TRAVEL AND ENTERTAINMENT - Northwestern University

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Approving University Official(s): Senior Vice President forBusiness and FinanceResponsible Office: Office of Financial OperationsEffective date: October 15, 2020Next review date: October 15, 2023TRAVEL AND ENTERTAINMENTPolicy StatementPurposeAudienceDefinitionsPolicy ImplementationConsequences of Violating this PolicyRelated InformationContactsHistoryPolicy StatementAll expenditures for travel, entertainment, and related expenses must support and advance Northwestern’smission of education, research, and public service. This policy establishes minimum requirements for theapproval and reimbursement of University-approved travel and entertainment expenses, as defined below.Each community member responsible for making decisions concerning such expenditures should always askwhether an expense represents an appropriate and worthy use of University funds. All travel andentertainment expenditures must be (i) documented as to business purpose, (ii) allocable to an appropriatefunding source, and (iii) approved by an appropriate supervisor.PurposeThe University is responsible for managing its resources prudently and for reimbursing expensesconsistent with legal and regulatory requirements. Accordingly, this policy provides guidance onpermissible expenditures of University funds from all sources for University-approved travel andentertainment; and outlines authority and responsibility for approval and reimbursement of such expenditures.AudienceAll members of the Northwestern community, including those authorized faculty, staff, students, andguests who travel, entertain, or extend courtesies on behalf of the University.

DefinitionsAccountable Plan: An expense reimbursement plan that satisfies the requirements of Internal RevenueService regulations by meeting the requirements of a business purpose, substantiation of the expense andpurpose, and returning amounts in excess of substantiated expenses in the case of advances. See IRSRegulations section 1.62-2(c)(2).Adequate records: Adequate records and documentary evidence, such as receipts, are needed for all lodgingexpenses, and other expenses of 40 or more; but are not required for non-lodging expenses less than 40,transportation expenses for which a receipt is not readily available, or per diem allowances for meals andincidentals reimbursed under an accountable plan and not exceeding the federal rates.Cost Allowability for Sponsored Charges: Northwestern follows the federal principles outlined in 2 CFR200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards(Uniform Guidance), including the Cost Accounting Standards contained therein, as well as specific termsand conditions of individual sponsored agreements.Scanned Receipts: Electronic copies of documentary evidence are acceptable by the IRS per RevenueProclamation 97-22; the copies must be identical to the originals and contain all of the information of theoriginal receipt.Deans and Vice Presidents: for purposes of this policy, the deans of Northwestern’s schools and the vicepresidents of its administrative units.Entertainment: meals, activities, or events provided for University purposes.In-town travel: travel within the City of Chicago and to/from/within its suburban areas, or othermetropolitan areas where Northwestern has a permanent location, with respect to employees of that location.Inter-campus travel: travel between the Evanston and Chicago campuses.Non-conventional lodging: a room, apartment, house, or other lodging that is not a hotel or motel.Per diem: a standard daily allowance for meals and incidental expenses incurred when traveling.Pre-approval review: advance notification of travel and entertainment plans before expenditures areauthorized. Administrative and academic units of the University may establish their own guidelines for thisreview.Post-audit review: review of transactions after approval and posting for conformance with policy and tomonitor effectiveness of reviews by approvers. Administrative and academic units of the University mayestablish their own guidelines for this review.University-approved travel: transportation on Northwestern business in excess of one's normal commute.University-approved travel includes movement on official University business from home or normal placeof employment to another destination, and return to home or normal place of employment from anotherdestination, but does not include commuting between one’s home and normal place of employment.

