08. Business Expenditures

Issue Date   Revised Date  
03/01/2000 001 07/01/2011  Introduction Business Expenditures
03/01/2000 002 11/01/2012 Advertising
03/01/2000 003 07/01/2011 Alcohol
03/01/2000 004 11/01/2012 Authorization for Certain Expenditures on Payment Vouchers
04/01/2012 005 04/01/2012 Portable Communication and Computing Devices
03/01/2000 006 07/01/2011 Contributions - Charitable and Political
03/01/2000 007 07/01/2011  Spousal Expenses
03/02/2001 008 01/01/2016  Awards, Gifts and Prizes
  008T 01/01/2016  Awards, Gifts and Prizes - Table
03/20/2001 009 10/24/2017  Meals and Entertainment
06/01/2006 010 07/01/2011  Employee Transition Allowance
05/17/2009 011 11/01/2012 Honoraria
  011F 11/01/2012 Honoraria Request for Payment Form
01/01/2016 012 01/01/2016 Apparel Benefits
03/06/2019 015  

Provision of Services to USNH Departments by Existing USNH Employees

07/16/2020 016   Student Group Fundraising Activities
General Expenditure Accounting Topics 
Issue Date   Revised Date  
03/01/1992 115 07/14/2022  Lease Agreements
07/14/2022 116   Subscription-based IT Agreements

 


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 001 Introduction to Business Expenditures

A. Summary

The University System of New Hampshire (USNH) was established by the N. H. Legislature in RSA 187-A:1 to "provide a well coordinated system of public higher education...to benefit the state and its people." Its mission is one of teaching, research, and public service. This business expenditure policy has been developed to provide guidelines for deciding whether expenditures are in furtherance of this mission and to ensure that fair, consistent, and equitable financial practices are carried on throughout the University System of New Hampshire.

B. Philosophy

USNH is committed to the highest level of accountability and stewardship with regard to USNH funds. Each person responsible for making decisions concerning its expenditures should consider whether the expense represents a worthy use of USNH funds. The University System's goal is the optimal use of USNH resources in fulfillment of its mission.

C. Scope

This policy applies to all expenditures, regardless of funding source. Specific restrictive terms of donors and sponsors take precedence over relevant, less restrictive USNH policy. Campuses or departments may also elect to impose stricter controls over expenditures than those required by this policy. In all cases, where the terms imposed by a donor, sponsor, campus, or department are more lenient than those of USNH, USNH policy applies.

D. Exceptions

While this policy is applicable to the majority of USNH transactions, it is recognized that unique circumstances may justify exceptions. Exception requests should be sent to the Vice Chancellor for Financial Affairs/Treasurer or USNH Controller for review and appropriate referral.

E. General Rule

All expenditures shall be consistent with applicable federal and state laws and regulations; with any restrictions, rules or regulations placed on the use of funds by donors and granting or contracting agencies; and with prudent management practices. Persons authorized to expend USNH funds are responsible to exercise discretion and good judgment in the use of USNH funds, regardless of their source. All expenditures must be reasonable and necessary for carrying out the programs and activities of USNH within the approved budget allocations. All expenditures must be documented in a way that clearly substantiates such reasonableness and necessity. All expenditures must be charged to the proper Fund, Area, and Org.

F. Requirements for Receipts

KSC requires receipts for all business expenditures except tips. For all other divisions of USNH, business expenditures of $25 or less per item (e.g., per fare) do not require receipts unless 1) the expense is paid for with a PCard, convenience check or petty cash/imprest checking; or 2) the actual expense method of meal reimbursement method is allowed; in these cases all receipts are required. Receipts are required for reimbursement of all business expenditures that total more than $25 per item.

G. TIMELINE FOR BUSINESS EXPENSE REIMBURSEMENT (OTHER THAN TRAVEL)

Per IRS requirements, reimbursement requests received later than 60 calendar days after the expense was incurred must be treated as taxable to the individual submitting the reimbursement request. Expense reimbursement requests are treated as taking place within a reasonable period if the request for reimbursement is adequately supported and is submitted within 60 calendar days of the expense being incurred, or before the end date of the grant if the expense is being charged to a Sponsored Program, whichever is sooner. A request is considered submitted on time when the date the requestor signed the form is within 60 calendar days of the expense being incurred, and the total cost is fully substantiated. With the exception of the 60 calendar day tax rule, the campus CFO or designee may authorize individual exceptions to this policy upon written justification showing cause for noncompliance. For information regarding processing the earnings related to late submission of reimbursement requests, please see How to Process Taxable Expense Reimbursements located on the USNH Sharepoint site (log in required; see instructions on the Employees section of the USNH website).


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 002 Advertising

A. Summary

Advertising expenses are allowed to the extent they are reasonable and necessary to carry out the mission of USNH. Restrictions regarding funding source must be complied with.

B. Promoting USNH Events

Advertising in newspapers, programs, etc. to promote USNH events is allowable. However, these costs must be charged to specific account codes (i.e., 71C100-Advertising non-employment, 71C120 - Advertising Radio, 71C130-Advertising TV/Cable) to ensure they are not charged to federally sponsored programs. See Procedure 2-065, Allocation of Centrally Funded Costs, and Procedure 2-060, Unallowable Costs, for further information.

C. Recruitment

Recruitment advertising (help-wanted ad) is allowable provided the ad has been approved by the campus Human Resources Office.

D. Charitable Organizations

Advertising accomplished through a charitable organization is allowed provided:

  1. There is a documented business purpose connected to the mission of USNH, and
  2. The total cost is less than or equal to the value of goods or services received.

For example:

  1. The School of Health and Human Services rents space at an Aids Awareness seminar to educate the public on a health issue. The rent paid for the space must be reasonable for the space provided.
  2. Plymouth State University advertises its MBA program on NH Public Radio. The price paid for advertising must be less than or equal to the value of the advertising services received.

E. Political Advertising

Political advertising is unallowable. This includes the expense of advertising in political programs or for admission to political fundraising functions and similar events (see Procedure 8-006, Contributions - Charitable and Political).

F. Sponsored Programs

Advertising expenses, whether for recruitment or for other purposes, may be allowed against a sponsored program. Prior to charging any type of advertising expense to a sponsored fund account, employees at UNH must consult with Sponsored Programs Administration; employees at KSC, PSU and GSC must consult with their campus grant administrator.


 The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.

08 - 003 Alcohol

A. Summary

Alcohol is generally an unallowable expense. It is recognized that there may be a bona fide business reason to purchase alcohol, such as important donor functions. In addition, Dining Services and other departments may purchase alcohol for cooking, laboratory or resale purposes. If there is a compelling business reason and the expense is reasonable, the purchase of alcohol is allowable, if an appropriate source of funds is cited.

B. Source of Funds

Alcohol purchased for purposes other than cooking, laboratory or resale may only be purchased:

  1. With internally designated funds clearly delineated as "DISCRETIONARY" within the USNH general ledger; or
  2. With restricted gift or endowment payout accounts that have been approved by the Controller.

C. Business Purpose

The bona fide business purpose for the purchase of alcohol must be clearly disclosed on supporting documentation accompanying purchase or reimbursement documents.


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.

