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A

Accountable Plan

When you receive reimbursement from NYU for expenses that you, as an NYU employee, have incurred while conducting University business (e.g., airfare, meals and lodging costs incurred on business travel), the reimbursement technically constitutes gross income to you.

"Gross income" generally includes all items of value received by an employee and is subject to taxation.

Any reimbursement that you receive from the University may be excluded from your gross income only if it is made pursuant to a reimbursement or expense allowance arrangement known as an "accountable plan." Under this plan, you are required to substantiate all expenses you report and to return any amounts received in excess of the substantiated expenses.

In order for the University's plan to qualify as an "accountable plan," the following criteria must be met:

  1. Reimbursements can be made only for business expenses incurred by employees in connection with the performance of their duties;
  2. The plan must require employees to substantiate their expenses within a reasonable period of time; and,
  3. The plan must require employees to repay within a reasonable period of time any reimbursements that exceed substantiated expenses.


If these criteria of the University's plan are not met, the full amount of the reimbursement will be included in your income. You then may claim the reimbursed expenses as a miscellaneous itemized deduction when you file your income tax return, but such deductions are only allowed to the extent to which they exceed 2 percent of your adjusted gross income.

Authorization and Approval Requirements (for Reimbursement Requests)

The general rule is that the "Approver" to any payment/ reimbursement request should be the individual with a supervisory relationship to the employee being paid or reimbursed ("Payee"). When the Approver is not available, an "Alternate Approver" may authorize the request, and this should be an individual who has signature authority over the funds being charged. In no case should the Approver (or Alternate Approver) and the Payee be the same individual. Also, rubber stamp signatures are not acceptable.

Contact AP Customer Service at (212) 998-2990 for specific questions.

Approver/Responsibilities

Source: NYU Expense Reimbursement Policy

The "Approver" is responsible for verifying the following:

  • that the expense is permitted under the Business Expenses Policy of the University, and that no non-reimbursable expenses are included;
  • that funds to which the expense is charged are sufficient;
  • that documentation is adequate and correct (In case of inadequate or missing documentation, the approver's signature signifies that he/she is aware of the fact, has verified the explanation, and deems the expense valid for reimbursement);
  • that any exception to policy has been noted and found appropriate.

B

Business Expenses

Source: NYU Business Expenses Policy

New York University funds may be used only for necessary and reasonable expenses that support the missions of the University. University funds come from a variety of sources (as gifts, grants and contracts, or revenue from the government, students, alumni, and various agencies) that carry with them fiduciary responsibilities. These responsibilities require the University to maintain operations according to guidelines established by the University's Board of Trustees, and to comply with applicable federal, state, and local rules and regulations. Below are some of those key rules and regulations that shape the University policy on business expenses.

IRS Rule on Accountable Plan

IRS on Business Meals and Entertainment

Federal Acquisitions Regulations (FAR)

OMB Circular A-21 (Cost Principles for Educational Institutions)

OMB Circular A-110 (Uniform Requirements for Federal Grants & Contracts)

NYU Standardized Policy on Reimbursement of Business Expenses

Business Meals (during meetings or events)

Source: NYU Business Expenses Policy

A business meal is defined as a meal taken with University faculty, staff, or students which may or may not include others from outside the University at which a substantial and bona fide business discussion takes place. The University requires the following for reimbursement:

  1. Substantiation of the meal itself as having a business purpose, which involves providing the reason for the meal itself, the names of individuals or group of individuals present, and the affiliations of those present.
  2. adequate documentation, which identifies specific costs and shows that no alcoholic beverages are included, or when included, shows that alcoholic beverages have been segregated and charged to an appropriate NYU account.

    Note: The federal government deems alcoholic beverages as unallowable (see Appendix 1: OMB Circular A-21 summary). When reporting expenses related to business meetings or events, make sure that every expense is identified and that receipts include a notation that either a) alcoholic beverages are not part of the expenses, or b) alcoholic beverages are included and have been segregated.

See the Expense Reimbursement Policy of the University for more information on reimbursement of business meals.

University funds cannot be used to pay for meals for which there is no clearly documented business purpose.

Business Meals (during travel)

Source: NYU Business Expenses Policy

Individuals who travel on University business are reimbursed for meal expenses they incur. The University reimburses meal expenses in two ways: according to actual, substantiated costs, or at established "per diem" rate. Travelers cannot switch between these two methods in one trip; the method travelers choose applies to all meal expenses incurred throughout the trip.

When opting to be reimbursed based on actual costs of each meal, travelers are required to provide detailed receipts or other appropriate documentation for all meals taken throughout the trip. Documentation is necessary in satisfying requirements of the University's "accountable plan," an expense allowance and reimbursement arrangement governed by IRS regulations (see the Expense Reimbursement Policy for detailed information).

The alternative to keeping receipts and other appropriate documentation for each meal during travel is the "per diem," or being reimbursed at an amount set as meal allowance for each day of travel. The per diem applies only when overnight travel is involved. The per diem rate is $50.

When reporting meal expenses for reimbursement based on the per diem rate, you are required to prorate the meal allowance for the first and last day of your trip. For example, if you left for your trip at 1 p.m., you cannot claim meal allowance for breakfast on that day; or, when you return home from your trip at 3 p.m., you cannot claim meal allowance for dinner on that day.

For foreign per diem rates applicable to federally sponsored projects, refer to http://www.state.gov/travel

Gratuities for meals are deemed part of the meal cost and will be reimbursed by the University provided these are reasonable (that is, do not exceed 20% of total meal cost).

Note: The University permits the use of University funds for employees' meal expenses only when overnight business travel is involved, or when employees are away from their normal work location for an entire day on University business (e.g., all-day conference or meeting "off-campus").

The University's general guideline is that total expenses for lodging and meals should not exceed $350 per day. Exceptions will be granted if the expense is necessary, documented, and approved by the appropriate school/department representative.

Business Meals, Appropriate Documentation for (reimbursement)

1. Receipts

Meals during business meetings and events are examples of occasions at which certain costs deemed unallowable by the federal government may ordinarily be incurred (e.g., alcoholic beverages; see Appendix 1, OMB Circular A-21, Section J-2). To avoid the inadvertent inclusion of such costs to direct or indirect charges to federal funds, federal guidelines require that such costs be identified and segregated in the University's general ledger.

The best documentation therefore for expenses related to meals and catering are original, itemized receipts showing detailed list of food and beverages purchased. Itemized receipts establish that federal unallowable costs are either (a) not part of the expenses, or (b) part of the expenses but are identified, segregated, and charged to an appropriate NYU account.

Restaurant tabs and credit card slips by themselves are not the best documentation for the reason that they cannot validate the types of expenses incurred. However, the University is cognizant of cases and circumstances where itemized receipts may not be available or obtainable. Some establishments may issue receipts that only provide a summary of expenses with the total charges; others issue only a customer's portion of a tab that indicates total charges. In such cases, the University will deem "appropriate" documentation those "summary receipts" and tabs; and in cases where receipts are not available at all, those credit card slips generated when payment was made using a credit card. However, the following conditions apply:

  • the expense report should include a notation that no alcoholic beverages are included in the expenses incurred; or,
  • when the expenses include alcoholic beverages, the report should specify the cost, segregate it from federal allowable costs, and charge it to an appropriate NYU account.

2. Business Purpose

Also required for reimbursement of business meal expenses is the substantiation of the meal itself as having a business purpose. When reporting expenses, include the reason for the business meal, the names of individuals present, and their affiliations.

Business Travel

Source: NYU Business Expenses Policy

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 before departure.

Note: This policy applies to all University business travel regardless of the source of funds (whether federal, state, private, or general). However, when travel is charged to federally funded or sponsored projects, the terms of a particular grant or contract should be consulted before incurring any expense to ensure compliance to specific or additional requirements. See the "Sponsored Projects" section above.

For all schools or units that have been migrated to NYU Traveler, all reimbursement requests related to travel will require the following the documentation to be submitted as part of the AP Workflow request.

For travel booked via NYU Traveler using one of the University’s two preferred travel agencies (American Express or Egencia):

  • a copy of the travel invoice (travelers will receive this documentation by email after making their travel reservation – it is important to retain this email for submission to Accounts Payable (AP)).
  • a copy of the travelers boarding pass (for air or rail travel).

For travel booked via any other agency:

  • a copy of the travel invoice;
  • a copy of the confirmation of registration in Worldcue (travelers will receive this documentation by email from Worldcue after manually entering their travel itinerary via NYU Traveler – it is important to retain this email for submission to AP).
  • a copy of the travelers boarding pass (for air or rail travel).

For Frequently Asked Questions about NYU Traveler and on how it will help keep you safer as you travel on NYU-related business, go to www.nyu.edu/nyutraveler.

C

Cash Advances

The University allows a maximum of $500 on a seven-day period to be issued as a cash advance to any University employee about to travel on University business. The amount may be issued in check through Accounts Payable, or withdrawn from any participating Automated Teller Machine (ATM) using the NYU Travel Card. You will be assessed a fee on your withdrawal; this fee is reimbursed as part of your business expenses.

Cash advances are intended for anticipated expenses that are best paid in cash, and for which the NYU Travel Card may not be feasible (e.g., taxi fare, gratuities, etc.).

