These policies are not expected to cover every possible situation. Items of an unusual nature should be
discussed with members of the Accounts Payable Department and/or Research and Sponsored
Programs Accounting before the submission of expenses. Officers, Vice Presidents and/or Deans can
make exceptions to this policy document in the event of extenuating circumstances; however, even if
approved, these exceptions may result in a taxable reimbursement. Written explanation and approval,
as needed, must be included with the request for reimbursement in exception situations.
Notre Dame’s Travel, Entertainment, and Business Expense Policy satisfies the Internal Revenue
Service definition of an “accountable plan.” Expense reimbursements that meet the accountable plan
rules are not reported as income to the traveler. Under Internal Revenue Service accountable plan
rules, travel advances and reimbursement of expenses must meet three requirements:
•
Expenses reimbursed must be business-related. Further travel advances must be
reasonably related to the cash business expenses expected to be incurred.
•
Employees must submit a Travel and Expense Report via travelND to an approver
substantiating amount, time, and business purpose within a reasonable time (within 60 days)
after the expenses are incurred. Travel and Expense Reports submitted after this
60 day
1
time frame will not qualify for accountable plan treatment.
2
•
Employees must return any advance amounts in excess of substantiated expenses no later
than when the related Travel and Expense Report is submitted (within 60 days).
All business and travel expenses must have a business purpose, which should clearly and without need
for interpretation explain how the business expense is connected to the university and supports its
mission. The submitter should include sufficient documentation to support the business purpose and
alignment to the purpose of the funds, such as agendas or travel itineraries, and demonstrate that the
expense was reasonable based on circumstances. The business purpose should be written so that a
detached party (e.g., outside auditor) could easily understand the business connection.
If an employee does not substantiate expenses and/or clear advances within 60 days, these
amounts will be treated as compensation, subject to required payroll tax withholding, and reported on
the employee’s Form W-2. Even in situations where the submitter is awaiting funding information or
FOAPAL assignment, substantiation of expenses must be within 60 days to qualify for accountable
plan treatment. Those in such a situation may temporarily charge a general departmental account
and later reclassify the charge via an accounting journal entry after receiving funding information or
FOAPAL assignment. Those awaiting information on grant funding, should also see the Pre-Award
Spending/Advance Account Guidelines issued by the Office of Research
.
In order for business expense reimbursements to be authorized and those eligible for tax-free
reimbursement to remain tax-free to the employee, the policies that follow must be adhered to.
1
The 60-day requirement is from the latter of the date paid or incurred. Prepaid business trip expenses will
be considered incurred during the trip and thus the 60 days calculated from the last date of the trip.
2
Due to general unfamiliarity with this Accountable Plan requirement, each employee is offered a one-time
exception to the 60-day requirement. To make use of this one-time exception, contact Accounts Payable at
acctpay@nd.edu
.