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Introduction

Last modified: July 1, 2019

The laws of the State of Georgia regarding unclaimed property are contained in the Official Code of Georgia Annotated (O.C.G.A.) Sections 44-12-190 through 44-12-235. For legal determinations, institutions are encouraged to review the O.C.G.A. to see the exact wording of the law.

Listed below is a highly summarized overview of the requirements of the law as it affects institutions of the �г��ٸ���Ƶ System of Georgia (�г��ٸ���Ƶ).

Note: This overview does not cover all possible circumstances described in the O.C.G.A. It is intended to provide the institution with an overview of the common circumstances regarding unclaimed property that may be encountered at an institution.

19.1 Unclaimed Property

Last modified: July 1, 2019

The laws of the State of Georgia regarding unclaimed property are contained in the Official Code of Georgia Annotated (O.C.G.A.) Sections 44-12-190 through 44-12-235. For legal determinations, institutions are encouraged to review the O.C.G.A. to see the exact wording of the law.

Listed below is a highly summarized overview of the requirements of the law as it affects institutions of the �г��ٸ���Ƶ System of Georgia (�г��ٸ���Ƶ).

Note: This overview does not cover all possible circumstances described in the O.C.G.A. It is intended to provide the institution with an overview of the common circumstances regarding unclaimed property that may be encountered at an institution.

19.1.1 Definition

Last modified: August 7, 2019

Basically, any property that has remained unclaimed by the owner for more than one (1) year for payroll checks or five (5) years for other checks is presumed abandoned. For a �г��ٸ���Ƶ institution, abandoned property may include, but is not limited to:

• Outstanding payroll checks
• Outstanding accounts payable checks
• Unclaimed deposits
• Unclaimed student refunds
• Unclaimed credit balances on accounts receivable
• Inactive Custodial fund balances

Refer to the Georgia Department of Revenue website at https://dor.georgia.gov/georgia-unclaimed-property for more information. This information includes detail on the Unclaimed Property Act, types of property remitted to the State, when property is considered abandoned and remitted to the State, and more.

�г��ٸ���Ƶ�Unpaid wages,�г��ٸ���Ƶ� including �г��ٸ���Ƶ�unpresented payroll checks,�г��ٸ���Ƶ� are presumed abandoned after they are at least one (1) year old as of the last day of the fiscal year, June 30th. Outstanding accounts payable checks are considered abandoned when they are at least five (5) years old as of the last day of the fiscal year, June 30th.

After a property becomes �г��ٸ���Ƶ�abandoned,�г��ٸ���Ƶ� it must be reported and remitted to the state of Georgia Commissioner of Revenue.

Note: The institution must exercise due diligence in trying to contact the owner of the unclaimed property before it becomes eligible for reporting to the Commissioner of Revenue. Documentation of due diligence efforts must be maintained on file.

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19.1.2 Contacting the Owner

Last modified: July 1, 2019

Between sixty (60) and one hundred twenty (120) days prior to filing the report to the Commissioner of Revenue, the institution should make a final attempt to contact the owner. O.C.G.A. § 44-12-214(e) states:

If the holder of property presumed abandoned under this article knows the whereabouts of the owner, the holder shall, before filing the annual report, communicate with the owner and take necessary steps to prevent abandonment from being presumed. All holders shall exercise due diligence, as defined in Code Section 44-12-192, at least 60 days but no more than 120 days prior to the submission of the report to ascertain the whereabouts of the owner if the holder has in its records an address for the apparent owner which the holder�г��ٸ���Ƶ�s records do not disclose to be inaccurate and the property has a value of $50.00 or more.

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19.1.3 Reporting to the Commissioner of Revenue

Last modified: July 1, 2019

The report and remittance for the fiscal year ending June 30th must be submitted to the Commissioner of Revenue before the following November 1st of each year. As per O.C.G.A. § 44-12-214, the report must include:

1. The name and Social Security or federal identification number, if known, and last known address, including ZIP Code, if any, of each person appearing from the records of the holder to be the owner of any property of the value of $50.00 or more presumed abandoned under this article.

