University at Buffalo Crest.

Policy Information

Date Established: 12/4/2017
Date Last Updated: 3/8/2022
Category:
Administration and Governance
Responsible Office:
Financial Management
Responsible Executive:
Vice President for Finance and Administration

Policy Contents

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Allowable Use of Funds Policy

Summary

The University at Buffalo allows for the use of State, University at Buffalo Foundation, Inc., and Research Foundation funds for the payment of reasonable and appropriate expenses incurred while conducting official university business.

Policy Statement

The University at Buffalo (UB, university) is entrusted with funds from various sources. Employees who incur or approve expenses must exercise prudent judgment to ensure that the expenses are for legitimate university business and comply with the appropriate allowability criteria. Employees are responsible for ensuring the appropriate use of funds within the constraints of limited resources.

The Allowable Use of Funds Policy governs the payment of expenditures incurred or approved by employees on behalf of the university. All expenditures funded with State, University at Buffalo Foundation (UBF), and Research Foundation (RF) accounts must be appropriate, reasonable, allowable and allocable; they also must support the education, research, and public service missions of the university.

All university departments must implement a system of supervisory checks and balances to ensure expenditures always meet university interests. Expenditures paid from various funding sources are subject to specific requirements for use. Details regarding the use of State, UBF, RF Non-Sponsored, and RF Sponsored funds are found in the Allowable Use of Funds Chart. The appropriate funding source is determined by the type of expense, not by the employee’s source of payroll. Units may apply this policy more restrictively where budget and other factors are considered. Additional restrictions established at the operating unit level supersede this policy and Allowable Use of Funds Chart.

Research Foundation Sponsored Funds

The terms and conditions of a sponsored award dictate the use of RF funds derived from that sponsored award. Each awarding mechanism (e.g., grant, contract, or cooperative agreement) is issued with guidance on the use of funding. Expenditures for sponsored activity must be allowable, reasonable, and allocable to the project.

Each sponsor provides unique terms and conditions for their award classes or sponsored programs. To ensure compliance with sponsor terms, faculty and staff must contact Sponsored Projects Services (SPS) when unsure about the terms that govern their sponsored awards. Expenditures deemed unallowable by the sponsor or an auditor will be treated under the Financial Responsibility for Sponsored Projects Policy.

Prior approval or justification may be required for the following expenditures:

  • Equipment purchased during the last year of project funding
  • Consumables purchased in the last 30 days of the award
  • Purchases of general use supplies, equipment, or services
  • Payroll cost transfer activity and retroactivity

Reimbursement requests for expenditures must be processed timely and may not be reimbursed beyond 120 days from the purchase date. Exception approval must be obtained to reimburse expenditures older than 120 days.

Expenditures in excess of the approved project budget require use of non-sponsored funds. In these instances, the RF Non-Sponsored guidelines apply.  

Reimbursement Maximum

The maximum allowable amount for individual reimbursement is $2,500 for any single item or total aggregate cost (excluding travel). Requests in excess of this amount follow the procurement guidelines.    

Food and Beverage

When incurring expenses for the purchase of food and beverages categorized as Internal Business Meals on the Allowable Use of Funds Chart, reimbursement is limited to the per diem as determined by U.S. General Services Administration. Internal Business Meals in excess of per diem are considered an exception and require the appropriate policy exception approval.

Hosted Business Meals and Student Meals are not limited to the per diem amount, however, the expectation is that the amount will be appropriate and reasonable.

Meals provided for virtual events are subject to all requirements outlined in this policy and must be provided in the form of an actual meal, delivered to the individual’s physical location. Gift cards to purchase a meal are not allowable. Alcohol is not a permissible expense for virtual events where a meal is included.

A maximum gratuity charge of 20 percent of the pre-tax total is permitted. If per diem is applicable (Internal Business Meals), gratuity, delivery, and alcohol charges must be covered by the per diem maximum.  

Administrative, service, technology, and room rental fees charged by a venue must be itemized and are considered separate from the per diem rate. Best efforts should be made to negotiate down administrative fees or seek a venue where these fees are not charged.

Annually, the Vice President for Finance and Administration issues the Holiday Spending Reminder. All holiday celebrations must comply with the requirements detailed in the announcement.

Alcoholic Beverages

State and RF non-sponsored funds may not be used to pay for alcoholic beverages. RF sponsored funds may be used for alcoholic beverages only if specifically approved by the sponsor.