Cash advances should not be used for airfare, lodging, conference fees, or other substantial costs that can be paid using the NYU Travel Card, or can be "prepaid" and invoiced though Accounts Payable. Because of tax implications, cash advances should also not be used for service payments such as honorariums, or for such expenses as gifts, prizes, or awards.

Cash advances should be cleared within 30 days from the "end date" of the trip or event specified on the cash advance request form (ADV3000).

Abuse of cash advance privileges may result in revocation of such privileges in the future.

Cash Advances Issued from the Petty Cash Fund

Cash advances of "petty" or minimal amount may be requested from the imprest petty cash fund to cover anticipated minor expenses (e.g., local taxi fare or subway fare for office errands about to be made).

Note: Cash advances may be issued only for those expenses that are deemed appropriate to be paid through the imprest petty cash fund (see "Purpose and Use of Petty Cash Fund").

Cash advances for expenses related to a future business meeting or office event may be issued from the petty cash fund, provided that these do not exceed $150 and are authorized. To clear this advance, you need to submit a completed Expense Breakdown Sheet for Business Meals (EXP2000M) to the Fund Custodian with appropriate documentation attached.

Note: The Office of the Bursar cannot issue cash advances. Schools, departments, or units that do not operate an imprest petty cash fund and normally process petty cash transactions through the Office of the Bursar must request cash advances, regardless of amount, through Accounts Payable.

The Request for Advance Form (ADV3000) is not required when requesting an advance from the petty cash fund; this form is required only when the request is submitted to Accounts Payable. However, an individual is required to sign on the Petty Cash Fund Log to signify receipt of a cash advance, and to also sign when clearing this advance. All cash advances must be accounted for, and any unspent amount returned, within a reasonable time.

Fund Custodians are responsible for ensuring that (1) advance payments issued from the fund are for valid purposes and fall within the guidelines on what may be paid through the petty cash fund; (2) that the advance is accounted for in due time; and, (3) that any unspent amount is returned to the fund.

Cash Incentive Payments (Human Subjects/Sponsored Projects)

Cash incentive payments are usually issued in appreciation and to encourage the participation of individuals in research projects (as human subjects), when such participation agrees with conditions of sponsoring agencies and the Institutional Review Board (IRB). These payments, to be deemed valid, must be made in accordance with the terms and conditions of sponsor agencies.

For specific guidance on cash incentive payments related to sponsored projects at the School of Medicine, contact the Office of Grants Administration and Research Services or the Finance Sponsored Programs in the Controller's Office. For all other schools, contact Research and Restricted Accounting Services (RRAS) in the Controller's Division or the Office of Sponsored Programs.

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 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.

For additional rules and requirements that apply to sponsored programs, see the Office of Sponsored Programs website.

Cost Accounting Standards

(from OMB Circular A-21)

In 1996, OMB issued revisions to Circular A-21 (61 Fed. Reg. 20,880) establishing the Cost Accounting Standards (CAS) applicable to educational institutions. The "standards" provide the principles and criteria for estimating, accumulating, and reporting costs of grants and contracts subject to OMB Circular A-21. The objective is to increase the uniformity and consistency of cost accounting practices across colleges and universities. The four standards, listed below, are outlined in Appendix A of OMB Circular A-21:

2.1. Cost Accounting Standard 501
This Standard ensures "consistency of estimating, accumulating and reporting costs by educational institutions." Costs included in contracts or grant proposals as direct costs must be accumulated as direct charges in accounting records.

2.2. Cost Accounting Standard 502
This standard ensures "consistency in allocating costs incurred for the same purpose by educational institutions." It requires the University to establish cost accounting practices that are consistently applied throughout the system. A department cannot account for costs in one manner and another department accounts for costs in another manner.

2.3. Cost Accounting Standard 505
This standard accounts for unallowable costs, requiring them to be identified and excluded from any costs charged to federal contracts and grants.

2.4. Cost Accounting Standard 506
This standard requires that a university establish its cost accounting period to be the same as their fiscal year.

Cost Accounting Standards Disclosure Statement (Form DS-2; OMB Circular A-21)

A Cost Accounting Standards Disclosure Statement is a standard federal form used to document or disclose an organization's cost accounting practices which must comply with Circular A-21 and any applicable cost accounting standards. A cost accounting practice is defined as any accounting method or technique used to measure cost, to assign cost to cost accounting periods, or to allocate costs to cost objectives.

An educational institution is required to file a CAS Disclosure Statement with its federal administrative cognizant agency if it receives federally sponsored agreements totaling $25 million or more in a fiscal year. Costs will be disallowed if the university fails to comply with Circular A-21 or fails to consistently follow its established or disclosed cost accounting practices (DS-2) when estimating, accumulating or reporting the costs of sponsored agreements such as contracts and grants.

D

Disbursement Operations

Of Cash Advances Issued from the Petty Cash Fund

Cash advances of "petty" or minimal amount may be requested from the imprest petty cash fund to cover anticipated minor expenses (e.g., local taxi fare or subway fare for office errands about to be made).

Note: Cash advances may be issued only for those expenses that are deemed appropriate to be paid through the imprest petty cash fund (see "Purpose and Use of Petty Cash Fund").

Cash advances for expenses related to a future business meeting or office event may be issued from the petty cash fund, provided that these do not exceed $150 and are authorized. To clear this advance, you need to submit a completed Expense Breakdown Sheet for Business Meals (EXP2000M) to the Fund Custodian with appropriate documentation attached.

Note: The Office of the Bursar cannot issue cash advances. Schools, departments, or units that do not operate an imprest petty cash fund and normally process petty cash transactions through the Office of the Bursar must request cash advances, regardless of amount, through Accounts Payable.

The Request for Advance Form (ADV3000) is not required when requesting an advance from the petty cash fund; this form is required only when the request is submitted to Accounts Payable. However, an individual is required to sign on the Petty Cash Fund Log to signify receipt of a cash advance, and to also sign when clearing this advance. All cash advances must be accounted for, and any unspent amount returned, within a reasonable time.

Fund Custodians are responsible for ensuring that (1) advance payments issued from the fund are for valid purposes and fall within the guidelines on what may be paid through the petty cash fund; (2) that the advance is accounted for in due time; and, (3) that any unspent amount is returned to the fund.

Of Petty Cash Fund

Due to the nature of minor expenditures reimbursed through the petty cash fund, the University does not require an Expense Reimbursement Form (EXP2000) to be completed for every request submitted to the Fund Custodian. Form EXP2000 is necessary only when reimbursement request is submitted to the Office of the Bursar. A subway or taxi fare for local travel, for instance, does not have to be reported on Form EXP2000. These minor expenditures are reported together by the Fund Custodian on Form EXP2000 when replenishment (or reimbursement to the fund itself) needs to be processed through the Office of the Bursar. This form is reviewed by the Approver to verify that expenses paid from the petty cash fund are valid and permissible.

Form EXP2000 is also not required when requesting reimbursement from the petty cash fund for expenses related to travel and non-travel business meals that total less than $150. Expenses however should be reported in detail on the appropriate Expense Breakdown Sheet (Form EXP2000T for travel or Form EXP2000M for business meals) and supported by appropriate documentation. The breakdown sheet and the appropriate documentation are necessary to establish that federal "unallowable costs" are not included in the reimbursement being requested, or are identified, segregated, and charged to appropriate NYU account (see "Documentation Requirements" section below).

Fund Custodians are advised to use the Petty Cash Fund Log (see "Forms" section) to record transactions made through the fund. This log reflects the type of expenses paid from the fund, the amount of each expense, the account charged for each expense, and the signatures of those paid from the fund. This log should be maintained and made readily available for examination by authorized representatives of the University, including its internal auditors and independent public accountants (see "Custodian Responsibilities" above).

Employees are advised to check with their Fund Custodian for whatever requirements that apply in their area. In order to assist the management of various minor expenses incurred outside of the regular purchasing system and cycle, and to ensure adherence to applicable University policies, some schools, departments, or units may impose stricter requirements for getting reimbursed through the local petty cash fund. Such requirements may involve completing a petty cash voucher designed for internal use and getting a prior, written approval for specific transactions.

Documentation Requirements

Examples of Appropriate Documentation

Source: NYU Expense Reimbursement Policy

As noted in the “General Reimbursement Guidelines” section of NYU's Expense Reimbursement Policy, New York University is subject to certain rules of the federal government, specifically those rules that apply to how the University records and reports expenses.

The University accepts funds from the federal government and is therefore required to abide by its cost accounting policies. Those policies apply not just to the federal funds themselves but to all funds at the University.

The federal government mandates that certain costs must not be charged directly to a federal fund, or charged indirectly to a federal fund through the University's facility and administrative (indirect) cost rate. See Appendix 1 for a list of common federal unallowable costs. For specific guidance on federal unallowable costs that the University may permit and reimburse, see the Business Expenses Policy of the University.

To ensure University compliance to the federal rule on “unallowable costs” and IRS guidelines, the University requires that expenses submitted for reimbursement be appropriately documented. The documentation that best satisfies federal requirements are the original vendor-generated receipts that identify each item purchased. In cases where original vendor-generated receipts are not available or possible, other appropriate documentation may be submitted.

Documentation, to be deemed appropriate or adequate, should show as much as possible the type of expenses incurred and should establish that federal “unallowable costs,” if part of the expenses, are identified and segregated. Table 1 below lists some documentation deemed appropriate for specific business expenses.