2. The nature and identifying number, if any, or description of the property and the amount appearing from the records to be due.

   Note: Items of value under $50.00 each may be reported in aggregate.

3. The date when the property became payable, demandable, or returnable, and the date of the last transaction with the owner with respect to the property.

4. Other information that the Commissioner of Revenue prescribes by rule as necessary for the administration of this article.

Note: If the institution has changed its name while holding the property, the institution shall file with its report all prior names (and addresses).

The institution�г��ٸ���Ƶ�s chief fiscal officer must verify the report. As per O.C.G.A. § 44-12-228(a), each institution shall:

�г��ٸ���Ƶ��г��ٸ���Ƶ�retain all books, records, and documents necessary to establish the accuracy and compliance of such report for ten years after the property becomes reportable, except to the extent that shorter time is provided in accordance with Article 5 of Chapter 18 of Title 50, the �г��ٸ���Ƶ�Georgia Records Act,�г��ٸ���Ƶ� or in subsection (b) of this Code section or by rule of the commissioner. As to any property for which it has obtained the last known address of the owner, the holder shall maintain a record of the name and last known address of the owner for the same ten-year period.�г��ٸ���Ƶ�

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19.1.4 Institutional Responsibilities

Last modified: July 1, 2019

Recommended institutional procedures to assist in complying with the Unclaimed Property law are listed below.

1. Establish the appropriate liability account, using Account 241500 to track unclaimed property in the fund of origination. It is suggested that separate unclaimed property departments be established for payroll checks and accounts payable checks, such as a department named �г��ٸ���Ƶ�Unclaimed Property-Payroll Checks�г��ٸ���Ƶ� and another department named �г��ٸ���Ƶ�Unclaimed Property-Accounts Payable Checks.�г��ٸ���Ƶ� The detail support for the journal entries must be maintained. This includes: check number, check date, payee name, and dollar amount. Sufficient information should be on file to support any future payee claims.

2. Review the old outstanding checks during every bank reconciliation. After one hundred eighty (180) days have passed from the check�г��ٸ���Ƶ�s issue date, the item should be removed from outstanding checks (i.e. voided) with the amount of the check being moved into the appropriate liability department and account or returned to the applicable FSA program. If the institution does not have physical custody of the check, then the bank should be notified to place a �г��ٸ���Ƶ�stop payment�г��ٸ���Ƶ� on the check. The method of removing the check from the list of outstanding checks with the balance going to unclaimed property will vary depending upon financial system software design.

3. At the time of moving the outstanding check to the liability account, update the listing of unclaimed property that is maintained as required by the Unclaimed Property law. Institutions should insure adequate procedures are in place to aid in finding the �г��ٸ���Ƶ�unclaimed property�г��ٸ���Ƶ� since it will be removed from the list of outstanding checks.

4. Initiate action to try to contact the payee of the check if this has not previously been accomplished. If the payee can be located, a replacement check can be issued charging the appropriate liability department and account.

5. At least annually, review all other accounts that have the potential to become unclaimed property. This should include all inactive custodial accounts, all deposits, all accounts receivable credit balances, etc.

6. Whenever an item of unclaimed property becomes reportable:

   • Include it on the report to the Commissioner of Revenue;
   • Annotate the listing of unclaimed property that this item has been remitted to the Commissioner; and,
   • Include the value in the remission to the Commissioner by debiting the appropriate unclaimed property liability account when issuing the check.

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19.2 Gifts and Donations

Last modified: July 3, 2019

The Board of Regents, recognizing that public institutions are dependent, in part, on private funding and encourages the institutions to seek the support of alumni, friends, corporations, and other private individuals and organizations that might be interested in contributing to the welfare of the institutions, their students, and their faculties..