Per person reimbursement for alcoholic beverages is restricted to the lesser of the cost of two alcoholic beverages or $20. An itemized receipt, that clearly identifies alcohol, must support alcohol reimbursements. When alcohol is provided at a hosted event, it must be served by a provider licensed to serve alcohol. Proof of use of a licensed provider is required at the time of approval; exceptions are not allowed and will not be processed when alcohol is served without a licensed provider.

Sales Tax

Best efforts should be made to use the New York State (NYS) sales tax exemption certificates. Reimbursement for sales tax expenses will be considered on a case-by-case basis when the expense appears to be unavoidable. RF sponsored funds may not be used to cover sales tax. If sales tax is not waived, and a per diem rate is applicable, the sales tax must be covered by the per diem maximum.

Parking

University employees are responsible for the cost of their own parking at their official station. Refer to the Traveling for Business guidance for reimbursement of parking costs incurred when traveling to another campus for business purposes.

Request Reimbursement

Three options to request reimbursement or payment of allowable expenses are available:

  • Complete an expense reimbursement request via the appropriate form or system (State, RF, UBF), obtain the appropriate approvals, attach applicable documentation, and submit to the appropriate business office
  • Complete an electronic requisition (eReq), attach the applicable documentation, and submit the transaction through the appropriate approval process
  • Utilize a PCard for purchases made directly from a store or vendor
    • The State and RF PCard cannot be used for dining in restaurants

Documentation

Documentation must accompany payment requests and include the following:

  • Original (paper or digital) receipts or itemized invoice
    • Itemized receipts are required for any purchase that includes alcohol and for all UBF-funded reimbursements
    • Alcohol must be easily identifiable on the receipt (consider highlighting or circling)
    • Proof of licensed provider for alcohol served at hosted events
  • Description of university business purpose
  • Location of the event
  • Names of the participants and their affiliation to UB
  • Brochure, program, or agenda related to the event
  • Name of the individual to be reimbursed, if appropriate
  • Exception approval form, if applicable

Gift card expenses for human research subjects require the items listed above and Institutional Review Board (IRB) approval. Tax documentation (W-9) is required for all gift cards issued for $100 or more.

Exceptions

Special circumstances may allow for exceptions on a case-by-case basis. An exception request must be initiated at the departmental level. All policy exceptions require pre-approval from the Unit Business Officer (UBO) or the RF Operations Manager (OM) (for SPS and RF non-sponsored funds). Pre-approval must be requested with reasonable notice as established by each UBO or the OM. The approver of the exception must not have attended or have incurred, in any way, the subject expenditure. To the extent that the UBO or OM was in attendance or personally incurred the subject expenditure, the approval must be advanced to the next highest approval authority.  

All exceptions to the terms of sponsored activities require strong justification and prior approval from the sponsor. Requests must be made through SPS.

Exception requests must be documented using the Allowable Use of Funds - Exception Request Form.

Background

Individuals making decisions concerning expenditures of university funds have a fiduciary responsibility to ensure compliance with federal, state, and local regulations while supporting the university’s mission of education, research, and public service. This policy provides strict rules around that decision making process.

Applicability

This policy applies to all university faculty, staff, and student employees who make decisions regarding the use of funds for the purchase of food and beverages, human subject consideration, crowdsourcing services, clothing, registration fees, decor, appliances, and memberships.

Separate policies govern the allowable use of funds for specific purposes:

Definitions

Allocable

The amount of expense for goods or services which can be charged (or allocated) to a particular unit, activity, or function because the goods or services provide a commensurate benefit to that unit, activity, or function.

Allowable

An expense is allowable when it is permissible to charge it to a particular source of funds. Expenses may be deemed allowable by law or regulation; by external parties such as donors or sponsors; or by university policy.

Approver

An individual with the authority to approve a business expense or transaction.

Business Entertainment

The primary purpose of business entertainment is to further business relations; business entertainment is smaller in scale, includes a small number of people, and is fairly low cost; (e.g., business lunches or dinners; tickets to athletic, cultural, or other events).

Business Expense

Charges for goods or services, whether paid, committed, or accrued, that foster or support the ongoing mission of the university.

Business Meal

A meal attended by faculty, staff, or students, which may or may not include individuals from outside UB, at which a substantive and bona fide business discussion takes place.

Business Purpose

In support of the goals, objectives, and mission of the university.