Policy ImplementationI.Allowable ExpensesExpense must meet the following minimum requirements for allowability:II. Allowable under Accountable Plan: An expense reimbursement that satisfies therequirements of Internal Revenue Service regulations by meeting the requirements of abusiness purpose, substantiation of the expense and purpose, and returning amounts inexcess of substantiated expenses in the case of advances. See IRS Regulations section1.62-2(c)(2). Adequate records Adequate records and documentary evidence, such as receipts, areneeded for all lodging expenses, and other expenses of 40 or more; but are not requiredfor non-lodging expenses less than 40, transportation expenses for which a receipt is notreadily available, or per diem allowances for meals and incidentals reimbursed under anaccountable plan and not exceeding the federal rates. Cost Allowability for Sponsored Charges: Northwestern follows the federal principlesoutlined in 2 CFR 200, Uniform Administrative Requirements, Cost Principles, andAudit Requirements for Federal Awards (Uniform Guidance), including the CostAccounting Standards contained therein, as well as specific terms and conditions ofindividual sponsored agreements. Transactions must be in compliance with Federal and State laws.Authority and Responsibility for Approving Expenses Deans and Vice Presidents are responsible for implementing this policy by assigningappropriate expense approver roles and establishing procedures for review in theapprovers’ respective areas and for authorization of exceptions to policies. Theseimplementing procedures and guidelines may be more restrictive than the requirementsin this policy and related policies. In very limited cases, when approved by a Dean orVice President and essential for University business purposes, certain less restrictiveexceptions may be granted. Review procedures may include a combination of preapproval and post-audit reviews. A process should be established within each school andadministrative unit for the timely submission, authorization, review, and approval oftransactions; such processes should have sufficient controls to mitigate the potential forunauthorized expenditure of University funds. Recommendations on best practices canbe found here. Guidance on electronic workflow approval roles and responsibilities is available on theAccounts Payable website. Standards for Business Conduct may be found here. The Provost and Senior Vice President review and approve expense reimbursementrequests submitted by Deans and Vice Presidents, respectively. The President reviewsand approves expense reimbursement requests submitted by the Provost and Senior VicePresident.

III.All transactions are subject to review and audit. Northwestern’s Accounts PayableDepartment (Accounts Payable) periodically reviews expenses for reasonableness andconsistency with this policy and related guidelines. Northwestern’s Office ofAccounting Services for Research and Sponsored Projects (ASRSP) reviews expensescharged to sponsored accounts. Northwestern’s Internal Audit Department conductsroutine audit activities to evaluate whether travel and entertainment expenses areappropriate, accurate and in compliance with the appropriate policies.Specific transaction requirements Timing of reimbursement requesti. Reimbursement requests must be submitted within 90 days after completion oftravel/incurrence of non-travel-related expense. Late submissions require additionalsubstantiation and supervisor review per University 90-day Policy.ii. Reimbursements to individuals will not be made prior to completion of travel toensure business activity is performed. Documentation of Expensesi. Documentary evidence, such as receipts, are required for all lodging expenses, andother expenses of 40 or more.ii. Receipts are not required for: non-lodging expenses less than 40 transportation expenses for which a receipt is not readily available per diem allowances for meals and incidentals reimbursed under anaccountable plan and not exceeding the federal rates.iii. Electronic copies of documentary evidence, such as scanned receipts, areacceptable by the IRS per Revenue Proclamation 97-22; the copies must beidentical to the originals and contain all of the information of the original receipt.Additional documentation guidance is available here. Unallowable on a sponsored programi. The costs listed here are not allowable as a direct cost on a sponsored program: Airfares, Business or Premium Economy class – Business or premiumeconomy class travel is reimbursable only with advance written approvalof the sponsor and when the scheduled flight time, including stopoversand change of planes, is in excess of 12 hours. (Cost accounting note:The additional cost of a business class fare over the coach fare is afederal unallowable cost and must be segregated in a separate nonsponsored chart string. Documented medical exceptions are allowable.) Alcohol