19.2.1 Gift and Donation Reporting

Last modified: July 3, 2019

As required by Board of Regents Policy 7.4, a �г��ٸ���Ƶ institution may accept gifts, bequests, agreements, or declarations of trust that do not carry obligations to the institution that may conflict with state law or Board policy and that do not impose a financial burden on the institution beyond that which can be managed within the institution�г��ٸ���Ƶ�s current budget. If acceptance of the gift or donation would require the institution to incur additional cost that cannot be borne within the institution�г��ٸ���Ƶ�s current resources, the institution must obtain the approval of the Board of Regents before accepting the gift or donation.

Each �г��ٸ���Ƶ institution must maintain an annual summary report for all gifts and donations valued at $500,000 or more containing the following information:
1. Donor name
2. Fair market value
3. Description of gift, including a listing of applicable equipment
4. Restrictions
5. Anticipated cost implications for the institution by accepting this gift, such as construction, maintenance or software support costs

Gift and Donation summary reports maintained by each �г��ٸ���Ƶ institution must be available upon request of the Chief Fiscal Officer.

Note:
1. Gifts given directly to an affiliated organization are not required to be included on this summary report.
2. An institution may not accept gifts of real property except as otherwise provided in Board of Regents Policy Section 9.9.2.

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19.2.2 Naming of Places, Colleges or Schools

Last modified: July 3, 2019

In accordance with Board of Regents Policy 7.4.1, the following factors, among others, will be considered by the Chancellor and Chief Administrative Officer when determining whether to present a naming request to the Board for approval for a place, building, or academic unit:

1. Whether the gift made is in irrevocable form to be paid within a five-year period and based upon a signed pledge commitment;
2. Whether the proposed naming is associated with endowment gifts. (If a gift is for the construction of a facility, then presidents are encouraged to seek at least a portion of the gift to support the facility or academic programs associated with the facility.);
3. Generally, deferred gifts such as life insurance and bequests are not to be used for current naming opportunities and institutions should discuss with the interested donor(s) about the possible naming opportunities that may be available when the gift is actually received;
4. In cases where a gift is paid over a period of time, presidents are encouraged to make the formal naming request to the Chancellor and Chief Administrative Officer only when at least half of the total gift has been received by the institution. (Note: The Board of Regents and System Office have a preference of only approving namings once at least half of the total gift has been received by the institution).

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19.3 Payment of Dues to a Chamber of Commerce

Last modified: July 3, 2019

The state auditor has interpreted various Attorney General opinions and Georgia Supreme Court rulings to mean that payment of membership dues to a chamber of commerce is an expenditure that does not qualify as necessary for the operation of an institution. Therefore, units under the supervision of the Board of Regents shall not make payment for dues to a chamber of commerce using general operating funds.

19.4.1 Cash Draws from the Treasury to Institutions

Last modified: July 3, 2019

The �г��ٸ���Ƶ System Office (USO) will deliver via the ACH banking system a sum equal to 1/12th of the total original appropriation to each institution on a monthly basis. This delivery of cash is timed to arrive in the institution�г��ٸ���Ƶ�s bank account on the 10th business day of the month.

The mechanics of this delivery system require that the USO draw from the state treasury the amount to be disbursed to the institutions for the month. This monthly draw from the state treasury is placed in the USO�г��ٸ���Ƶ�s bank account a few days prior to the 10th business day. ACH software is used to move the institution�г��ٸ���Ƶ�s cash draw from the USO�г��ٸ���Ƶ�s bank account to the institution�г��ٸ���Ƶ�s bank account on the 10th business day.

For additional increases during the fiscal year, funds are drawn from the state treasury and placed into the USO�г��ٸ���Ƶ�s bank account in a similar manner as described above. For these increases, however, checks are issued and mailed to the institution.

