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Policy Title:

Travel and Business Expense

Policy No. OFS - 3

Responsible Office

Office of Financial Services Issue Date/ Effective Date

3.1.2014

Responsible Officer

Controller Last Revision 6.26.2017

1.0 Purpose

The Brookings Institution is a nonprofit public policy organization which was established to conduct high-quality, independent research. As such, Brookings employees and other non-employees often need to travel on behalf of the Institution and/or incur business expenses to conduct their work. This policy will outline how travelers will procure various travel or business related goods or services, the types of expenses that Brookings will reimburse, required documentation to reimburse expenses and the timing and procedures for submitting requests for reimbursement. Additionally, as Brookings is the recipient of various forms of funding, this policy adheres to good stewardship of our donor’s funding. Finally, under this policy, travelers are expected to comply with IRS accountable plan rules. Brookings has elected to participate in an accountable plan in part because accountable plans eliminate the need for employees to report reimbursements as income on their tax returns. The IRS outlines accountable plan rules as follows:

To be an accountable plan, your employer’s reimbursement or allowance arrangement must include all of the following:

1. Your expenses must have a business connection - that is, you must have paid or incurred

deductible expenses while performing services as an employee of your employer.

2. You must adequately account to your employer for these expenses within a reasonable period

of time. Brookings requests reimbursement requests within 30 days, please see Brookings

reimbursement timeframes and guidelines in Appendix A.

3. You must return any excess reimbursement or allowance within a reasonable period of time.

Brookings requests return of allowance requests within 30 days, please see Brookings

reimbursement timeframes and guidelines in Appendix A.

Please note, any hyperlinks in blue can be accessed on or off the Brookings network. Any hyperlinks in red can only be accessed on Brookings network.

2.0 People Affected

Brookings employees or non-employees traveling for the purpose of conducting business for the benefit of Brookings.

3.0 Definitions Accountable Plan: An IRS term for a plan under which an employer reimburses an employee for expenses and is not required to report the reimbursement as taxable income to the employee. The employee must document business purpose, substantiate expenses, and return any amount of allowance in excess of substantiated expenses to the employer.

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CONUS: The 48 contiguous states in the United States. Non-CONUS includes Hawaii, Alaska, Puerto Rico and Guam. Federal Awards: Projects that are federally funded, whether Brookings is the direct recipient of federal government funding or a sub-recipient. Financial Manager: Individual in your program who is responsible for administering the funding for your projects. Flying Time: Period of time a flight from departure city to destination or connecting city is expected to take per the airline’s posted schedule. Layover time(s) are not included when calculating flying time. Per Diem (Meals & Incidentals (M&IE): Is an allowance determined by the U.S. government to cover meals and incidentals while traveling for business purposes and are submitted for reimbursement upon completion of travel. Per diem amounts are published by the General Services Administration (Domestic CONUS), Department of Defense (Domestic Non-CONUS), and State Department (Foreign) and are specific to major cities.

Incidentals Domestic (Per Diems): are tips for services (e.g. porters, baggage carriers, bellhops, and hotel maids)

Incidentals Foreign (Per Diems): are tips for services (e.g. porters, baggage carriers, bellhops, and hotel maids), laundry and dry cleaning

Procurement Card (PCard) – Credit card issued to Brookings employees for business related-travel and entertainment expenses. Reasonable Expenses: An expense that is ordinary and reflects a prudent decision to incur the expense on behalf of Brookings business. Not extreme or excessive. Senior Financial Officer: The position in research and non-research programs who is primarily responsible for overseeing and managing the budget and finances for their program. Travel: Travel on official Brookings business from one’s home or normal place of employment to another destination. Travel does not include commuting to and from work. Traveler: Brookings employee or non-employee traveling for the sole purpose of conducting business for the benefits of Brookings. Travel Expense Reimbursement Approvers: Designated individuals in each Brookings program who have signature authority to review and approve travel reimbursement requests (up to their signature authority).

4.0 Policy Prior to traveling on Brookings business, travelers should research the area(s) that they are traveling to and make all necessary precautions. This should be done whether the travel is domestic (within the United States) or international. Travelers on Brookings business should pay specific attention to any potential safety or security risks associated with the travel location(s). Such information can be found in a number of sources, such as speaking to others who have traveled to the location, reviewing news coverage or other media, or consulting the State Department travel alerts and advisories. Approval of Expenses All travel and business expenses must be authorized and approved by Brookings prior to any expenses being incurred. The traveler must consult with their programs project/program director and financial manager to obtain approval and if approved, the appropriate project and activity to charge. Travelers should always use the lowest priced transportation option that is reasonably available.

