Human Resource Policy No. 5

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1 Page 1 of 13 REVIEW BY: 06/22/14 POLICY It is the policy of Catholic Health Initiatives ( CHI ), its Direct Affiliates 1 and Subsidiaries 2 [collectively referred to as CHI Entity(ies) ] to reimburse travel expenses incurred by employees of CHI Entities, in conjunction with the conduct of corporate business. Reimbursement requests for expenses of non-employees and unrelated individuals (i.e., spouses or family members) shall be subject to prior review and authorization by the responsible party (defined below). Expenses of spouses and other family members of executives shall be paid by the executive and are not reimbursable. SCOPE This Policy is applicable to all CHI Entities. It is recommended that each CHI Entity update its travel policy to ensure alignment with this Policy. RELATED POLICIES The following related Human Resource ( HR ) policies should be consulted for additional information and requirements associated with aspects of incurring and reporting business expenses: Human Resource Policy No. 2, Corporate Credit Cards Human Resource Policy No. 4, Spouse or Family Travel for Volunteers Human Resource Policy No. 7, Tax Indemnification Payments (Gross-Ups) 1 A Direct Affiliate is any corporation of which CHI is the sole corporate member or sole shareholder. 2 A Subsidiary refers to either an organization, whether nonprofit or for-profit, in which a Direct Affiliate holds the power to appoint a majority of the voting members of the governing body of such organization or any organization in which a Subsidiary holds such power.

2 Page 2 of 13 REVIEW BY: 06/22/14 PURPOSE The purpose of this Policy is to ensure consistent application of travel and expense reimbursement guidelines across all CHI entities. RESPONSIBILITIES All business related expenses must be submitted using the individual CHI Entity s expense reimbursement system and policies. Expenses shall not be reimbursed through the invoicing process unless associated with a meeting or conference requiring an invoice from the vendor. Responsibilities of Employee Incurring Expenses Each Employee incurring expenses on behalf of a CHI Entity is responsible for the following items: Obtain supervisor pre-approval for any planned expenditure that requires a supervisor preapproval before incurring the expense. Provide a complete and detailed business description to substantiate the business purpose for an expenditure. Select appropriate travel category for proper expense reporting. Submit request for reimbursement in a timely manner. Every effort should be made to submit reimbursement request no later than 30 days from the completion of a trip or expenditure. Failure to submit a timely expense reimbursement request (within 120 days) could result in the loss of CHI corporate credit card privileges, denial of reimbursement request or the expense being considered taxable income to the employee. Provide detailed receipt documentation according to this Policy. Required receipts include an entire airline itinerary, hotel portfolio and receipts for any other expenses over $25. Receipts for expenses costing less than $25 will be accepted but are not required. The date that an expense was incurred should also clearly appear on the receipt. Submit one expense report per trip or combined trip (multiple locations/legs of travel).

3 Page 3 of 13 REVIEW BY: 06/22/14 Responsibilities of Supervisor Approving Expenses All expense reports will be approved by the employee s supervisor as reflected in the HR database at the time that the expense report is submitted. The approving supervisor for expense reports is responsible for the following items: Ensure expenses are in accordance with this Policy. Check for timely submission of expenses. Review travel categories for expenditure to ensure appropriateness. Ensure all necessary documentation (receipts) have been submitted in accordance with the guideline above. Ensure all physician expenses are in compliance with the terms of the physician s contract. (Consult Legal Services Group if expenditures are in question) Approve/reject expense reports in a timely manner (i.e., within 5 business days, or as soon as possible thereafter, from submission). Ensure all employee expenditures requiring pre-approval are authorized prior to the employee incurring the expense. PROCESS OVERVIEW CHI Entities that are part of CHI Connect shall use the Lawson PSA expense reporting module for all reimbursement requests. The Accounts Payable Support Center ( APSC ) audit team will complete a final review and when complete will authorize the expense report for reimbursement of out-of-pocket monies or the clearing of corporate card charges. CHI Entities that are not on CHI Connect will continue to use their current processes for submitting expenses. It is understood that while the toolset may be different, the adherence to this Policy is expected.