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19.4.2 Cash Draws from the Treasury to Libraries

Last modified: July 3, 2019

The Georgia Public Library System (GPLS) provides spreadsheets to the �г��ٸ���Ƶ System Office a few days prior to the 10th business day indicating amounts to be sent to each library. Funds are drawn down from the state treasury and then distributed to the libraries in the same manner as for the institutions.

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19.5.1 Transfer In

Last modified: July 3, 2019

Transactions affected by wire transfers-in are to be recognized by the issuance of a receipt and thus find their way into the accounting records by way of the cash receipts subsystem. All such transactions are to be supported by either a validated deposit slip or a properly executed credit memo from the bank.

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19.5.2 Transfer Out

Last modified: July 3, 2019

When the issuance of a check is not appropriate and it is deemed necessary to issue an order to the bank to initiate a wire transfer-out, the recording of the transaction by journal entry shall be supported by full and adequate documentation of reason and objective.

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19.6 Sales Tax Collection and Reporting

Last modified: July 3, 2019

Institutional sales that are subject to state of Georgia sales tax must be reported on Department of Revenue form ST-3. Generally, the form provides space for reporting total sales, taxable sales (including local option sales taxes), taxes collected, vendor�г��ٸ���Ƶ�s compensation, and amount to be remitted. The report is due the 20th of the month for the preceding month�г��ٸ���Ƶ�s sales.

If the amount to be remitted exceeds $15,000, the funds should be remitted electronically.

Note: Electronic remission requires an application and approval process.

Complete details may be found at the Department of Revenue web site: http://www.etax.dor.ga.gov/BusTax_SalesTax.aspx.

19.7 Employee Group Meals

Last modified: July 3, 2019

The purpose of this section is to provide guidance regarding situations in which an employer might purchase meals for a group of employees when such employees may not be on travel status or otherwise eligible for payment for meals.

In accordance with O.C.G.A. 50-5B-5, the State Accounting Office, in cooperation with the Office of Planning and Budget, is responsible for the development and dissemination of travel policy. Included in the travel policy is a methodology for requesting exceptions. The number of instances in which requests for exceptions related to the employer purchase of meals for a group of employees, led both the State Accounting Office and the Office of Planning and Budget to recognize the need for a policy to address this issue, which the BOR is also adopting. This policy is detailed in Section 19.7.1 below.

The �г��ٸ���Ƶ also recognized the need to address and regulate purchases made in support of the various multi-institutional events, such as advisory councils to the BOR, training events, meetings for Presidents, Chief Business Officers, Chief Academic Officers, etc. The policy governing purchases made for these multi-institutional events is detailed in Section 19.7.2 below.

19.7.1 Employee Group Meals within an Institution

Last modified: July 3, 2019

Under certain infrequent circumstances, employees may be required to remain at the work site during mealtime. Such circumstances include emergency situations such as natural disasters or significant public safety events, but may also include intra-departmental meetings or training sessions, where the meeting or training session continues during the meal and the employees are not permitted to leave the premises of the meeting site.

�г��ٸ���Ƶ institutions shall use the following standards when deciding whether a meal may be purchased under this policy:

1. Group meals should be held only to facilitate the effective and efficient operations of the departments involved. For example, it may be that scheduling an intra-departmental meeting or training session is the most effective and efficient use of employees�г��ٸ���Ƶ� time given teaching schedules, other meeting commitments, etc. In this instance, requiring employees to participate in a meeting over lunch may be the best means available to get the required participants in the same place for the period of time required.

2. Group meals should only be provided in those instances where the meeting lasts for at least four (4) hours. A meeting less than four hours could generally be scheduled prior to or after a normal meal without significantly impacting employees on different work schedules.

3. Group meals held at the start and/or finish of a meeting are not eligible for payment under this policy. Purchase of a group meal is authorized solely as a convenience to the employer and in those instances where employees may not leave for a normal meal due to the time constraints associated with the meeting or training session. Those events not starting until the normal meal time should be delayed until after the normal meal time, or employees may bring employee-purchased food (�г��ٸ���Ƶ�brown-bag�г��ٸ���Ƶ�) to the meeting.