Note: The University prefers to get receipts for all expenses submitted for reimbursement. It will however reimburse approved non-meal expenses under $25 without receipts. Expenses related to meals, regardless of the amount, require receipts to be reimbursed.

Table 1: Appropriate Documentation for Common Business Expenses

Airline/Rail

Paper Ticket: The original “passenger receipt coupon” from the airline that is usually issued to a passenger when a printed paper ticket has been purchased.

Electronic Ticket: Passengers who are issued electronic tickets should request a “passenger receipt coupon,” or, when purchase is made online, attach a printout of the page confirming the purchase.

Car Rental

Car rental agreement or receipt for payment made

Cell Phones

Monthly itemized bill

Conference/Seminar

Registration receipt, which should show name, date, venue, and registration cost for conference or seminar

Foreign Currency

All expenses paid in foreign currency should be reported in U.S. dollars. The conversion rate as indicated by the University's banking institution for the period in which the purchase was made should be included on the form. Any fee paid for currency conversion is reimbursable and should be supported by the receipt provided by the establishment that processed the conversion.

Hotel/Lodging

The final hotel folio or itemized bill for lodging and expenses charged to the room.

When hotels do not include charges for a room in the hotel folio, as in cases when hotel accommodations were not arranged directly with the hotel but “purchased” online through Web sites guaranteeing low, flat rates, the printout of your online transaction should serve as appropriate documentation.

Meals (Non-Travel) / Catering Related to Business Meetings or Events

1)  Receipts

Meals during business meetings and events are examples of occasions at which certain costs deemed unallowable by the federal government may ordinarily be incurred (e.g., alcoholic beverages; see Appendix 1, OMB Circular A-21, Section J-2 of NYU's Expense Reimbursement Policy). To avoid the inadvertent inclusion of such costs to direct or indirect charges to federal funds, federal guidelines require that such costs be identified and segregated in the University's general ledger.

The best documentation therefore for expenses related to meals and catering are original, itemized receipts showing detailed list of food and beverages purchased. Itemized receipts establish that federal unallowable costs are either (a) not part of the expenses, or (b) part of the expenses but are identified, segregated, and charged to an appropriate NYU account.

Restaurant tabs and credit card slips by themselves are not the best documentation for the reason that they cannot validate the types of expenses incurred. However, the University is cognizant of cases and circumstances where itemized receipts may not be available or obtainable. Some establishments may issue receipts that only provide a summary of expenses with the total charges; others issue only a customer's portion of a tab that indicates total charges. In such cases, the University will deem "appropriate" documentation those "summary receipts" and tabs; and in cases where receipts are not available at all, those credit card slips generated when payment was made using a credit card. However, the following conditions apply:

a)  the expense report should include a notation that no alcoholic beverages are included in the expenses incurred; or,

b) when the expenses include alcoholic beverages, the report should specify the cost, segregate it from federal allowable costs, and charge it to an appropriate NYU account.

2) Business Purpose

Also required for reimbursement of business meal expenses is the substantiation of the meal itself as having a business purpose. When reporting expenses, include the reason for the business meal, the names of individuals present, and their affiliations.

Meals During Travel

1) Receipts

Individuals who travel on University business are reimbursed for meal expenses they incur in two ways: according to actual, substantiated costs, or at an established “per diem” rate. Travelers cannot switch between these two methods on one trip; the method travelers choose applies to all meal expenses incurred throughout a trip.

  • Based on actual substantiated costs

    When opting to be reimbursed based on actual costs of each meal, travelers are required to provide detailed receipts or other appropriate documentation for all meals taken throughout the trip. Gratuities for meals are deemed part of the meal cost and will be reimbursed by the University provided these are reasonable (that is, do not exceed 20% of total meal cost).

  • Based on “per diem” rate

    The alternative to keeping receipts and other appropriate documentation for each meal during travel is the “per diem,” or being reimbursed at an amount set as meal allowance for each day of travel. The per diem applies only when overnight travel is involved. The per diem rate is $50.

    For foreign per diem rates applicable to federally sponsored projects, refer to www.state.gov/travel.

2) Business Purpose

Meals taken by employees during business travel are deemed “business meals.” The business purpose of the trip also serves as the business purpose for the meals.

Private Vehicles

Receipts for expenses related to the use of private vehicles for University business such as those issued by toll stations or parking facilities. Reimbursement request should include mileage calculation. For current rate, see the CDV Web site.

Telephone/Fax Charges

If made from home, the monthly bill detailing calls or fax transmissions made. If made at commercial establishments, the vendor-generated receipt showing amount, date, and type of expense. If charged to the hotel room, these charges should be included in the final hotel folio.

Office Supplies (Incidental Purchases)

Original receipt issued by the vendor

Request for reimbursement must also include an explanation why office supplies were purchased outside of the University's regular procurement methods.

Online Purchases

Printout of the page confirming the purchase; or, a printout of the page summarizing the type of purchase made, the date, and the amount.

 

 

When reporting expenses that are not supported by original receipts or by other documentation deemed appropriate in Table 1 above, you are required to provide other proofs of purchase and/or other documentation to support the validity of your expense. See the “Missing or Inadequate Documentation” section of NYU's Expense Reimbursement Policy.

For Payment Requests

In order to be reimbursed for any business expense, adequate supporting documentation is required. The documentation that best satisfies Internal Revenue Service (IRS) requirements is the detailed original receipt produced by the establishment from which products or services were purchased. If a purchase is made online, adequate documentation is the page confirming the purchase, or the summary page that is usually generated when an online purchase has been processed. At a hotel, appropriate documentation is the final detailed printout of charges. For an airline, it is the ticket stub or an electronic ticket confirmation page. At a restaurant, it is the detailed printout of all food and beverage items you purchased.

Credit card slips and credit card statements are not adequate documentation by themselves.

If you do not have adequate documentation for a transaction, attach a signed note to your reimbursement request explaining the details of the transaction, why adequate documentation is not available, and why an exception to policy should be made in that instance. You may also attach any credit card slips or copies of credit card statements that can help support your explanation, even though these are not adequate documentation by themselves.

See Documentation Requirements (for Payment Requests) in Expense Reimbursement Standardized Policy

For Petty Cash Fund

The documentation requirements for petty cash fund transactions reflect the University’s policy on expense reimbursement. Any expense that is paid using University funds must be justified as well as properly documented.

The documentation that best satisfies federal requirements and ensures University compliance are the vendor-generated receipts that identify each item purchased. In cases where itemized receipts cannot be obtained, individuals should provide other forms of documentation appropriate for the expense. See the Expense Reimbursement Policy of the University for specific requirements and guidelines.

Note: The University prefers to get receipts for all expenses submitted for reimbursement. It will however reimburse approved expenses under $25 without receipts (except meals).

Missing or Inadequate Documentation (for Reimbursement of Expenses)

When the original receipts of expenses that you are requesting reimbursement for have been lost or cannot be obtained, you need to provide other documentation that may support the validity of your expenses. When submitting documentation in lieu of original receipts, complete a “Missing/Inadequate Documentation Report”. Check the policy of your school, department, or unit as it may require that the Report be signed by an individual designated specifically to review and approve the Report before the request is submitted to the “Approver.” Attach this Report with your documentation to your request form.

Note: The Report is not required for the following:

  • expenses under $25 (except meal expenses that, regardless of amount, must be supported by receipts);
  • business meal expenses incurred in establishments that do not issue itemized receipts, or for which original itemized receipts have been lost;
  • expenses related to individual’s meals during business travel, when the traveler has opted for the “per diem” method of reimbursement.

E

Expense Reimbursement, Offices to Contact on specific Issues

Source: NYU Expense Reimbursement Policy

Direct any general questions about the Expense Reimbursement Policy to your department's administrative office. If you need guidance or assistance on specific issues, contact the offices listed below:

Subject

Contact

Approval and Authorization

Cash Advance

Documentation Requirements

Missing or Lost Receipts

Policy Clarification

Record Retention Requirements

Reimbursable Expenses

Reimbursement Process

Timing

Accounts Payable Customer Service
Controller's Division
726 Broadway, 2nd Floor
New York, NY 10003

Tel: 212-998-2990
Fax: 212-995-4586

Email: cdv.apcs@nyu.edu

 

 

 

 

Reimbursement in Cash

Office of the Bursar
Tel: 212-998-2829

Reimbursement of Expenses Charged to Sponsored Programs

For School of Medicine:

Sponsored Programs, Controller's Office
Tel: 212-263-7006

Office of Grants Administration and Research Services
Tel: 212-263-8822

For All Other Schools:

Research and Restricted Accounting Services
Tel: 212-998-2704

Office of Sponsored Programs
Tel: 212-998-2121

F

Federal Allowable and Unallowable Costs

Source: NYU Business Expenses Policy

The University permits the use of University funds for those expenses that support its missions. For details on these expenses, see the "NYU Permissible Expenses" section of NYU's Business Expenses Policy. For types of expenses that the University will not permit University funds to be used, see the "NYU Nonpermissible Expenses" section of the same policy.

Certain expenses that the University deems legitimate and permissible may be deemed unallowable by the federal government. The University will permit University funds to be used for such expenses, however, they must be identified and segregated in the University's general ledger. See the "Federal Allowable and Unallowable Expenses" section of NYU's Business Expenses Policy for more information.

