Purpose of the Policy
This policy is intended to ensure proper stewardship of University funds by providing guidelines for their appropriate use, and outlining procedures that will help members of the University community comply with all applicable rules and regulations.
Scope of this Policy
This policy applies to any member of the University community who initiates, processes, approves, or records financial transactions that involve University funds. This policy does not apply to NYU Langone Medical Center (or its component parts: NYU Hospitals Center, its affiliates, and New York University School of Medicine).
This policy does not apply to externally sponsored agreements that are governed by the Sponsored Programs Administration Handbook and administered by the Office of Sponsored Programs and Post Award Administration. Please refer to the Sponsored Programs Administration’s Post Award Policies and Procedures Handbook (SPA Handbook - nyu.edu/spahandbook) for information and guidance regarding allowable and unallowable expenses associated with sponsored research.
Procedures for Implementation
Business expenses are those costs that are incurred for activities that benefit the University and advance its missions of being a “top quality international center of scholarship, teaching and research”. Business expenses may take the form of direct payments to individuals or organizations that provide the University with goods or services, or reimbursements to University employees for costs they incur on behalf of the University.
University funds may be used only for business expenses. This policy provides the guidelines on the various expenses for which University funds may be used. It is intended to provide general guidelines to help all employees of New York University specifically to:
• understand their responsibilities related to the protection, use, and management of University funds;
• identify expenses that may be charged to specific University funds;
• determine expenses for which University funds could not be used;
• properly record and report expenses incurred in support of University missions; and,
• ensure consistent compliance with applicable federal, state, and local regulations.
Before incurring or approving any expense on behalf of the University, you must know which expenses are allowable or unallowable under the guidelines of the federal government and which are permissible or non-permissible according to the policies of the University. To avoid costs for which you will not be reimbursed and to avoid incurring financial risks or liabilities to the University, follow the guidelines provided in this document and the SPA Handbook (nyu.edu/spahandbook).
Policies executed by schools, departments and units can be more restrictive than the University policy. Enforcement of the more restrictive policy will be the responsibility of the school, department or unit. In no case can a school, department or unit have a policy less restrictive than the University policy.
All individuals who incur or authorize business expenses on behalf of the University have a responsibility to ensure that University funds are used appropriately. All employees of the University are expected to exercise due diligence when generating, reviewing, and approving transactions that commit to the expenditure of University funds.
Certain individuals are delegated the responsibility or authority to initiate or enter into transactions that commit the University to spend funds. All individuals incurring, approving, recording or processing payment of business expenses must know the signatory approval structure established in his/her school, department, or unit. This structure ensures that business expenses are properly reviewed. The Signature Authority Policy and the Delegated Authority Database (which details the signatory approval structure established in each school, or unit) can be found at http://www.nyu.edu/about/policies-guidelines-compliance/policies-and-guidelines/signature-authority-policy.html.
Conflict of Interest
The Board of Trustees of New York University prohibits those activities or behavior which conflict with the best interests of the University. Transactions therefore between a supplier of goods or services and the University in which a conflict of interest exists are prohibited.
“Conflict of interest” is defined as a situation in which a University official, faculty, staff, or any of his/her family or associates either has an existing or potential financial or other material interest that (1) impairs or might appear to impair his/her independence and objectivity of judgment in the discharge of responsibilities to the University, or (2) may receive a financial or other material benefit from knowledge of information confidential to the University.
For specific rules and requirements established by the Board of Trustees, see the Conflict of Interest Policy of the University.
The Office of Sponsored Programs (www.nyu.edu/osp) provides additional rules and requirements that apply to sponsored programs.
University Policies on Procurement and Expense Reimbursement
To avoid incurring costs for which you may not be reimbursed, or committing the University to costs that cannot be paid using University funds, consult the procurement policies of the University before you incur the expense. Certain expenses may be subject to specific procurement rules and requirements of the government.
Individuals who incur business expenses using personal funds may be reimbursed by the University through Accounts Payable. Refer to the Expense Reimbursement Policy of the University for specific guidance.
Allowable and Unallowable Expenses
Certain expenses that the University deems legitimate and permissible may be deemed unallowable by the federal government. University funds may be used for such expenses, but they must be identified and segregated in the University’s general ledger. Please refer to the SPA Handbook for information and guidance regarding allowable and unallowable expenses associated with Sponsored Research.
NYU Nonpermissible Expenses
Any expense that does not support the missions of the University and does not reflect proper stewardship is considered by the University as nonpermissible regardless of the source of funds.
When the nonpermissible expenses listed below are submitted to the University for reimbursement or payment, they will be rejected, unless they are justified in a memo as necessary in carrying out a University task or function. The memo should provide a clear explanation of why such an expense should be deemed a business expense, and should be submitted to the “Approver” (the individual responsible for funds being charged) for review and approval. Accounts Payable will not process any payment or reimbursement of nonpermissible expenses unless the memo is attached.
Personal expenses refer to those expenses that are not related to any activity of the University, are not required in carrying out an individual’s task or responsibility at work, or do not benefit the University. Personal expenses include, but are not limited to, the following:
- Automobile repairs
- Child care
- Credit card annual fees
- Delinquency fees or finance charges on NYU Travel and Entertainment Card (“T&E Card”) or personal credit cards
- Dues in private clubs
- Frequent flyer and other similar awards for hotel and car rentals
- Grooming services (haircuts and shoe shines)
- Gym and recreational fees, including massages and saunas
- In-room movies
- Pet care
- Telephone charges in excess of what is deemed reasonable for calls to home when on business travel (see “Expenses Related to Business Travel” section in this document)
- Traffic violation penalties -Upgrades (air, hotel, car, etc.) when traveling on University business
Other Nonpermissible Expenses
Other expenses for which University funds cannot be used are:
• Expenses that should not be paid using personal funds (e.g., independent contractor fees, stipends, cash gifts, etc.; these types of expenses should be charged directly to the University)
• Any expense prohibited by law (e.g., University funds cannot be used for payments or donations to political organizations or candidates)
NYU Permissible Expenses
Expenses that support the missions of the University are deemed valid and therefore permissible. The following sections of the document detail those expenses that are generally deemed permissible.
University employees are advised to use established University methods to incur business expenses. A business expense should be paid by the University directly to the vendor through Accounts Payable; procured through a Purchase Order; purchased using the Procurement Card; or, when expenses are related to travel, incurred using the T&E Card or the Departmental Travel Card.
Certain expenses may be incurred by University employees in the conduct of University business using personal funds. These expenses may be reimbursed when University and government requirements are met (see the Expense Reimbursement Policy of the University for specific guidance). They may also be excluded from an individual’s taxable income if they meet IRS requirements for an “accountable plan.”
1. Expenses Related to Business Travel
The University deems permissible those expenses related to business travel that are reasonable and necessary to conduct University business. Individuals who travel on University business are responsible for verifying availability of funds, permissibility of expenses, and obtaining necessary approval prior to departure.
POLICY CONTINUES...Click here to download the entire PDF of the policy
- Dates of official enactment and amendments: Jul 15, 2004
- History: Revised: March 2012, September 2014, June 2016 Revised November, 2014: Additional language added to per diems and incidental expenses sections, found on pages 10-11 of Policy PDF.
- Cross References: N/A