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Compliance
This section contains policies and guidelines explaining the College’s requirements and expectations for appropriate use of institutional funds during the course of day-to-day operations and also business travel and entertainment while representing Gettysburg College. All purchases and expenditures made with College funds must meet the business standards of ordinary, necessary, and reasonable, have a legitimate business purpose in relation to College department and/or program activities, comply with federal tax regulations, and must not conflict with the College’s not-for-profit status. These requirements are defined by federal, state and local government regulations and are supported by not-for-profit accounting standards. These policies and guidelines apply to all payment types - check, purchasing card, ACH/EFT, and internal departmental charge.
The College’s operating budget funds most department and program expenses. Our students’ tuition payments and donations to the College’s Annual Fund substantially fund our operating budget. As fiduciaries of these resources, individuals with departmental or program procurement authority are responsible for committing budget resources efficiently and effectively to meet the needs of the department or program.
At their discretion, College departments and programs may impose more restrictive expense rules than those stated herein, but no department or program may set forth lesser restrictions than those stated.
The following expense policies assure compliance with the legal requirements of not-for profit educational institutions. There may be unusual circumstances when a non-allowable expense incurred by an employee will be paid by the College. If so, the employee, as beneficiary, may incur an income tax liability and will be so advised. The following expense guidelines align with best practices of like organizations and support equitable operations across College departments.
Acquisition of goods and services for department requirements is limited to employees with procurement authority as defined by College policy. Budgetary responsibility, including monitoring and oversight remains with the director of the budgeted department. Compliance with all fiscal policies and procedures is required of all College purchasing and contracting agents.
Buyers
Sales Tax
Buyers are required to utilize exemptions and purchase tax free whenever possible. Sales and use taxes are typically levied on retail purchases, and on the consumption, rental or use of tangible personal property. Most of the College’s purchases are eligible for exemption. The College's status as a nonprofit educational institution allows the College to apply for exemption from sales and use tax in locations where we conduct substantial business. Sales and use taxes are governed at a state or local level and exemptions vary. The College holds exemption certificates in the District of Columbia, Florida, Maryland, Massachusetts, New Jersey, New York, Pennsylvania and Virginia. Please be aware that sales tax exemption does not extend to hotel occupancy tax, which must be paid on room rentals for College employees in any locale.
Department Charge System
Department business purchases at the bookstore, all dining venues, or the Majestic Theater should be made utilizing the direct department charge system in place at these locations. This method is preferred over use of a pcard or requesting reimbursement for campus business expenses.
Gifts/Prizes/Awards
The College has established practices whereby gifts are made from time to time by the Human Resources Office to employees in recognition of various professional or personal events. Departments, programs, or student organizations may make additional gifts with College funds in the following circumstances only:
To Employees
Memorial/Remembrances
The value of a gift expressing sympathy or a health related acknowledgement of an employee or employee’s family member cannot exceed $75 and it must be in the form of tangible goods (flowers, fruit basket, etc.). Gift cards are not allowed for this purpose.
Retirement/Resignation
The value of a gift expressing congratulations and good wishes upon the departure of a long standing employee cannot exceed $50 and must be a tangible gift. Check or gift cards are not allowed. Departments may also host a modest reception or meal.
Appreciation
The value of a gift to recognize years of service or extraordinary service (to augment Pillars and Years of Service awards) cannot exceed $50. When a check or gift card is given, the amount is taxable income to the employee and the required payroll taxes will be withheld from a future paycheck. A tangible gift less than $50 is not taxable.
Prizes
From time to time the College holds events where prizes are awarded (drawings, raffles, etc.) An employee receiving a tangible prize not exceeding $50 or a gift card from a College venue will not be taxed on the prize. If a gift card to an entity outside of the College is awarded, the amount of the gift card is taxable income to the employee and the required payroll taxes must be withheld from a future paycheck.
Not Allowed
College funds cannot be used to purchase gifts to recognize employees for holidays and personal events (birthday, wedding, birth, housewarming, promotion, etc.). Such purchases must be paid for with personal funds and cannot be commingled with or facilitated by College accounts.
To Students (Excluding Scholarships and Fellowships)
From Department
It is recommended that any gift/prize/award for a student that is purchased with department operating funds, be tangible (plaque, trophy, etc.) and not exceed $50.
College and Department Awards
Prizes and awards funded from endowed or other restricted funds must comply with the conditions governing the funds. These types of prizes and awards are typically paid to the student by College check and are taxable.
Taxability
If a student receives more than $600 (check and gift cards) in gifts/prizes/awards during a calendar year, the College must issue a form 1099-MISC to the student for income tax reporting. If a student is a non-resident alien additional tax withholding may be required at the time of award.
To Non-Employees
Outside Organizations
Institutional gifts associated with College operations and community support are considered and approved by President’s Council. Donations of College funds from department operating budgets to outside organizations are generally not allowed. The exception is a gift in memory of an employee or employee’s family member per the Employee section above.