08 - 004: Authorization for Certain Expenditures on Payment Vouchers

Unless there is written delegation of authority from the officials below to someone else, the following authorizations are required prior to commitment of USNH funds for these expenditures:

 

Type of Expenditure

Authorization

Real Property (Land and Buildings) Acquisitions Vice Chancellor for Financial Affairs/Treasurer
Insurance USNH Manager of Cash & Investments
Taxes Vice Chancellor for Financial Affairs/Treasurer, USNH Controller, or USNH Disbursements Services Director
Charitable Contributions, Procedure 8-006 Vice Chancellor for Financial Affairs/Treasurer
Political Contributions, Procedure 8-006 Not Allowed
Payments to Auditors/Public Accountants Vice Chancellor for Financial Affairs/Treasurer, USNH Controller
Legal Fees and Settlements Vice Chancellor for Financial Affairs/Treasurer and USNH General Counsel
Payments to or on Behalf of Employee Spouse/Partner (See Procedure 8-007, Spousal Expenses) Campus CFO
Payments to Affiliated Foundations (See BOT - Trustee Policy on Foundations Established for the Benefit of USNH or its Component Institutions) Vice Chancellor for Financial Affairs/Treasurer or USNH Controller
Travel Advances over $300/Week/Person (See Procedure 4-008, Cash Advances (for travel and other purposes) USNH Controller, USNH Disbursements Services Manager/Director or Campus CFO
Establishment of New Petty Cash, Imprest Checking, Change Funds (See Procedure 4-001, Petty Cash Funds; Procedure 4-002, Imprest Checking Accounts; Procedure 4-003, Change Funds); USNH Controller
Any Large or Unusual Payments (e.g., Payments to Employees, Municipalities, etc.) Vice Chancellor for Financial Affairs/Treasurer or USNH Controller
Exceptions to USNH Travel Policy (Except for use of Per Diems, see Procedure 7-007, Travel Meals, and ADA concerns.) Campus VPFA office. Exceptions due to disability or medical condition(s) require approval from the Campus ADA Compliance Officer, or equivalent.
All Other Exceptions to USNH Business Expenditure Policy Vice Chancellor for Financial Affairs/Treasurer or USNH Controller

The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 005 Portable Communication and Computing Devices

A. Summary

Faculty and staff are sometimes required to use cell phones and other portable communication and computing devices in the performance of their jobs.  The cost of the business use of these devices can be significant and such devices are capable of being used by employees for personal purposes.  This policy addresses the conditions under which a cell phone or other portable communication and computing device may be provided to an employee.  

B. Scope

This policy applies to cell phones, pagers, iPhones, iPads, and similar portable communication and computing devices and related services paid for by USNH from any source.  This policy does not apply to devices purchased with taxable allowances paid to employees and owned by them. Campuses, schools, or departments may elect to impose stricter controls over these devices than those required by USNH but may not be more lenient.

C. Business Purpose

USNH campuses and departments may issue cell phones or other portable communication and computing devices to USNH employees if the employee meets the eligibility standards established by this policy.  Devices provided by and paid for by USNH must be necessary for USNH business on an ongoing, recurring basis with no more than minor or incidental personal use by the employee. In addition, all such devices must comply with the USNH Administrative Board Information Technology Security Policy governing USNH property.

D. Eligibility and Approvals

Eligibility for a USNH-provided cell phone or other portable communication and computing device is based on the demonstrated and documented need for the employee to use such device frequently in the performance of their job.  The business use must be substantiated as part of the required documentation when the device is purchased. The device/service plan may not exceed the employee’s job requirements and must be ordinary and necessary to enable the employee to:

  1. Remain in touch with others due to the nature of the job, such as frequent business-related travel or work outside the office setting, or
  2. Be available for emergency contact, for instance: police/security, IT support, building and grounds maintenance, health and counseling services, etc.

The department director is responsible for identifying jobs that may require use of cell phones and other portable communication and computing devices, and for indicating the type of device and service (e.g., for cell phones, the number of hours/month, national vs. international service plans, etc.) appropriate to meet business needs.  All such devices/services paid for by USNH funds must be approved by a supervising senior officer at the level of at least Dean, Vice President, or Vice Chancellor and will be based upon funds availability. Specific procedures will be developed by HRPAC to address Operating Staff with employer-provided cellular phones and other portable communication and computing devices.

E. Effect of Termination or Change in Job Requirements

If an employee’s duties change over time so that the employee no longer needs a cell phone or other portable communication and computing device to perform his/her job, or if the employee ceases to be employed by USNH after being provided with such equipment, the employee is required to return the equipment to USNH.  The department director is responsible for reviewing the necessity of providing such equipment to employees at least annually and taking steps to recall equipment no longer needed by employees for the performance of their duties. The review and documented continued business requirement for these devices must be available upon request by USNH Financial Services.

F. Business Use of Personal Cell Phones or Other Portable Communication and Computing Devices

An employee may be reimbursed for the business use of his/her personal phone or other portable communication and computing device by submitting a bill identifying the actual incremental or apportioned cost of the business use. This payment needs to be approved by the supervisor and processed as a normal business expense reimbursement.

G. Sponsored Programs

Normally, cell phone purchases, maintenance and operating costs are not allowable charges to federally-sponsored programs.  The UNH Office of Sponsored Programs Administration or campus grant office should be consulted for clarification on the allowability of these costs.


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 006 Contributions - Charitable and Political

A. Charitable Contributions

Gifts to charitable organizations are generally not allowable. With certain exceptions, all charitable requests must be approved by the Vice Chancellor for Financial Affairs/Treasurer prior to payment (See Procedure 8-004, Authorization for Certain Expenditures on Payment Vouchers). This policy does not apply to:

  1. Fundraising and other activities conducted by student organizations for the benefit of charitable organizations (see Procedure 08-016 Student Group Fundraising Activities), or

  2. Surplus property donated to charity (See Procedure 11-030, Equipment, Disposal of Surplus Property).

It is recognized that certain charitable organizations offer donors a benefit such as a publication or other item in exchange for a charitable contribution. If the primary purpose of making a charitable contribution is to obtain a benefit for use in carrying out an employee's job responsibilities, and that benefit is approximately equal to the contribution made, prior approval by the Vice Chancellor for Financial Affairs/Treasurer is not required. The benefit received and its job applicability must be explained on the request for payment.

B. Political Contributions

Organizations exempt from tax under Internal Revenue Code Section 501(c)(3) (such as the University System of NH and its component units) may have their exempt status revoked if they are involved in any political activity. For this reason, all political contributions are strictly forbidden. The prohibition applies to all political expenditures, regardless of fund source (e.g., operating accounts, gift accounts, discretionary funds, affiliated organizations, etc.). There is no exception to this policy.

The following expenditures are unallowable:

  1. Payments to political candidates.

  2. Employee reimbursement for political contributions.

  3. Advertising in political programs (See Procedure 8-002, Advertising).

  4. Admission to any dinner or program (including testimonial dinners, receptions, and sporting events) if any part of the proceeds of the event directly or indirectly inures to the use of a political party or a political candidate.

  5. Admission to any event that is identified with a political party or candidate including tickets to fund-raising events.

  6. Lobbying portion of dues to professional organizations that are otherwise allowable.


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.

08 - 007 Spousal Expenses

A. Summary

This procedure explains when expenses for spouses, partners and families of USNH employees may be reimbursed.

B. Detailed Procedures

  1. Expenses for spouses, partners and families of USNH employees are generally not paid or reimbursed by USNH. These include such expenses as travel, entertainment and participation in local events. However, these expenses may be allowed when (a) there is a compelling business reason, (b) the expense is reasonable and prudent, and (c) prior written approval has been granted by the Campus Chief Financial Officer (CFO) (see Procedure 8-004, Authorization for Certain Expenditures on Payment Vouchers). Approval by the President is required for expenses of the spouse or partner of the Campus CFO. Only expenses which are non-taxable under Internal Revenue Service (IRS) regulations will be considered. The Controller's Office interprets taxability. Even when IRS standards are met, it is important to keep in mind that the limited resources and frequent public scrutiny of expenses at USNH make it particularly important that only the most essential events be proposed for spousal or partner attendance.
  2. To request prior approval, write to the Campus CFO describing (a) the event, (b) the spouse's or partner's role, (c) the compelling business reason for that role, (d) the account number to be used for reimbursement, and (e) the estimated type and amount of spousal or partner expenses. While the same standards apply to all sources of funds, some funds may exclude spouse or partner reimbursement. Attach a copy of the Campus CFO's approval to the expense report submitted for reimbursement.

The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.

08 - 008 Awards, Gifts, and Prizes

A. SUMMARY

For quick reference, see table in Procedure 8-008T.

1. Awards, gifts and prizes are allowed to the extent the expense is reasonable and necessary to carry out the mission of USNH. Awards, gifts, and prizes may not be lavish or extravagant. Restrictions regarding funding source must be complied with. Proper classification of payments is necessary to differentiate between those considered scholarships, which may be tax-free and not reportable to the Internal Revenue Service and those that are awards, gifts or prizes, which may be taxable.

