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INTRODUCTION

Purpose of Policy

This document sets forth the policies of GBH with respect to certain business and travel expenses of independent contractors working on GBH projects.  This policy outlines what qualifies as an accountable reimbursement plan under US Treasury Regulation §1.62-2(c).

Please direct any questions regarding this policy to your GBH Project contact or the GBH Compliance Department at (617) 300-2000.

GBH appreciates the efforts of those who travel on GBH-related business.  It is necessary to keep travel costs within reasonable limits and to follow consistent procedures. Independent contractors working on GBH projects are required to submit an itemized accounting of these expenditures. Sound judgment is necessary in managing such expenses.

GBH retains final approval of all expenditures and periodically reviews and adjusts its reimbursement policies.

This policy is intended to:

• Ensure clear and consistent understanding of procedures
• Ensure compliance with state, federal, and IRS regulations, including federal cost regulations under the Office of Management and Budget (OMB) and including donor and funder guidelines
• Ensure maximum insurance coverage for the travelers as well as for GBH
• Provide guidelines that simplify travel arrangements and enable GBH to better manage its annual travel costs

Responsibility of the Traveler

Independent Contractors working on GBH projects are expected to spend funds prudently. Business expenses will be reimbursed by GBH if they are:

• Reasonable
• Appropriately documented
• Properly authorized by the GBH project contact
• Within the guidelines of this policy

Non-compliance with these policies and procedures or failure of Independent Contractors working on GBH projects to properly and accurately expense documentation will result in a delay in receiving reimbursements when due, difficulties in obtaining additional funds, and in some cases disallowance of part or all of the expense(s). Questions regarding the interpretation of these policies and procedures should be directed to the GBH Compliance Department.

For travel associated with projects funded by federal grants, additional restrictions may apply. See the Appendix for further information.

Reimbursable Expenses

In addition to expenses for hotels, transportation, and meals, as defined in the policy, travelers will be reimbursed for the following expenses with proper receipt documentation:

• TSA Pre-check will be reimbursed to frequent travelers with a projected business travel schedule and once approved by their supervisor.
• Business office expenses (fax, copy service, )
• Business phone calls
• Conference fees (include copy of registration form with expense report)
• Currency conversion fees
• Personal phone calls, not to exceed an average of 15 minutes per day
• Gasoline allowance for rental car (if mileage allowance not claimed)
• Mileage allowance for personal car usage per IRS rates, allowable only above and beyond normal daily commute

• Ground transportation (taxi, bus, train, subway,)
  • Laundry/dry cleaning/suit pressing for trips exceeding 5 days
  • Luggage fees for airlines that charge for normal baggage
  • Overnight delivery/postage for business purposes
  • Parking and tolls for business purposes
  • Tips related to business meals and travel (see guide to tipping, page 10)
  • Visa/passport consulate fees for business travel
  • Supplies when on site (production, conference,)

For Independent Contractors that work on projects funded by federal funds, the Independent Contractor should also refer to the Appendix to this policy for special requirements applicable to these types of grants.

Non-Reimbursable Expenses

Travelers will notbe reimbursed for the following expenses:

• Alcohol see Appendix re: travel and expenses for projects funded by federal grants
• Airline club membership dues and other award programs
• Annual fees for personal credit card used for travel purposes
• Airline upgrades
• Car rental upgrades or GPS systems
• Purchase of prepaid cards are not allowed for travel related expenses.
• Auto repairs
• Child care services
• Barbers, hairdressers, clothing, or toiletry items
• Baggage fees associated with personal items such as skis, golf equipment,
• Portion of meals for conference where meals are part of registration
• Health club/resort fees, gym, or recreational fees
• Corporate card delinquency fees or finance charges
• Expenses related to vacation or personal days taken before, during, or after a business trip
• Laundry or dry-cleaning services for travel of fewer than 5 consecutive days
• Valet service (unless mandatory at the location)
• Loss or theft of cash or airline tickets
• Loss or theft of personal funds or property
• Lost baggage or associated costs (losses covered by airlines)
• Luggage, briefcases
• Magazines, books, or personal reading materials
• Medical expenses incurred while traveling, except for business-related injury or accident (medical services covered by insurance)
• Mini-bar/ in-room refreshments (non-alcoholic only may be meal expense)
• Movies (including in-flight and hotel in-house)
• “No show” charges for hotel or car service
• Optional personal travel or baggage insurance
• Parking tickets or traffic violations
• Personal entertainment, including sports events
• Personal telephone calls in excess of reasonable calls home, as defined in the “Reimbursable Expenses” section
• Pet care
• Spa services, shoe shines
• Personal guest travel and expenditures
• Souvenirs, personal gifts (except in lieu of lodging)