Appreciation/Thanks
Tangible gifts of appreciation when an overnight stay is provided must not exceed $100 and for all other occasions may not exceed $50.
Travel
Transportation
Employees
Standard air, rail, and vehicle rental accommodations with the least costly fare that meets scheduling needs are allowed for employees traveling on College business. Traveler must pay for any personal preference upgrade.
Use of a personal vehicle is allowed for regional short duration or day trips and usage is compensated at the prevailing mileage allowance rate. Mileage reimbursement is limited to the lesser of the computed amount or the cost of public transportation to destination. Insurance coverage on the vehicle driven applies. Be aware that use of personal vehicle when transporting other employees, students, or College guests is potentially problematic. The College’s insurance does not provide coverage to its employees, students, or guests while traveling in a private vehicle on College business. In the event of an accident or loss, the coverages on the vehicle driven prevail and may not provide adequate protection for the vehicle owner.
Travel Insurance is an allowable expense when the desired coverage is not available through the College’s insurance and coverages through our VISA program. Buyer beware: Travel insurance offered as a booking add-on rarely provides for refunds or re-ticketing. Travelers may be asked to justify the purchase.
Rental Vehicle Insurances – Loss Damage Coverage, and/or Personal Accident Insurance, and/or Additional Liability Insurance offered by a vehicle rental company should be declined at point of service. The College will not pay for these excess coverages as it maintains comprehensive, collision, and liability insurance on all vehicles rented or leased in its name.
Employee with Spouse/Partner/Dependent
Expenses of a spouse, partner, dependent or another accompanying an employee to a business related event are not allowable unless their presence is required and benefits the College. Reservations for non-allowable companion travel are not to be made with College funds. The employee must use a personal form of payment when booking arrangements together and seek reimbursement for their portion.
Employee Travel with Compensation
College funds are not to be used for transportation, lodging, meals, or other expenses related to travel for an event for which the employee will be personally compensated with no expectation or requirement to donate such compensation to the College. Personal resources must be used for all bookings and related expenses.
Expenses are allowed when employee’s engagement relates to job expertise and they are nominally compensated (< $250), not compensated at all, or the College is paid directly for employee’s services. All reimbursements received for allowable expenses from event sponsors are due to the College.
Students
For students traveling for College programs and/or events, the Employee section above applies.
Guests
The Employee section above also defines allowable transportation expenses of College guests such as candidates, lecturers, and other invited visitors when the College is contractually bound to pay travel expenses or when pre-approved by the sponsoring department head. Best practice is for guests to make and pay for their own transportation services. Providing these personal services may be beyond the scope of departments. Additionally, guests are not covered by the College’s insurances until they arrive on campus and they may derive personal benefits from direct payments to travel providers.
Lodging
All College Business Travelers
Standard business lodging accommodations at mid-market properties are allowed. Regional price variances are acknowledged. The College is not exempt from hotel occupancy taxes but our sales tax exemption applies to properties in PA, MD, DC, NJ, NY, VA, FL, and MA.
Personal expenses incurred during stay are not allowed and must be paid for with personal funds upon check out. Examples are: laundry services, fitness center, in-room movies, adult beverages, etc. This also includes any companion related expenses.
“No Show” charges are not an allowable expense.
Overnight stays by employees near campus for reasons of scheduling convenience (as opposed to campus emergencies) must be pre-approved by employee’s divisional vice-president and will be additional taxable income to the employee. Written approval must be submitted with expense report.
Overnight Stay with Friends and/or Family – the purchase of a meal with hosts or a tangible gift to express gratitude is allowed but limited to $100.
Meals and Refreshments
Personal Meal/Non-Entertainment Expense
Those incurred by employee when traveling out of the local area on College business are allowed. The actual cost of the meal with gratuity applies. Documentation submitted for meals should include itemized receipts.
The College does not provide a per diem meal allowance but departments may have established thresholds. Confirm your department’s expectations.
Alcoholic beverages included with personal meals are not institutionally prohibited but may be restricted by departments. Confirm your department's expectations.
Business Meal/Entertainment Expense
Those incurred by employee when the meal includes individuals invited as guests of the College for business reasons are allowed. Guests may include, but are not limited to, students, candidates, prospects, lecturers, etc. The actual cost of the meal with gratuity applies. Documentation submitted for meals should include itemized receipts and must include the names of attendees and the business purpose for the expense.
The College does not provide business meal allowances but departments may have established thresholds. Confirm your department’s expectations.
Alcoholic beverages included with business meals are not institutionally prohibited but may be restricted by departments. Confirm your department's expectations.
Spouse/Partner/Dependent Meal Expense
The cost of a spouse, partner, dependent or another accompanying an employee to a business meal is not allowable unless their presence is required and benefits the College. On occasions when companions attend on a non-business basis, their meal must be paid for with personal funds. In these instances, the bill must be paid for with employee personal funds and a submission made for reimbursement of the employee business expense portion.