2. Individual campuses or departmental policies may be more restrictive than USNH policy, but not less restrictive.

3. If a third party provides USNH with funds or property for administration and distribution, these will be administered according to USNH policies and procedures (e.g., Employee of the Month award or prizes awarded to employees at USNH outings which are provided by local vendors). 

4. In all circumstances, cash, gift cards and gift certificates of any amount are taxable when provided to a recipient, regardless of classification as an award, gift or prize.

5. Per the Administrative Board action approved March 13, 2009:

"USNH shall not compensate any employee for the federal income tax consequences of accepting from USNH any award, [gift], prize, incentive or compensation in any form whatsoever, regardless of whether the tax consequences cause or may cause the employee to decline the award, [gift], prize, incentive, benefit, or compensation."

B. DEFINITIONS AND REQUIRED APPROVALS

1. An award is tangible property, cash, gift card or gift certificate given to an individual in recognition of meritorious performance or productivity. Awards are generally taxable to the recipient. All awards must be approved by a Dean, Vice President or President.

2. A gift is tangible property bestowed voluntarily on an individual, often as a gesture of gratitude or expression of sympathy.  To qualify as a gift, there should be no negotiation in advance for the gift.  Cash, gift cards, gift certificates and alcohol are not allowed as gifts.  Gifts should be of minimal value (generally ≤ $25) and ideally bear one of the USNH institution’s licensed logos.  Gifts so defined are not taxable income to the recipient and not reportable to the IRS. All gifts must be approved by a Dean, Vice President or President.

3. A prize is tangible property, cash, a gift card or gift certificate won by an individual in a game of chance or in connection with a USNH-sponsored event.  The prize may result from a wager (e.g., UNH Hockey 50/50 raffle) or no wager (e.g., the 100th person to walk through the door). All prizes are taxable income to the recipient. All prizes must be approved by a Dean, Vice President or President.

4. A scholarship or fellowship is value (i.e., cash, tuition waiver, etc.)  provided to an individual for the educational benefit of the recipient, with no requirement for present or future services.  The scholarship/fellowship may be taxable and/or reportable, depending on the use of the funds and citizenship of the recipient. Note: Scholarships/fellowships are not addressed in this policy.

C. DETAILED PROCEDURES - EMPLOYEES

1. Awards to employees. With two exceptions (see Sections a. and b. below), awards provided to employees, including student employees, in the form of tangible property, cash, gift cards or gift certificates for meritorious performance, productivity or other reasons connected with their employment are considered taxable compensation. Please contact USNH Disbursement Services for any questions regarding reportability of the awards in your award programs.

The value of an award is reported as compensation on the employee's Form W-2 and is subject to federal and FICA tax withholding. Cash awards given to employees must be paid through the Human Resources System in accordance with USNH policy USY V.F.7.5.7. Unless qualifying for one of the exceptions below, departments making non-cash awards must notify their Campus Payroll Office of the employee's name, the last 4 digits of the employee's USNH identification number, the value of the award and the date it will be presented to the employee. This information will be used to record the non-cash compensation in the Payroll system and facilitate tax withholding.

Under certain circumstances, some types of awards may qualify as nontaxable as noted below:

a. Certain achievement awards of tangible property (other than cash, gift cards or gift certificates in any amount) may be given tax-free to an employee if they are awarded in a meaningful presentation that emphasizes the purpose of the award. The value of the award may not exceed $400 per year per employee. These awards and additional criteria are as follows:

i. A length of service award is not taxable if it is not granted to an employee more frequently than every 5 years.

An award presented at retirement may be considered a length of service award and is subject to the rules of this section. Retirement gifts are generally funded by employees taking up a collection of personal funds; in these cases, there are no tax consequences to the recipient and no USNH reporting requirements. Retirement gifts funded with USNH funds must be charged to a discretionary fund (a list of these funds is maintained by USNH Accounting Services) unless the gift is part of a campus-wide recognition program sponsored by the Campus President or Chancellor for all retirees meeting certain criteria.

ii. A safety award is not taxable as long as both of the following conditions are met:

  • It is provided to no more than 10% of eligible employees; and,
  • Managers, administrators, clerical and professional staff are ineligible for the award.??

b. Non-cash, de minimis awards are not taxable to an employee. IRS regulations use the example of a holiday turkey to define "de minimis.”  For USNH policy, de minimis is defined as a value less than or equal to $75.  Since the IRS considers gift cards and gift certificates to be the equivalent of cash, gift cards and gift certificates in any amount awarded to employees for any reason are considered taxable compensation and are subject to reporting and withholding. 

2. Gifts to employees. Gifts - including those for birthdays, weddings, showers and other personal events - are never allowable expenditures of USNH funds, regardless of the source of funds.  Holiday gifts and gifts for occasions such as Boss’ Day and Secretary’s Day are also examples of unallowable expenditures.  At their discretion, co-workers may contribute personal funds to commemorate a personal event, but these funds should never be deposited to any USNH bank account.  In limited circumstances, gifts of flowers or other expressions of sympathy are allowed if paid from a discretionary fund (a list of these funds is maintained by USNH Accounting Services).

Gifts presented to employees in recognition of service to USNH (including retirement gifts) are awards and fall under the rules discussed in Section C.1. above.

3. Cash and non-cash prizes to employees.  In general, no prize may be awarded to a USNH employee except in situations where the individual's employment is incidental to the basis on which the prize is awarded.  For example, an employee would be eligible to win a door prize awarded at random to those in attendance at an athletic event.  In this instance, the door prize is taxable and reportable on Form 1099 if the prize is $600 or more. If an employee won a game of chance that involves a wager, the prize is reportable on Form W-2G if the prize is $600 or more.

Prizes provided by an outside vendor and presented directly to the employee by the vendor would be considered to be administered by the vendor (e.g., prizes provided by vendors at the Benefits Fair with no involvement by USNH as to administration, processing, etc.).

D. DETAILED PROCEDURES - STUDENTS

1. Awards classified as scholarships or fellowships to U.S. students must be processed through the Campus Student Information System.  Scholarships/fellowships are generally not reportable as taxable income; however, they should be disclosed on Form 1098-T.

If the recipient is not a USNH student, scholarship/fellowship payments should be processed through USNH Accounts Payable and will be reported on Form 1099-MISC for U.S. citizens.  If the recipient is a nonresident alien, USNH Disbursement Services should be notified prior to processing to insure proper tax withholding and reporting on the award.

2. Academic achievement awards given to students in recognition of meritorious accomplishment (e.g., UNH Holloway Award) that are unrelated to employment are taxable income to the student. Cash awards of this nature are paid through USNH Accounts Payable and reported on Form 1099-MISC for U.S. citizens and Form 1042-S for nonresident aliens. If the award is $200 or more, the department presenting the award must:

a. ?Notify USNH Accounts Payable of the recipient’s name, address, Social Security number, date and value of the award; and,
b. Obtain a completed Form W-9 from the recipient prior to payment.
c. If the recipient is a nonresident alien, USNH Disbursement Services will work with the department to insure proper tax withholding and reporting on the award.

3. Awards related to a student’s employment (See Section C.1.)

4. Gifts to students (See Section E.2.)

5. Prizes given to students that are associated with academic achievement or competition are awards.  (See Section D.2.)  For other cash and non-cash prizes to students, see Section E.3.

E. DETAILED PROCEDURES - NON-EMPLOYEES

1. Awards to non-employees.  Awards may occasionally be given to non-employees in recognition of meritorious achievement as well as for other valid business reasons.

Awards paid through Accounts Payable that are paid to non-employees are considered taxable income, regardless of value.  There is no de minimus exception to taxation for awards to non-employees.  USNH will report these awards on Form 1099-MISC when the cumulative total of all payments to an individual in a calendar year is $600 or more.

If such an award is $200 or more, the department presenting the award must:

a. Notify USNH Accounts Payable of the recipient’s name, address, Social Security number, date and value of the award; and,
b. Obtain a completed Form W-9 from the recipient prior to payment.