RequiredReceiptsfor Reimbursement

The traveler should include:

• A copy of the airfare itinerary or original ticket receipt
• Original folio for all lodging expenditures, regardless of amount
• Car rental agreement and detailed statement of amount paid (not estimate)
• Credit card receipts (not statements) for entertainment expenses (must include names, titles, and business purpose of meeting and detailed restaurant meal receipts)

AIR/TRAINTRAVEL

Air Travel

All air travel is restricted to coach class or to the least expensive airfare available, unless circumstances prevent it. It is GBH’s policy not to cover the cost of business class travel, even for international flights, except under extraordinary circumstances. Independent Contractors seeking reimbursement for business class travel outside North America under such unusual circumstances must obtain prior written approval from GBH’s Accounting office. Business class travel that does not follow this procedure will risk non-reimbursement of expenses.  When traveling on a federally funded project, (see Appendix) travelers must book the lowest coach class airfare available, and travel may only be on approved airlines (generally American-owned carriers).  Any international travel on non-American-owned carriers must receive prior written approval from GBH’s Accounting office.

First-class travel is prohibited for all destinations unless pre-approved by GBH’s Accounting office.  First class travel is not allowed for federally-funded projects.

Travelers attending a conference are strongly encouraged to consider multiple-stop fares as time allows and should review the conference registration forms for details regarding discount airfare and hotel rate made available through the agency of the conference.

The use of personal aircraft is not allowed for GBH business travel. 

 TrainTravel

Out-of-town train travel is restricted to coach class or its equivalent. First class or business class train travel is not allowed under GBH policy. For rail travel only, if coach class is not available due to the type of train, business class is acceptable. This fact should be documented. First class rail travel is not acceptable in any circumstances.

HOTEL/LODGING

Independent contractors working on GBH projects who are required to stay overnight when traveling for business purposes should stay in a standard, business-class, single room in a non-luxury hotel. Suite or luxury accommodations will not be reimbursed unless pre-approved by GBH’s Accounting office, or unless no other rooms are available.  Approved supporting documentation should be submitted.

Hotel rates in major cities (Chicago, Los Angeles, San Francisco, Washington, DC) may not exceed $250 per night, excluding taxes. New York rates may not exceed $400 per night, October through December; $300 all other months. Please note: GBH is exempt from some hotel taxes in New York, and a tax- exempt certificate for the state of New York (available from the Accounting office) should be provided upon check-in.

It is the responsibility of the traveler to notify the hotel to cancel a room reservation. Travelers should request and record the cancellation number in case of billing disputes. Travelers will not be reimbursed for “no show” charges.

Original hotel paid folio receipts must be retained.  If a business trip is 5 or more days long, laundry, dry cleaning, and pressing services are allowed when reasonable and receipts are retained.

Reasonable gratuities to porters and bellmen will be reimbursed:

• Bellmen: $2-$3 per bag
• Housekeeping: $5 per night maximum
• Cabs: 15-18% of fare
• Porters: $2-$3 per bag
• Valet 15 – 18%

Travelers who stay in a private residence (with relatives or friends) in lieu of a hotel while on business travel will be reimbursed for reasonable, actual expenses up to a limit of $150 per trip, to extend appreciation to their hosts for their hospitality. A dated receipt (e.g., florist receipt, restaurant receipt, grocery receipt) must be submitted with the expense report under this provision.  Note: When traveling on a federally funded project, tokens of appreciation are not allowable (see Appendix regarding federal grant travel and business expenses)

Airbnb can be used in a limited basis and only with proof of it being the least expensive option.  Any damages caused to a property by guest(s) will be the responsibility of the traveler. 

GBH independent contractors who travel with persons not tied to the purpose of the business trip are expected to pay all incremental costs associated with the guests’ travel, including transportation costs, additional lodging expenses, if any, meal expenses, and registration fees.

TRANSPORTATION

Automobile Rental

Car rentals are currently not allowed unless used for out of town travel. Local car rentals will only be allowed with proof of least expensive option or when contractually obligated. 

Car rental should be limited to situations where public or other forms of transportation would not be practical or economical.

A compact to mid-size car is considered adequate for general transportation, but larger vehicles may be rented if required for the number of passengers or equipment being transported.  Approval for a larger car should be obtained from your GBH project contact and documented as to the reason a larger car is required.  A car to be used for more than a few days should be contracted at the most economical weekly rate available. Independent contractors traveling to the same destination should make every effort to share automobile rentals whenever possible.

Gas tanks should be filled prior to returning cars to rental agencies to avoid refueling charges, which may be billed at as much as $5 per gallon or more. Cars should be returned on time to avoid additional hourly charges. 