Employee Only Meals/Refreshments
Meals/refreshments involving only employees are allowable:
- When employees have a meal together while traveling away from home on College business
- When a department is hosting an interdepartmental meeting or event. (E.g. Financial Services provides continental breakfast for its annual FYE information sessions.)
- When the meeting is held at a College dining venue
- Names of attendees must be provided
- Business reason for meeting is provided and clear. (e.g., Debrief on candidate interviews)
- When meals or refreshments are consumed during a business meeting.
- Names of attendees must be provided
- Business purpose for meeting is provided and clear (e.g. Debrief on candidate interviews)
- Alcoholic beverages included with employee only events are not institutionally prohibited but may be restricted by departments. Confirm your department's expectations.
Intra-Department Meals/Refreshments/Meetings/Events
College funds may be used to provide food and beverages for intra-office functions when:
- The business purpose for the meeting is clearly stated.
- The event celebrates an academic or professional achievement or milestone. The costs for office recognition of birthdays, holidays, showers for babies or weddings, etc. are not College business expenses and must be paid for with personal funds and cannot be commingled with or facilitated by College accounts.
- Alcoholic beverages included with employee only events are not institutionally prohibited but may be restricted by departments. Confirm your department's expectations.
Break Room and Office Provisions
Departments may use College funds to provide office typical hot beverages and bottled or dispensed water for employees and also snacks intended for and available to students in departmental lounges, study areas, etc. This includes related equipment and serving supplies. All other desired snacks and beverages for employees should be paid for with personal funds collected from department members. Purchases of this nature cannot be commingled with or facilitated by College accounts.
Meals for Teams and Student Groups
Per diem meal allowances are permissible for student groups in reasonable amounts determined by the program budget but cannot exceed $50 for all meals in a day. This is the 2019 PA regional per diem meal allowance pursuant to IRS regulations.
Department Events
Retreats/In-service/Training
Recommended and preferred locations for convening working groups away from usual environs are campus venues, Majestic Theater, and Gettysburg Hotel. Costs must not exceed $100 per person per day. This includes venue, meals, set-ups, etc.
Department Good Will Outings
One social event for department employees per year is allowed. Cost may not exceed $25 per employee. Cost includes all related expenses such as tickets, refreshments, transportation.
Restricted External Funds
All purchases, including travel expenses, charged to a federal or privately sponsored grant are governed by the terms of the applicable award which take precedence over this policy. Terms of this policy apply where the fund instrument is silent. The adherence of fund usage is the responsibility of the principal investigator, chair, or director charged with administration of the award.
Donor Restricted Funds
The College is legally obligated to follow donor directives regarding the use of their gifts. Terms of this policy apply where the fund instrument is silent.
Provost Awarded Funds
All purchases, including travel expenses, charged to any of the various faculty support accounts (e.g. Professional Papers, Start-Up, RPDs, Field Trip, etc.) are governed by the terms of the applicable award that take precedence over this policy. Only expenses identified in the award may be purchased with these funds. Terms of this policy apply where the award document is silent. Compliance with the expressed conditions of the award is the responsibility of the grantee.
Sabbatical and/or Research Leave
Expense allowances and restrictions of financial support for a leave are defined by the funding documents. Only expenses identified in the award may be purchased with these funds. The cost of temporary housing, utilities, communication services, and vehicle use if away from home for more than 10 days, are not allowable unless specifically provided for in the funding document. Terms of this policy apply where the award document is silent.
Non-Allowable List
The sections above identify allowable expenses in broad context. Below are some specific expenses not permitted for purchase or reimbursement with College funds:
- Personal expenses are purchases either made in error with College funds or non-compliant with College policy and procedures. They include those in above and below sections but may not be limited to those identified herein:
- Cost of care for family members, pets, houses, etc. for traveling employees
- Cost of commuting to/from normal work location
- Cost of an employee’s home office
- Equipment or supplies for employee’s home office
- Membership fees for benefits derived from business travel
- Towing of personal vehicle due to mechanical failure
- Fuel for personal vehicle (Fuel is accounted for in mileage reimbursement allowance)
- Optional conference activities not included in conference registration fee
- Items purchased during travel including umbrella, medication, haircut, laundry, materials, entertainment, etc.
- Loss or damage to personal property
- Home internet service
- First class travel including airfare, express trains, and upgraded rental vehicles
- Sales tax paid in error in excess of $10: Employee must obtain a credit from the vendor or reimburse
- Office “kitties” to fund pantries, birthdays, etc. may not be seeded or facilitated with College funds. (Items may not be purchased with a pcard and reimbursed with cash collected. The entire cycle must be handled privately.)
- Political contributions or payments to elected officials or political campaign activities on behalf of or in opposition to candidates for public office
- Honorariums to elected officials (e.g. payment for a speaking engagement)
- Traffic violations including related towing
- Locksmith charges
- Reimbursement for personal expenses is due upon receipt of notice from Financial Services.