4 Page 4 of 13 REVIEW BY: 06/22/14 PROCEDURES Travel Agency CHI has contracted with a preferred travel agency to arrange for all CHI business travel, including all airline, lodging and rental car expenditures. All employees are required to use the preferred agency to arrange their travel, unless reasonable circumstances occur (i.e., using reward travel, booking family member travel with employee trip, unable to reach agency, etc.) Utilization of the online booking tool is the preferred method to access this service, as there is a significant cost savings to booking travel on line. An explanation of the use of an alternate agency or booking method is required on an expense report. Rates negotiated by CHI for lodging facilities near national offices and high volume areas near CHI Entities have been incorporated in the information system used by the preferred agency, as well as rental car agency rates contracted through CHI s group purchasing organization. (Exception: If traveling to a conference/meeting offering negotiated hotel and airline discounts, an employee may book directly with the event planner as instructed.) Changes During Travel CHI business travelers shall not be required to use the preferred agency to make emergency changes to travel arrangements, if circumstances make it impractical to contact preferred agency. In such situations, travelers shall provide documentation describing the circumstances on the traveler s expense report. Reimbursable Expense Categories Airline Travel o Timing for airline booking impacts travel costs and all effort should be considered for airline travel arrangements to be made no more than 35 days and no less than 14 days in advance of travel. o Only coach fares will be reimbursed unless first class fares or seat upgrades are pre-approved by a department s most senior Vice President or Board Chair if applicable. o Mileage in lieu of air travel may be used when it is determined to be a less expensive mode of transportation or when it would be more appropriate for the business circumstance. o Use of charter air travel is not permitted unless the use of charter air travel is lower in cost than the total airfare for all CHI business travelers making the same trip and the use of charter

5 Page 5 of 13 REVIEW BY: 06/22/14 travel is approved in advance by the department s most senior Vice President or Board Chair, if applicable. Hotel/Lodging o CHI employees shall stay at preferred hotels with which CHI has negotiated discount rates, unless such rooms or preferred hotels are not available. o Hotel rooms booked as a part of a conference are not subject to the preferred hotel guideline and will be reimbursed. o Long distance charges incurred on a hotel room phone are not reimbursable. Employees should use a lower cost alternative such as a company calling card or a cellular phone. Minimal local charges, long distance access and internet access charges will be reimbursed. Car Rentals o CHI s preferred rental car vendor shall be used to the extent it is cost effective and available. o Mid-size vehicles should be used, unless group size or business circumstances dictate otherwise. Rental Car Insurance o CHI shall provide insurance coverage for business travelers who require rental cars for company business needs. o A CHI business traveler shall decline all rental firm insurance coverage. o The coverage provided by CHI shall apply if either the traveler or the traveler's spouse is driving while on company business. This coverage shall further apply to situations in which a vehicle is rented for company business and such rental is extended for personal use by the traveler and/or the traveler's spouse. o The Risk and Insurance department shall provide insurance cards annually to CHI business travelers who rent cars. Replacement cards shall be obtained by contacting the Risk and Insurance department in the Erlanger office. o CHI travelers involved in an accident while driving a rental car, shall not provide personal insurance information to other parties involved in an accident situation. The CHI insurance

6 Page 6 of 13 REVIEW BY: 06/22/14 card information shall be presented to any and all authorities and any secondary parties requesting such information. o The Risk and Insurance claims area in the Erlanger office (800/ ) shall be contacted as soon as possible with information about any accident situation. Meals While Traveling o Meals will be reimbursed at actual expense incurred while an employee is traveling. If meals and beverages are provided during standard work hours, no additional reimbursement for meals will apply unless for extenuating circumstances. o Meals occurring at the end of the business trip (i.e., at an employee s home location) will not be reimbursed. o Meal costs should be conservative for the area in which the employee is traveling, in keeping with good stewardship. Mileage Reimbursement o An employee will receive reimbursement for any incremental mileage incurred while using his/her personal automobile on approved company business. o Mileage shall be reimbursed at the current announced IRS-approved rate per mile. o CHI employees shall not receive a mileage reimbursement for normal/routine commuting expenses. Travel from home to the regular or main place of work is considered personal commuting expense, regardless of the distance from an employee s home to his/her regular place of business. However, travel to an alternate work location in the same metropolitan area as the worker s primary work location is considered work related. o A business traveler who travels to his/her place of work prior to a business trip shall be reimbursed business travel mileage only for the mileage between the office and the airport or business destination. o If a business traveler travels from his/her home directly to the airport, the total roundtrip mileage is considered reimbursable. o CHI business travelers who receive an automobile allowance typically are not eligible for mileage reimbursement. The only exception is when a business traveler, who has an automobile allowance, chooses to utilize his/her personal automobile for authorized travel purposes. That individual may request reimbursement for the trip only if the round-trip