2. Gifts to non-employees. Non-cash gifts may be presented as a token of appreciation to a dignitary, guest or visitor when a valid and documented business purpose exists such as to recognize contributions to USNH or to honor a distinguished visitor. In limited circumstances, gifts of flowers or other expressions of sympathy are allowed if paid from a discretionary fund. A list of these funds is maintained by USNH Accounting Services. Items purchased for use in a department's business operations should be accounted for as supplies expense rather than awards, gifts or prizes. Examples are insignia mugs given to visiting speakers or T-shirts given to conference attendees. Gifts to volunteers, donors and prospective donors are not covered by this policy and will be addressed in a future policy.  Until such policy is issued, please contact the USNH Controller with questions on these types of gifts.

3. Cash and non-cash prizes to non-employees.  Prizes may be awarded to a non-employee in connection with games of chance and door prizes in connection with a USNH-sponsored event.

a. For recipients who are U. S. citizens and residents, prizes of $600 or more are reportable by USNH.  If the prize is won in connection with an event that involves a wager, the value is reportable on Form W-2G.  If the prize is won in connection with an event that does not involve a wager, the prize is reportable on Form 1099-MISC.

i. If the prize is the result of a wager and the winnings are $600 or more, the department sponsoring the event is responsible for completing Form W-2G. Copies A, D, 1, and Instructions for Payers of Form W-2G should be forwarded to USNH Disbursement Services who is responsible for filing with the IRS.  Copies B, C, 2 and Instructions to Winner should be provided to the winner after the event.

If the value of winnings is $600 or more and the winner either fails to provide USNH with a Social Security number or provides a number that USNH has been notified is incorrect, USNH must withhold federal income tax at the rate of 24% of the winnings. If the fair market value of any prize exceeds $5,000 and a wager has been made, withholding of 24% is required even if USNH has accurate filing information. The department sponsoring an event where it is anticipated that a prize will be valued at $600 or more, must notify USNH Disbursement Services prior to the event. USNH Disbursement Services will work with the department to satisfy the withholding and reporting requirements of the Internal Revenue Code.

ii. If the prize is not the result of a wager and the winnings are $200 or more, the department presenting the prize must:

  • Notify USNH Disbursement Services of the recipient’s name, address, Social Security number, date and value of the prize; and
  • Obtain a completed Form W-9 from the recipient prior to payment.

b. For recipients who are nonresident aliens, the prize value is reportable by USNH on Form 1042-S, regardless of amount.  In addition, federal income tax withholding in the amount of 30% of the value of the prize is generally required unless 1) the recipient is a resident of a country with a treaty that exempts prize income from taxation, and 2) the recipient files Form W-8BEN with USNH to claim the exemption.  The department sponsoring the event is responsible for contacting USNH Disbursement Services prior to presenting the prize to the recipient. USNH Disbursement Services will work with the department to satisfy the withholding and reporting requirements of the Internal Revenue Code.


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.

 

08 - 008T Awards, Prizes, and Gift Table

Table of Awards, Gifts and Prizes
(refer to Procedure 08-008 for details)
For Recipients Who Are U.S. Citizens

This document is for General Guidance ONLY.
CONSULT PROCEDURE 08-008 FOR A DETAILED EXPLANATION OF THE RULES.
CONTACT USNH DISBURSEMENT SERVICES MANAGER WITH QUESTIONS

1. EMPLOYEES

Policy Reference       Tangible Goods
  A.         Awards    
C.1.a.   Length of Service or Safety Award Taxable; Reportable on W-2 Not Taxable if limited to < $400 and 1-time every 5 years
C. 1.   All Other Awards Taxable; Reportable on W-2 Not Taxable or Reportable if < $75; Taxable withholdings and Reportable if >$75
C.2. B. Gift    
C.2.   Sympathy Not Allowed Not Taxable or Reportable if < $25
C.2.   Other than Sympathy (e.g., Birthday, Wedding, etc.) Not Allowed Not Allowed
  C. Prize - Game of Chance    
C.3.   With Wager Taxable; Reportable on W-2G if >$600 Taxable; Reportable on W-2G if >=$600
C.3.   Without Wager Taxable; Reportable on 1099-MISC if >=$600 Taxable; Reportable on 1099-MISC if >=$600
   

2. STUDENTS 

Policy Reference       Tangible Goods
D.2. & D.3. A. Award Taxable; Reportable on 1099-MISC if >=$600 Taxable; Reportable on 1099-MISC if >=$600
  B. Gift    
E.2.   Sympathy Not Allowed Not Taxable or Reportable if < $25
E.2.   Other than Sympathy (e.g., Birthday, Wedding, etc.) Not Allowed Not Allowed
  C. Prize - Game of Chance    
E.3.   With Wager Taxable; Reportable on W-2G if >=$600 Taxable; Reportable on W-2G if >=$600
E.3.   Without Wager Taxable; Reportable on 1099-MISC if >=$600 Taxable; Reportable on 1099-MISC if >=$600

3. NON-EMPLOYEES OTHER THAN VOLUNTEERS, DONORS AND PROSPECTIVE DONORS

Policy Reference       Tangible Goods
E.1. A. Award Taxable; Reportable on 1099-MISC if >=$600 Taxable; Reportable on 1099-MISC if >=$600
  B. Gift    
E.2.   Sympathy Not Allowed Not Taxable or Reportable if < $25
E.2.   Other than Sympathy (e.g., Birthday, Wedding, etc.) Not Allowed Not Allowed
  C. Prize - Game of Chance    
E.3.   With Wager Taxable; Reportable on W-2G if >$600 Taxable; Reportable on W-2G if >$600
E.3.   Without Wager Taxable; Reportable on 1099-MISC if >=$600 Taxable; Reportable on 1099-MISC if >=$600

 


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 009 Meals and Entertainment

A. Summary

Meals and entertainment expenses are allowable expenditures of USNH funds if they are reasonable and necessary expenses of carrying out the mission of USNH. The guidelines in this procedure govern the allowability of these expenditures. While specific campuses, departments and funding sources may choose to be more restrictive than this policy allows due to budget constraints or other reasons, they may not be less restrictive.

B. Allowable and Non-Taxable Meals

Meals provided to USNH employees that fall into one of the following five classifications are allowable and nontaxable to the recipient USNH employee:

1. Meals provided while the employee is in overnight travel status in accordance with Procedure 7-007, Travel Meals.

2. Meals with a clearly substantiated business purpose, i. e., those directly associated with the active conduct of USNH business. Examples of business meals include departmental meetings and other business meetings with colleagues, as well as dinners with potential students, donors or prospective employees at which a bona fide business discussion takes place. The business discussion may not be secondary to the purpose of the meal. The employee must be present at the meal where the business discussion takes place. Meals eaten alone do not qualify as business meals.

The per diem method of reimbursement is not allowable for business meals.

Documentation must adhere to Procedure 2-210, Adequate Supporting Documentation and requirements include the date, time, location, names and titles of those in attendance, and business matters discussed. In cases where there are more than 6 people in attendance, the name of the committee or organization and the number of participants will suffice (e.g., Faculty Senate meeting, 12 in attendance). Original receipts must accompany the request for reimbursement of actual meal cost. Documentation requirements stated above (i.e., date, time, location, names and titles of attendees and business matters discussed) also apply to meals charged on an interdepartmental voucher (e.g. at the Student Union) and to catered meals.

3. De minimis "supper money" provided on an occasional and infrequent basis to enable employees to work an extended day, which is defined as a period lasting at least 12 consecutive hours. De minimis is defined as any benefit whose value is so small that accounting for it would be unreasonable or impracticable. The employee may be reimbursed for actual meal cost or be paid a meal allowance not to exceed $10, whichever is less. Documentation requirements include supervisor authorization, the date, time, location, hours worked and reason for the extended day. Receipts may be required if the expense is to be charged to a sponsored project; otherwise, receipts are not required. Employees should check with the grant administrator to confirm receipt requirements. These documentation requirements also apply to meals charged on an interdepartmental voucher or reimbursed through petty cash.

Supper money may not be routinely paid to an employee whose job consistently requires working an extended day. The employee's supervisor is solely responsible for making this determination, as signified by his/her authorization.