Allowance for Personal Auto

The use of a personal car for GBH business will be reimbursed at the federal reimbursement rate per mile for the most direct route to and from the business destination. Federal reimbursement rate is issued by the IRS every year and will be updated every year. Independent contractors on GBH projects must keep track of the origin and destination of the trip and total number of miles driven. Costs incurred for parking and tolls are reimbursable and receipts should be submitted for all auto expenses.

Unacceptable transportation expenses include:

• Car repairs
• Rental car costs during repair of personal car
• Tickets, fines, or traffic violations incurred while driving a car for business purposes or for commuting to work

Local Public Transportation

Business travel expenses for bus, MBTA, train, or taxis within the local area are reimbursable Travelers should note the origination and destination of each portion of the trip.

Taxi Service

Taxi fares paid out of pocket are acceptable and receipts should be retained. Taxis are not authorized for routine commuting to and/or from work.

Car Services

Car services are more expensive than taxis and should not be used.  Use of car services should be limited to talent/VIP purposes only and requires pre-approval by GBH.

Uber and other services will be reimbursed and should only be used for business purposes.  Reimbursement requires written explanation for the business purpose of the Uber trip.

MEALS (INDIVIDUAL)

 Individual

Individual meals are defined as food or beverage consumed on-site or off-site by one independent contractor while on GBH business. Meals also include food items consumed during a hotel stay.

Expense Limits

Independent contractors working on GBH projects will be reimbursed for personal meal expenses by providing original detailed receipts. Meal expenses per day, including tax and gratuity should not exceed $75. (For New York, San Francisco, and Los Angeles an additional $20 per day is reimbursable.)

The individual daily meal allowance (including snacks and non-alcoholic refreshments) is not to exceed the daily spending limit of $75.  If meals are provided as part of a conference, event, or meeting, there will be no additional reimbursement for the meal. The daily spending limit will be reduced by the following amounts- breakfast $15, lunch $20, dinner $40 - for these meals provided to the traveler.  Independent contractors working on GBH projects must submit itemized receipts for all meals for which they are expecting reimbursement. Individuals performing work for projects funded by federal grants should refer to the Appendix for additional restrictions.

Receipt Requirements

Receipts are required for individual meals.

 GROUP MEALS/MEETINGS

Group

Group meals are food and beverages consumed on- or off-site by more than one person.

Receipt Requirements

Itemized receipts are required for all group meals. In order to be reimbursed for all meal expenses (including business lunches and dinners), the following information must be included with your receipt:

• Names and titles of attendees
• Date and place
• Nature of the business taking place

For audit purposes, the meeting agenda (or summary of business discussed) also should be attached.

TELECOMMUNICATIONS

BusinessPhoneCalls

The Foundation will reimburse independent contractors working on GBH projects for reasonable business phone calls, while traveling. Hotel bills, telephone bills, or other documentation detailing names and companies are required for phone call reimbursement.

 APPENDIX:  ADDITIONAL GUIDELINES FOR TRAVEL AND BUSINESS EXPENSES WHEN WORKING ON PROJECTS FUNDED BY FEDERAL GRANTS

Independent contractors charging expenses to projects funded by federal grants should be cognizant of the special requirements and limitations related to expenses charged to federal grants.  These policies are in addition to the GBH travel and expense policies and expenses need to be in compliance with both policies.

1. All expense reports are subject to review by the Compliance Manager before being submitted for processing.
2. The independent contractor submitting the expense report and the Supervisor/Manager approving the expense report are responsible for ensuring each expense is allowable under the terms of the grant, and 2 CFR, Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance). 2 CFR, Part 200 sets forth standards for obtaining consistence and uniformity among Federal agencies in the administration of grants to agreements with the institutions of higher education, hospitals, and other non-profit   2 CFR, Part 200, Appendix IV establishes principles of determining costs of grants, contracts and other agreements with non-profit organizations.
3. Every expense item must be supported by a detailed receipt, regardless of A credit card statement is not an acceptable form of receipt.
4. GBH will not reimburse an independent contractor for expenses associated with the purchase of alcoholic beverages, gifts or contributions, donations and entertainment charged to federal To provide positive proof that meal reimbursements do not include charges for alcohol, detailed receipts with proof of payment (listing of items included in the total) must be submitted for reimbursement of meal expenses.
5. The Uniform Guidance discourages grant recipients (GBH) from purchasing unnecessary items and incurring meal expenses when not traveling on grant related business, with federal grant Local lunches, and dinners that are not deemed necessary will not be reimbursed.  Additionally, entertainment costs such as the cost of amusement, diversion, social activities (including “wrap parties” or other project completion celebratory events), ceremonials, and costs relating thereto, such as meals, lodging, rentals, transportation and gratuities are unallowable.
6. Expenses for gifts may not be charged to federal