4. Purchase of group meals should be approved by the head of the organization, or his/her designee, prior to the date of the event (for non-emergency situations). The prior approval request should include:

   • The purpose of the meeting or event;
   • A formal written agenda including session times;
   • A list of attendees with their associated departments/entities; and,
   • The expected cost of the meal per person.

   All of the documents that were a part of the prior approval package should be submitted with the payment request along with the signed prior approval. All documents should be retained with the voucher package for audit purposes.

5. Authorized group meal expenditures are limited to the purchase of meals only and do not include snacks.

6. Meal limits outlined in BPM Section 4.4, Per Diem Allowance for Meals, must be followed. However, the meal limits apply to the actual food and drink purchased for the meal. Set-up and delivery costs associated with the group meal shall not be included in the meal limit calculation.

7. Group meals for a �г��ٸ���Ƶ�lunch meeting,�г��ٸ���Ƶ� in which the meal and the meeting are one and the same, are prohibited for payment under this policy.

These meals should be charged to the 727700 expenditure account, �г��ٸ���Ƶ�Other Operating Expenses �г��ٸ���Ƶ� Special Group Meals.�г��ٸ���Ƶ� The �г��ٸ���Ƶ�Special Group Meals�г��ٸ���Ƶ� expenditure account should only be used for such meal purchases. Once again, documentation of the purchase must be retained as outlined above. This account will be subject to special audit scrutiny, to ensure that such expenditures are infrequent, rather than routine.

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19.7.2 Employee Group Meals Involving Multiple Institutions

Last modified: July 3, 2019

Efficient and effective administration of �г��ٸ���Ƶ institutions may require instances when various groups of university officials, such as presidents, executive officers, or employees representing functional areas such as student activities, academic affairs, business affairs, etc., may be required to meet. The purpose of these meetings must support the official business purpose of the institutions represented.

These events are often sponsored by a �г��ٸ���Ƶ institution or by the �г��ٸ���Ƶ System Office and are supported through the use of registration fees charged to participants. These registration fees may be reimbursed by the participant�г��ٸ���Ƶ�s home institution and may be used for expenses such as speaker fees, room rentals, equipment charges, food for meals and breaks, and items directly related to the purpose of the meeting. Funds collected by the sponsoring institution are normally collected in and expended from an agency account created for that purpose as specified in BPM Section 14.5.1.

It is recognized that these events may often be held at a conference center or similar facility in order to facilitate these events. Additionally, conference events are usually scheduled to require participation on-site for the duration of the conference in order to maximize use of available time. Releasing participants to purchase off-site meals is time-consuming and does not allow for best use of limited time resources. As a result, �г��ٸ���Ƶ institutions and the USO will often contract with catering services to provide food for on-site meals and snack breaks.

This policy is being provided to both recognize the legitimacy of these purchases and to enumerate the requirements governing these purchases. �г��ٸ���Ƶ institutions shall use the following standards when deciding whether purchases are valid as made under this policy:

1. Group meals held at the finish of a conference event are not eligible for payment under this policy. Purchase of a group meal is authorized solely as a convenience to the employer and in those instances where employees may not leave for a normal meal due to the time constraints associated with the meeting or training session.

2. Purchases for conference events should include appropriate documentation to include:

   • The purpose of the meeting or event;
   • A formal written agenda including session times;
   • A list of attendees with their associated institutions; and,
   • The expected cost of the meal per person.

3. Reasonable purchases may be made for refreshment breaks.

4. Every effort should be made to negotiate reasonable meal costs. However, it is recognized that catered event charges will often exceed the per diem limits outlined in BPM Section 4.4. Catered meal events shall be held only to facilitate conference events and not for social or entertainment purposes. Under no circumstances will any institutional funds as defined in Section 19.8 be used to purchase alcohol.

