EMPLOYEE BUSINESS EXPENSE AND TRAVEL POLICY Updated July 2008 TABLE OF CONTENTS Objective................................................................................................................................... 4 Scope ........................................................................................................................................ 4 Employee Responsibility ......................................................................................................... 4 I. TRAVEL ARRANGEMENTS ............................................................................................. 4 A. Business Trips ............................................................................................................. 4 1) Making reservations .......................................................................................... 4 2) Canceling reservations ................................................................................ 5 B. Reward Programs............................................................................................... 5 C. Conferences/Seminars ............................................................................................... 5 II. PAYMENTS & REIMBURSEMENTS .................................................................................. 6 A. Corporate Credit Cards ....................................................................................... 6 B. Cash Advances ................................................................................................... 6 C. Deposits/Registration Fees ................................................................................ 7 A. EXPENSES – Allowable ............................................................................................. 7 Baggage Fees ...................................................................................................... 7 B. Dry Cleaning/Laundry ......................................................................................... 7 C. Gratuities/Tipping................................................................................................ 7 D. 1) Hotels ................................................................................................................... 8 Preferred properties/Direct Bill (Areas in HealthNow locations) .............. 8 2) Areas outside HealthNow locations ............................................................ 8 3) Government Rates ....................................................................................... 8 III. E. F. Meals .................................................................................................................... 8 Transportation ..................................................................................................... 8 G. Entertainment ...................................................................................................... 9 H. IV. Telecommunications Charges ........................................................................... 9 EXPENSES – Non-allowable ...................................................................................... 9 V. NEW YORK STATE SALES TAX EXEMPTION .......................................................... 9 VI. TRANSPORTATION .................................................................................................... 9 A. Air ......................................................................................................................... 9 1) Airfares ........................................................................................................10 2) Airline tickets...............................................................................................10 a. Changes to airline tickets ...........................................................................10 b. Unused airline tickets ...................................................................10 Cars .....................................................................................................................10 B. 1) Mileage for use of personal cars ................................................................10 2) Rental ...........................................................................................................11 Business Expense and Travel Policy 2 of 14 C. Rail ......................................................................................................................11 D. Taxi/bus/shuttle ..................................................................................................11 E. Foreign Travel ....................................................................................................11 VII. ENTERTAINMENT .....................................................................................................11 VIII. TELECOMMUNICATIONS CHARGES .......................................................................12 A. Cellular Phones and Pagers ..............................................................................12 B. Long Distance Calls ...........................................................................................12 C. Hotel Internet Fees .............................................................................................12 IX. EXPENSE SHEET REPORTING REQUIREMENTS ...................................................12 A. B. Documentation/Receipts ...................................................................................13 1) Documentation of travel expenses ............................................................13 2) Documentation of ........................................................................................13 3) Receipts .......................................................................................................13 X. Shared Expenses ...............................................................................................14 EXPENSE SHEET APPROVAL ..................................................................................14 XI. EXPENSE SHEET