To ensure that federal guidelines are identified and distinguished from those guidelines specific only to or established by NYU, expenses that are deemed permissible/nonpermissible by the University will be referred to as "NYU permissible/nonpermissible expenses." Expenses specifically identified in OMB Circular A-21 will be referred to as "federal allowable/unallowable expenses."

Segregation of Federal Allowable and Unallowable Costs

Source: NYU Business Expenses Policy

A federal unallowable cost may be permissible under University guidelines. Flowers and alcoholic beverages are examples of costs that are "unallowable" for federal purposes. However, when deemed appropriate and legitimate under University guidelines, the University may permit such expenses.

Federal regulations require that all federal unallowable costs be segregated in the University's general ledger so that they can be excluded from the University's indirect cost submissions. To ensure that an unallowable cost is not inadvertently charged directly or indirectly to federal funds, unallowable costs must be identified, segregated, and charged to appropriate NYU accounts.

Note: It is because of this federal rule on "unallowable costs" that certain requirements in this policy and in the Expense Reimbursement Policy of the University are very specific. To ensure University compliance, all expenses submitted to the University for payment or reimbursement must be (1) justified to establish their business purpose, and (2) sufficiently substantiated by such documents as detailed original receipts to identify the nature of each expense. See the Expense Reimbursement Policy for details on the University's documentation requirements and for examples of documentation deemed appropriate for specific business expenses.

Financial Misconduct, Reporting and Investigation of

Source: NYU Policy on the Reporting and Investigation of Potential Financial Misconduct

All members of the New York University community have a responsibility to ensure that University funds and resources are used only in activities that support the missions of the University; to protect University funds and resources from theft, misuse, misappropriation and other conduct that may be injurious to the financial welfare and reputation of the University; and, to ensure the integrity of the University’s financial records through accurate reporting.

Reporting Potential Financial Misconduct

Source: NYU Policy on the Reporting and Investigation of Potential Financial Misconduct

When financial misconduct is suspected or uncovered by any member of the University community, it should be reported promptly and in a confidential manner.

To report known or suspected financial misconduct, contact the Audit Director or any audit staff of the University's Department of Internal Audit (see the "Contacts" section of the NYU's Standardized Policy on the Reporting and Investigation of Financial Misconduct).

Heads of any school, department, or unit of the University who receive reports of potential financial misconduct from any member of their staff are required to contact Internal Audit. All are advised to refrain from conducting an investigation on their own, or from taking any action to resolve the irregularity before consulting Internal Audit.

University employees who wish to report potential misconduct anonymously may call the NYU Compliance "Hotline" (see the "Contacts" section of the NYU's Standardized Policy on the Reporting and Investigation of Financial Misconduct). This service was established according to the policy of the University's Board of Trustees (through its Audit Committee). University Employees may also directly call the Office of the Audit Committee Chair of the University's Board of Trustees.

All information regarding known or suspected of financial misconduct is deemed privileged and confidential. The University protects the identity of both those who alert the University to any irregularity and those suspected of wrongdoing.

Fringe Benefit Rate

G

Gifts and Awards

To Employees

Source: NYU Business Expenses Policy

The University recognizes the contribution of employees to the furtherance of University missions and may on occasion confer gifts, prizes or awards as tokens of appreciation. The federal government deems these expenses as "unallowable costs" (see Appendix 1, Section J-14 of NYU's Standardized Policy on Business Expenses). However, wherever deemed appropriate and so long as reasonable, justified, and substantiated, these expenses may be deemed permissible under NYU guidelines. Specific requirements apply for gifts, prizes, and awards to be deemed excludable from the recipient's taxable income.

Gifts: Cash gifts (including gift certificates) are considered taxable income and are subject to withholding tax, unless the gift is less than $25. Non-cash gifts or gifts of property are exempt from tax if the value is minor; the value of a non-cash gift is deemed minor when it does not exceed $400.

Length of Service Award: To be considered a "length of service award" and excluded from taxable income, all the conditions below must apply:

  • The award is administered under a University-wide program and every University employee is presented with the award at least five years apart.
  • The employee presented with the award has been employed by the University no less than five years.
  • The value of any non-cash gift presented in recognition of an employee's length of service must not exceed $1600. When the value of the gift exceeds $1600, the amount in excess of $1600 will be reported as income to the individual. The University is required to include the taxable amount in the employee's W2 and to deduct withholding taxes on his/her paycheck.

For government rules on items listed above, see Section 74 of the Internal Revenue Code: Prizes and Awards.

Note: Under no circumstances will individuals be reimbursed for cash gifts (cash or personal checks) given to another employee or student. All cash gifts, regardless of the amount, must be issued as University Accounts Payable checks or processed through Payroll to ensure correct documentation and tax reporting.

To Non-Employees

Source: NYU Business Expenses Policy

University funds may be used for costs related to gifts, prizes, and awards presented to individuals who are not University employees, provided they serve the mission of the University and are authorized. Such costs must not be charged directly or indirectly to a federally sponsored account.

Goods and Services

Not subject to Purchasing Guidelines

Source: NYU Business Expenses Policy

In general, goods and services listed in categories below are not within the purview of Purchasing Services. These expenses may be incurred without Purchasing Services review and approval:

A. Goods and services managed by a specific University designee:

  • the purchase, sale or lease of real estate (which is handled by NYU's Office of Real Estate);
  • the design, construction, or alteration of plant (which, at the School of Medicine, is handled by its Office of Real Estate and Strategic Capital Initiatives (RESCI) and, for all other schools, is handled by NYU's Planning and Construction Department);
  • the procurement of books and periodicals for University libraries (which is handled by the University Libraries)

B. Items that do not require a Purchase Order, such as the following:

  1. Goods or services below a specific value obtained through the following methods:
    • goods or services totaling $2,500 or less that are obtained using the Procurement Card;
    • goods or services totaling $1,000 or less that are obtained using the Low Dollar Order System or paid/reimbursed through Accounts Payable;
    • minor, incidental expenditures that may be paid or reimbursed through a department's imprest petty cash fund (see "Goods of Minimal Value" in the NYU Business Expenses Policy).
  2. Catering expense totaling $1,000 or less

    • Note: Effective September 1st, 2010, the Re-Engineering II Catering initiative requires that all on-campus catered events costing more than $1,000 be conducted with a very limited number of catering firms. Such catering expenses per occasion must be handled via Purchase Order.
  3. Goods and services in specific categories, regardless of value:
    • advertisements*
    • advisory fees
    • annuity payments
    • books and periodicals
    • cable and television bills
    • car services*
    • catering*
    • commission fees
    • conference/registration fees
    • conference space*
    • courier services
    • events tickets when purchased for program related activities
    • insurance payments (comprehensive, general liability, malpractice)
    • legal fees
    • mailing lists
    • mass transit tickets to be used for local business travel by the school or department
    • medical billing companies*
    • membership fees
    • permits
    • refunds (Sponsored Research grants, classes or seminars not paid through the Office of the Bursar, patient refunds)
    • reprints
    • subscriptions (renewals, magazines, newspapers, etc.)
    • temporary service agencies
    • test materials (standardized testing)
    • utility bills

      * These do not require a Purchase Order when no contract is required; a Blanket Order may be established when ordered on a repetitive basis.
  1. 2. Professional or consulting services provided by companies or individuals involving fees less than $50,000. When fees involved are over $50,000, Purchasing Services requires a Purchase Requisition. The Purchase Requisition is not required only when the service provider has signed a University Consulting Agreement, (see Purchasing Services website at www.nyu.edu/purchasing.services) or a distinct signed agreement that has been approved by the University's legal counsel. Appropriate school or departmental approval is always required.

    Note: Professional or consulting services provided by individuals are subject to specific federal rules and requirements. To ensure consistent compliance and provide guidance to those involved in the procurement and payment of these services, the University has established the Independent Contractors and Consultants Policy. For more information, see “Independent Contractors and Consultants” in the NYU Business Expenses Policy.

Subject to Purchasing Guidelines

Source: NYU Business Expenses Policy

The Purchasing Services and Contract Administration Department of the University has been given the responsibility by the Trustees of New York University to purchase goods and services on behalf of the University, which includes the selection of vendor, negotiation of price, and assurance of quality and delivery. Purchasing Services functions as an agent of the University and is responsible for advising schools, departments, and units on availability and value of goods and services in the marketplace.

NYU Purchasing Services is required by federal regulations to maintain a formal procurement system. Its purchasing files are subject to audit by federal agencies and must include proper documentation (i.e., purchase orders, contract negotiations, bid awards, sole source justifications, etc.).

Any goods and/or services purchased with University funds or University-managed funds (i.e., Sponsored Research Accounts), unless identified as outside of Purchasing Services purview, are bound by conditions and requirements detailed in the Purchasing Policies and Procedures Manual.

Goods purchased and charged to sponsored projects, regardless of the amount, are subject to the terms and conditions of a particular grant or contract. These terms should be referred to for guidance on what expenses are allowed. Projects that are funded by the federal government are subject to the rules and requirements detailed in the Office of Management and Budget (OMB) Circular A-21 (see Appendix 1 of the NYU Business Expenses Policy for a summary). All schools other than the School of Medicine should contact Research and Restricted Accounting Services (RRAS) in the Controller's Division or the Office of Sponsored Programs for questions related to a specific grant or contract. For questions related to sponsored projects at the School of Medicine, contact the Office of Grants Administration and Research Services or the Finance Sponsored Programs in the Controller's Office.