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Personal Meals While on Brookings Travel Employees will be reimbursed according to the federally published domestic (CONUS), domestic (Non-CONUS) or foreign per diem rates for meals and incidental expenses (M&IE) applicable for the city and dates of travel. On the first and last day of travel, the M&IE per diem will be based on the start and return time.

Start Time - First Day Eligible Per Diem Meals Return Time - Last Day Eligible Per Diem Meals

Midnight – 9:59 am Breakfast, Lunch and Dinner 12:01 am – 9:59 am Breakfast

10:00 am – 3:59 pm Lunch and Dinner 10:00 am – 3:59 pm Breakfast and Lunch

4:00 pm – 7:59 pm Dinner 4:00 pm – Midnight Breakfast, Lunch and Dinner

8:00 pm and beyond N/A Additionally, when a meal is paid for by a host, included in a conference registration fee, or covered by another source, the per diem will be reduced accordingly. For non-employees, please check with the program you are traveling on behalf of to see if you are eligible for meal and incidental expenses as some programs have stricter eligibility restrictions. Business Meals and Entertainment Business meals and entertainment are expenses incurred when a specific business discussion takes place. (IRS guidelines limit business meals and entertainment expenses to situations where the expenditure "directly precedes, includes or follows a substantial and bona fide business discussion for the purpose of obtaining income or other specific trade or business benefit.") Travelers may request reimbursement for actual documented expenses. For business meals or entertainment that involves Brookings employees only, alcohol expenses will not be reimbursed. The traveler must provide the names of individuals present, their titles, affiliation, and the business purpose of the meeting. Please note, in instances when the IRS guidelines are not met above, such as social occasions, these expenses are not classified as business meals or entertainment and will not be reimbursed as such. Non-business meal or entertainment examples include: social occasions, employee birthdays, employee morale events, holiday parties, or employee farewell parties. Reimbursement requests for non-business meals or entertainment expenses do not fall under this policy and if approved by the program, should be submitted via a check request form and coded to the program’s Director’s Account (73530). Additionally, these expenses may never be charged to grants, but rather the program’s unrestricted funds. In some cases, these expenses may be charged to gifts, but Senior Financial Officers should first consult with the Controller’s Office. Alcoholic Beverages If alcoholic beverages are consumed at a function at which Brookings can expect to derive a specific business benefit and non-employees are present, reasonable costs will be reimbursed. Alcoholic beverages consumed en route to a destination, in a hotel room, during functions not of a direct business nature, or with employees only, will not be reimbursed. No alcohol may be charged to federal awards.

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Travel Arrangements It is strongly recommended that Travelers use Brookings authorized travel agencies for airfare, train, rental cars and hotels. See “Authorized Travel Agencies.” Travelers must request airline reservations according to necessary departure or arrival times rather than specific airline, flight number, or personal travel incentives offered. In addition, care should also be taken to make travel arrangements as far in advance as possible, thereby allowing travelers to take advantage of the most inexpensive flights. Travelers may retain frequent flyer and hotel program benefits. Participation in these programs must not influence flight or hotel selections that would result in additional cost to Brookings beyond the lowest available airfare or hotel. Authorized Travel Agencies It is strongly recommended that Travelers use Brookings authorized travel agencies for airfare, train, rental cars and hotels. Please see a list of our authorized travel agencies. The benefits of using our authorized travel agencies include:

Agency discounted airfares (negotiated with the airlines)

24 hour accessibility/emergency assistance throughout the world

Provide travel assistance if any travel issues arise (including cancelled flights, flight delays or

changes)

Direct billing to Brookings, i.e. the traveler will not have to seek reimbursement for their flight

Discounted hotel/car rentals

Group participant bookings for meetings/conferences, travel agent will contact participants to

make travel arrangements

Special last minute shuttle fares (Garber/FCM), ex: DC to LGA or BOS

Travel not booked through an Authorized Agency If a traveler doesn’t book their travel with an authorized travel agency, the traveler may submit the expense to be reimbursed after the completion of travel. The traveler will be responsible for the timely submission of appropriate documentation for reimbursement. Travel Booked to Federal Award All travel booked to a federal award must comply with 2 CFR 200.474, this policy, as well as any specific federal award contractual requirements. See also “Air Travel”. Lodging Travelers must reserve low cost, reasonable room rates as defined by the domestic and foreign lodging per diem rates. The lodging per diem rates are based on location of travel and time of year.