4. Infrequent, occasional meals provided to a group of employees, such as a campus picnic or holiday party. These meals are generally for the purpose of promoting goodwill, employee relations, morale, team spirit, etc. or for retirements, or major (e.g., 25 years) anniversaries of employment with the University. They must be reasonable and may not be lavish or extravagant. Documentation requirements include the date, time, location and nature of the gathering, name of the group and the approximate number of participants in attendance. Original receipts must accompany the request for reimbursement of actual meal cost. Documentation requirements stated above (i.e., date, time, location, nature of the gathering, group name and the approximate number of participants) also apply to meals charged on an interdepartmental voucher. The per diem method of reimbursement is not allowable. Generally, these expenses may not be charged to federal funds.

5. Meals provided for the convenience of USNH, on the premises of USNH, for a valid business reason. Examples include providing meals to food service employees or to an employee to ensure the employee is available for emergencies. In the latter case, to be exempt, the department must be able to show a history of emergencies in the employee's position as well as demonstrate that providing meals to the employee promotes readiness in dealing with the emergencies. The individual authorizing the award of meals to an employee is responsible for communicating the information to the USNH Disbursement Services Manager. This information must include the value of meals being provided, substantiation of why the benefit is being provided, and an explanation if this benefit should not be considered taxable wages.

c. Meals Considered Taxable Wages

Meals provided to USNH employees that do not fall into one of the five classifications specified in Section B of this procedure are considered taxable wages. The value of the meals will be included in the employee's wages with appropriate federal and FICA taxes deducted from the employee's normal wage payments. The taxable benefit and all taxes withheld will be reported on the employee's Form W-2 at year-end.

D. Entertainment Expense

Entertainment expense must be directly related to the conduct of USNH business. IRS regulations require that the USNH employee engage in the active conduct of business with the person being entertained.

1. Entertainment expenses associated with the active conduct of USNH business are allowed if they directly precede or follow a bona fide and substantial business discussion. This includes goodwill expenditures to obtain contributions from potential donors. The business discussion must be the principal aspect of the combined business and entertainment and must represent an active effort of the USNH employee to obtain a specific business benefit necessary to carrying out the mission of USNH.
2. The expense may not be lavish or extravagant.
3. Documentation requirements include the date, time, and location of the entertainment, names and titles of those in attendance, and the business matters discussed. Original receipts must accompany the request for reimbursement. Entertainment expenses are not allowed to be charged to any federally-sourced sponsored projects and may not be allowable on other sponsored projects; check with the grant administrator to confirm requirements.

E. Reimbursement

An employee may be reimbursed for his/her actual cost of meals and gratuities or the reasonable cost of a moderately-priced meal of acceptable quality, whichever is less. Meals may not be lavish or extravagant. The per diem rate should be used to judge the reasonableness of meal costs incurred. Tips for meals in excess of 15% to 20% of meal cost are generally not appropriate as a USNH business expense and therefore will not be reimbursed.

F. Receipts

Receipts for meals and entertainment expense should include a breakdown of meal cost, beverage cost, tax and tip, if available. Alcohol costs are generally not reimbursable (see Procedure 8-003, Alcohol). In the absence of a detailed receipt, original documentation (e.g., a credit card slip) indicating the total cost is acceptable if accompanied by a signed or initialed statement indicating that no alcohol is included in the expense submitted for reimbursement. Please note, KSC requires receipts for all business meals and entertainment costs.

G. Related Policies

For a discussion of related policies on alcohol, spousal attendance, and gifts, (see Procedure 8-003, Alcohol); (see Procedure 8-007, Spousal Expenses); and (see Procedure 8-008, Awards, Gifts, and Prizes), respectively. Requirements for appropriate supporting documentation can be found in Procedure 2-210, Adequate Supporting Documentation.


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 010 Employee Transition Allowance

A. Summary

If considered necessary by the supervisor and with appropriate campus approvals, USNH departments may pay a new employee a reasonable transition allowance to cover their personal moving, relocation and employment transition costs. If a transition allowance is paid, the allowance will be taxable to the employee and paid via Payroll. The allowance must be (1) authorized in advance, (2) documented in writing to the employee and for USNH files, and (3) directly related to the commencement of employment at USNH.

B. SCOPE

Effective January 1, 2018, reimbursement of actual qualified moving expenses incurred is required to be included in the gross income of the employee receiving these payments.  Consequently, USNH shall neither reimburse an employee, nor pay vendors directly for these expenses.  This includes:  moving company expenses, temporary storage or housing, travel, meals or other personal or family relocation expenses.  All relocation and related payments must be paid as a transition allowance directly to the employee. The transition allowance is the total amount authorized to be paid for the employee's transition costs.

The transition allowance does not apply to special situations involving the establishment or relocation of professional labs, libraries, supplies and equipment of faculty and researchers. These latter payments, if any, will be paid directly to vendors through normal purchasing and accounts payable procedures.

C. EMPLOYMENT NEGOTIATIONS AND PRE-APPROVAL

The transition allowance, if any, is determined for each prospective employee on a case-by-case basis. USNH Policy UNH V.F.7.3.3 specifically allows "compensation paid to faculty or exempt staff members as part of a recruiting effort..."  While there is no standard or maximum USNH transition allowance, employment negotiations should result in a reasonable amount necessary to recruit the employee to USNH giving due consideration to USNH budgetary and funding constraints. All agreements which include the payment of a transition allowance must be in writing and be pre-approved by the President, Vice President or Dean. Any offer of a transition allowance for an Executive Officer requires approval of the USNH Board of Trustees' Executive Committee.

Allowances in excess of 10% of an employee's regular starting salary require the approval of the campus President. Each campus may set a limit on the maximum transition allowance that is more restrictive than this policy. In addition, a campus may consider the transition allowance earned ratably over the first six months of employment and therefore may require repayment upon termination before 6 months of employment. The hiring department is responsible for securing, in advance, the funding source(s) to support the authorized payment and the related applicable USNH fringe benefit charge thereon.

D. TIMING OF PAYMENT

The transition allowance will generally be paid within the first month after the employee has begun employment. The department, however, can choose to defer payment up to one year after employment. In rare exceptions, and with written approval by the President, Vice President or Dean, all or a portion of the transition allowance may be advanced to the employee prior to commencement of employment. All employees receiving a transition allowance in advance of the first day physically on the job will be required to sign a promissory note payable to USNH. In the event the employee does not commence employment, the campus will pursue formal collection efforts and the hiring department will be responsible for funding the full amount of the advance including fringe benefit charges thereon if the advance is not repaid.

E. PROCESSING THROUGH PAYROLL

The transition allowance is paid through the Payroll system as taxable additional pay, following normal Payroll procedures.

F. REQUIRED COMMUNICATION WITH EMPLOYEE

The hiring department is responsible for communicating information regarding payment and taxability of the allowance to the employee. To accomplish this, the following paragraph should be included in the employment agreement or offer letter.

DISCLOSURE
A comprehensive transition allowance in the amount of $____________ will be paid in lieu of moving, relocation and employment transition cost reimbursement and/or payment. The allowance will be paid to you during your first month of employment. It will be processed as additional taxable compensation through the Payroll system with all applicable income taxes and FICA amounts deducted.

G. EFFECTIVE DATE

This policy is effective for all negotiations with prospective employees initiated or settled after December 31, 2017.

H. ADDITIONAL GUIDANCE FOR UNIVERSITY OF NEW HAMPSHIRE SPONSORED PROGRAMS

Payments to vendors to relocate professional labs are allowable direct charges to sponsored programs.

1. Criteria for charging employee transitional allowances to sponsored programs:

a.   Must be "reasonable" and justified with written documentation prepared and maintained by the hiring department, based on comparable industry or survey data for each individual receiving an employee transition allowance;

b.   Must be "allocable" for proportional benefit, according to the terms of the employee's appointment. If appointment is 50% research and 50% teaching, the sponsored program can be charged no more than 50% of the total employee transition allowance;

c.   Must be "consistently applied" such that the average transition allowance charged to federal funds is not materially and substantially higher than the allowances charged to other UNH funds; 

d.   The amount of each employee transition allowance must adhere to the pertinent sponsor rules and regulations, and to specific OMB circulars when federal funds are involved.

