Business Meals

I. Scope

This policy applies to all University employees who participate in business meals and/or entertainment on behalf of William & Mary.

II. Purpose

This policy provides guidance for business meals and entertainment expenses. It is intended to comply with the Internal Revenue Service (IRS) regulations and Internal Revenue Code (IRC) definition of an
"Accountable Plan" and University policies and procedures.

III. Definitions

• Business Meals and Entertainment: Entertainment includes any activity generally considered to provide entertainment, amusement, or recreation. Entertainment may include the cost of a meal provided to a customer or donor, whether the meal is a part of other entertainment or by itself. A meal expense generally includes the cost of food, beverages, taxes, and reasonable tips for the meal.
• Ordinary Expense: An ordinary expense is one that is common and accepted in University business.
• Necessary Expense: A necessary expense is one that is helpful and appropriate for University business.
• Bonafide Business Purpose: Generally, an expense is associated with the active conduct of business if a clear business purpose for the expense can be documented. The purpose may be to generate new business or to encourage the continuation of an existing business relationship.
• De Minimis: A de minimis benefit is any property or service you provide that has so little value that accounting for it would be unreasonable or administratively impracticable. Cash and cash equivalent fringe benefits (for example, use of gift card, charge card, or credit card), no matter how little, are never excludable as a de minimis benefit.
• Reasonable Period of Time: The definition of reasonable period of time depends on the facts and
  circumstances of your situation. However, regardless of the facts and circumstances of your situation, actions that take place within the times specified in the following list will be treated as taking place within a reasonable period of time.

IV. Policy

Generally, meal expenses must involve an overnight stay to qualify for reimbursement. In these instances, the traveler must adhere to the travel regulations outlined earlier for meal reimbursement. Individuals who are not in a travel status are eligible for meal reimbursement if they participate in a business meal. Individuals in travel status may occasionally attend meals that qualify as business meals. Departments must use Chrome River for business meal expenses incurred during travel and non-travel status.

Such meals occur while the individual is on official business and must:

• Include Agency Head or Designee approval. Department approvals will be routed in Chrome River based on the designated Chrome River approver of the allocation and overage exceptions.
• Involve substantive and bona fide business discussions and include the original, itemized receipt.
• List by name all the people involved in the meal and affiliations (up to 10 persons) and the reason for the meal. For a group of more than 10 people, a description of the group/attendees is required. If the reimbursement is for a group of conference participants, identify the number of people fed and an explanation of additional meals, if necessary (example: Coverage of walk-ins).
• Be reimbursed for actual expenses up to the amount shown for the applicable meal in the M&IE Rate Table, excluding the incidental allowance.
• For the individuals in travel status, the per diem allowance applicable to the business meal must be clearly excluded from the daily reimbursement.
• Delivery costs and a reasonable tip (up to 20%) are reimbursable if the total cost does not exceed the allowable per diem for the meal.

For an employee to receive reimbursement for a business meal, there must be two or more attendees on the business meal form. All business meal receipts must be for two meals or more. If an employee attends a meeting whereas each person is paying for his or her own lunch, it is not considered a business meal and it is not reimbursable under the guidelines for State Funds.

If the business meal falls under Grant funding, which restricts employees from being reimbursed for business meals (allows only guest meals to be reimbursed), a statement from OSP specific to the employee's reimbursement voucher must be provided which states the grant does not allow business meal reimbursement for employees. If the business meal falls under non-grant funding, but the department only wants to reimburse the guest's meal and not the employee's meal, the reimbursement will be processed only if an original, detailed receipt showing two meals, or more, is provided.

Business Meal Exceptions

Business meals that exceed the meal allowance rate require an approved justification statement for up to 150% of the meal allowance and are allowable expenses to charge to State Funds. Meals that exceed 150% of the allowance up to 200% of the standard rate with Dean or VP approval are allowable with William & Mary Local Funds.