For domestic travel, if lodging is not available at the lodging per diem rate, travelers may procure lodging up to 150% of the lodging per diem rate or $200, whichever is higher.

For foreign travel, travelers may procure lodging up to the lodging per diem rate or $200, whichever is higher.

Without advance approval from the Senior Financial Officer, lodging costs above the maximum allowed under these guidelines will not be reimbursed.

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Lodging per diem rate guidelines:

For domestic (CONUS) travel, GSA website,

For domestic (non-CONUS) travel, Department of Defense

Foreign travel, State Department

Please note that Brookings does not have federally negotiated lodging per diem agreements and will not reimburse travelers based on the lodging per diem rate. Travelers must submit lodging receipts for reimbursement. Travelers should also do the following:

Use available hotel transportation to and from airports in lieu of rental cars or cabs.

Inquire, when checking in, if a lower rate is available. Hotels often offer specials depending on

number of rooms not yet booked for that night.

Travelers may make hotel reservations through the designated travel agencies and should use negotiated or preferred rates whenever possible. The travel agents will make the reservation, but cannot authorize charges. Therefore, the traveler will still be required to arrange for payment. If travelers stay in a private residence while traveling on business and if additional expenses are incurred to extend appreciation to friends or relatives for their hospitality, travelers may expense up to $75 without prior approval from the program Senior Financial Officer. All travelers staying in Washington, DC hotels should consult Brookings preferred lodging options. The preferred hotels are set up for direct billing to Brookings. Additionally, any reservations that are direct billed or paid with a Brookings PCard will qualify for tax exemption. All other reservations will incur DC taxes. Air Travel All continental U.S. air travel must be in coach class. All other travel with a flying time which exceeds 6 hours one-way may be in business class if approved in advanced by the Senior Financial Officer. No business class travel may be booked to projects funded by federal awards except in limited exceptions as outlined in 2 CFR 200.474. If one of the stated exceptions exists, the exception must be documented and approved in advance of ticket purchase by the traveler’s Senior Financial Officer and the Assistant Director of Procurement. Additionally, if a federal award specifically states that business class is allowable the request may be approved by the Senior Financial Officer. At the traveler’s expense, upgrades are allowable. In the event of extenuating circumstances (typically a documented medical condition), upgraded tickets may be requested by the traveler and may be reimbursable where it is normally prohibited. Each request will be reviewed by Brookings on a case by case basis and must be approved in advance of purchase. The traveler’s Senior Financial Officer will review and if appropriate, approve. First class air travel is not allowed under Brookings policy. Under highly extenuating circumstances (typically a documented medical condition), a traveler may seek advance purchase approval by either the CFO or Controller. In the case of documented medical reasons, those requests should be forwarded for review and approval by Human Resources (Assistant Director of HR, Benefits). Travelers are expected to use lowest logical airfares whenever reasonably possible. These include:

Non-refundable fares

Saturday night stay over

Advance purchase fares

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Connecting flights

Flights from alternate airports

Electronic ticketing

Brookings will reimburse for a Saturday night hotel stay over provided the additional hotel expenses and M&IE per diem is less expensive than a ticket without a Saturday stay over. Should an airline delay necessitate an overnight stay, the traveler should attempt to secure complimentary lodging from the airline. If you purchased a ticket and are no longer traveling, the traveler must call the travel agent or airline to cancel and/or refund the ticket. Rail Travel First class rail travel is not authorized. No business class travel may be booked to federal awards. Rental Cars Travelers should make rental car reservations for an economy or compact car through the designated travel agencies. Please note, if there are three or more travelers, an upgraded car to accommodate the travelers may be procured. Please see our list of authorized rental car agencies. A rental car should be refueled before returning it to the agency. Additionally, travelers will be reimbursed for fuel purchased, not on a per mileage basis. Personal Vehicles Employees using their personal vehicles for business are required to carry the minimum automobile insurance required in your state of residence. Brookings reimburses mileage at the federal government rate. Current rates are available at the GSA website. To be reimbursed, travelers must provide their start and end location and if applicable, provide receipts for tolls and parking. Travelers will not be reimbursed for any parking or traffic violations. Driver Safety Travelers traveling on Brookings's business should exercise utmost care towards their safety as well as the safety of others, including following all federal, state, and local laws and regulations. While driving a personal or rental vehicle, travelers should avoid distractions, such as texting, using a handheld cell phone, and other activities that interfere with a driver's due care and attention. Travelers should also limit their use of hands-free devices for cell phones. Travelers traveling on Brookings's business should always use the reasonable safety measures available to them, including but not limited to wearing their seatbelts. International Travel Foreign currency may be purchased at banks, airport foreign exchange counters and major hotels abroad. Travelers may want to consider purchasing travelers checks in foreign currency before leaving home. Travelers abroad should change unused local currency back to U.S. dollars before departing the foreign country to get a better exchange rate. In most countries, ATMs are available to obtain cash. Brookings travelers are required to use loaner equipment (laptops, smart phones and tablets) supplied by ITS when travelling to mainland China, Russia, Cuba, North Korea and Iran. There is no charge for loaner equipment, but fees may apply if the equipment is returned late, lost, or damaged.

