Integrated California State University Administrative Manual (ICSUAM) §1301.00; California Education Code §89044, §66600, §89030, and §89035. This policy is issued under delegation of authority from the Chancellor to the Executive Vice Chancellor and Chief Financial Officer, and implementation and compliance with the policy is further delegated to the campus Chief Financial Officer.
The objective of this practice directive is to comply with ICSUAM §1301.00 and to ensure financial, procedural and operational responsibility and accountability for hospitality paid for with San Francisco State University (the University) funds.
300 Practice Directive Statement
501 Approving Authority
502 Auxiliary Organization Funds
Funds controlled by the CSU’s auxiliary organizations including, sponsored programs or grants, donor funds, and endowment funds subject to any restrictions based on the fund agreements. CSU auxiliary organizations are separate legal entities authorized in the Education Code to provide essential services to students and employees. Auxiliary organizations operate in association with campuses pursuant to special written agreements, and are authorized to perform specific functions that contribute to the educational mission of the campus. Auxiliary organizations are separate 501(c)(3) corporations established for the benefit of the university they support. These organizations are subject to applicable state and federal laws and regulations. In addition, they operate within the policies established by the CSU Board of Trustees, the Chancellor, and the campuses. The auxiliary organizations are self-supporting and therefore, do not receive funding from General Fund sources.
503 Employee Meetings
504 Employee Recognition
506 Membership in Social Organizations
507 Official Host
508 Official Guest
509 Private Purpose Trust and Agency Funds
510 Public Purpose (or business purpose)
511 Sponsored Program Administration Funds
512 State Funds
513 Student Organizations
514 Work Location
- The main campus
- Estuary & Ocean Science Center (Romberg Tiburon Center)
- The downtown campus
- Sierra Nevada field campus
600 Practice Directive
601 Hospitality Expenditures
- the importance of the event in terms of the costs that will be incurred;
- the benefits to be derived from such an expense;
- the availability of funds; and
- any alternatives that would be equally effective in accomplishing the desired objectives.
- The University hosts or sponsors business meetings that directly correlate with the operations of the University;
- The University hosts official guests with an interest in the University;
- The University is the host or sponsor of a meeting of a learned society or professional organization;
- The University hosts receptions held in connection with conferences, meetings of a learned society or professional organization, meetings of student organizations and groups, student events such as commencement exercises, and events or meetings of other University-related groups such as alumni associations;
- The University hosts or participates in community relations or fundraising events to promote the University, enhance partnerships, recognize distinguished service, or cultivate donors;
- The University hosts receptions for the benefit of employee morale, employee recognition, official presentations for length or exceptional contributions of service awards, with at least 5 years of service are permissible.
- Occur infrequently (12 times or less per calendar year);
- Are reasonable (see Appendix A – Maximum Rates for Hospitality); and
- Are appropriate to the business purpose.
Meals or light refreshments provided to employees on a frequent or routine basis are considered taxable income by the IRS and are therefore not permitted under this practice directive. When a meeting takes place over an extended period and the agenda includes a working meal, there may be justification that the meal is integral to the business function.
Meals for employees from the same work location
Meals taken with individual colleagues from the same work location generally may not be reimbursed by the University unless the business purpose of the meal could not be conducted during working hours or the meal is part of an employee meeting as described in §601.1. On an exceptional basis, these meals may be reimbursed. Exceptions must be approved by the official host’s Vice President or in the case of a Vice President serving as host, must be approved by the President.
- Employee recognition;
- Length of service; and
- Retirement awards.
- State funds may not be used for expenditures associated with
- Sympathy gifts;
- Get well gifts;
- Birthday, wedding, anniversary, and baby showers.
Reasonable gifts made on behalf of the University to non-employees and outside organizations are allowed when the gift benefits the University, is in furtherance of a University business purpose, and is clearly necessary to the University fulfillment of its mission.
The business reason for making the gift or the nature of the business benefit the University derives or expects to derive must be documented in writing. In most cases, the promotion of goodwill in the University community is an acceptable business purpose. The cost of such gifts must be reasonable in relation to the actual or expected benefits.
Example of individuals and organizations that may be presented an award or gift on behalf of the University include: a visiting dignitary or scholar, a donor or potential donor, a civic or cultural organization or a member of the local community.