Employees provided a meal pursuant to this policy shall not be permitted to claim per diem on their travel expense statement as specified in BPM Section 4.4.1.

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19.8 Purchase of Food Using Institutional Funds

Last modified: December 20, 2019

The purpose of this section is to clarify those instances when food may be purchased for consumption by students, potential students, volunteers and employees using institutional funds. This policy addresses instances when food may be purchased or food expenses may be reimbursed that are not otherwise addressed in BPM Sections 4.0 and 19.7.

Food includes meals, beverages, snacks, etc., but specifically excludes alcohol as an allowable food expense. The purchase of food for resale in connection with the auxiliary operations of an institution is allowable, and is not addressed in this policy.

An individual may be subject to different rules depending on the capacity in which they are participating in an event. For example, volunteers might include employees or students if the individual is operating in a capacity separate from their employee or student role. An employee or volunteer attending a student event in the capacity of a student would be considered a student. A student worker participating in an event while being paid would be considered an employee.

Note: Employees working additional hours in their own area, using work time to provide volunteer service, or otherwise participating in activities expected of employees, are not volunteers for the purposes of this policy.

Institutional funds include all funds to which an institution holds title, such as student fees, auxiliary revenues, state appropriated funds, etc. Purchases of food using institutional funds should still be recorded using the proper account as designated in BPM Section 2.0 and should be made using the appropriate fund source as outlined below. This policy does not address use of affiliated organization funds to provide food to employees, students, or volunteers. Also note that this policy does not address any potential tax implications associated with the purchase and consumption of food for individuals.

The chart on the following pages outlines the funding sources that may be used when making food purchases and provides some broad examples of allowable purchases.

Note: This chart is intended to provide guidance on allowable food purchases. This chart should be used in conjunction with the relevant BPM sections referenced. Please note, however, that the method of payment via P-Cards is only allowable as described in BPM Section 3.3.1.2.

The funding source should generally be matched to the supported program and participants. For example, student activity fees might be used to purchase water for a volunteer event sponsored by a student group. In this instance, students, volunteers, and employees would presumably consume the water. However, student activity fees should not be used to purchase water for employees conducting outside activities as part of their normal job, e.g., groundskeepers. Please refer to BPM Section 2.0 for more information on the appropriate uses of various fund sources.

Activity	Allowable Participants	Potential Funding Source(s)	Notes
Sanctioned Student Events (excluding athletic events)	• Students • Volunteers • Employees whose participation is required	• Custodial Funds if authorized by fund agreement • Auxiliary Funds • Endowment funds where authorized by fund agreement • Grants or Contract Funds as authorized by fund provider • Student Activity Fees	• See BPM Sections 19.8.1, 19.8.2, and 19.8.3 • Per diem limits apply
Athletic Events & Recruiting	• Students • Potential students & parents/guardians • Volunteers • Employees whose participation is required	• Athletic Auxiliary Funds • Endowment funds where authorized by fund agreement • Student Athletic Fees	• See BPM Sections 19.8.1, 19.8.2, and 19.8.3 • Per diem limits apply • Applicable athletic conference rules shall also be followed
Classroom & Academic Programs	• Students • Employees whose participation is required	• Sales & Service Revenue • State appropriated funds for use only in for credit courses • Tuition & Fee Revenue	• See BPM Sections 19.8.1 and 19.8.2
Student Recruiting Events	• Students • Potential students & parents/guardians • Volunteers • Employees whose participation is required	• Auxiliary Funds • Student Activity Fees	• See BPM Sections 19.8.1, 19.8.2, and 19.8.3 • Per diem limits apply
Volunteer Events	• Students • Volunteers • Employees whose participation is required	• Non-appropriated funds, Custodial funds if allowed by fund agreement • Recognized �г��ٸ���Ƶ�executive�г��ٸ���Ƶ� program tuition revenue may be used to purchase food for volunteer events	• See BPM Sections 19.8.2 and 19.8.3 • Per diem limits apply • Volunteer events with sole purpose of recognition or appreciation for past services may not be paid using any fund source except for Foundation funds
Safety Products	• Students • Volunteers • Employees at risk due to environmental or workplace conditions	• Auxiliary funds • Sales and service revenue • State appropriated funds • Student Activity Fees • Tuition & Fee Revenue	• See BPM Section 19.8.3 • Expenses should be paid using the departmental budget of the assigned employees
Educational or Business Meetings	• Students • Volunteers • Employees whose participation is required	• Auxiliary funds • Sales and service revenue • State appropriated funds	• See BPM Section 19.8.3 • Meeting must consist of predominantly non-employees • Per diem limits apply