7 Page 7 of 13 REVIEW BY: 06/22/14 mileage is 250 miles or more and the use of alternative travel, including both air and ground transportation, would exceed the mileage reimbursement or would be a business inconvenience to the traveler. Business Meals and Entertainment o Expenses associated with business meals and entertainment will be reimbursed. A detailed description is required for any meal charge that includes expenses other than those for the CHI business traveler. The description for meals shall be accurately and completely recorded. The explanation shall include the amount, the place, the complete business purpose, and each participant s name, title and affiliation. o Expenses for alcoholic beverages are generally reimbursable when part of a meal expense and reasonable to the corresponding restaurant venue. Alcoholic beverage expenses incurred outside of a business meal and that are not associated with a legitimate business purpose are not reimbursable.. When there is an expense associated with alcoholic beverages, the corresponding charges must be broken out separately in order to comply with CHI s cost reporting requirement. o When expenses are incurred for two or more employees, the most senior employee in attendance is expected to pay for the charges. Any necessary accounting allocations can be handled when the expense report is being completed. o Reimbursement for entertainment events such as sporting, concert or theatre, must be approved in advance by an Employee s Group Vice President. Documentation shall include business purpose and each participant s name, title and affiliation, and the portion of any such reimbursement that is for alcoholic beverages. Other o Frequent Flyer Dividends CHI business travelers may accumulate and use frequent flyer mileage awards at their discretion, however, expenses associated with the redemption and/or use of frequent flyer awards or fees associated with membership awards programs are not reimbursable. o Spouse and Family Travel A CHI business traveler shall not claim any expenses for reimbursement for spouse and family members when submitting a reimbursement request. All spousal and family travel

8 Page 8 of 13 REVIEW BY: 06/22/14 expenses shall be the responsibility of the CHI business traveler, unless such expenses are approved prior to the program/event in accordance with either the CHI Core and Supplemental Benefits program for executives, HR Policy No. 4, Spouse or Family Travel for Volunteers, or Governance Policy No. 5, Travel and Educational Expense Reimbursement Policy for. In such instances, the CHI business traveler shall submit appropriate forms for reimbursement claims, which are processed through the accounts payable and/or payroll department. CHI is not responsible for any spouse/family travel costs associated with canceling a business trip due to business needs. o Personal Side Trips or Other Expenses A CHI business traveler may attach personal travel to, or incur other personal transactions during, an authorized business trip. However, the CHI business traveler shall be responsible for any personal expenses incurred. If the CHI corporate credit card has been used for any personal expenses, the CHI business traveler shall make appropriate deductions, properly explained, when submitting the expense report for such personal expenses charged to the CHI corporate credit card. If such deductions for personal expenses cause the out-of-pocket expenses for the expense report to be negative, the CHI business traveler shall attach a personal check in the amount due to CHI, made payable to Catholic Health Initiatives, and send it to the Accounts Payable Support Center at P.O. Box , Littleton, Colorado A copy of the check should be included with the expense report documentation that is faxed to the APSC. o Weekend Savings The CHI business traveler shall be reimbursed for lodging, meal and reasonable taxi or rental car expenses when extending a business trip to achieve lower overall airfare expenses as compared with the expected itinerary for the business portion of the trip. Such reimbursement shall not exceed the amount of the airfare savings. The business traveler shall receive approval from the immediate supervisor prior to the trip and an airline itinerary documenting the lower cost of extending the stay shall be included with the expense report.

9 Page 9 of 13 REVIEW BY: 06/22/14 o Club Dues Health or social club dues (including entrance fee, periodic fee or use fee) for the membership of a listed person are not reimbursable. Club dues are reimbursable when they are paid as reimbursement to or on behalf of an employed Foundation Executive Director who is responsible for fund-raising and only when such club membership is associated with the fulfillment of that Director s fundraising role on behalf of the Foundation. Social club dues reimbursed or paid by the CHI Entity on behalf of a Foundation Executive Director pursuant to this section are fully taxable to the recipient regardless of the extent of business purpose. o Rewards and Recognition If reward or recognition is for a physician, contact the CHI Entity s Corporate Responsibility Officer or Legal Service Group representative for guidance prior to incurring the expense. Expenses associated with employee rewards and recognition are reimbursable, if preapproved by the supervisor. Cash and cash equivalents (e.g., gift cards) must be considered as taxable income to the recipient. Accordingly, a list of recipients and individual amounts is required with the expense report. It is the approving supervisor s responsibility to insure compliance with the tax liabilities associated with reward and recognition expenses. Reimbursement of Physician Business Expenses o Reimbursement of a legitimate business expense for a physician, his spouse and/or his family members may only be made if the reimbursement would be reimbursable under paragraphs 1-8 of this Policy AND the reimbursement meets one of the Stark Law exceptions. CHI Entities should consult with their Legal Services Group representative to determine which physicianrelated expenses will qualify for a Stark Law exception. o All expenses associated with a non-employed physician must be tracked in the physician gift database. Non-Reimbursable Expense Categories The following list contains categories of expenses that are typically not considered a business expense and therefore are not reimbursable. Any exceptions must be approved by the

