Hospitality Expenses

Policy Objective

Hospitality expenses may be paid to the extent that such expenses are necessary, appropriate to the occasion, reasonable in amount and serve a purpose consistent with the mission and fiduciary responsibilities of the university. This policy applies to activities that promote the university to the public and the provision of hospitality in connection with official university business and specifies the sources of funds that may be used for such purposes.

Policy Statement

100 Purpose

This policy governs the manner and extent to which the university and its auxiliaries may provide hospitality to students, employees, donors, guests, visitors, volunteers, and other individuals as part of a business meeting; recreational, sporting or entertainment event; or other occasion that promotes the mission of the university. The policy also addresses meals served to employees and meals provided to prospective students and employees.  The university receives the bulk of its funding from state appropriations and student fees.  Regardless of the source, the university and its employees have an obligation to practice conscious and wise stewardship of these limited resources.

200 Scope

This policy governs the appropriate use of the operating fund, self-support student fee funds, and private support funds, unless legally exempted or otherwise restricted; e.g. documented trust agreements. The university and its auxiliaries will comply with additional restrictions when established by funding sources.

300 Authority

ICSUAM 1301.00 Hospitality,  effective September 14, 2018 states that “Each campus and its auxiliaries are required to develop written procedures, consistent with this policy, regarding the payment of ordinary and necessary hospitality expenses”. In addition to ICSUAM 1301.00, authority for this policy is pursuant to California Education Code section 89044. 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. California Education Code sections 66600, 89030, and 89035.

400 Definitions

401 Approving Authority
A person to whom authority has been delegated in writing to approve expenses via the Delegation of Expenditure Authority form, Trust Fund Agreement, or financial services approved equivalent.

402 Awards and Prizes
Something of value given or bestowed upon an individual, group or entity e.g. financial prizes, trophies, or plaques for recognition of an achievement benefiting the university.

Cash and cash equivalent items, such as gift cards and gift certificates, given to employees are not permitted with the exception of Wolfbucks, limits apply. 

403 Employee-Only Meetings and Events
Meetings which serve a university business purpose and are generally administrative in nature such campus meetings of deans and directors, employee morale functions, extended formal training sessions, conferences, extended strategic planning sessions, professional development and meetings of workgroups and committees. 

404 Entertainment Services
Expenditures incurred in connection with events or activities that are primarily social or recreational such as equipment and venue rental, decor, music, and performers. Service expenditures related to showcasing the talent of students or employees are considered a regular business expense and are not governed by this policy.  Expenditures incurred in connection with events or activities attending in a business capacity, i.e. an Artistic Director attending a performance of a prospective artist, are considered a business expense and not subject to this policy.

405 Fund-raising Event
Events conducted for the primary purpose of raising charitable funds where participants make a charitable contribution and a purchase for the fair market value of goods or services.

406 Gift
Something given in appreciation and for no value in exchange. 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 or entity.

407 Hospitality
The reasonable provision of meals (catered or restaurant) or light refreshments (beverages, hors d’oeuvres, pastries, cookies), entertainment services, promotional items, service recognition, awards, and prizes. Hospitality includes expenses for activities that promote the university to the public, with the expectation of benefits accruing directly or indirectly to the university.

408 Membership in Social Organizations
University clubs, athletic clubs, civic organizations and other membership organizations that provide a venue for hosting hospitality events or a means for promoting goodwill in the community. Memberships in business leagues, chambers of commerce, trade associations and professional organizations are considered a regular business expense and are not governed by this policy.

409 Official Guest
A person invited by an official host to attend a university meeting, conference, reception, activity or event. Examples of official guests include employees visiting from another CSU work location, students, donors, recruitment candidates, volunteers, members of the community, or media representatives. Students attending a meeting or event in their role as a student-employee are considered employees for purposes of this definition.

410 Official Host
The university employee who is providing hospitality and responsible for incurring hospitality expenditures that are in compliance with this policy, such as a university or auxiliary employee who hosts guests at a meeting, conference, reception, activity, or event for the active conduct of university business.

411 Promotional Items
A tangible item that is distributed to promote the name or image of the university to provide information, or to enhance university productivity. Promotional items are of minor value and display the name, logo or other icon identifying the university such as a keychain, coffee mug, calendar, or clothing.