Employees with responsibility for administering institutional funds and employees requesting reimbursement from institutional funds should ensure that funds are spent only for legitimate public purposes and not for the personal benefit of the employee or other individuals. The misuse of institutional funds may result in both employment termination and various civil and criminal penalties.

19.8.1 Food for Students

Last modified: July 3, 2019

Students include individuals enrolled to take classes at an institution, including students enrolled in Continuing Education, and individuals being recruited as potential students.

Institutional funds may be used to purchase food for students at sanctioned student events. Sanctioned student events include events and travel sponsored by recognized student groups, athletic team events, and other campus events open to the general student body and designed to further the development and education of students. Additionally, food may be purchased for a class in those instances where food is an integral part of the instructional methodology. For example, food could be purchased for students in a food appreciation or cooking class offered by a Continuing Education unit. While not necessarily in a travel status, the per diem limits in BPM Section 4.4 should apply to food purchased for consumption by students participating in sanctioned student events.

Potential students and their guardians may be provided food at an event designed to encourage the student to attend the institution. Food for athletic recruits may be purchased subject to the rules and regulations of the athletic conference of which the institution is a member.

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19.8.2 Food for Volunteers

Last modified: July 3, 2019

Volunteers include individuals that provide benefits to the institution (serving on an advisory board, student mentors, etc.) without receiving compensation.

Institutional funds may be used to purchase food for volunteers in those instances where a quid pro quo relationship exists. For example, an academic unit might form a volunteer advisory board for the purpose of obtaining advice, support, and expertise from members of the community as it relates to an academic program. It would be allowable to provide food to those volunteers as part of the advisory board meeting. However, food purchased solely in connection with volunteer appreciation or volunteer recognition events would not be allowable under this policy. While not necessarily in a travel status, the per diem limits in BPM Section 4.4 should apply to food purchased for volunteers.

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19.8.3 Food for Employees

Last modified: July 3, 2019

Employees include temporary, part-time, and full-time staff, faculty, administrators, Resident Assistants (RAs), student assistants, and other student workers.

Employees in a travel status are subject to the employee travel regulations as contained in BPM Sections 4.0. Employees in a group meal status are subject to the guidance contained in BPM Section 19.7. However, there are instances not addressed in BPM Sections 4.0 and 19.7 when food may be purchased for employees or employees may be reimbursed for food purchased. Those instances shall be addressed using the following general categories: Safety, and Academic Programs, Student Events, and Educational or Business Meetings Involving Predominantly Non-Employees.

1. Safety. Water or other hydration products may be purchased insofar as these products are required by OSHA or are necessary to prevent serious harm to an employee.

2. Academic Programs, Student Events, and Educational or Business Meetings Involving Predominantly Non-Employees. When conducting a program, event or meeting involving predominantly non-employees (of any institution of the Board of Regents) where attendance by the employee is essential and in furtherance of an official institutional program, and the meal is an integral part of the meeting, an employee can partake in the meal and be reimbursed for his or her actual meal cost up to the per diem limits established in BPM Section 4.4. An employee may not be paid a reimbursement unless the employee actually incurs a cost.