AUDITING ....................................................................................14 XII. REIMBURSEMENT ....................................................................................................14 Business Expense and Travel Policy 3 of 14 EMPLOYEE BUSINESS EXPENSE AND TRAVEL POLICY Objective HealthNow New York Inc.’s Employee Business Expense and Travel Policy provides standard procedures and guidelines for all employees who travel or incur legitimate business expenses, with the intent of minimizing travel-related costs, ensuring consistent treatment among employees, and satisfying corporate compliance requirements, including those of the Internal Revenue Service (IRS) and the Federal Acquisition Regulation (FAR). Scope The Employee Business Expense and Travel Policy applies to all employees incurring expenses on behalf of the company,. These guidelines supersede all corporate and divisional procedures related to travel and expense reporting, either written or informal. Employee Responsibility As stated in the HealthNow Code of Conduct, employees have a responsibility to follow all company policies and procedures. Failure to adhere to the Employee Business Expense and Travel Policy may be considered a violation of the HealthNow Code of Conduct and may result in disciplinary action as described in the Code. I. TRAVEL ARRANGEMENTS A. Business Trips All trips must be approved by management prior to making reservations. 1) Making reservations After plans to travel are firm, employees are to contact their Travel Planners for reservations. A listing of departmental travel planners is found on the PeopleSoft Travel Information Website. The corporate travel service must be used for airline reservations. Employees obtaining airline tickets on their own, risk the chance of not being reimbursed. Other than in emergency situations, any exceptions must have management approval prior to the arrangements being made. In certain rare cases, an employee may find a lower fare than what is offered by our corporate travel service. Employees are advised to contact the travel agency with specifics on the fare offered. If the flight is available, our agency may be able to secure this flight. Hotel and car rental reservations may be made directly or through the corporate travel service. Whenever possible, travel arrangements should be booked a minimum of 21 days prior to the date of travel. Please note that all Buffalo-Albany or Albany-Buffalo airline reservations must be made through TTO, an on-line booking. Business Expense and Travel Policy 4 of 14 When traveling involves government business, the traveler must be identified as such in order to secure government preferred rates. 2) Canceling reservations If travel plans are canceled or changed, the Travel Planner must be contacted immediately to make the necessary arrangements. During non-business hours, employees should make the changes by calling the Travel Team’s 24-hour emergency service at 1-888-919-1127, access code L3i0 or 2LA9, and identify themselves as HealthNow employees. Reservations that were not made through the Travel Team must be canceled directly by employees. If a scheduled flight is canceled, the company will reimburse additional expenses resulting from the rescheduling or from the securing of an alternate means of transportation. The company will also reimburse additional expenses incurred as a result of an emergency situation. Charges that result from changes in flight times may not be considered valid business expenses. If changes were made for non-business purposes, employees may be responsible for all associated costs. B. Reward Programs Reservations will be made with the airline or hotel that provides the most reasonable rate while meeting business requirements. Program benefits must in no way influence flight and hotel selection. C. Conferences/Seminars It is recommended that the number of people from within a department attending out-of-town meetings or conferences be limited. The completion of registration forms, requests for travel advances, payment of registration fees, and completed request for travel forms are the responsibility of the employee or the Travel Planner, except in Binghamton where all arrangements are to be handled by the Travel Planner. The Travel Planner will make hotel, car rental (if approved), and airline reservations. Frequently, the host organizations make arrangements with airlines and/or hotels for special reduced fares or rates. The conference/seminar attendee must advise the Travel Planner of “800” numbers and the conference/seminar program number, and are strongly encouraged to secure these discounted rates. Registration fees and associated expenses for conferences/seminars must be reported on an expense sheet through the PeopleSoft Expense Module. Business Expense and Travel Policy 5 of 14 Documentation must be submitted with expense sheets for out-of-town conferences, forums, seminars, etc., that includes “what, where, and when” information, e.g., registration forms, agendas, and/or conference summaries. These agendas are required for submission and reimbursement. II. PAYMENTS & REIMBURSEMENTS A. Corporate Credit Cards (Officer, Employee Ghost) Employee corporate credit cards require vice president approval and may be obtained through request to the Travel and Expense Department staff. All corporate credit cards must be used for business purposes only. Corporate credit cards are intended to be used for allowable personal business expenses (see Section III). They are not intended for charging major corporate expenses. Such payments should be handled through Accounts Payable. Employee corporate credit cardholders are responsible for maintaining their accounts on a current basis, remitting payments by the stated due dates. Accounts delinquent over 60 days will be suspended from use and/or canceled. Delinquency charges on all corporate card accounts are the responsibility of the cardholder and may adversely affect the cardholder’s personal credit record. All cardholders are