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Personal equipment should not be used to access Brookings email or other technology-based services while travelling to mainland China, Russia, Cuba, North Korea and Iran. See also “Air Travel.” Travel Insurance The Brookings Institution has various types of insurance which may cover individuals traveling on Brookings behalf in the event of illness or injury. Furthermore, employees who have Institutional Procurement Cards (PCards) may be eligible for additional insurance provided by our banking partners. In the event of questions, please contact the Procurement Department (202-797-6070) for more information. International Travel Liability Insurance & Europ Assistance Emergency Assistance Individuals traveling overseas on Brooking’s business may be covered under our business travel accident policy (Chubb) or our international package policy (Ace USA). In the event an emergency arises, please contact Europ Assistance for medical and travel related assistance services. Additionally, please notify your program. For more information, please visit their website at www.europ-assistance.com. A Europ Assistance identification card showing Brookings policy number and appropriate phone numbers for services in various countries is available. Please print the ID Card and keep it with you. Insurance Requirements for Protection from War Please note that individuals traveling to war risk countries may not be covered under Brookings’s insurance policies. In the event that an individual is traveling to any of the countries listed in Appendix C, approval from the Institution and/or the appropriate insurance company must be obtained in advance of travel. Brookings may also request that travelers sign a waiver acknowledging that insurance coverage(s) are not available for the requested trip. This list of countries is subject to change. Travelers concerned about the risk of war should contact the Office of General Counsel to verify the list is current and inquire about purchasing additional insurance. To apply for this additional coverage, travelers should send an e-mail to their program’s Senior Financial Officer at least two weeks before the travel is booked with the following information:

What cities or areas will be visited?

What are the dates of travel?

Where will the traveler be staying in each area?

What transportation arrangements have been/will be made for the traveler to get around the country?

What security arrangements have been/will be made to keep the traveler safe while in this/these countries?

What is the purpose of the trip?

What will the traveler be doing while there? The Senior Financial Officer should then forward the information, including the project number to be charged for the cost of the insurance to the Office of General Counsel. The Office of the General Counsel will inform the Senior Financial Officer once the insurer has approved or denied the request for additional coverage.

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Lost Baggage The ultimate responsibility for retrieving and compensating for lost baggage lies with the airlines. Brookings will not reimburse travelers for personal items lost while traveling on business. ITS Equipment (Employees only) ITS has a variety of laptops, tablets, and smart phones available. To request a loaner contact the ITS Service Desk two weeks in advance of your trip. A fee for late returns may apply. Telephone Usage (Employees only) Employee travelers who have Brookings issued devices should notify the ITS Service Desk two weeks in advance of international travel so that voice and data plans can be altered to minimize costs while abroad. Loaner laptops with internet calling software and loaner smart phones are also available from ITS. Please notify ITS at least two weeks in advance of your travel. Loaner items will be provided on shorter notice if available. Spousal/Family Member Travel (Employees only) Expenses related to an employee’s spouse or other family members are not reimbursable unless there is a bona fide business purpose for their presence while traveling. For Employee’s only, if there is no bona fide business purpose and the program still wishes to reimburse the family member’s business expenses, those expenses must be processed as additional pay to the Brookings employee. Non-Employee non-bona fide spousal/family member travel will not be reimbursed.

Bona Fide Business Purpose for Spousal/Family Member Travel. When an employee

spouse/family member who attends a function has a significant role in the business proceedings,

or is involved in fund-raising activities, this constitutes a business purpose under IRS regulations.