2. Pre-Approval requirements

a.   Prior approval by UNH Sponsored Programs Administration (SPA) is required for employee transition allowances, as with all other forms of additional pay when charges are proposed for UNH sponsored programs. (See UNH V.F.7.3.3.1.6.2).

b.   Prior to the President's and SPA's approvals, when an allowance is proposed to exceed 10% of the new employee's regular starting salary, approval by the VP for Research and Public Services is required when UNH sponsored programs funds will be charged.

3. Timing of Payment

If sponsored programs funds are paid to an employee who does not commence employment or the advance is not fully repaid on a timely basis, the charges must be moved to an unrestricted funding source.

4. References

a. Uniform Guidance § 200.463 Federal requirements related to recruiting costs

b. National Science Foundation's Grants Policy Manual, section 642, Relocation Costs

Forms

USNH Transition Allowance Promissory Note

USNH Transition Allowance Promissory Note (Optional)

08 - 011 Honoraria

A. Summary

USNH allows for the payment of an honorarium as a monetary token of appreciation for short-term activities or events where the University does not expect, nor is payment contingent upon, a particular result. The purpose of an honorarium is primarily to confer distinction upon or to symbolize respect, esteem or admiration for the recipient. It is paid as a non-negotiated one-time payment that is not legally required and is not provided in lieu of reimbursement of travel expenses. An honorarium and related travel expenses may be reportable to the recipient and IRS (see Section B.).

1. Honoraria or other payments for the purpose of conferring distinction or to symbolize respect, esteem, or admiration may not be paid from federally-sourced grant funds. The cost of professional and consultant services paid from restricted grant funds are allowable when reasonable in relation to the services rendered and are ordinarily arranged using an Independent Contractor Agreement.

2. Honoraria payments may not be negotiated by either the individual providing service or USNH.  Negotiation of a set fee in exchange for a prescribed service taints the payment as wages rather than an honorarium and applicable federal and FICA taxes must be withheld.  The individual authorizing the honorarium is responsible for deciding the amount of the honorarium which must be reasonable in light of the honor bestowed.

3. Approval is required by the Dean, Director or equivalent campus officer prior to payment.  Proposed honoraria payments that are charged to restricted grant funds require the pre-approval of the campus office responsible for Sponsored Research.

4. Specific vendor codes are necessary as follows:

a. A vendor code must be set up for payees who are U. S. citizens or resident aliens prior to payment when the payment equals or exceeds $200.
b. Vendor codes must be set up for all honorarium payments to nonresident aliens, regardless of the dollar amount, if the foreign national comes to the U.S. and is honored for services performed in the U.S.

B. The procedures for reporting honorarium payments

1. Requirements for reporting and tax withholding depend on whether the recipient is an employee or non-employee, as well as whether the individual is a U.S. citizen, resident alien or nonresident alien.  The reporting and taxation of payments to nonresident aliens are also based on whether the individual is honored for services rendered in the U.S. or abroad.

2. The Procedure 8-011F: USNH Request for Honorarium Payment Form may be completed to provide the information required to document the honorarium payment. Alternative documentation is acceptable so long as it contains all essential information to support the payment, including the appropriate approvals as outlined in Section A.3 (above).

3. Travel expenses reimbursed to an honorarium recipient follow Procedure Chapter 7: USNH Travel Policy (Chapter 7 of the procedure manual)

C. Employees

Any honorarium provided to employees as a token of appreciation (e.g., to faculty as a keynote speaker) for service unrelated to the faculty/staff base rate of pay is compensation. Payments are made through the Payroll system and are reported as Form W-2 wages subject to applicable tax withholding. The administrator engaging the employee for the honored activity must complete the Procedure 8-011F: USNH Request for Honorarium Payment Form. A campus 'Additional Pay Form' to request payment is not required. Due to strict federal regulations related to nonresident aliens, any honorarium paid to a nonresident alien must be pre-approved by the campus Human Resource Office or their designee as required by USNH HR policy at USY V.F.7.5.6 and USY V. F.10.7.

D. Non-Employees

All honorarium payments to non-employees should be charged to Account Code 717210.

1. Payments to non-employees who are U. S. citizens or resident aliens are processed through the Accounts Payable system.  If the payment is $200 or more, it is processed as a “direct pay” invoice and requires a vendor code; one-time payments of less than $200 may be processed as a “one-time direct payment” without a vendor code. Honoraria payments totaling $600 or more per individual per year are reportable on Form 1099-MISC.  The administrator engaging the individual must complete the Procedure 08-011F: USNH Request for Honorarium Payment Form.

2. Payments to non-employees who are nonresident aliens.

a. Payments to nonresident aliens who are non-employees for services performed in the U.S. are subject to federal immigration restrictions based on their visa classification.

Generally, an allowable payment is subject to 30% income tax withholding unless 1. the recipient is a resident of a country with a treaty that exempts honorarium income from taxation, and 2. the recipient files Form 8233 with USNH Disbursement Services to claim the exemption.  The payment is reported on Form 1042-S. 

The Banner invoice document supporting the payment should include an indication that the individual is a nonresident alien, the location services are rendered (i.e., in U.S. or outside U.S.) and whether Form 8233 has been filed with USNH Disbursement Services. The originator must contact USNH Accounts Payable when a nonresident alien honorarium payment is being processed.
b. Payments to nonresident aliens who are non-employees for services rendered outside the U. S. are not subject to tax withholding or reporting.  The place that services are rendered should be clearly documented on the request for payment.


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version. 

08 - 012 Apparel Benefits

A. Summary

Per IRS code regulations, the value of employer-provided apparel (including items donated by outside parties, such as vendors or other donors) is taxable to an employee unless both of the following two conditions are met:

1. The employee must wear the clothing as a condition of employment; and,
2. The clothing is not suitable for everyday wear.

Any benefit deemed taxable to an employee must be included in the employee's taxable income reported on Form W-2. Accordingly, we have created a new earnings code to allow units to post the value of these benefits to individual employee earnings in Banner and trigger the required tax withholdings/reporting.

B. Scope

The IRS has recently begun auditing colleges and universities for compliance in this area. To facilitate compliance, USNH has chosen to exclude apparel provided to student workers from reporting requirements at this time. Accordingly, the value of apparel provided to all non-student employees will be subject to taxation unless specifically excluded in Section D below.

C. Taxability

All clothing is deemed a taxable fringe benefit to an employee unless the value of the clothing is de minimis (defined as $75 or less per employee per item) or meets the IRS conditions for exclusion as specified in Section D.

This taxable fringe benefit is subject to all applicable taxes at the time the compensation is added to the employee's wage history. This includes FICA-OASDI tax, FICA-Medicare tax, Additional Medicare tax (if applicable) and Federal Withholding taxes.

The reporting year for this fringe benefit will be December 1 through November 30, similar to the term for taxation of employer-provided vehicles, etc. The taxable fringe benefit reporting is due to the applicable Campus Payroll office by the 10th of each month. The value of the taxable fringe benefit will be added to the employee's reportable compensation and the tax amount will be withheld from the employee's payroll wages in the month of the due date of its communication to Campus Payroll. For example, values reported through December 10 will be reported as income in December of the current tax year, and values reported December 11-31 will be reported in January of the next tax year.

D. Specific Exceptions from Taxability

The following major categories of apparel have been determined by IRS to be working condition fringe benefits and nontaxable:

1. Uniforms required to be worn in the performance of an employee's assigned job duties that are not adaptable to general usage as ordinary clothing.

The IRS specifically excludes uniforms for law enforcement officials, firefighters and healthcare workers from taxation.

2. Protective or safety apparel that is worn over personal attire to protect the employee or to maintain a sanitary environment. Examples include, but are not limited to: face masks, safety glasses, heat-resistant gloves, hard hats, steel-toed work boots, aprons and laboratory coats.

The purchase of clothing by a department for the purpose of professional image and visual recognition is not sufficient justification for an exception from taxability to the recipient.