Appropriate Food and Beverage Functions

The functions or events at which it is considered appropriate for food and beverages to be served to university personnel are listed below as 5 allowable business meal types:

1. Business Meals Involving External Parties: Business meals involving external parties refer to dining occasions in which individuals or groups from the university and external participants come together for the purpose of discussing and conducting business-related matters.
2. Internal Training and Related Business Functions:
   1. Internal Training: Internal training refers to the process of providing education, skill development, and learning opportunities to employees within an organization. This type of training is conducted by the organization itself and is designed to enhance the knowledge, capabilities, and performance of its workforce. Internal training programs can cover a wide range of topics, including job-specific skills, compliance with company policies and procedures, leadership development, or communication and teamwork.
   2. Retreats: Employee retreats refer to organized on-site/off-site gatherings or events arranged by a department for their employees. These retreats are designed to provide a break from the usual work environment and routine, offering participants a chance to engage in team-building activities, professional development, and bonding. These retreats may involve workshops, seminars, recreational activities, and discussions aimed at improving teamwork, communication, morale, and overall job satisfaction among employees. To optimize cost-effectiveness, it is encouraged that retreats take place at properties either owned or leased by William & Mary. However, retreats held at off-campus locations require advance written approval in the form of a Travel Authorization from an authorized approver.
3. Events with Students: Events with students primarily serve as opportunities to enhance their educational and social experiences. These gatherings, often organized by the departments or student associations, aim to foster a sense of community and engagement among students. The primary purpose of such events is to provide a platform where students can interact with their peers, faculty, and staff outside of the traditional classroom setting. These events can take various forms, including academic conferences, workshops, cultural festivals, and extracurricular activities.
4. Employee Retirement and Appreciation Events:
   1. Retirement Events: Retirement events are gatherings or celebrations held to mark the end of an individual's working career and their transition into retirement. These events are typically organized to honor and recognize the retiree's contributions, accomplishments, and years of service in their profession or occupation.
   2. Appreciation Events: Appreciation events for employees are special occasions organized by a department or university to express gratitude and recognition for the contributions, hard work, and dedication of their staff members. These events are designed to acknowledge employees' efforts and accomplishments, boosting morale, motivation, and a positive work environment. These events are typical for group appreciation NOT individual employee recognition or appreciation. 
5. Meals, Food or Beverages for One University Employee: Allowed if the employee is meeting with a non-employee who is covering his or her own meal expenses. The expense must be approved by the responsible Dean or Vice President and must be handled on a reimbursement basis.   his expense is allowable under Local Funds only. These expenses are prohibited on the University Small Purchase Charge Card (SPCC).

Unallowable Expenses

Activities that are excluded and not allowable under the Business Meal Policy:

• Lunches for deans and department heads
• Regularly scheduled meetings for university employees
• Faculty and/or staff department meetings
• Group Planning meetings
• Round Table discussions
• General discussion meetings between faculty and staff
• Mentor/Mentee meetings between faculty and staff
• A one-on-one appreciation meal
• A new employee meal
• A farewell gathering for an employee that is NOT retiring (an employee departing from the university)
• Employee monthly birthdays, weddings, and work anniversaries

Alcohol

Any expenses for alcohol including tax and tip during a business meal will NOT be paid from State funds. Alcoholic beverages up to $30 per person, including tax and tip are allowable with University Local Funds. Food must be included in the business meal for reimbursement. The alcohol is not part of the per diem cap and it must be excluded from the per diem rates.  Request for alcohol only payments are disallowed.

Spouses and Children

Spouses and children of a business meal participants may attend a business meal, but their portion of the expense will NOT be reimbursed from State Funds. Only meal expenses for job candidates' spouses are allowable under the same rules as business meal exceptions with university local funds.

On-Campus Catering

America to Go (ATG) is a web-based, managed catering platform for local food ordering. ATG is required to be used for all William & Mary on-campus food (pick-up order delivery) or catering orders. ATG Ordering Portal: catering.wm.edu

Funding Policy

A three-column table for organizational purposes.

Description	State Policy	University Local Funds
Business Meals (e.g. Meals with external parties, internal training and student events)	Up to 150% maximum of per diem amount	Excess of 150% up to 200% of standard rate with Dean or VP approval
Expenses for Candidates’ Spouses	Not Allowable	Up to 200% of standard rate with Dean or VP Approval
Employee Appreciation Events	Not Allowable	Up to 200% of standard rate with Dean or VP approval
University Employee Meal with Non-Employee Covering His/her Own Expenses	Not Allowable	Up to standard per diem rate and alcohol rate (if applicable) with receipt and with Dean or VP approval; may not be charged directly to SPCC

VI. Approval and Amendment

This policy was created by the Office of Financial Operations and may be amended or terminated by the Chief Operating Officer.

Questions about the implementation of this policy or its interpretation should be directed to the Chief Financial Officer.