IV. Expenses associated with the recruitment of faculty Passports, vaccinations, and visas, when not required as a specific andnecessary condition of the travel assignment. Only certain visa fees areallowable on sponsored projects. A current list of allowable fees can befound here. Meals for in-town conferences Expenses related to amusement, diversion, and social activitiesTravel Non-Reimbursable Travel Expendituresi. Expenses not directly related to the performance of the travel assignment arenon-reimbursable, regardless of funding source. Examples of Non-ReimbursableTravel Expenditures include, but are not limited to: Books, Magazines, Newspapers for personal use Child-care, babysitting, adult or senior care, house-sitting, petsitting/kennel charges Commuting between home and campus Costs incurred by traveler's failure to cancel transportation or hotelreservations in a timely fashion Evening-wear rentals; formal wear expenses Flowers Gifts Haircuts and personal grooming Laundry and dry-cleaning; shoeshine services Passports, vaccinations, and visas, unless required as a specific andnecessary condition of the travel assignment Fees for visas, passports, vaccinations, and prophylacticprescription medications are allowable when they are a specificand necessary condition of fulfilling a work assignment onbehalf of the University. Reimbursement of visa fees is allowable where foreign travel isauthorized as part of a sponsored program budget and a visa isnecessary for travel. Only certain immigration fees are allowableon sponsored projects.

Personal entertainment expenses including in-flight movies, headsets,health club facilities, hotel pay-per-view movies, in-theatre movies,social activities, and related incidental costs Travel accident insurance premiums and/or purchase of additional travelinsurance (with the exception of international health insurance) Because Northwestern provides travel insurance coverage forfaculty and staff traveling on University business, separateinsurance is not eligible for travel expense reimbursement. Faculty and staff are covered by the University’s blanketaccidental death and dismemberment insurance while onapproved travel outside the city or cities in which they resideand/or normally work. Such insurance does not covercommuting between home and normal work sites or traveling inaircraft other than commercial or approved charter aircraft. Thebeneficiary is the same as the beneficiary designated under theNorthwestern University Group Life Insurance program.Additional coverage guidance is available here.Spouse or Dependent Expenses Incremental costs for travel, lodging, meal, or other travelexpenses for spouses or other dependents will not be reimbursed. Although spousal travel generally is not reimbursable, anexception may be made when the University requires the spouseto attend an event as a condition of one’s work assignment. Theexception generally should be limited to deans and seniorofficers, and should occur infrequently; see here for additionalguidelines.Per Diem Requirementsi. Per diems are permissible for meals and incidental expenses (M&IE) forauthorized business travel. For M&IE, the reimbursement method selected mustbe used for the entire trip and should be established ahead of the trip.ii. For lodging, all actual expenses must be supported by receipts.iii. Per diem allowances shall not exceed the maximum stated by the government'spublished standards, including only 75% of the per diem rate on the first and lastday of travel. In the case of travel charged to a sponsored program, thereimbursement arrangements may require prior sponsor approval.iv. Additional per diem guidance is available here. Specific Transportation Expenses

i. Airfares/Airline Fees First class travel is generally not allowable. Airfare classes other thaneconomy (such as Business Class) are permitted when scheduled flighttime, including stopovers and change of planes, is in excess of 7 hours,and when using non-sponsored sources of funds. Airlines continue to add distinctions of economy seating as a mechanismto price-separate consumers. In cases where an “Economy Plus” ticket isa reasonable additional cost on non-sponsored travel and provides forcertain benefits to improve the travel experience, such fare class isallowable. Premium fares may not be charged to a sponsored program. If travel is on a sponsored program, the sponsoring agency may haveadditional restrictions and require advance approval. For guidance, seeASRSP’s travel webpage. Travel services and arrangement guides may be found on Northwestern’sTravel website.ii. Foreign Air Carriers Foreign carriers are allowed on non-sponsored sources of funds. Foreign carriers are restricted on sponsored programs. For guidance, seeASRSP’s travel webpage.iii. Ground Transportation Reimbursable ground transportation to or from a destination includestravel between hotels and railroad stations or airports, betweenappointments, or between hotels and places of temporary duty. Direct billing arrangements for ground transit options are not allowed foremployees. Direct billing arrangements for University guests are permitted foroffices that have responsibility for frequent coordination of guest visitsand must be approved in advance by Procurement and Payment Services. For units authorized for direct transportation billing, a log of Universityguests or employees using the service must be maintained, the businesspurpose recorded, and proof of reconciliation of the billing to the logmaintained. Guidance on the use of ground transportation services for Universityguests is available here.