In such cases, Brookings will reimburse the traveler for the spouse’s (or other family member’s)

non-personal expenses directly resulting from travel on Brookings business.

Non-Bona Fide Business Purpose for Spousal/Family Member Travel. The IRS has ruled that

when a spouse attends a meeting or conference as a companion and has no significant role or

performs only incidental duties of a social, clerical or medical nature, then the attendance does

not constitute a business purpose.

For more information, see Appendix B. Travel Advances (Employees only) Travel advances for Brookings employees may be obtained to pay for out-of-pocket expenses when traveling on Brookings business. Requests for advances must be submitted at least seven business days before the day of departure and are limited to $75 per day. If an employee requires more than $75/day, please contact the Procurement Department. Within 30 days upon the employee’s return, the employee must fill out and submit their travel expense report. If the employee did not expend all of their advance on business travel expenses in accordance with this policy, they must return the balance to Brookings when they submit their travel and expense report. If an employee fails to turn in a travel expense report within 60 days or return the unexpended balance, the travel advance will be processed as taxable income to the employee.

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Brookings Procurement Cards (PCards) (Employees only) Travel and business expenses that are charged to an employee’s PCard must be in accordance with this policy. Any travel and business expense not in accordance with this policy must be paid back to Brookings within 60 days. If an expense is not paid back within 60 days, disciplinary action may be taken and the employee’s PCard may be revoked. Travelers are not allowed to charge any personal meals to their Brookings PCard as the traveler will be reimbursed the appropriate M&IE per diem amount. Brookings Tax Exempt Status and Certifications If you are procuring goods or services or traveling in one of the states which Brookings has tax exempt status, please notify the vendor of this status when you are booking your travel. By providing the vendor with the appropriate tax exempt documentation, Brookings may be not charged the associated sales tax (depending on state law). List of tax exempt states

6.0 Reimbursement Documentation for Reimbursement: Guidelines:

No receipts are required for M&IE per diem expenses. Travelers will be reimbursed according to

the travel location per diem rate, their length of travel and whether or not meals were provided to

them.

No receipts are required for business and travel expenses equal to or less than $50. However,

the traveler will be required to provide an itemized list of expenses on their Travel

Reimbursement Request form.

Receipts are required for all non-M&IE per diem expenses over $50. See “Receipts Required

Documentation.”

Receipts Required Documentation: Reimbursements for non-M&IE per diem expenses over $50 incurred on behalf of Brookings business must include itemized receipts. Please note, if copies of receipts are provided, they must be legible. In the rare occurrence that a vendor does not provide an itemized receipt (predominately foreign vendors), the traveler shall ask for the vendor to sign documentation stating which services were provided, amount paid and date. Please see authorized sample receipt. Additionally, some expenses require further documentation and/or approval. Additional documentation is required for the following expenses:

Airline or train tickets not purchased via an authorized travel agency:

o Documentation of the ticket purchased with the travelers name, total amount of fare and

status of “paid”; and

o Itinerary

Hotel Bills:

o Itemized hotel bill showing dates stayed and rates; and

o Hotel bill showing that the bill is “paid in full”

Room Service in Hotels (for business meals, not M&IE per diem expenses):

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o Itemized receipt as provided by room service. “Meals” listed on the hotel bill will not

suffice.

Business Meals:

o Names of individuals present, their titles, and affiliation; and

o Business purpose of the meeting

Foreign currency expenses:

o Printout of Oanda conversion for each expense for date of expense; or

o If your credit card exchange rates are higher than Oanda, you must submit a copy of your

credit card statement to claim the higher expenses.

Additional approval is required by your Senior Financial Officer for the following expenses:

Business Class Travel:

o International

o Domestic, extenuating circumstances (note, in cases of documented medical reasons,

Human Resources will review and approve)

Lodging costs above the maximum allowed

Reimbursement requests 91-180 days after the completion of travel

Reimbursable and Non-Reimbursable Travel and Business Expenses Reimbursable Expenses Travelers will be reimbursed for the following reasonable expenses in accordance with the preceding guidelines:

Airline baggage fees (up to 2 bags)

Business office expenses such as phone, fax, internet and copy services

Calling cards for business purposes

Currency conversion fees

Fare penalties

Foreign transaction fees

Gasoline for rental car

Ground transportation (including taxis, metro, bus, etc.)

