS accountable plan requirements.
Employees who improperly submit and approvers who improperly authorize the use of º£½Ç¹Ù·½Ê×Ò³ funds may be subject to disciplinary action. Purchases for food using º£½Ç¹Ù·½Ê×Ò³ funds that are not in accordance with this policy must be reimbursed to º£½Ç¹Ù·½Ê×Ò³ from external funds (e.g., Foundation funds or personal funds).
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