iv. Commercial Rental Vehicles Incidental costs associated with the use of a rental vehicle, includingparking fees; tolls; fuel may be reimbursed. Collision damage waiver (CDW) coverage is reimbursable only forinternational rentals. Additional commercial vehicle rental and insurance guidelines areavailable here.v. Private Air Carrier The use of private aircraft for University business is generally prohibited.However, if a determination is made that private aircraft travel isessential to the achievement of a critical University business objective,the Provost or Senior Vice President may approve in advance selectUniversity personnel for private aircraft travel. Such events must followthe University’s Protocol for Private Air Travel. The University reserves the right to refuse reimbursement of expensesrelated to private aircraft use if there is no consultation in advance of Private Automobile Transportation Travel on University business using privately-owned vehicles isreimbursed based on IRS reimbursement rates. Tolls and parking charges may be reimbursed in addition to the mileageallowance. Repairs to the vehicle and charges for parking and moving violations arenot reimbursable. Additional guidance on travel by private automobile is available here.vii. Intercampus and In-Town Travel Inter-campus and in-town travel is generally not reimbursable as theUniversity provides transportation solutions to address this need, but inlimited cases with business justification, Deans and Vice Presidents mayelect to approve such in-town or inter-campus expenses.Specific Lodging Expensesi. Travelers will be reimbursed for actual cost of lodging. Guidelines andrecommendations for reserving accommodations are available here.ii. Non-conventional Lodging

Rentals of non-conventional lodging are reimbursable. If lodging with family or friends, employees may be reimbursed foradditional costs the host incurs in accommodating them. When an employee rents a room, apartment, house, or other lodging on along-term basis (weekly or monthly), additional expenses may beconsidered part of the lodging cost; guidelines for such expenses areavailable here.Meals while Travelingi. Expenses for meals while traveling are reimbursable under the actual cost or perdiem reimbursement method (see Per Diem Requirements).ii. Meals including multiple other individuals must be supported by listing namesand relationship of individuals to the University on the expense report, and thebusiness purpose of the meal.iii. Recommendations for reimbursement guidelines are available here. Other Travel Expendituresi. Taxes on travel lodging, meals, and business entertainment services are allowableand reimbursable.ii. Telephone/Other Communications/Internet Costs for telephone and other communication methods during travel arereimbursable. Guidelines on international communications are availablehere. Charges for Internet connections for business use at hotels, conferencesites, airports, airplanes and cafes while traveling are reimbursable.iii. Tips and gratuities associated with baggage handling, storage, and other servicesare reimbursable. When the per diem method of reimbursement is used, thisexpense is covered by the incidentals portion of M&IE. Travel of Non-University Personneli. Non-University personnel (including guest lecturers, researchers, consultants,research subject participants, and prospective faculty or staff) may be reimbursedfor travel expenses incurred for authorized University business purposes andsubject to University travel policies and procedures. Additional guidelines andconsiderations relating to visitor travel are available here.V.Entertainment

Entertainment costs are reimbursable using non-sponsored sources of funds per discretion ofDeans and Vice Presidents and when deemed to support University objectivesThe following events are subject to these spending thresholds: University Funded Eventsi. Two events in the following categories each year, with a 30 per personmaximum, per event, including facility costs. Annual Holiday Parties General appreciation party or event Retreatsii. Social entertainment that is essential for fulfillment of leadership duties. Theseevents may occur in personal residences, in University space or outside theUniversity, with a 30 per person maximum, per event, including facility costs.iii. Certain departmental, social and life events, with a 15 per person maximum, perevent, including facility costs. School-wide or departmental meetings Committee, society, and other faculty organization meetings Faculty/Staff retirement from Northwestern events Social events for the purpose of introducing new faculty andstaffiv. Events for which University funds may not be used Events that do not have a specific University business objectivepurpose should be funded by the par

Travel accident insurance premiums and/or purchase of additional travel insurance (with the exception of international health insurance) Because Northwestern provides travel insurance coverage for faculty and staff traveling on University business, separate insurance is not eligible for travel expense reimbursement.

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