H

Honorariums, Payment of

Source: NYU Business Expenses Policy

University funds may be used for an amount or item presented as a gesture of goodwill or in appreciation of efforts and time given by individuals to the University, such as a guest lecturer or a speaker from outside the University. The University requires that such expenses be reasonable and made under conditions or circumstances that do not create a significant likelihood for the gesture to be deemed as "disguised" payment.

Honorariums are considered taxable income to the individual receiving the benefit.

I

Independent Contractors and Consultants

Source: NYU Business Expenses Policy

The University allows schools, departments, or units to engage the services of independent contractors or consultants when the needed skills or expertise are not readily available within the University.

The classification and reporting of payments to individuals who provide services to the University as independent contractors and consultants are subject to specific federal regulations. The tax and other requirements appropriate to their designation differ from those applied to individuals classified as employees. Incorrect classification of a service provider as an independent contractor may subject the University to significant tax penalties and other risks.

Therefore, those intending to engage the services of independent contractors and consultants are required to follow the status determination, procurement, and payment procedures established in the Independent Contractors and Consultants Policy of the University before services are performed.

Appropriate Documentation for Paying Independent Contractors

All other conditions and requirements established for reimbursements issued to University employees also apply to reimbursements issued to independent contractors and consultants. When the independent contractors or consultants are not citizens or residents of the United States, additional requirements may apply. See the IRS guidelines on the CDV Web site.

J

Journal Entries (Automated)

M

Meals

"Per Diem" Rate for Meals During Travel

Source: NYU Business Expenses Policy

Individuals who travel on University business are reimbursed for meal expenses they incur. The University reimburses meal expenses in two ways: according to actual, substantiated costs, or at established "per diem" rate. Travelers cannot switch between these two methods in one trip; the method travelers choose applies to all meal expenses incurred throughout the trip.

When opting to be reimbursed based on actual costs of each meal, travelers are required to provide detailed receipts or other appropriate documentation for all meals taken throughout the trip. Documentation is necessary in satisfying requirements of the University's "accountable plan," an expense allowance and reimbursement arrangement governed by IRS regulations (see the Expense Reimbursement Policy for detailed information).

The alternative to keeping receipts and other appropriate documentation for each meal during travel is the "per diem," or being reimbursed at an amount set as meal allowance for each day of travel. The per diem applies only when overnight travel is involved. The per diem rate is $50.

When reporting meal expenses for reimbursement based on the per diem rate, you are required to prorate the meal allowance for the first and last day of your trip. For example, if you left for your trip at 1 p.m., you cannot claim meal allowance for breakfast on that day; or, when you return home from your trip at 3 p.m., you cannot claim meal allowance for dinner on that day.

For foreign per diem rates applicable to federally sponsored projects, refer to http://www.state.gov/travel

Gratuities for meals are deemed part of the meal cost and will be reimbursed by the University provided these are reasonable (that is, do not exceed 20% of total meal cost).

Note: The University permits the use of University funds for employees' meal expenses only when overnight business travel is involved, or when employees are away from their normal work location for an entire day on University business (e.g., all-day conference or meeting "off-campus").

The University's general guideline is that total expenses for lodging and meals should not exceed $350 per day. Exceptions will be granted if the expense is necessary, documented, and approved by the appropriate school/department representative.

During Business Meetings and Events

1. Receipts

Meals during business meetings and events are examples of occasions at which certain costs deemed unallowable by the federal government may ordinarily be incurred (e.g., alcoholic beverages; see Appendix 1, OMB Circular A-21, Section J-2). To avoid the inadvertent inclusion of such costs to direct or indirect charges to federal funds, federal guidelines require that such costs be identified and segregated in the University's general ledger.

The best documentation therefore for expenses related to meals and catering are original, itemized receipts showing detailed list of food and beverages purchased. Itemized receipts establish that federal unallowable costs are either (a) not part of the expenses, or (b) part of the expenses but are identified, segregated, and charged to an appropriate NYU account.

Restaurant tabs and credit card slips by themselves are not the best documentation for the reason that they cannot validate the types of expenses incurred. However, the University is cognizant of cases and circumstances where itemized receipts may not be available or obtainable. Some establishments may issue receipts that only provide a summary of expenses with the total charges; others issue only a customer's portion of a tab that indicates total charges. In such cases, the University will deem "appropriate" documentation those "summary receipts" and tabs; and in cases where receipts are not available at all, those credit card slips generated when payment was made using a credit card. However, the following conditions apply:

  • the expense report should include a notation that no alcoholic beverages are included in the expenses incurred; or,
  • when the expenses include alcoholic beverages, the report should specify the cost, segregate it from federal allowable costs, and charge it to an appropriate NYU account.

2. Business Purpose

Also required for reimbursement of business meal expenses is the substantiation of the meal itself as having a business purpose. When reporting expenses, include the reason for the business meal, the names of individuals present, and their affiliations.

During Travel

1. Receipts

Individuals who travel on University business are reimbursed for meal expenses they incur in two ways: according to actual, substantiated costs, or at an established "per diem" rate. Travelers cannot switch between these two methods on one trip; the method travelers choose applies to all meal expenses incurred throughout a trip.

A. Based on actual substantiated costs

When opting to be reimbursed based on actual costs of each meal, travelers are required to provide detailed receipts or other appropriate documentation for all meals taken throughout the trip. Gratuities for meals are deemed part of the meal cost and will be reimbursed by the University provided these are reasonable (that is, do not exceed 20% of total meal cost).

B. Based on "per diem" rate

The alternative to keeping receipts and other appropriate documentation for each meal during travel is the "per diem," or being reimbursed at an amount set as meal allowance for each day of travel. The per diem applies only when overnight travel is involved. The per diem rate is $50.

For foreign per diem rates applicable to federally sponsored projects, refer to www.state.gov/travel.

2. Business Purpose

Also required for reimbursement of business meal expenses is the substantiation of the meal itself as having a business purpose. When reporting expenses, include the reason for the business meal, the names of individuals present, and their affiliations.

Mileage Rates

Employees may use personal vehicles for business travel when doing so is less expensive than renting a car or taking a taxi. Valid expenses related to the use of personal vehicles for business travel are reimbursed based on the federal government's standard mileage rate, which covers the use of the vehicle and gasoline. A new rate is issued each January by the IRS; for current rate, see the Controller's Division Website.

N

Nonresident Aliens

Note: The below document serves only as a general guideline on tax issues related to payments to NYU employees. Because individual cases differ and may involve issues not tackled in this document adequately, the Controller's Division strongly recommends that you consult your own Tax Specialist for advice specific to your case. The Controller's Division does not offer this guideline as sufficient for all cases.

Payments Made to Nonresident Aliens - A Procedures Guide (PDF - netID & password login required)

O

OMB Circulars

These Circulars are information or instructions that are issued by the Office of Management and Budget (White House). Those of particular relevance to NYU are:

  • OMB Circular A-21 - Cost Principles for Educational Institutions
  • OMB Circular A-110 - Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Nonprofit Organizations
  • OMB Circular A-122 - Cost Principles for Nonprofit Organizations
  • OMB Circular A-133 - Audits of States, Local Governments, and Non-Profit Organizations (06/24/1997, includes revisions published in Federal Register 06/27/03)

See the sections below for more details.

OMB Circular A-110

(Uniform Administrative Requirements for Grants and Agreements)

This circular establishes uniform and consistent administrative standards that guide federal agencies in the administration of grants and agreements they award to institutions of higher education as well as hospitals and non-profit organizations. These standards dictate how universities do business with federal awarding agencies, the financial systems they must put in place, and how they are to administer these awards.

The A-110 standards are instructions to the federal agencies and not to fund recipients. These agencies have flexibility in implementing A-110 regulations that do apply to the recipients of federal funds. If an agency's statute specifically outlines policies differing from the standards in A-110, the provisions of the statute shall govern; such modification is called "agency implementation of A-110." Those regulations should be consulted first particularly on individual areas of costing and administrative policy.

Click here for OMB Circular A-110

OMB Circular A-110 on Budget Revisions: Recipients of federal and federal pass-through grants are required to report deviations from budget and program plans and to request prior approval for budget and program plan revisions. For non-construction awards, recipients are required to request prior approval from federal awarding agencies in case of one or more of the following program or budget-related instances:

  • Change in the scope or the objective of the project or program (even if there is no associated budget revision)
  • Change in a key person specified in the application or award document
  • The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator
  • The need for additional federal funding
  • The transfer of amounts budgeted for indirect costs to absorb increases or decreases in direct costs
  • The transfer of funds allotted for training allowances to other categories of expense
  • The sub-award, transfer or contracting out of any work under an award

OMB Circular A-122

(Cost Principles for Non-Profit Organizations)

This circular establishes principles to determine the costs of contracts, grants and other agreements between the government and non-profit organizations. It does not apply to colleges and universities which are covered by OMB Circular A-21. The intent is to ensure that the Federal Government bears its fair share of costs, except where restricted or prohibited by law. The principles do not attempt to prescribe the extent of cost sharing or matching on grants, contracts, or other agreements

Applicability

The principles set forth are to be followed by all Federal agencies in determining awards to non-profits. These "awards" comprise the costs of work performed under any agreements with the Federal Government whereby the non-profit organization is required to account for actual costs incurred. Such agreements include grants, reimbursement contracts, and cooperative agreements.