responsible for reporting discrepancies and/or disputed charges: HSBC Bank USA contact information: General Customer Service 1-800-975-HSBC (4722) Option 1 Lost/Stolen Cards 1-800-975-HSBC (4722) Option 5 All corporate credit card charges must be reported on expense sheets via the PeopleSoft Expense Module. B. Cash Advances Advances must be approved by management on-line via the PeopleSoft Expense Module. A maximum of $1,200 may be advanced for employees who do not have corporate credit cards. Advances should not be requested more than seven business days prior to the trip. An employee with two outstanding advances will not be permitted an additional advance until expense sheets are received and the advances are reconciled by the Finance Travel & Expense staff. Business Expense and Travel Policy 6 of 14 There should be no commingling of advances funds, i.e., sharing of advance funds among employees and/or applying advance funds to more than one trip. All expense advances must be reported on expense sheets via the PeopleSoft Expense Module. If the travel expenses incurred exceed the amount advanced, reimbursement (either check or EFT) will automatically be generated via the PeopleSoft Expense Module upon approval and audit of the expense sheet. If the advance exceeds the total expenses incurred, the remaining balance must be returned to the company. A check payable to HealthNow New York Inc. must be submitted with the expense sheet promptly upon return to the office. C. Deposits/Registration Fees In certain rare cases, Corporate Credit Cards will not be accepted. Requests for Accounts Payable (AP) generated checks payable to the vendor for hotel deposits and registration fees should be sent to AP at least seven business days before they are required. The Request for Check form is available on Lotus Notes and is routed electronically for approval and check creation. The path is as follows: III. Go Into TAO Bulletin Boards and Conferences Scroll down to Corporate Double Click on Corporate Click on the toolbar Create Click on Other Scroll down to Request For Check; click OK EXPENSES – Allowable The following expenses are reimbursable. The listing is not all-inclusive. Expenses must be reported on expense sheets via the PeopleSoft Expense Module. For a listing of non-allowable expenses, see Section IV. A. Baggage Fees Baggage fees will be reimbursed. Certain carriers currently allow for one bag per traveler at no cost. HealthNow will cover the cost of the first and second bag only. Please pack prudently and avoid the second baggage fee, if at all possible. B. Dry Cleaning/Laundry Expenses incurred for reasonable dry cleaning and laundry when away from home for more than five days are allowed when supported by out-oftown receipts. C. Gratuities/Tipping Reasonable tipping is an allowable, reimbursable expense, e.g. bellhops, skycaps, or maids. Restaurant gratuities should not exceed 20 percent. Business Expense and Travel Policy 7 of 14 D. Hotels Hotel reservations must be made through Travel Planners. 1) Preferred properties/Direct Bill (Areas in HealthNow locations) Lodging in Albany, Binghamton, Buffalo, will be selected from preferred properties with which HealthNow has negotiated rates and direct-bill arrangements. The preferred properties that have direct-bill arrangements with HealthNow will invoice only for the room. All other charges are the employee’s responsibility at the time of checkout. Direct-bill expenditures must be reported on an expense sheet under the payment method “AP Prepaid.” 2) Areas outside HealthNow locations At destinations where HealthNow negotiated rates do not exist, lodging may be selected from a BCBSA preferred property found on the PeopleSoft Travel Information Website or one offering the most beneficial pricing, with consideration given to the convenience of the traveler. 3) Government Rates Hotel rooms may be reserved at government rates when the business being conducted is in conjunction with government business, such as, Medicare B and FEP. E. Meals Meal expenses incurred on overnight business trips or for those trips long enough to require a stop to properly perform those duties will be limited to the lesser of the actual expense incurred or the daily federal government per diem, according to the geographic location of the destination. The federal per diems are found on the PeopleSoft Travel Information Website. Meals involving only employees will not be reimbursed unless there is an explicit business purpose. Department lunches held to recognize achievements will be charged to reward and recognition. Meals will be reimbursed as a business expense if a customer is present with whom a valid business relationship exists. Customers are defined as agents, brokers, prospective employees, providers, and vendors. Receipts for meal expenses must be obtained, detailed receipts are preferred. Gratuities are not to exceed 20 percent. F. Transportation Please refer to Section VI for details on allowable transportation expenses. Business Expense and Travel Policy 8 of 14 G. Entertainment Please refer to Section VII for details on allowable entertainment expenses. H. Telecommunications Charges Please refer to Section VIII for details on allowable telecommunication charges. IV. EXPENSES – Non-allowable The following expenses are not reimbursable. The listing is not all-inclusive. Accident Insurance – Travel accident insurance is provided under a corporate Blanket Travel Accident Insurance Policy that covers all employees for business-related travel. Additional insurance is not necessary and will not be reimbursed. Alcoholic beverages – Employees who are conducting government related business will not be reimbursed for alcoholic beverages. Expenses of family members or companions while accompanying employees on business trips, including cancellation and transfer charges or additional fees. Personal items, such as clothing, umbrellas, health and beauty aids, etc. Personal reading materials Hotel and in-flight movies Mini bar items Luggage and attaché cases Birthday