Awards and gifts to non-employees exceeding $200 must be approved by the Vice President for the associated department or by the President when a Vice President gives or directs the giving or an award or gift.
State funds may not be used to pay for gifts to non-employees unless the gift is justified by a University business purpose.
- Annual faculty/staff picnics; and
- Holiday gatherings
602 Prohibited Expenditures
Hospitality expenses that are of a personal nature and not related to the active conduct of official CSU business will not be paid or reimbursed. The California gift of public funds doctrine set forth in the California Constitution, article XVI §6, prohibits the giving or lending of public funds to any person or entity, public or private, unless there is a public purpose. Examples include, but are not limited to employee birthdays, weddings, anniversaries, and baby showers.
603 Event Location
700 Funding Sources
701 State Funds
- • Pay for food and beverages or entertainment services that do not serve a business purpose;
- • Pay for alcoholic beverages, memberships in social organizations, or tobacco products; and
- To pay for awards and prizes to employees for exceptional contributions, to students for excellence, and individuals to participate in a research funded survey or study; and
- For employee recognition, and official presentations for length of service awards or exceptional contributions, with at least 5 years of service.
- To pay for official employee morale-building and appreciation activities that serve a business purpose.
702 Auxiliary Organization Funds
703 Sponsored Programs Administration Funds
704 Private-Purpose Trust and Agency Funds
801 Authorized Rates
802 Authorization of Hospitality Expenses
803 Community Relations and Funding Raising Requirements
804 Recreational, Sporting, and Entertainment Events
805 Expenses for Spouses, Domestic Partners or Significant Others of an Employee Requirements
806 Payment and Reimbursement Procedures
Official host’s name and department (official host and approver may not be the same person)
Type of activity (e.g. reception, meeting, fund raising event, community relations activity)
Date(s) of activity or event (only one activity or event per form)
Location of activity or event (must be an established business location)
Purpose of activity or event – explain why event is necessary; what the public (or business) purpose of the event is; how the event contributes to achieving the University’s mission.
For fundraising and community relations events, the description must include what the direct or indirect benefit from the expense is to be derived.
Participants – For small activities or events, less 25 participants, provide a list of attendees, their relationship with the University; for established campus groups (e.g. Council of Deans, Boards of Directors) and for large groups (25 or more participants), a list of attendees is not required but the a descriptive title of the participant groups is required.
Type and amount of expenses; describe what was purchased, how much it cost and the total amount the reimbursement/payment requested.
Chartfield (i.e. funding source(s)) to be charged for the expenses; for hospitality, the following PROGRAM CODES must be recorded:
|Type of Hospitality||Program Code|
|Awards to non-employees||2050|
|Awards to employees||2060|
|Awards to students (new)||2065|
Certification from the official host that the expenses were incurred for a University business purpose
Approval signature from the Official Host’s Appropriate Administrator (MPP) or more senior administrator, if the Official Host’s appropriate administrator is not available.
If necessary, approval from the individual with delegated fiscal authority to authorize payments from the funding source(s)
If any of the hospitality expenses are exceptions to this practice directive, the form must be signed by the Official Host’s Vice President (or President if the Vice President is the Official Host).
807 Supporting Documentation and Receipts
Requests for payment and reimbursement must be supported by original, itemized receipts or acceptable electronic receipts. Credit card receipts are not acceptable. The level of detail contained in electronic receipts must be equivalent to that contained in paper receipts. Reimbursement or payment requests submitted without adequate supporting documentation may be returned to the preparer for additional documentation. A Vice President must approve requests without adequate, supporting documentation.
808 Contracts for Hospitality Products and Services
Must be processed through Procurement Services before the event via the purchase requisition process. The Hospitality Form should be attached to the requisition when it is submitted to Procurement Services.
809 Payments for Hospitality
Payments for hospitality will be mailed or electronic fund transferred to the payee of the claim by Fiscal Affairs. Official hosts, prepares and approvers of the Hospitality form may not deliver the payment to the payee.
810 Hospitality While on Travel Status
The CSU Travel Policy and the Hospitality Policy are separate and distinct policies. Hospitality expenses incurred while on travel status must comply with this practice directive. Hospitality expenses should be recorded as a Business Expense on the Travel Expense Reimbursement form and the Hospitality form attached with the travel claim.