"All cost reimbursement subawards (subgrants, subcontracts, etc.) are subject to those Federal cost principles applicable to the particular organization concerned. Thus, if a subaward is to a college or university, Circular A-21 shall apply."

For the full text of OMB Circular A-122: http://www.whitehouse.gov/omb/circulars/a122/a122_2004.html#aa

OMB Circular A-133

(Audits of Institutions of Higher Education and Other Non-Profit Institutions)

This circular lays out the audit standards for colleges and universities. It is the implementation of the Single Audit Act of 1984 and Single Audit Act Amendments of 1996. The standards set forth apply to contracts and intergovernmental contracts entered into by the Government with all non-Federal organizations (including institutions of higher education), whether they are direct recipients of Government awards, or are sub-recipients expending Government awards received from a pass-through entity (a recipient or another sub-recipient). Furthermore, A-133 rescinds Circular A-128, "Audits of State and Local Governments," issued April 12, 1985, and supersedes the prior Circular A-133, "Audits of Institutions of Higher Education and Other Non-Profit Institutions," issued April 22, 1996.

Click here for OMB Circular 133

"Under A-133, non-Federal organizations that expend $300,000 or more in a fiscal year in Federal awards are required to have a single or program-specific audit for that year. Recipients receiving less than $300,000 a year in Federal awards are exempt from the Federal audit requirement for that year, with some exceptions noted in the circular. However, the organization must make its records available for review or audit by appropriate officials of the Federal agency, pass-through entity, and the General Accounting Office (GAO).

OMB Circular A-133 implements the Single Audit Act to provide that an audit made in accordance with the circular shall be in lieu of any financial or financial compliance audit required under individual Federal assistance programs. To the extent that a single audit provides Federal agencies with information and assurances they need to carry out their overall responsibility, they shall rely upon and use such information.

The circular retains the concept of a cognizant Federal agency to oversee the audits performed. The circular does not limit the authority of Federal agencies to make or contract for additional audits and evaluations of Federal financial assistance programs. Any additional audits required to carry out responsibilities under Federal law and regulation should be planned and carried out in such a way as to avoid duplication.”

-- Text excerpted from: http://www.bpa.gov/corporate/business/bpi/BPI13.DOC

 

Final Revisions to Circular A-133 (68 Fed. Reg. 38401, June 27, 2003)

"The purpose of Final Revisions is to (1) increase the threshold for audit from $300,000 to $500,000, (2) increase the threshold for cognizant agency for audit from $25 million to $50 million, and (3) make related technical changes to facilitate the determination of cognizant agency for audit and provide for Federal agency reassignment of oversight agency for audit."

Go to http://www.whitehouse.gov/OMB/fedreg/062703_audits.pdf for the revision.

OMB Circular A-21

(Cost Principles for Educational Institutions)

This Circular provides the guidelines for determining costs that the federal government will or will not allow to be charged directly to a federal fund, or charged indirectly to a federal fund through the University's facility and administrative (indirect) cost rate.

Note: All members of the NYU community are urged to be diligent in identifying federal unallowable costs. Wherever necessary, appropriate, and authorized, these costs may be incurred and charged to appropriate University funds.

Tests of allowability of costs (Section C): Costs must be reasonable, allocable to sponsored agreements under principles and methods provided, must be given consistent treatment through application of those generally accepted accounting principles appropriate to circumstances, must conform to any limitations or exclusions set forth in the cost principles or in the sponsored agreement as to types or amounts.

For details on allowable/unallowable costs in the University, see NYU Business Expenses Policy. For examples of federal unallowable costs, see Appendix 1 of the Policy.

OMB Circulars are issued by the White House Office of Management and Budget. For the full text of OMB Circular A-21, go to: http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

Online Purchases

Source: NYU Expense Reimbursement Policy

For reimbursement of online purchases, a printout of the page confirming the purchase is required; or, a printout of the page summarizing the type of purchase made, the date, and the amount.

P

Personal Vehicles

Employees may use personal vehicles for business travel when doing so is less expensive than renting a car or taking a taxi. Valid expenses related to the use of personal vehicles for business travel are reimbursed based on the federal government's standard mileage rate, which covers the use of the vehicle and gasoline. A new rate is issued each January by the IRS; for current rate, see the Controller's Division Website.

Petty Cash Funds

Source: NYU Petty Cash Funds Policy

Any transaction that involves the use of University funds is subject to specific policies and requirements of both the University and the government (see the "Related Documents" section of the NYU Petty Cash Funds Policy). All individuals involved in any transaction related to petty cash funds are required to know those policies and understand the requirements that apply in particular to business expenses, purchasing, and expense reimbursement.

The Business Expenses Policy of the University should be consulted for guidance on which expenses are legitimate or valid and thus may be incurred using University funds. Individuals who use personal funds for expenses they will request the University to remunerate are advised to refer to the policy, before they incur any expenses, to avoid incurring costs that may not be reimbursed. Individuals who approve or process requests for reimbursement are required to know and understand the policy, to ensure that University funds are used appropriately and to assist compliance to applicable University and government requirements.

The University's Purchasing Policies and Procedures Manual should also be consulted for guidance on how certain types of purchases may be made. Certain expenses may be subject to specific procurement rules and requirements of the University and the government.

The Expense Reimbursement Policy should be referred to for guidance on how specific expenses are reported and reimbursed. Unless noted in this document as not required for transactions processed through the imprest petty cash fund, the guidelines detailed in the Expense Reimbursement Policy of the University apply.

Note:  It is the responsibility of the Approver and the Fund Custodian to know, understand, and enforce this policy on petty cash funds and other University policies.

Authorization

Source: NYU Petty Cash Funds Policy

The approval and authorization requirements for petty cash transactions follow the policy of the University for Expense Reimbursement, which provides that the Approver and the Payee cannot be the same individual. Also, no individual may request a subordinate to approve a request for reimbursement.

Changing The Custodian/Alternate Custodian

Source: NYU Petty Cash Funds Policy

In case of the Custodian’s absence, the individual named as Alternate Custodian on the Request to Establish a Petty Cash Fund form should assume management of the fund. If either the Custodian or Alternate Custodian is no longer available to manage the petty cash fund a Petty Cash Fund Transfer of Custodial Responsibilities form must be completed and sent to General and Restricted Accounting.

Disbursement Operations (of Petty Cash Fund)

Source: NYU Petty Cash Funds Policy

The petty cash fund must be disbursed only for minor student expenses, not to exceed $150, that are valid and for which appropriate documentation is supplied. If a valid receipt in not available and the expense is less than $25, an explanation of the expense must be included on EXP2000P when receipts are submitted for replenishment of a petty cash fund.

Documentation Requirements (for Petty Cash Fund)

Source: NYU Petty Cash Funds Policy

The documentation requirements for petty cash fund transactions reflect the University’s policy on expense reimbursement. Any expense that is paid using University funds must be justified as well as properly documented. See the Expense Reimbursement Policy of the University for specific requirements and guidelines. All items that do not have a receipt, and are under $25.00 must be documented on the EXP2000P form when replenishment is requested.

Establishing a Petty Cash Fund

Source: NYU Petty Cash Funds Policy

To establish a petty cash fund for an academic or administrative unit, do the following:

1. Complete the Form for Petty Cash Funds -- EXP2000P and
2. Form to Request to Establish a Petty Cash Fund – EXP2000Pa

Both forms must be completed before documents will be reviewed.

Submit both forms in PDF to General and Restricted Accounting at the Controller’s Division.

The Custodian named on the form will be notified if the request has been approved. The Controller evaluates the purpose for which the fund is established, the appropriateness of the amount being requested, measures taken to safeguard the fund, etc.

Note: Only permanent employees of the University may be designated as Custodian or Alternate Custodian.

To obtain the cash for the fund, the Custodian must present both approved forms to the Office of the Bursar. The Office of the Bursar requires Fund Custodians to present a valid NYU identification card to process transactions.

Increasing, Decreasing Or Terminating A Petty Cash Fund

Source: NYU Petty Cash Funds Policy

A petty cash fund may be reduced, increased, or terminated at any time.

Increasing a Fund

To increase the amount of a petty cash fund, the Approver should complete both the EXP2000P and EXP2000Pa forms, indicating the “Z” number for the existing fund and the amount the fund is to increase.

Decreasing a Fund

To decrease the amount of the petty cash fund, the Approver must:

  • Complete an EXP2000P form and take the form and the excess funding to the Bursar for deposit, including an explanation of why the fund is being decreased or closed to the Banking Window in the Office of the Bursar.
  • Send a copy of the EXP2000P, a fund reconciliation, and proof of deposit to General and Restricted Accounting.

Terminating a Fund

When terminating a fund, the Custodian must ensure that the following are satisfied:

  • outstanding requests are paid;
  • receipts and cash on hand are reconciled;
  • all logs and reconciliation records are on file in case of audit review;
  • An EXP2000P form is completed and the funds are deposited with the Bursar.
  • General and Restricted Accounting is notified in writing and provided with a copy of the final EXP2000P form, the final reconciliation form, and the record of the deposit (stamped copy of the “Transmittal for Funds to be Deposited”) made at the Bursar’s Office.

