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Financial Affairs Policies
UMB FOOD AND BUSINESS MEALS EXPENSE
Financial Affairs | Approved February 4, 2014
Applies to Staff, Faculty
Policy Effective: February 1, 2014, Revision of A&F Policy 3332
Required By: State of Maryland General Accounting Division Guidelines
To describe and provide some examples of allowable and unallowable business meal reimbursements and food purchases using UMB 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
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 (UMB). 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 UMB business may be allowable use of UMB funds.
Department approvers have the right to reject all or part of the reimbursement requests at their discretion.
Using UMB 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 UMB 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 UMB for the purpose of developing student interaction, future contributions to programs, or developing business relationships benefitting UMB.
- Meetings with colleagues from other universities to discuss university research, instruction, administrative functions, etc.
- Business meals where external consultants are participating in official UMB business.
- Conferences, convocations, symposiums and other special events which are on behalf of or substantially involve personnel not employed by UMB.
- Events where participant fees are collected to offset the food cost (e.g., a conference).
- UMB-wide events coordinated through the Office of Communications and Public Affairs to promote or further UMB’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.
- UMB-wide employee awards/appreciation events coordinated through the Department of Human Resource Services (within UMB University Operations).
- Meals during unusual hours or at unusual places of work for employee groups performing required UMB 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.
Business meals or food/catering services are not appropriate in the following circumstances:
- Personal meals among UMB employees.
- Routine (see definitions) meetings among UMB 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 UMB 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.
Affiliated Entity- An entity that has a relationship with UMB authorized by the Board of Regents or by law, e.g., faculty practice plan organizations, UMB 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.
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.
UMB funds – All funds administered by UMB, regardless of fund source. UMB funds include State Appropriations, Auxiliary funds, Revolving/Discretionary funds, Designated Research Initiative Funds, Contracts or Grants, and Other Restricted funds.
Scope and Exceptions
This policy applies to all food and business meal purchases with UMB funds. The requirements stated in this policy apply when reimbursement or payment is being requested directly from UMB. The policy also applies when reimbursement or payment is being requested from an affiliated entity and subsequently reimbursed by UMB.
1.This policy does not apply to food/meal purchases during travel that are covered under UMB Policy VIII-11.00 (A) – UMB 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 UMB (e.g. Donaldson Brown Center).
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 UMB 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 UMB funds may be subject to disciplinary action. Purchases for food using UMB funds that are not in accordance with this policy must be reimbursed to UMB from external funds (e.g., Foundation funds or personal funds).