Crowdsourcing

The practice of obtaining information or input into a task or project by enlisting the services of a large number of people.  

External Beneficiaries

Individuals who benefit from goods or services paid for with UB funds but do not have a defined affiliation with the university.  

Guest

Person invited to visit the university or take part in a function organized by the university; the guest visit must be related to a business purpose and support the mission of the university.

Hosted Event

Any event, hospitality, or social activity, held in person or virtually, organized or funded by UB.

Immediate Family

The spouse, children (son or daughter), and parents of a staff, faculty, or student employee.

Internal Beneficiaries

Individuals who benefit from a good or services paid for with UB funds while maintaining the status of faculty, staff, student, student employee, appointed volunteer, or honoraria.

Licensed Provider

Person holding a license to sell and serve alcohol, by the glass, for consumption on the premises.

Official Station

Official station is generally the address of the office to which the employee is assigned; an employee can have only one official station. The designation of official station is determined by the university in the best interest of the university and not for the convenience of the employee.

Reasonable

Those costs which a prudent person would have incurred under the circumstances prevailing at the time the decision to incur the cost was made; consider how the public would view the expense if reported in the media.

Research Foundation (RF) Funded Revenue (also called indirect costs)

Funds generated through the recovery of indirect (facilities and administrative (F&A)) costs charged on sponsored accounts, and distributed per the campus Financial Plan.

Responsible Executive

The vice president, vice provost, dean, or their designee with authority over and responsibility for the unit.

State Funds

Include State Operating, Income Fund Reimbursable (IFR), State University Tuition Reimbursable Account (SUTRA), and Dormitory Income Fund Reimbursable (DIFR) funds.

Responsibility

Deans, Vice Presidents, Vice Provosts, and University Business Officers

  • Account for all expenditures that fall within the scope of their budgetary jurisdiction.

Employee (Faculty, Staff, Student Employee)

Responsible Executive, Principal Investigator (PI), Authorized Approver

  • Review and approve requests for the use of university funds in accordance with this policy.
  • Verify that the expense is reasonable, allowable, and allocable; consider how the public would view the expense if reported by the media.
    • Expenditures benefitting  more than one account (including at least one RF Sponsored account), require that the cost be allocated to the accounts based on the proportional benefit to each account.

Responsible Office

  • Determine the appropriate funding source(s) for payments.
  • Complete the appropriate paperwork and provide all required documentation; forward to the responsible executive or PI for approval.

Unit Business Officer, Research Foundation Operations Manager

  • Communicate this policy to units and departments.
  • Support strong unit financial stewardship through ongoing dialog regarding reasonableness and business purpose.
  • Act as a consultant to unit employees seeking guidance on policy clarification or interpretation.
  • Review, and approve as appropriate, all expenditure exceptions.

Accounts Payable Representatives

  • Ensure proper documentation is included with each request.
  • Investigate transactions that do not appear to be reasonable.
  • Act as a consultant to university employees seeking guidance on the reasonableness of requests.
  • Process transactions for payment.

Internal Audit

  • Conduct ongoing reviews of all university expenditures to maintain compliance with internal policies and external requirements.

Contact Information

Consult with your Unit Business Officer for initial clarification or interpretation questions.

Funding specific questions can be directed to the following subject matter experts:

Contact An Expert
Office Contact Phone Email
State Angie Rzeszut 716-645-4533 rzeszut@buffalo.edu
RF Non-Sponsored Brendan Davis 716-645-2602 ubsd.nsgroup@business.buffalo.edu
Sponsored Projects Services
Mary Kraft 716-645-4420 mekraft@buffalo.edu
UB Foundation Rose Dommer
716-645-8749 ubf-ap@buffalo.edu

Related Information

University Links

Forms

Related Links

History

Policy Revision History
March 2022

Updated the Allowable Use of Funds Chart to specify that completion of the Taxable Income Reporting Form is not required when a prepaid debit card (e.g., U. S. Bank Prepaid Debit Card Program) is used to pay subjects who participate in research studies (Human Subject Consideration)