When a petty cash fund is inactive for six months, the fund will be suspended.

Lost or Stolen Petty Cash Fund

Source: NYU Petty Cash Funds Policy

In the event of theft or loss of the petty cash fund, the University’s Public Safety and Internal Audit departments must be immediately notified (General and Restricted Accounting will be notified by Internal Audit). An investigation will be conducted.

Maintaining a Petty Cash Fund

Source: NYU Petty Cash Funds Policy

The petty cash fund is the property of the University and must be used in accordance with its applicable policies. It must be under the control solely of the Custodian named on the request form or, in his/her absence, the Alternate Custodian also identified on the form. In the absence of both, any individual who assumes management of the fund on a temporary basis becomes the Fund Custodian. General and Restricted Accounting must be notified immediately, using the appropriate form (See Changing Fund Custodian), when the Custodian and Alternate Custodian are unable to fulfill their duties.

Non-Compliance with this policy will result in suspension of the Petty Cash Fund.

Due to the nature of minor expenditures reimbursed through the petty cash fund, the University does not require an Expense Reimbursement Form (EXP2000P) to be completed for every request submitted to the Fund Custodian. Form EXP2000P is necessary only when reimbursement request is submitted to the Office of the Bursar. Minor expenditures are reported together by the Fund Custodian on Form EXP2000P when replenishment needs to be processed through the Bursar. This form is reviewed by the Approver to verify that expenses paid from the petty cash fund are valid and permissible.

Petty Cash Fund Transactions (Purchases of Minimal Value)

Source: NYU Petty Cash Funds Policy

Expenses that may be reimbursed from the petty cash fund include, but are not limited to, the following:

  • Payments to Human Subjects, when the fund is set up for this purpose. All expenses must be allocated to account 65295 - "Payments to Human Subjects"
  • Student related expenses such as taxi fare, parking fees, tolls not connected with University Travel. Reimbursement may not exceed $150.
  • Meal allowance (normally provided when an “exempt” employee is required to work two or more hours over regular time; the rate at date of publication is $10. See the HR policies online for more information)
  • Incidental office expenses

R

Rates

Record Retention

For Expense Reimbursement

Source: NYU Expense Reimbursement Policy

The University and the federal government require that records related to the reimbursement of business expenses incurred by University employees must be retained for a prescribed length of time. In case of audit, these records provide the materials that support the tax reports made by the University. The Controller's Division is responsible for maintaining and retaining such records as those listed below for the period of time required by law, and for making them readily available for audit. Other records related to expense reimbursement that are not submitted to the Controller's Division should be retained by individuals or originating units. For further guidance, see the Record Retention Policy of the University.

Records related to expense reimbursement that are retained by the Controller's Division include:

  • original receipts or other documentation that support the validity of the expenses being reported for reimbursement;
  • request for reimbursement forms;
  • attachments such as the Expense Breakdown Sheet and the Missing/Inadequate Documentation Affidavit;
  • any memo that may have been necessary to support the request for reimbursement.

For Petty Cash Fund (Imprest)

Source: NYU Petty Cash Funds (IMPREST) Policy

The University and the federal government require that records related to the reimbursement of business expenses incurred by University employees must be retained for a prescribed length of time. In case of audit, these records provide the materials that support the tax reports made by the University.

The Controller’s Division is responsible for maintaining and retaining such records as those listed below for the period of time required by law, and for making them readily available for audit. Other records related to petty cash fund transactions that are not submitted to the Controller’s Division should be retained by individuals or originating units. For further guidance, see the Record Retention Policy of the University.

Records related to petty cash fund transactions that are retained by the Controller’s Division include:

  • original receipts or other documentation that support the validity of the expenses being reported for reimbursement;
  • request for reimbursement forms;
  • attachments such as the Expense Breakdown Sheet; and,
  • any memo that may have been necessary to support the request for reimbursement from the fund.

Records related to petty cash fund transactions that are not submitted to the Controller’s Division or the Office of the Bursar and which local units are advised to maintain include:

  • Petty Cash Fund Log; and,
  • any petty cash voucher or form established for internal use by local units.

Reimbursement of Business Expenses

New York University funds may be used only for necessary and reasonable expenses that support the missions of the University. University funds come from a variety of sources (as gifts, grants and contracts, or revenue from the government, students, alumni, and various agencies) that carry with them fiduciary responsibilities. These responsibilities require the University to maintain operations according to guidelines established by the University’s Board of Trustees, and to comply with applicable federal, state, and local rules and regulations. Below are some of those key rules and regulations that shape the University policy on business expenses.

  • IRS Rule on Accountable Plan
  • IRS on Business Meals and Entertainment
  • Federal Acquisitions Regulations (FAR)
  • OMB Circular A-21 (Cost Principles for Educational Institutions)
  • OMB Circular A-110 (Uniform Requirements for Federal Grants & Contracts)
  • NYU Standardized Policy on Reimbursement of Business Expenses

Expenses not reimbursable from Petty Cash Funds

Source: NYU Petty Cash Funds (Imprest) Policy

Expenses that may not be reimbursed from the petty cash fund include, but are not limited to:

  • Expenses that do not comply with the Business Expenses Policy and Expense Reimbursement Policy of the University (e.g., personal expenses, any fraudulent and illegal expense, expenses that will be reimbursed from another source)
  • Purchases in excess of $150 per order (reimbursements for such purchases should be processed through Accounts Payable)
  • Travel expenses over $150 (reimbursement should be processed through Accounts Payable)
  • Expenses related to travel for which a cash advance was previously requested, and issued, by submitting a Cash Advance Request Form (ADV3000) to Accounts Payable (reimbursement should be processed through Accounts Payable in order for this cash
    advance to be cleared)

    Note: The Petty Cash Fund may not be used to cash checks of any kind or to grant salary advances to University employees.

Expenses reimbursable from Petty Cash Funds

Source: NYU Petty Cash Funds (Imprest) Policy

Expenses that may be reimbursed from the imprest petty cash fund include, but are not limited to, the following:

  • Miscellaneous office supplies with a total value of $150 or less per order, provided the items are not obtainable through any of the University's regular procurement methods
  • Refreshments or meals in connection with business meetings or events
  • Local travel expenses under $150 (e.g., taxi fare, parking fees, tolls, business mileage when personal vehicle is used) that are not part of an aggregate travel expenses report

    Note: Per diem allowances are not reimbursed through the imprest petty cash fund.

  • Freight charges or postage due on incoming shipments
  • Meal allowance (normally provided when an “exempt” employee is required to work two or more hours over regular time. The rate at time of publication is $10; see the HR policies online for more information.)
  • Postage (only in extraordinary or special situations, and if the University's Mail Service is not able to accommodate requirements)
  • Telephone calls made outside of University premises for business purposes

Reimbursement through Accounts Payable (By check or direct deposit)

Reimbursement of business expenses may be requested through Accounts Payable by submitting a fully completed, adequately documented, and appropriately approved Expense Reimbursement Form (EXP2000) and, when expenses involve travel or business meals, a properly completed Expense Breakdown Sheet (EXP2000T for travel or EXP2000M for non-travel meals). See “Forms” section of the University's Policy on Expense Reimbursement.

Reimbursements are generally issued in check and mailed to the individual's home address. To facilitate quick and convenient reimbursements however, the options below may be requested by checking the appropriate box on the EXP2000 form:

  1. that reimbursements be sent directly to your bank account (available to those who have enrolled in the “Accounts Payable Direct Deposit” program. Contact Accounts Payable for questions related to the program; see “Forms” section of the University's Policy on Expense Reimbursement.;
  2. that total or partial amount of the reimbursement due you be issued to the credit card company administering the NYU Travel Card as payment on your behalf.

 

Note: Accounts Payable will only issue to the credit card company any amount up to the total reported and authorized on the EXP2000 form as your appropriate reimbursement. Do not attach your credit card statements to your reimbursement request. Accounts Payable does not require your monthly card invoice or statement and does not require you to report what you have charged to your NYU Travel Card. As cardholder, you are directly responsible for all expenses that you have charged to your NYU Travel Card -- be they related to NYU business or not. Those expenses charged to the card that are related to NYU business are reimbursed by following the guidelines provided in this document.

Reimbursement through the departmental Imprest Petty Cash Fund (Cash)

Source: NYU Expense Reimbursement Policy

Minor expenditures such as local cab fares, parking fees, tolls, or business meals may be reimbursed in cash through the department's locally maintained petty cash fund (imprest petty cash fund), provided each expenditure does not exceed $150.

Note:  See Petty Cash Fund (Imprest) Policy of the University for guidance on how to be reimbursed through the imprest petty cash fund. This document does not detail the requirements and procedures specific to reimbursements processed through the fund.

Relocation of Faculty and Staff (Expense Reimbursement)

Source: NYU Business Expenses Policy

Expenses related to the relocation of employees are deemed business expenses only when appropriate, reasonable, authorized by an appropriate University designee, and when they meet conditions established below by the IRS:

  1. Distance: The new place of work must be at least 50 miles farther from the former home than the former place of work was from the former home.
  2. Length of Employment: The new employee must be a full-time employee at the new place of work during the 12-month period immediately following the relocation.
  3. Commencement: In general, the move must be in connection with the commencement of work at the new location and the moving expenses must be incurred within one year from the time the taxpayer first reports to the new job or business.