Fitness center use (your hotel only) ($10 per day max)

Laundry and dry cleaning

o For domestic travel, trips lasting five days or longer

Parking

Personal car mileage

Rental car insurance

Taxis

Tips for baggage handling up to $1.00 per bag (if you are not claiming a M&IE per diem)

Tolls

Travelers checks fees

Visa and passport fees

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Non-Reimbursable Expenses The following expenses will not be reimbursed:

Personal meals, actual expenses incurred (rather an M&IE per diem will be issued for employees

and non-employees may be eligible for a per diem)

Airline club memberships

Alcoholic beverages except as covered in “Alcoholic Beverages”

ATM fees (domestic)

First Class Travel

Fitness center use outside your hotel or over $10 per day

Hotel mini-bar/ honor bar refreshments

Laundry and dry cleaning

o For domestic travel, for trips lasting four days or less

o For all foreign travel as expenses are covered under M&IE

Lost baggage

Personal entertainment (ex: movies)

Parking/traffic violation fines

Rental car upgrades (unless three or more individuals traveling)

Frequent flyer miles (purchase of or redemption of)

Spa services (ex: massages)

Items in excess of reasonable expenses

First or business class for domestic travel (unless extenuating circumstances are approved in

advance by Senior Financial Officer or Human Resources)

First or business class for international travel (unless approved in advance by Senior Financial

Officer

Unreasonable Expenses If the traveler’s program Senior Financial Officer determines that the expenses submitted for reimbursement are unreasonable, the expense will be reimbursed up to a reasonable amount. If the Senior Financial Officer has a question as to what constitutes reasonable, the Senior Financial Officer shall consult with the Controller or CFO. The CFO will have ultimate discretion in what is determined to be reasonable. Travel Policy Scope This policy was developed with the intent to cover the most common travel-related situations. This policy does not address every travel-related situation. If a situation arises that is not covered by this policy, the traveler should contact the Procurement Department for guidance. Exceptions to this policy may only be made with the approval of either the Controller or CFO. Submitting for Reimbursement Upon the completion of travel, the Traveler shall submit a request for reimbursement, along with the appropriate documentation to their Financial Manager or TER Approver for payment. All travelers are encouraged to submit their reimbursement within 30 days. For employees, if a reimbursement is submitted between 61 – 90 days, the reimbursement will be considered taxable income and the appropriate taxes will be withheld. For reimbursements submitted between 91 and 180 days, the reimbursement may be approved if the Senior Financial Officer approves the request and there is available funding. For employees, these reimbursements (submitted between 91 and 180 days) will be

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considered taxable income and the appropriate taxes will be withheld. Under no circumstances will reimbursement requests from employees and non-employees over 180 days be approved. See Appendix A for further details. Submission forms:

Employee Travelers:

o If the reimbursement is under $30 and within 60 days of completion of travel, submit a

Petty Cash form

o If the reimbursement is over $30 or greater than 60 days after completion of travel,

submit a Travel Expense Report form.

Non-Employee Travelers:

o All reimbursement amounts, submit a Travel Expense Report form

If the traveler extended their travel for personal or non-Brookings business, the traveler shall adjust their expenses to reflect expenses incurred while traveling on behalf of Brookings. When filing expense reports for travel outside the U.S. complete the reports in U.S. dollars and clearly indicate the U.S. dollar amount on all accompanying foreign currency receipts. The Controller’s Office at Brookings utilizes www.oanda.com for your foreign currency conversions. The traveler can convert one expense or for multiple expenses. Please make the required conversions based on the date the expenditure was made (not the date the TER is being prepared) and include the printed Oanda page for reimbursement. Please note however for hotel expenditures, the date utilized should be the date that the expense was incurred and should not be adjusted daily. See “Required Documentation for Reimbursement.”

7.0 Responsibilities Travelers: Those traveling on Brookings business must abide by this policy and the accompanying procedures. Travel Expense Reimbursement Approvers: Approvers have primary responsibility for ensuring compliance with this policy. When approving travel expense requests, approvers must:

Verify that all expenses have a Brookings business purpose.

Verify that all submitted information and supporting documentation is accurate and in accordance

with this policy.

Verify that all expenses are charged to the appropriate general ledger account(s) and project(s).

Verify that all expenses were not charged to a Brookings PCard

Contact the Senior Financial Officer for instructions and/or approval if travel expenses exceed the

guidelines of this policy or if expenses seem excessive or unreasonable.