E. Responsibilities

1. Campus Department Responsibilities. Each campus department is responsible for communicating to their employees whether or not apparel provided to them is a taxable fringe benefit that is subject to tax withholding. If the apparel is deemed a taxable fringe benefit, the department should notify the employee of the taxable value of the apparel and when the tax withholding will occur.

Each campus department is responsible for reporting the following to the offices identified in Section E.2 when taxable items are provided to employees:

  • Name of the employee
  • Employee's USNH ID
  • Description of the taxable item
  • Value of item and the quantity issued (the value of the benefit is generally equal to the cost of each taxable apparel item received)

2. Responsibility for Reporting Taxable Items and Posting Process. Each campus department shall remit the information noted in Section E.1 above to their Campus office(s) listed below. The reporting should occur monthly by the 10th of the following month, with an annual reporting deadline of December 10th for income to be reported for the current tax year.

UNH    From department to RC Unit/BSC and then to UNH HR/Payroll
GSC    From department to BSC and then to GSC HR/Payroll
KSC    From department to KSC Payroll
PSU    From department to PSU Payroll

The units above should use the GIFTAX epaf and earnings code 929 (TFP - Apparel) to post the value of the related apparel benefit to impacted employee's earnings on a monthly basis.

08 - 015 Provision of Services to USNH Departments by Existing USNH Employees

A. SUMMARY

USNH departments must pay any individual for services provided through the USNH payroll system if they are currently an employee of USNH, or were an employee during the current calendar year. Applicable tax withholdings, overtime pay rates and fringe benefit allocations apply to each position.

B. SCOPE

USNH faculty, professional/administrative/technical staff, operating staff, student workers and all other employees are covered by this policy. It also applies to individuals at all levels who were employed by USNH in any capacity during the current calendar year. With limited exceptions as approved by the USNH Vice Chancellor for Finance and Administration, a USNH employee will be paid as an employee for all services provided to any USNH campus.

C. EMPLOYMENT NEGOTIATIONS

Before engaging any individuals as service providers, each department must ask applicants if they are currently, or were at any time during the current calendar year, employed at any of the USNH campuses. The hiring department is responsible for confirming an applicant’s USNH employment by contacting their campus HR office. If the answer is yes, the individual is hired as an employee with all payments for services treated as wages paid through the USNH payroll system. The fact that services provided through one position are substantially different than another has no bearing on how payments for the additional position will be executed. Since it is likely that we already have an existing approved position doing similar work at another location, this process will ensure equitable treatment for the provision of similar services. While there is no maximum dollar limit on individual transactions of this nature, hiring departments must be cognizant of potential issues such relationships could cause with labor unions and/or the general public.

D. TIMING OF PAYMENT

Payment for services provided in the additional position will be paid when the hours/services are reported, as part of normal payroll procedures.

E. PROCESSED THROUGH PAYROLL

All payments for additional positions are paid through the Payroll system, taxable as additional or hourly pay, and follow all normal Payroll procedures. In short, an employee is always paid as an employee regardless of any difference in work assignments, campuses, or departments.

F. REQUIRED COMMUNICATION WITH EMPLOYEE

The hiring department is responsible for communicating information regarding these payments and their taxability to employees. To accomplish this the following paragraph should be included in the employment agreement or offer letter:

DISCLOSURE 

All payments to you for services rendered to USNH will be made through the USNH Payroll system, net of applicable taxes and other withholdings. USNH will match applicable FICA withholdings for applicable employees and a single Form W2 will be issued each year. If the additional position increases your total USNH employment to more than 20 hours per week we recommend that you consult with the HR office at your campus regarding potential eligibility for certain USNH employee benefit programs.

G. EFFECTIVE DATE

This policy is effective 7/1/2019, for all payments made to USNH employees. Earlier application is encouraged.

H.  ADDITIONAL GUIDANCE

1. Criteria for charges to sponsored programs:

(a) Must be “reasonable” and justified with written documentation prepared and maintained by the secondary hiring department, based on comparable industry or survey data for each individual employee; and

(b) Must be “allocable” for proportional benefit, according to the terms of the employee’s appointments. If any appointments are for work on USNH grant awards, please consult your campus sponsored programs office for assistance; and

(c) Must be “consistently applied” such that the average charges to federal funds are not materially and substantially higher than the amounts charged to other USNH funds; and

(d) The amount of each employee’s payments must adhere to the pertinent sponsor rules and regulations and to Uniform Guidance when federal funds are involved.

2. Pre-Approval requirements

(a) Prior approval by the campus Office of Sponsored Programs Administration is required for employee secondary payments, as with all other forms of additional pay when charges are proposed for USNH sponsored programs. (See USY V.F.7.2.2, USY V. F. 7.2.3, USY V. F. 7.4.1, UNH V. F. 7.4.2, UNH V. F. 7.3.5, UNH V. F. 7.3.6, UNH V. F. 7.4.1, and UNH V. F. 7.5.1).

3. References:

(a) Uniform Guidance § 200.463 Federal requirements related to recruiting costs

(b) https://www.usnh.edu/usnh-financial-services-policies-and-procedures/06-purchasing. See section 050 for information related to independent contractors.

(c) http://www.unh.edu/purchasing/independent-contractor.pdf. See page 3 for independent contractor’s determination checklist.

4. In the event that a current employment relationship is terminated during the fiscal year, but some services will continue to be provided to USNH by the individual through their own business entity, such changes should be made at the start of a new calendar year to limit possible tax consequences.

08 - 016 Student Group Fundraising Activities

A. SUMMARY

For purposes of this policy, fundraising is defined as the collection of money through donations, sales, and/or event programming for the purposes of a charitable donation to entities other than USNH campuses or organizations, or for organizational budget enhancement.  This activity must not conflict with the USNH missions of Instruction, Research and Public Service, and requires the approval of the campus Chief Financial Officer (CFO) or his/her designee at least two weeks before the fundraising activities are planned to begin.

B. APPLICABILITY

This policy is applicable to all fundraising activities by student organizations on campus owned, operated, or controlled property for the benefit of the student organization or for non-university affiliated charitable organizations. Due to the scope and breadth of student fundraising activities, USNH acknowledges that this policy cannot address every possible issue that may arise.  Thus, each campus has the authority to impose reasonable restrictions and/or requirements with respect to the time, place, and manner of fundraising activities that may be in addition to those set forth in this policy.

For the purpose of this policy student organizations are defined as any student group authorized to conduct activities on campus grounds. This includes student organization receiving student activity fees allocation, athletic or recreational clubs and any other student group authorized to operate on campus.

C. GUIDELINES

  1. Only student organizations defined above may set up these types of fundraising activities.
  2. The student organization planning the event is responsible for all costs incurred in connection with the event.
  3. When the activity is on behalf of third-party, the student organization should ensure that the receiving organization is a legal not-for-profit organization. For more information on charitable organizations refer to: https://www.irs.gov/charities-non-profits/exempt-organization-types
  4. Fundraising activity for external organizations other than legal 501(c)(3) charitable organization is not permitted 
  5. Only a member of the student organization may engage in the solicitation of donations.
  6. USNH faculty and staff (including paid student workers) must refrain from solicitation activities during regular work hours unless they have approval from the campus CFO or designee.
  7. Campuses may provide department space for bake sale items, t-shirt/jewelry sales, or space for seasonal clothing and food drive collections. 
  8. Campuses should have procedures in place for how donations are to be collected, safeguarded, and deposited, as well as how the student organization should request payment to the charitable organization after funds are deposited, if applicable.
  9. Any student handling credit card payments must complete a PCI Compliance training. This should be coordinated with the related department.
  10. Monies raised and expenses incurred for fundraising activity that benefits a non-university affiliated charitable organization must be recorded in an assigned campus custodial fund code. Activity of individual student organizations, clubs, or groups may be tracked using other Chart of Account elements such as an Org code or an Activity code.   
  11. Student organizations are prohibited from engaging in activities using crowdfunding platforms such as GoFundMe, or mobile wallets such as Venmo and the like. Any use of campus names, registered trademarks, or campus/team logos in conjunction with crowdsourcing is prohibited.