412 Work Location
The place where the major portion of an employee’s working time is spent or the place to which the employee returns during working hours upon completion of special assignments.

500 Allowable Expenditures and Occasions

Hospitality expenses must be directly related to, or associated with, the active conduct of official university business. When an employee acts as an official host, the occasion must, in the best judgment of the approving authority, serve a clear university business purpose, with only incremental personal benefit derived by the official host or other employees. In addition, the expenditure of funds for hospitality should be cost effective and in accordance with the best use of public funds.
When determining whether a hospitality expense is appropriate, the approving authority must evaluate 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.
Following are examples of occasions when the provision of hospitality may be permitted:

• The university hosts or sponsors business meetings that directly correlate with the operations of the university.
• The university hosts students, donors, visitors, volunteers, and other official guests, including employees visiting from another CSU work location, with an interest in the university.
• 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 student orientation programs for incoming students and family members.
• The university hosts receptions for the benefit of employee morale, employee recognition, and exceptional contributions or official presentation for length of service awards with at least 5 years of service.

Hospitality expenses incurred while on travel status are subject to this policy.

501 Employee-only Meetings or Events (see 403 for definition)
Food and beverage provided to employees may be permitted when it serves a university business purpose, occurs infrequently per group or committee, is reasonable in amount, is appropriate to the business purpose, and one of the following criteria are met:

• The meeting or event lasts 3 hours or more,
• More than 2 employees are present,
• The majority of the attendees are on travel status

Additionally, public expenditures that are driven by personal motives are an impermissible use of university funds. When a meeting takes place and the agenda includes a working meal, it must be demonstrated that the meal is an integral component of the business meeting or event.  The requirements for allowable meals or light refreshments are noted below:

• Detailed justification must be provided on the hospitality form stating why hospitality is a necessary and integral part of the business meeting.
• An agenda from the meeting must be attached to the hospitality form.
• Approval by the authorized signer (approving authority). Approval shall be documented through use of the Hospitality Form for all expenditure methods, except Sonoma State Enterprises (SSE) catering events utilizing an SSE catering contract; however, the contract must contain the same elements, provisions, and approval requirements as the Hospitality Form.

 (Note: These requirements apply to all expenditures methods including: Employee Reimbursement (EBER), Direct Pay, Pro-Card, EREQ, and SSE catering contracts.)

502 Meal Limits for Employee-only Meetings or Events
In accordance with CSU policy, a maximum per person rate shall be established by the Chief Financial Officer for breakfast, lunch, dinner and light refreshments inclusive of the total cost of food, beverages, labor, sales tax, delivery fees or other services. These maximum rates should be reviewed periodically by the Chief Financial Officer. The maximum meal limits for employee meetings or events are as follows. 

Vice Presidents or above may approve limited exceptions to the maximum per person per meal rate with a documented explanation.

Food and beverage hospitality expenses provided for other than employee meetings or events are not subject to these meal limits and are approved at the discretion of the approving authority, but must be reasonable and appropriate to the business purpose of the event.

503 Employee Awards, Service Recognition, and Morale
Awards, service recognition, or employee morale functions are allowable and must serve a purpose consistent with the mission and fiduciary responsibilities of the university and align with IRS regulations.  Current university wide sponsored programs can be found at www.sonoma.edu/hr under employee recognition.

Awards, service recognition, or employee morale functions at the department level are allowable.  A non-cash award or prize may have a taxable consequence to the employee if it does not meet the IRS definition of de minimis ($75 or less) and infrequent, and is part of the university’s established employee recognition program.

504A Employee Farewell Gatherings 
Celebrations to recognize an employee’s years of service at the time of separation and/or exceptional contributions to the university are permissible after a minimum of 5 years of service with a maximum of $750 in university funding. Alcohol may not be purchased with the Operating Fund. Vice Presidents or above may approve limited exceptions to the $750.

504B Employee Farewell Award
An employee farewell recognition award that is tangible in nature, i.e. plaque, book, or other customary farewell gifts are allowed with university funding up to $75. Cash or gift cards are not permissible with university funds; however, employees wishing to pool personal donations for such gifts is allowed.