Note: For hospitality expenses incurred while on travel status, original receipts must be attached – regardless of the amount. The $75.00 minimum for travel expenses does not apply to hospitality expenses.
811 Responsible Parties
811.1 President and Vice Presidents
- Must approve any exceptions to this practice directive
811.2 Associate Vice President, Fiscal Affairs
- Must ensure maximum rates for hospitality remain reasonable and are approved by the Vice President for Administration & Finance;
- Must ensure campus is provided with procedures to comply with the practice directive
811.3 Employees with Delegated Fiscal Authority
- Must ensure hospitality expenses submitted for reimbursement and payment comply with this practice directive including ensuring appropriate supporting documentation is attached to the reimbursement or payment form.
- Must ensure hospitality is restricted to allowable expenses and occasions that Official Hosts comply with this practice directive
- Must approve that hospitality expenses are appropriate for the funding source(s) to which they are being charged
811.4 Accounts Payable, Fiscal Affairs
- Must ensure that payments and reimbursements for hospitality comply with this practice directive before any disbursement is made
- Must ensure supporting documentation is adequate and appropriate to support hospitality payments and reimbursements
- Must make payments and reimbursement in a timely manner once the hospitality expenses have been determined to comply with this practice directive
Exceptions to this policy must be approved by the Official Host’s appropriate Vice President (or the President in cases where a Vice President is the Official Host). The exception must be noted and a justification provided for the exception. For meals and light refreshment that exceed the maximum limits, the justification must include a specific reason why the higher costs were reasonable to achieve the University business purpose.
900 Record Retention
Manual and electronic records related to disbursements must comply with the CSU’s record retention policies unless the University Controller determines records should be retained longer.
Hospitality, employee morale
APPENDIX A - 1
The table below presents the maximum per person expenditures for individuals entertained by the University, including University employees. Hosts are encouraged to identify the most cost efficient method of providing hospitality.
|Type of Hospitality (1)||Maximum Rate (2)|
(1) For buffet-type receptions or meals, the maximum expense cannot exceed the maximum rate for the type of buffet (e.g. breakfast, lunch, dinner)
(2) The maximum rate is inclusive of tax and service (e.g. tax, tips, and service fees)
APPENDIX A – 2
The maximum, individual award to an employee for recognition of extraordinary work contributions, length of service, or retirement recognition is $200.
FREQUENTLY ASKED QUESTIONS
(Questions/Answers 1 – 14 were provided by the CSU Chancellor’s Office; Questions 14 and above were added by SFSU Fiscal Affairs/Accounts Payable)
Q1. What constitutes a gift of “public funds?”
The California gift of public funds doctrine set forth in the California Constitution, Article XVI, §6, prohibits the giving or lending of public funds to any person or entity, public or private. “In determining whether an appropriation of state funds or property is to be considered a gift, the primary question is whether the funds are to be used for a “public” or “private” purpose. If they are for a “public purpose”, they are not a gift within the meaning of [§6 of art. XVI]. If an expenditure serves a primary public purpose, it is not a gift even if it incidentally benefits an individual.
Q2. Can I give awards to CSU employees or students?
An employee can be recognized for superior accomplishments, within specified campus guidelines. Life transition events like birthdays, weddings, and the like, occur to everyone so cannot be considered superior accomplishments. Awards are permitted within the campus defined monetary limits and subject to IRS reporting requirements. Awards may be given to recognize years of service at the time of retirement, but the statutory authority to make awards does not authorize paying for a “retirement party”.
Q3. Can I send gifts or flowers with state funds?
Typically, no. Gifts or flowers are not permissible when there is solely a personal benefit. There may be justification if the intended business purposes complies with campus, CSU, IRS andGovernment Code restrictions.
Q4. What CSU funds are included in state funds?
State University Trust fund (state fund 0948) is continuously appropriated by the legislature (EC §89700-89726) and therefore all CSU funds within state fund 0948 are state [public] funds. This includes, but is not limited to, State University Parking Revenue Fund (EC §89701(b)), State University [Health] Facilities Revenue Fund (Education Code §89702(c)), State University Continuing Education Revenue Fund (Education Code §89704(a)), CSU Dormitory Revenue Fund (Education Code §90036) and Lottery (Government Code 8880.5).