 

Relocation or moving expenses are deemed either taxable or non-taxable income to the employee.

  1. Taxable relocation expenses

    Relocation expenses that may be deemed in certain cases as permissible by the University are deemed taxable income to the employee under IRS guidelines. Regardless of whether they are paid directly by the University to the vendor or are issued as reimbursement to the employee, the University is required by law to include payments for these expenses as income in the employee's W2 Form and to deduct appropriate withholding taxes on this income from the employee's paycheck. These expenses include, but are not limited to, the following:

    • personal expenses
    • pre-move house hunting, including travel, meals and lodging
    • any part of the purchase of a new home or sale of the old home, including real estate fees incurred when leaving former residence and acquiring new one
    • expenses related to getting or breaking a lease
    • loss on the sale of the old home
    • mortgage penalties
    • losses from cancellations of club memberships
    • meals and lodging while occupying temporary quarters
    • in-transit storage charges beyond 30 days

  2. Non-taxable relocation expenses

    Expenses that are deemed non-taxable refer to expenses incurred to move household goods and personal effects from a former residence to the new residence, as well as those related to the new employee's travel from the former residence to the new. Such expenses include:

    • packing of furniture and personal items;
    • transportation of furniture and personal belongings from the previous principal place of residence to the new principal place of residence;
    • insurance and in-transit storage for periods of up to 30 consecutive days;
    • travel and lodging costs, excluding meal costs, associated with one trip to move from old to new residence.

    Non-taxable relocation expenses, however, may either be reportable or non-reportable to the government:

    2.a) Non-taxable and non-reportable

    Non-taxable relocation expenses are not reported in the employee's W-2 only when they are paid directly by the University to the moving company or vendor.

    2.b) Non-taxable but reportable

    When the non-taxable relocation expenses however are issued as reimbursement to the employee, the reimbursement is deemed reportable. The University is required under Section 132 of the Internal Revenue Code to “report” the reimbursement in Box 12 of the employee's W2. The amount reported in Box 12 is not deemed income; it has no impact on the tax treatment of an individuals' gross income. Box 12 serves only to “inform” the IRS of any reimbursement the University issues to individuals according to requirements specific to certain types of expenses.

Wherever possible, therefore, a Purchase Order should be processed to arrange for direct payment from the University to a moving company or vendor for qualified moving expenses.

T

Tax (Sales) Exempt Form

Source: NYU Expense Reimbursement Policy

The University is exempt from state and local sales taxes. Wherever possible, the University's tax exemption certificate should be presented to the vendor in order for sales tax to be excluded from total charges on legitimate purchases of goods. This certificate is available in the administrative office of each school, department or unit, as well as from Accounts Payable in the Controller's Division and from Purchasing Services (sees “Contacts”). Sales tax on goods that exceed $150, the University's administrative definition of a petty cash transaction, will not be reimbursed.

Travel Advances

Cash advances are amounts issued upon authorized request to regular employees who are about to travel for University business, or are making arrangements for a future business event. Also deemed cash advances are those payments made by Accounts Payable to the agency administering the NYU Travel Card, on behalf of regular employees, for authorized expenses related to a future business event or travel.

Cash advances should be cleared within 30 days from the “end date” specified on the Cash Advance Request form (see “Timing” section of the University's Policy on Expense Reimbursement).

Unused portions of a cash advance should be returned to the University within the prescribed time period. To return unused cash advances, submit to Accounts Payable a completed Form EXP2000 with a check payable to NYU attached. Checks or cash intended to clear outstanding cash advances should not be deposited at the Office of the Bursar.

Travel Expenses (Allowable and Reimbursable)

Appropriate Documentation for Student and Volunteer Travel

Source: NYU Expense Reimbursement Policy

The University may reimburse the travel expenses of students who are not NYU employees only when travel meets the criteria established in the Business Expenses Policy of the University.

Reimbursement for expenses incurred by students on approved travel are not reportable as income to the student, provided detailed receipts are provided along with documentation that establishes the business purpose of the expenses.

Appropriate Documentation, Independent Contractor and Consultant

Source: NYU Expense Reimbursement Policy

Expenses incurred by independent contractors and consultants may be reimbursed when travel itself is legitimate and authorized, when expenses are deemed permissible by the Business Expenses Policy of the University, and expenses are not part of the service/contract fees.

Necessary for reimbursement are original receipts. When no original receipts are provided, the reimbursement will be reported on IRS Form 1099.

Note: The Missing/Inadequate Documentation Report can be used only by University employees.

Requests for reimbursement to an independent contractor or consultant must be made on the Payment to Individual Form (IND4000) and indicated as not part of the individual's service fee. The Expense Breakdown Sheet for Travel (EXP200T) must be attached, reporting every expense incurred by the individual. Approval of the appropriate University designee is necessary.

All other conditions and requirements established for reimbursements issued to University employees also apply to reimbursements issued to independent contractors and consultants. When the independent contractors or consultants are not citizens or residents of the United States, additional requirements may apply. See the IRS guidelines on the CDV Website.

Cancelled Trips/Events

Source: NYU Expense Reimbursement Policy

Employees and students who have purchased tickets for trips that are subsequently cancelled should inquire about using the same ticket for future travel. Unused tickets or flight coupons have a cash value and must not be discarded or destroyed. A copy of the unused ticket must be attached to Form EXP2000; the ticket itself must be kept by schools, departments, or units for future use of the employee. Indicate on the form that these tickets have been submitted to the area's administrative office.

If the event or trip that was cancelled involved expenses that were earlier paid using personal funds, it is the responsibility of the employee to request a refund or to recover the advance payment wherever possible.

Note:  The University will only reimburse those expenses related to a cancelled trip or event if the cancellation was due to circumstances beyond an employee's control. A memo explaining the cancellation should be attached to Form EXP2000.

Other expenses related to events or trips that are cancelled or moved to later dates due to unavoidable or work-related reasons will be reimbursed. Such expenses include charges made by airlines for ticket modifications or by hotels for cancelled reservations.

If a cash advance was received for an event or trip that was subsequently cancelled, submit a completed and approved Expense Reimbursement Form (Form EXP2000) to Accounts Payable indicating “Event Cancelled.” Attach a check payable to NYU in the amount of cash advance you received from the University.

Non-Employee Travel

Source: NYU Business Expenses Policy

University funds cannot be used for expenses of individuals who are not employees of the University, are not affiliated with the University, and whose activities do not advance University missions. Examples include, but are not limited to, the following:

  • travel expenses of a spouse accompanying a University employee on business travel (unless the travel itself of the spouse is deemed a legitimate NYU business expense and meets University guidelines)

    Note: University funds may be used for expenses related to spousal travel only when circumstances show that the attendance of a spouse was necessary in carrying out a University task or function, or supports University business. Travel must be approved before departure. A memo justifying the travel itself must be provided to the appropriate "Approver" (the individual responsible for funds being charged) and attached to the request for payment or reimbursement submitted to the University. See "Non-Employee Travel" section of NYU's Business Expenses Policy for more information.

Permissible Travel Expenses

Source: NYU Business Expenses Policy

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 before departure.

Note: This policy applies to all University business travel regardless of the source of funds (whether federal, state, private, or general). However, when travel is charged to federally funded or sponsored projects, the terms of a particular grant or contract should be consulted before incurring any expense to ensure compliance to specific or additional requirements. See the "Sponsored Projects" section of the University's Policy on Business Expenses.

Tuition Remission Costs

(OMB Rule on Allowability of Cost)

OMB Circular A-21 (Cost Principles for Educational Institutions) provides the guidelines for determining costs that the federal government will or will not allow to be charged directly to a federal fund, or charged indirectly to a federal fund through the University’s facility and administrative (indirect) cost rate. In a January 5, 2001 memorandum, OMB clarified the rule on tuition remission costs in specifying that a graduate student is not required to be an employee of the institution for IRS tax purposes in order for the allowance of tuition remission costs under a federal contract. The clarification states:

"In recognition of the dual role of students (as both students and researchers) engaged in research and the resulting benefits to sponsored agreements (as recognized in Section A.2c of OMB Circular A-21) and research overall, tuition remission and other forms of reasonable support that are associated with student status and provided to individuals participating in the necessary work of a sponsored agreement are allowable provided that:

  • The individual is conducting activities necessary to the sponsored agreement;
  • Tuition remission and other support are provided in accordance with established educational institutional policy and consistently provided in a like manner to students in return for similar activities conducted in non-sponsored as well sponsored activities; and,
  • During the academic period, the student is enrolled in an advanced degree program at a grantee or affiliated institution and the activities of the student in relation to the Federally-sponsored research project are related to the degree program.

Accordingly, tuition remission and other forms of support that satisfy these criteria are allowable, regardless of whether the tuition remission or other form of support qualifies as wages for tax purposes. The memo also clarifies that voluntary uncommitted cost sharing should be treated differently from committed cost sharing, and should not be included in any allocation of F&A costs.

OMB Circulars are issued by the White House Office of Management and Budget. For the full text of OMB Circular A-21, go to: http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

U

Unallowable Costs

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.