505 Spouses and Domestic Partners
Hospitality provided to the spouse or domestic partner of an employee may be permitted when it serves a university business purpose. Such an individual’s presence is considered to serve a university business purpose if he or she has a significant role in the proceedings or makes an important contribution to the success of the event. Official functions to which spouses or domestic partners are invited as a matter of protocol or tradition such as ceremonial functions, fundraising events, alumni gatherings, athletic games, and community events may be considered business related. An agenda, invitation or similar documentation should be included with the payment record.

506 Students and Prospective Students
Hospitality provided to students or prospective students may be permitted when it serves a university business purpose. To justify an expenditure, the approving authority must determine that the expenditure is consistent with the mission of the university.  Permissible activities may include recruitment efforts, student activities, student programs, student organization events, student recognition events and commencements. Students may attend fundraising and other community relations events that enhance their learning experience, in recognition of their student achievement, to engage with alumni and donors, or as representatives of elected student leadership.  Hospitality provided to student athletes and recruits must be in accordance with the rules, regulations, guidelines, standards and procedures of the intercollegiate athletic association’s national governing board; e.g., National Collegiate Athletic Association.

506A Student Programs and Activities
Hospitality expenditures provided to students for programmatic expenditures that serve students in accordance with the purpose of a university program or instructional course are subject to the requirements of this policy.

506B Chartered Student Organization/Club Events
Hospitality expenditures provided by chartered student organizations and clubs are subject to the requirements of this policy. All hospitality expenditures shall be reviewed for compliance with this policy and approved for payment by Student Involvement.

507 Sponsored Programs and Related Activities
All hospitality expenditures from sponsored program related funds must follow the terms and conditions of the award agreement. As such, hospitality provided by sponsored program funds must be reviewed and approved by the applicable principal investigator for compliance with the hospitality policy and the terms and conditions of the grant or contract agreement. In the event of a conflict between the award agreement and university policy, the stricter of the two policies shall apply.

508 Sonoma State Enterprises Catering Services
All hospitality expenditures associated with catering services received from Sonoma State Enterprises (SSE) are subject to the requirements of this policy. Hospitality expenditures for catering services may be approved through use of the SSE catering contract; however, the contract must contain the same elements, provisions, and approval requirements as the Hospitality Form.

600 Unallowed Expenditures 

601 Personal Benefit
Hospitality expenses that are of a personal nature and not related to the active conduct of official university 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, bridal/baby showers, bereavement or sympathy gifts
• Gifts as a thank you to consultants, guest speakers, or employees at another campus

602 Discrimination
Hospitality expenses will not be paid or reimbursed for membership in social organizations, activities or entertainment services that discriminate based on race, color, religion, national origin, ancestry, age, gender, sexual orientation, marital status, veteran status, or disability.

603 Tobacco Product
No university funds may be used to purchase tobacco products.

700 Funding Sources

Hospitality expenses may be paid from various fund sources, subject to the rules outlined below and the restrictions identified in Table 1.
Lottery funds shall be used exclusively for the education of students and are not to be used for any non-instructional purpose and thus cannot be used for hospitality.

The following restrictions apply to the use of the CSU Operating Fund:

• CSU Operating Fund may not be used to pay for alcoholic beverages, entertainment services, or memberships in social organizations.
• CSU Operating Fund may not be used to pay for any expenditure prohibited by applicable laws, regulations, or agreements including the California Budget Act.

¹See Hospitality Expenses Policy FAQ for fund specifics

800 Approval of Transactions

Hospitality expenses should be reviewed for compliance with this policy by the approving authority, in conjunction with the submission of a payment or reimbursement request and the Hospitality Form.  See policy FAQs for more detail on approvals and documentation requirements.  

Approval shall be documented through use of the Hospitality Form for all expenditure methods, except Sonoma State Enterprises (SSE) catering events utilizing an SSE catering contract; however, the contract must contain the same elements, provisions, and approval requirements as the Hospitality Form.

The approving authority may not approve their own hospitality expenses and may not approve expenses of their supervisor.  The exception is approval of the President’s expenditures by the CFO.

Vice Presidential approval or above is required for payment or reimbursement of hospitality expenditures for a spouse or domestic partner of an employee and for recreational, sporting or entertainment events.