08 - 115 Lease Agreements

A. SUMMARY

This document sets forth system-wide standards for financial accounting and reporting of leases as set forth by Statement No. 87 of the Governmental Accounting Standards Board (GASB 87) to ensure that the policies and procedures related to financial accounting and reporting of leases are documented, communicated, clearly understood, and consistently applied. Review of lease agreements is particularly important for several reasons (a.) a lease/purchase analysis needs to be done because it may be less costly to purchase an item than to lease it, (b.) leases have an implicit interest rate involved which may be higher than other sources of funds, and (c.) lease agreements are often presented on forms which, if signed, could expose the campus to unreasonable liabilities against which no insurance is held.

B. SCOPE

This policy applies to all component institutions of USNH, and all leases as defined in Section C below that has a term of 12 months or more including all optional renewals.

C. DEFINITIONS

GASB 87 defines a lease as a contract that conveys control of the right to use another entity’s nonfinancial asset (the underlying asset), including land, buildings, equipment, facilities, and infrastructure, as specified in the contract for a period of time in an exchange or exchange-like transaction. GASB 87 does not apply to the following:

  • Leases of intangible assets
  • Leases of biological assets
  • Leases of inventory
  • Contracts that meet the definition of a Service Concession Arrangement
  • Leases in which the underlying asset is financed with USNH standing conduit debt, unless both the underlying asset and the conduit debt are reported to the lessor
  • Supply contracts, such as power purchase agreements

GASB 87 also includes embedded leases which occurs when a service contract with a vendor uses a tangible asset as part of the value provided and the use of that asset meets the definition of a lease. An embedded lease exists when there is an asset in a contract and the department controls the use of the asset, by directing the use and derives all benefits from the asset, and the vendor does not have the practical ability to substitute an alternative asset throughout the period of use.

D. APPLICABILITY

USNH adopted GASB 87 for the fiscal year starting July 1, 2021. All leases will be accounted for as set forth in this policy as of the date of the adoption.

E. RESPONSIBILITY

A department that wishes to lease (USNH is the Lessee) or to provide for lease (USNH is the Lessor) property or equipment must contact the USNH Contract Office t (under USNH Procurement Services). If the lease is to be charged to, or to fund a sponsored program, departments need to request approval from the Support Team for Administration of Research (STAR) prior to contacting USNH Contract Office. USNH Procurement staff will work with campus Finance and Administration Officers and/or the USNH Treasury office, and Legal counsel for review and approval of lease agreements. The Board of Trustee approval may be required for certain types of leases consistent with BOT Policy VI.E.

F. LEASE ACCOUNTING

1. Reporting requirements. USNH Procurement Services will provide access to all executed leases to USNH Financial Services for USNH FOC Accounting to (a.) determine the appropriate recording of each lease based on accounting standards (b.) accumulate minimum lease payment data for disclosure in the annual audited financial statements, and (c.) track outstanding lease commitments system-wide for management information purposes.

2. Accounting impacts when USNH is the Lessee. The Lessee will recognize a lease asset and a lease liability at the inception of the agreement. Generally speaking, these amounts will be equal to the present value of the liability for the future lease payments. The lease liability amounts are reduced as lease payments are made, excluding the interest expense portion of the payments, and the lease asset is amortized on a straight-line basis over the remaining lease term. Lease contracts should include a breakdown of payments to show the interest and principal portion of the transaction whenever possible.

3. Accounting impacts when USNH is the Lessor. If an USNH department leases out property or equipment, those amounts will be recorded as lease receivable with an offsetting deferred inflow of resources. USNH as a lessor should breakdown the payments to show the interest and principal payment portions in each lease contract.

4. Recording lease payments. All lease payments should be encumbered at the time of contract through the execution of a Banner PO document, using account codes provided by USNH FOC accounting.

5. Recording lease revenue. At the inception of the lease, USNH FOC Accounting will record a lease receivable, corresponding deferred inflow of resources and if necessary, provide USNH Non-Student Accounts Receivable (NSAR) department with an amortization schedule. USNH NSAR will record the cash receipt on a CR for lease revenue according to the amortization schedule by debiting lease receivable and lease interest revenue accounts. On a quarterly basis, USNH FOC Accounting will recognize lease revenue by recording amortization of deferred inflow of resources over the life of the lease.

G. RELATED PROCEDURES, FORMS, AND RESOURCES

A comprehensive guide describing detail processes to ensure compliance with GASB 87 is available on the USNH Finance Hub.

GASB 87 Decision Tree

Board of Trustee Policy – Leasing of Property BOT VI.E

CONTACTS:
Policy Owner: Manager, Accounting and Financial Reporting
USNH FOC Accounting: foc.accounting@usnh.edu


The official version of this information will only be maintained in an on-line web format. Any and all printed copies of this material are dated as of the print date. Please make certain to review the material on-line prior to placing reliance on a dated printed version.

 

08 - 116 Subscription-based IT Agreements

A. SUMMARY

This document sets forth system-wide standards for financial accounting and reporting of subscription-based IT agreements (SBITA) as set forth by Statement No. 96 of the Governmental Accounting Standards Board (GASB 96) to ensure that the policies and procedures related to financial accounting and reporting of SBITA are documented, communicated, clearly understood, and consistently applied.

B. SCOPE

This policy applies to all component institutions of USNH.

C. DEFINITIONS

GASB 96 defines a SBITA as a contract that conveys control of the right to use another party’s information technology (IT) software, alone or in combination with tangible capital assets (the underlying assets), as specified in the contract for a period of time in an exchange or exchange-like transaction. Control over the use of the SBITA asset means that USNH has:

  • The right to obtain the present service capacity from use of the underlying asset
  • The right to determine the nature and manner of use of the underlying asset.

D. APPLICABILITY

Beginning with July 1, 2022, all SBITA agreements will be recorded as described in this policy. GASB 96 does not apply to the following:

  • Contracts with an initial subscription term of 12 months or less not including optional periods
  • Perpetual licensing arrangements

Contracts that include the right-to-use combination of both IT software and tangible assets that meet the definition of a lease, should be accounted for under the significant component (component with most value) and do not need to be bifurcated. (Example - a computer with operating software or a smart copier that is connected to an IT system, whichever asset, physical or IT, is of more value will determine if Right of Use asset is GASB 87 or GASB 96 respectively.)

E. RESPONSIBILITY

A department that wishes to enter into a SBITA agreement of more than one year must contact USNH Contract Office (under USNH Procurement Services). If the agreement is to be charged to or to fund a sponsored program, departments need to request approval from the Support Team for Administration of Research (STAR) prior to contacting the USNH Contract Office. USNH Procurement staff will work with campus Finance and Administration Officers and/or the USNH Treasury office, legal counsel for review and approval of SBITA agreements. In certain circumstances, additional approval may be required from the USNH Board of Trustees for certain agreement that may have a significant impact to USNH’s debt profile. Any relevant IT needs and security assessments are still required.

F. SBITA ACCOUNTING

1. Reporting requirements. USNH Procurement Services will provide access to all SBITA agreements to USNH Financial Services for USNH FOC accounting to (a.) determine the appropriate recording of each agreement based on accounting standards (b.) accumulate data for disclosure in the annual audited financial statements, and (c.) track outstanding agreement commitments system-wide for management information purposes.

2. Accounting impacts. USNH Accounting FOC will recognize a right-to-use asset and a subscription liability at the inception of the agreement. The liability amounts are reduced as payments are made, excluding the interest expense portion of the payments, and the asset is amortized on a straight-line basis over the remaining agreement term.

3. Recording payments. All SBITA payments should be encumbered at the time of contract through the execution of a Banner PO document using account codes provided by USNH FOC Accounting.

Please note that all other campus related IT requirements related to the acquisition of a software still applies.

G. RELATED PROCEDURES, FORMS, AND RESOURCES

A comprehensive guide describing detail processes to ensure compliance with GASB 96 is available on USNH Finance Hub.

GASB 96 Decision Tree

CONTACTS:

Policy Owner: Manager, Accounting and Financial Reporting

USNH FOC Accounting: foc.accounting@usnh.edu