10 Page 10 of 13 REVIEW BY: 06/22/14 responsible party (see below), using the exception form. Any personal charges associated with a business expense report will not be reimbursed and will require an attached corresponding personal check to the appropriate CHI Entity, in accordance with CHI HR Policy No. 2, Corporate Credit Cards. Hotel Charges - Personal Services Personal services available at some hotels (e.g., movie rentals, fitness center, spa, dry cleaning/laundry, concierge, etc.) shall be the financial responsibility of the traveler. It is preferred that personal charges are separated on the lodging bill and personally paid to the hotel by the traveler, rather than including such personal charges on the CHI corporate credit card. Laundry and Dry Cleaning The costs of laundry and dry cleaning shall be the responsibility of the CHI business traveler. Entertainment and Bar Social expenses, entertainment and refreshments (including in-room bar cabinets) are the responsibility of the CHI business traveler. Mini bar charges in lieu of a meal expense will be reimbursed if documented. If expenses are incurred, it is important that the expenses are broken out and identified separately on the traveler s expense report as business or personal. Computer Equipment/Cell Phones/Software These expense items should be acquired through the CHI Entity s local IT purchasing process. Minor miscellaneous equipment, under $100 (e.g., batteries, memory cards, power cords) will be allowed, if approved by the immediate supervisor. Airline Club Memberships o One airline club membership may be reimbursable annually for national non-executive employees, if his/her job requires frequent travel. The employee s direct supervisor must approve this expense prior to incurring the cost. o National executives airline club membership dues are not reimbursable. o Other CHI Entity employees should follow the CHI Entity local guidelines.

11 Page 11 of 13 REVIEW BY: 06/22/14 Relocation Expenses. Relocation expenses are managed and approved outside of the expense reporting process. For more information, contact HR/Payroll Connection or the CHI Entity local HR representative. Anniversary Gifts Expenses associated with National Office anniversary gifts are not reimbursable under this Policy. Other CHI Entity employees should follow their local Mission/HR guidelines. Flowers/Gifts for Life Events (Births, Marriage, Bereavement) Expenses associated with National Office life events are not reimbursable under this Policy. Other CHI Entity employees should follow their local Mission/HR guidelines. Miscellaneous Fees Fees/charges associated with personal situations such as traffic infractions, bank fees, parking tickets late fees, etc., are not reimbursable items. Authorization for Approval All expense reports shall be approved by the employee s immediate supervisor. No person shall sign on behalf of the employee s supervisor, nor shall a supervisor provide his or her user name and log-in information to any other employee for the purpose of conducting business on their behalf. If the employee s supervisor is not available on a timely basis for signature, the expense report shall be approved by the supervisor of the employee s immediate supervisor. No other person shall approve an expense report. At no time shall a subordinate of the employee approve an expense report. Photocopies, faxes or signature stamps shall not be acceptable forms of approval. CHI President/Chief Executive Officer The CHI Chief Financial Officer may review the expense reports of the CHI President/Chief Executive Officer for accuracy, completeness, and provisional reimbursement; however, final

12 Page 12 of 13 REVIEW BY: 06/22/14 approval of the expense reports shall be made by the Chairperson of the Board of Directors or a designated board member when the board meets for its quarterly meeting. Direct Reports of CHI President/Chief Executive Officer The CHI Chief Financial Officer may review the expense reports of those employees who report directly to the President and Chief Executive Officer for accuracy and completeness, however, the final approval of the expense reports shall be made by the President and Chief Executive Officer. Direct Affiliate CEOs The expense reports of a Direct Affiliate Chief Executive Officer shall be approved by the Senior Vice President of Operations for the respective Affiliate or that individual s direct supervisor, if CEO is also a Senior Vice President of Operations. Board Members The expense reports of a member of shall be approved by the Senior Vice President, Sponsorship and Governance, as delegated by the CHI President and Chief Executive Officer. No other person may approve the reports. Board Committee Members The expense reports of the members of each Board Committee of CHI shall be preliminarily reviewed by the appropriate CHI senior staff member sponsor for each committee. Final approval shall be given by the Senior Vice President, Sponsorship and Governance. Responsible Party When approval is required by a responsible party, the definition of responsible party is as follows:

13 Page 13 of 13 REVIEW BY: 06/22/14 Reimbursement Recipient CHI Board of Stewardship Trustees CHI BOST Committee Members CHI National CEO Direct Reports of CHI CEO CEO of Direct Affiliate and its collective subsidiaries Board Members (except for Board Chair) of Direct Affiliate and its collective subsidiaries Board Chair and Employees of Direct Affiliate and its collective subsidiaries All other Employees Responsible Party SVP Sponsorship and Governance SVP Sponsorship and Governance CHI Chairperson CHI President & CEO SVP of Operations, Group Vice Presidents or Direct Supervisor CEO or Board Chair of Direct Affiliate CEO of Direct Affiliate or SVP of Operations Employee s Direct Supervisor AMENDED 07/01/98 11/18/98 03/09/00 09/01/02 07/01/03 11/21/03 07/01/04 06/22/11