Q5. I would like to meet with my colleague over lunch to discuss a business topic, can I be reimbursed?
Typically no. Reimbursement for meals are not permissible when there is solely a personal benefit. In general, business meeting with individual colleagues is not permitted. There may be justification if the business purposes for such an expense complies with campus; CSU, IRS and Government Code restrictions then it could be allowed.
Q6. Can I provide lunch for an all-day meeting?
When a meeting takes place over an extended period and the agenda includes a working meal, there may be justification that the meal is integral to the business function. Considerations include:
- Meals or light refreshments provided to employees on a frequent or routine basis are considered taxable income by the IRS and are therefore not permitted under this policy.
- Meals or light refreshments should be limited to no more than twelve times per year, per group.
- Meals or light refreshments provided to a group should be counted on an event basis (e.g. a two-day meeting should be counted as one event in determining compliance with these guidelines).
Examples where food and beverage may be permitted include:
- A meeting where there is a scheduled speaker during the meal period;
- A meeting where the participants work through the meal period; or
- Circumstances where it would be too time-consuming or disruptive for participants to take a meal break away from the meeting location.
Q7. Can I use state funds to have a retirement party?
No, parties are not allowed. An employee can be recognized for superior accomplishments, within specified campus guidelines.
Q8. For employee morale purposes, I would like to use state funds to provide a departmental welcome breakfast each time we bring in a new employee. Is this permitted?
Typically no. Employee meetings that are carried out on a regular or frequent basis are not permitted under this policy. Additionally, public expenditures that are driven solely by personal motives are an impermissible use of state funds. However, if the business purposes for such an expense complies with campus, CSU, IRS and Government Code restrictions then it could be allowed.
Q9. What activities may be permissible with state funds when it is determined that there is a business purpose for the expenditure?
- Awards to students to participate in a non-researched (grant) funded survey. (Subject to IRS tax laws)
- Incentives to anyone, including employees, to participate in a research funded survey or study, within the terms of the grant and the grant serves an instructional purpose. (Subject to IRS tax laws)
- Awards and recognition to students
- Decorations purchased as part of a ceremony at a public event.
- Expense related to Fundraising in support of providing a better student experience.
Q10. What activities would not be permissible without a business purpose?
- Gift card, gift basket, flowers or other non-cash gift as a thank you to consultants, guest speakers, or employees at another campus;
- Gifts for employee birthdays, weddings, anniversaries, baby showers, etc.;
- Farewell gatherings and retirement parties; and
- Bereavement or sympathy gifts.
Q11. How is “infrequent” defined?
Infrequent is defined by the IRS as no more than 12 times per year per group.
Q12. How do you define reasonable and appropriate?
This should be documented in the campus procedures.
Q13. Some departments provide logo apparel to their employees and require them to wear the shirts during business hours (e.g. orientation). Is this a gift?
No this would not be considered a gift, if it supports a business purpose.
Q14. The college has a standard (monthly) lunch meeting with outside industry advisors to discuss course development and research collaboration of their college. Can state fund be use for this type of event?
Meals or light refreshments may be permitted if the expenses occur infrequently, are reasonable and appropriate to the business purpose in accordance with campus policy.
Q15. Our department celebrates employee birthdays on a quarterly basis. Can state funds be used to pay for any part of this celebration?
Q16. Our department is located on a floor in our building that has a small, employee kitchen. Can state funds be used to furnish or to supply the kitchen?
State funds may only be used for basic cleaning supplies to keep the kitchen clean and sanitary outside of the normal maintenance and cleaning performed by University Housekeeping. Examples include dishwashing detergent, sponges, hand soap. However these items are not hospitality.
State funds may not be used for any type of food item or other food-related item (e.g. plates, cups, glasses, napkins, cutlery, serving dishes).
Q17. Our department would like to honor our student assistants for their work at the end of the year. Can state funds be used for this?
Yes. Employee recognition events may be paid for with state funds. However, awards should only be made to employees who make extraordinary work contributions to the University.
Q18. Our department would like to boost the morale of our student assistants by providing a light meal and giving them $5 gift cards. Can state funds be used for this?
Yes, employee-morale building events, with a documented business purpose, may be paid for with state funds. Employee-morale building events must be approved by a Vice President. However, awards, such as the $5 gift cards, should only be made to employees who make extraordinary work contributions to the University.