Clarification of specific instances of allowable reimbursement include:

1. Athletic recruiting. An employee may be reimbursed for food purchased at a meeting whose primary purpose is the recruitment of an individual to attend the institution. The employee�г��ٸ���Ƶ�s participation in this meeting should be required as part of his or her job performance, and the institution should strictly control the numbers of individuals who may receive reimbursement for food purchased at a given recruitment meeting.

2. A prior/existing contractual or grant arrangement, which must be quid pro quo, not gratuitous. For example, an external organization may award funds to the institution with the specific proviso that these funds may be used for employee food expenses as it relates to grant activities or meetings. In this instance, food could be purchased within the grant guidelines.

   However, federal grant funds should NOT be used to purchase food for employees unless the federal grantor agency, in writing, authorizes this expenditure and certifies that this waiver is not a violation of applicable federal regulations.

Business purpose should be clearly indicated on any invoices submitted for payment. Additionally, the per diem limits of BPM Section 4.4 apply to food purchased for consumption by employees participating in a program, event, or meeting or otherwise reimbursed to the employee by the institution.

Per diem limits apply only to food purchased with institutional funds. Food purchased by outside organizations does not fall under the scope of this policy. However, employees must comply with the provisions of Section 8.2.13 of the BoR Policy Manual as it pertains to receiving gifts.

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19.8.4 Documentation Requirements and Enforcement of Per Diem Limits at Group Events

Last modified: July 3, 2019

Nothing in this policy shall be construed as requiring an institution to provide food to employees for events or to reimburse employees for participation in events. Institutions should establish the appropriate procedures to ensure that funds for employee food are not spent without the appropriate supervisory review and approval.

Appropriate procedures shall include adequate documentation associated with the event and/or purchase. For example, food purchased for a group event should include a flyer, email, agenda, or other documentation substantiating that the event was an official event. Food purchased at a restaurant or on a per person basis should include a list of participants.

In the event that an employee expends funds in excess of the authorized per diem contained in BPM Section 4.4, then the amount spent in excess should be reimbursed by the employee making that expenditure.

While the per diem limits also apply to group events where food is purchased on a group basis (pizza parties, etc.), institutions are not required to document the actual numbers or names of participants. However, institutions should require employees expending institutional funds for those events to certify that the appropriate per diem limits were followed.

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19.9 Non-Employee Travel

Last modified: March 11, 2020

This section addresses non-employee travel to include students, consultants, and individuals applying for a job at the institution. Travel expenses for non-employees should be limited to certain circumstances as described below:

1. Students authorized to travel for participation in academic programs and sanctioned student events to include athletic and recruiting events. Students include individuals enrolled to take classes at an institution, including students enrolled in Continuing Education, and individuals being recruited as potential students.

2. Individuals contracted to perform a service for the institution where the contract provides for travel expense reimbursement.

3. Research, academic conference, or academic event travel funded by a grant award to the institution in those instances when the grant award specifically authorizes payment for non-employee travel in support of research, academic conference, or academic event.

4. Job applicant travel associated with an interview as specified in institutional policy. Institutions electing to pay travel expenses for job applicants shall develop a policy, approved by the president, which addresses the positions that are eligible for travel expense reimbursement. When developing this policy, consideration should be given to funding availability and the business necessity of paying travel. Consideration also should be given to allowing travel expenses to be paid only for senior administration and faculty job applicants. Any exceptions to the institution policy shall be pre-approved by the institution president.

   Viable methods to pay job applicants include:

   • Including interview expenses in the contract with an external search firm.
   • Requiring a job candidate to perform a service to the institution, such as a presentation on subject matter applicable to the position applied for. Consideration provided to the candidate for this service would be the reimbursement of travel expenses.
   • Requesting travel expense reimbursement for the job candidate from the Foundation.

Note: Reimbursement of authorized travel expenses is subject to the allowable limits and conditions as discussed in BPM Section 4.3 through 4.9. All travel expenses in these categories should be charged to account 6501XX and properly documented using a travel form designed for that purpose.

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