January 2022

Full review. Updated the Allowable Use of Funds Policy to:
•  Clarify that Hosted Business Meals and Student Meals are not subject to the per diem, but the amount must be appropriate and reasonable
•  Specify that meals provided for virtual events are subject to all requirements of the policy and must be provided in the form of an actual meal, delivered to an individual's physical location; gift cards to purchase a meal are not allowable; alcohol is not a permissible expense for a virtual event
•  Include a reference to the annual Holiday Spending Reminder
•  Increase the dollar limit for the per person reimbursement for alcoholic beverages from the lesser of the cost of two alcoholic beverages or $15 to the lesser of the cost of two alcoholic beverages or $20
•  Specify that when alcohol is provided at a hosted event, it must be served by a provider licensed to serve alcohol
•  Require documentation that alcohol was served by a licensed provider
•  Add definitions for Crowdsourcing, Hosted Event, and Licensed Provider
•  Add the following responsibilities for the UBO:
   •  Communicate the policy to departments and units
   •  Support strong unit financial stewardship through ongoing dialog regarding reasonableness and business purpose
   •  Act as a consultant to unit employees seeking guidance on policy clarification or interpretation

 

Full review. Updated the Allowable Use of Funds Chart to:
•  Add a link to the Holiday Spending Reminder (Food and Beverage Expenses - Internal Business Meals)
•  Increase the dollar limit for the per person reimbursement for alcoholic beverages from the lesser of the cost of two alcoholic beverages or $15 to the lesser of the cost of two alcoholic beverages or $20 (Food and Beverage Expenses - Alcoholic Beverages)
•  Add a section for Crowdsourcing Services
•  Add a Revision History section

July 2019

Full review. Updated the Allowable Use of Funds Policy to:
•  Require reimbursement requests for expenditures from RF sponsored funds to be processed timely and not more than 120 days from the purchase date
•  Specify that administrative, service, technology, and room rental fees are separate from the food and beverage per diem and must be itemized
•  Require alcohol reimbursement to be supported by an itemized receipt where the cost of alcohol can be clearly identified
•  Specify that university employees are responsible for their own parking costs at their official station
•  Add the definition of official station
•  Increase the dollar amount from $50 to $100 for tax documentation required for gift card expenses for human research subjects

 

Full review. Updated the Allowable Use of Funds Chart to:
•  Disallow the use of RF sponsored funds for hosted business meals for visiting dignitaries, speakers, performing artists, and community leaders (Food and Beverage Expenses - Hosted Business Meals)
•  Allow the use of RF non-sponsored funds for student meals at events to support student curriculum or promote student morale, retention, recognition, or student life activities (Food and Beverage Expenses - Student Meals)
•  Allow the use of RF non-sponsored funds for student meals at student club or organization meetings or events, and as a complimentary offering to students when they participate in focus groups, tutoring or advisement with faculty, staff, or student employees (Food and Beverage Expenses - Student Meals)
•  Clarify that all food expenses, not just meal expenses, for faculty and staff are restricted to the GSA per diem (Food and Beverage Expenses - Internal Business Meals)
•  Restrict staff appreciation, recognition, professional achievement, or employee relations events to build morale to twice per year rather than monthly (Food and Beverage Expenses - Internal Business Meals)
•  Clarify that occasional food and beverages for university staff, when engaged in business discussions during normal business hours or staff meetings, does not include routine or individual meetings held at meal times (Food and Beverage Expenses - Internal Business Meals)
•  Clarify that employee celebrations (e.g., professional achievement, holiday parties, new employee welcome, retirement recognition) may include a guest(s) when the guest accompanies a specific employee being recognized or honored; the guest(s) at holiday parties must be pre-approved as an exception (Food and Beverage Expenses - Internal Business Meals)
•  Clarify that delivery charges (as well as gratuity) are included in the per diem (Food and Beverage Expenses - Internal Business Meals)
•  Remove the Gifts section from the Chart; gifts are covered in the Gifts, Prizes, and Awards Policy
•  Rename the Gifts section the Human Subject Consideration section to address gift cards as consideration or incentive for participating in surveys, volunteering, or services provided to the university
•  Allow the use of State funds for commencement cap and gown rental, purchase, or cleaning (Clothing)

April 2018 Full review. Updated the Allowable Use of Funds Chart to:
•  Allow State and RF Non-Sponsored funds to be used for internal business meals provided at professional development or training retreats, seminars, workshops, or strategic planning. Objectives must incorporate the sharing of subject matter expertise, communication of initiatives, or other material that is not part of the employee's day-to-day responsibilities. (Food and Beverage Expenses - Internal Business Meals)

Presidential Approval

Signed by President Satish K. Tripathi

Satish K. Tripathi, President

1/18/2022

Date