Q19. My dean would like to recognize the outstanding contributions of a few faculty members by presenting them with gift cards. Can state funds be used for this?
Yes, if the award is justified by the faculty members’ outstanding contributions. The maximum award amount is $200 and is reportable and taxable.
Q20. My dean would like to recognize the outstanding contributions of all faculty and staff by presenting them with gift cards. Can state funds be used for this?
No. An award to an employee must be for extraordinary work contributions made by that employee. Offering an award to large number of employees is not consistent with the term “extraordinary.”
Q21. My college hosts an annual retreat. Can state funds be used for expenses related to the retreat?
Yes, if the retreat has a business purpose with a predetermined agenda. Expenses must comply with this practice directive.
Q22. My college (or department) hosts a meeting at the beginning of each semester. Can state funds be used to provide light refreshments at these meetings?
Yes, if the meetings have a business purpose with a predetermined agenda.
Q23. My program will be tabling on behalf of the University at an off-campus event. We would like to offer promotional items that promote the mission of our program. Can state funds be used to purchase these promotional items?
Yes. If a University business purpose is being achieved, state funds may be used to purchase these items. Promotional items bearing the University’s logo must be approved by University Advancement.
Informational and educational items, related to a University program, such as brochures, illustrative guides, etc. are deemed programmatic and are not subject to the requirements of this practice directive.
Q24. My department would like to collect money from our employees to send flowers to an employee who is in the hospital. Is this allowed?
This practice is not governed by this practice directive.
Q25. My department chair would like to reward several students for their outstanding academic performance by paying them a stipend. Is this hospitality? If so, can state funds be used?
This is an award – not a stipend. This is hospitality and state funds can be used for this expense. The award should be either a tangible item or a gift card; cash awards are not allowed.
Q26. We will be providing participating students with a stipend in our program. Our program helps prepare students to apply for graduate programs. Is this hospitality? If so, can state funds be used?
No, this is not hospitality. States funds may be used for this.
Q27. I will be traveling to conduct interviews for an open position in my department. I will be paying for each candidate’s dinner as part of the interview. Is this a hospitality or travel expense? Can state funds be used for this?
The meals are subject to this practice directive and should be listed as a business expense and a hospitality form must be attached to your travel expense claim.
State funds can be used to pay for the meals (with the exception of alcoholic beverages). Maximum limits apply (e.g. $50 for dinner).
Q28. A Pulitzer Prize-winning author has agreed to give a lecture and conduct a workshop for my writing class. She is not charging the University anything for this or seeking reimbursement for any related costs such as travel. I would like to acknowledge her generosity and thank her with a small gift basket from a local gift shop. The gift basket costs $25. Can state funds be used for this?
Yes, while gifts are not typically allowed to be purchased with state funds, these circumstances indicate a clear business purpose and public benefit for this reasonable gift.
Q29. Our department would like to send flowers to an employee whose spouse recently died. Can state funds be used for this?
No. State funds may not be used for sympathy gifts.
Q30. Can state funds be used to purchase alcoholic beverages for a fundraising event?
No. State funds may not be used to purchase alcoholic beverages.
Q31. An alum from our college just won a prestigious award in her discipline. Can state funds be used to send congratulatory flowers?
No. State funds may not be used for gifts.
Q32. I am contemplating providing hospitality that does not comply with this policy. I am afraid I will not achieve an important business purpose if I don’t provide this hospitality. What are my options?
Exceptions to this practice directive may be approved by your Vice President. It is suggested you obtain this approval prior to incurring any costs.
Q33. Are Trust Funds considered state funds?
Yes. Trust funds agreements may impose stricter hospitality rules (and not allow hospitality) but an agreement cannot be less restrictive than this practice directive.
Q34. Can state funds be used to purchase coffee, tea, sugar, candy, bottled and snack items for my Vice President’s (Dean’s) Office?
Generally, no. Exceptions to the practice directive should follow §812.
Q35. Can state funds be used to purchase plates, cups, napkins, cutlery, etc. for an event where a meal and light refreshments are served?
If the event is for a University business purpose and complies with this practice directive, state funds may be used to purchase these items. Bulk purchases of large quantities of these items must be monitored to ensure left over items are used appropriately.