Senior Financial Officers:

Ensure that their program abides by this policy and the accompanying procedures.

Ensure that individuals involved in the process of reimbursing travel expenses are properly

trained.

Ensure that the travelers understand the requirements of this policy.

Maintain an appropriate hierarchy for review and approval of travel and travel-reimbursement

requests.

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Answer any questions on “reasonable” costs. If necessary, follow up with Controller for guidance.

Review requests for expenses that exceed the guidelines and if appropriate, approval of said

expenses.

Controller’s Office:

Maintain Brookings Travel and Business Expense policy.

Audit travel reimbursement requests to ensure compliance with Brookings policy and with IRS

and other regulations.

Process reimbursements in a timely manner.

Properly record and report any taxable reimbursements.

Provide training to travelers and approvers on this policy.

If needed, follow up with CFO for guidance on reasonable expenses.

Human Resources (Assistant Director of HR, Benefits):

Review and if applicable, approve documented medical reasons as they relate to travel requests.

If necessary, consult with HR Director on a case by case basis.

Chief Financial Officer or Controller:

If requested by the employee, review and approve or deny reasonable exceptions for employee

reimbursement requests between 61 – 90 days.

Review and approve or deny reimbursement requests between 91 – 180 days

In the event of extenuating circumstances (typically a documented medical condition), review

requests and if appropriate, approve first class air travel.

If required, determine if an exception to this policy is approved.

8.0 Supporting Forms/Documents

Oanda Currency Conversion

Oanda Currency Conversion with multiple expenses

Sample Receipt (for vendors without receipts)

Travel Advance Request

Travel Expense Report (TER)

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Appendix A: Travel Expense Reimbursement Submission Time Lines

Time Line*

Approval Status Comments Forms

0-60 days

Okay Submit expenses within 30 days to ensure adequate processing time.

Employees:

If $30 and under, Petty Cash Form

If over $30, Travel Expense Form Non Employees: Travel Expense Form

61-90 days

Okay, but for employees taxes withheld and reported as personal income unless exception approved by Controller or CFO

Examples of reasonable exceptions are:

Extended personal illness

Death in the family

Unanticipated leave of absence

Travel outside of the country for an unexpected extended period of time (30 days or more) Administrative oversight or workload is not an acceptable exception.

Travel Expense Form

91-180 days

Okay, subject to funding availability and approval by the Senior Financial Officer and either Controller or CFO, but for employees taxes withheld and reported as personal income

No exceptions Travel Expense Form

After 180 days

Not reimbursable No Way! Not Applicable

*timeline starts upon the completion of travel and stops when the request is submitted to your program for approval and is in accordance with the travel policy.

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Appendix B: Spousal and Family Travel: Bona Fide vs Non-Bona Fide Business Purpose

A spouse who attends a function is considered to have a business purpose if he or she has a significant role in the proceedings or makes an important contribution to the success of an event. Generally, protocol or tradition dictates when the participation of a high-level official’s spouse is required at official Brookings functions, such as fundraising or ceremonial events. The following grid is provided to help determine if spousal/family travel is taxable or non-taxable. This is not a complete list of circumstances that may be considered.

Expenses more likely to be taxable when: Expenses more likely “bona fide” (non-taxable) when:

No formal request for family member to attend event(s)

Formal or official correspondence requests spouse or other family members of Brookings employees to make the trip or attend event(s)

Family members are not required to attend meetings, given assignments in advance, or make presentation at the event(s)

Spouses or other family members are required to attend meetings, given assignments in advance, or make presentations at the event(s)

Family member performs only “helpful” services, such as social, medical assistance, etc.

Family member performs “necessary” services by acting as a representative of Brookings in a substantial manner

Only Brookings employees and family member attend event(s)

Non-Brookings individuals (donors, panelists, etc) attend event(s)

Family members participate in substantial tourist activities

Family members do not participate in tourist activities

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Appendix C: War Risk Countries

Afghanistan

Algeria

Angola

Bahrain

Bosnia & Herzegovina

Burundi

Cambodia

Central African Republic

Cote d'Ivoire

Cuba

Democratic Republic of Congo

Guinea- Bissau

Haiti

Iran

Iraq

Kosovo

Kyrgyz Republic

Lebanon

Liberia

Libya

Mali

Niger

North Korea

Northern Ireland

Pakistan

Sierra Leone

Somalia

South Sudan

Sudan

Syria

Venezuela

West Bank and Gaza

Yemen

Zimbabwe