cakes and gifts to employees Parking tickets Formal wear rentals and purchases V. NEW YORK STATE SALES TAX EXEMPTION As a not-for-profit corporation, HealthNow is not required to pay New York State sales tax on hotel rooms, as well as all other purchases subject to the tax. Tax Exempt forms, must be presented to the reservations desk clerk when registering, regardless of the method of payment. The Tax Exempt form can be found on the PeopleSoft Travel Information Website. Obtaining this exemption is an employee responsibility. VI. TRANSPORTATION All transportation charges, except those for corporate officers, are to be charged to the Corporate Ghost Card. To ensure proper accounting controls, all ticket charges must be reported on expense sheets via the PeopleSoft Expense Module. A. Air Business Expense and Travel Policy 9 of 14 Officers and Directors are encouraged to exercise judgment in the selection of flights to ensure that several key employees are not on the same flight. Airlines tickets should be secured through the corporate travel agency. Employees obtaining airline tickets on their own risk the chance of not being reimbursed. Other than in emergency situations, any exceptions must have management approval prior to the arrangements being made. 1) Airfares All air travel will be at coach.. Lowest fares require 21-, 14-, or 7-day advance purchases. It is imperative that passengers understand the various rules and additional fees are charged for changes. Upgrades to business or first class are considered a personal expense and will not be reimbursed. The company has nationally negotiated rates with United Airlines, which should be utilized whenever possible. Any low-fare options declined by the traveler or travel arranger will be reported to the company. 2) Airline tickets Airline ticket numbers must be indicated on expense sheets and should be noted when reporting changes or cancellations to tickets. a. Changes to airline tickets Charges that result from changes in flight times may not be considered a valid business expense. If the changes were made for a non-business purpose, the employee may be responsible for the cancellation fee and/or the difference in the cost of the air travel. b. Unused airline tickets If a trip is canceled or postponed, an unused ticket that is nonrefundable must be applied to a future trip. Unused tickets should be noted by Travel Planners and employees and used as soon as possible. B. Cars 1) Mileage for use of personal cars Expenses for mileage, tolls, and parking incurred while using personal cars during approved business travel will be reimbursed. Mileage will be reimbursed at the current IRS rate and includes the cost of insurance, gas, oil, etc. Business Expense and Travel Policy 10 of 14 You are allowed the current IRS mileage rate times the number of allowable business miles. Commuting mileage is non-reimbursable. Total allowable mileage should be defined as the number of miles incurred less the number of miles incurred between home and your normal place of business. Mileage reimbursements must be submitted on a monthly basis immediately following month end and reported on an expense sheet via the PeopleSoft Expense Module. A mileage form is available on the PeopleSoft Travel Information Website. 2) Rental Rental cars must be approved in advance by the employee’s manager. Standard allowable class size is intermediate for Hertz, full size for Enterprise. Please return the vehicle fully fueled. It should be noted that rental car locations on or near the airport charge an excess fee. If at all possible, please arrange pickup and drop-off at non-airport locations. Navigational systems are considered a personal expense, and if reserved, will be the employee’s responsibility. The company has nationally negotiated contracts, which cover insurance liability, with Hertz and Enterprise. Additional rental insurance is not needed. C. Rail Rail transportation may be used instead of air for travel that can be completed within a reasonable amount of time. Our corporate travel agency can book this, or you may call directly. D. Taxi/bus/shuttle The most reasonable ground transportation available should be chosen. E. Foreign Travel HealthNow will reimburse for reasonable expenses incurred for foreign travel including, passport fees and photos, visa charges and required immunizations. VII. ENTERTAINMENT The expenses of providing entertainment to a client, customer, or employee can qualify as an ordinary business expense. Entertainment activities can include the cost of meals. Entertainment can be provided at facilities such as nightclubs, social clubs, sports facilities, and theatres. To qualify for a deduction, the expenses must be “directly related to” or “associated with” the active conduct of the trade or business or for the production or collection of income. Expenses are not allowed for entertainment that is lavish or extravagant. Business Expense and Travel Policy 11 of 14 Business must be discussed in a substantial manner before, during, or after the entertainment activity. The IRS has established the following documentation guidelines for business meals and entertainment, which must be followed to conform to the tax laws: A receipt for an expense Names of individuals, their titles and company name The name and location of the establishment where the meal or event took place The exact amount and date of the expense The specific business topic discussed Entertainment expenses are not reimbursable when government-related business is conducted. VIII. TELECOMMUNICATIONS CHARGES A. Cellular Phones and Pagers All business cellular phones and pagers must be approved by Director level or above and ordered through the Corporate Purchasing Department. Failure to comply may risk denial for reimbursement. Senior management must approve any exceptions. B. Long Distance Calls In an effort to reduce costs when traveling, the purchase of phone cards is recommended. The company considers personal calls of reasonable length an allowable expense. Hotel receipts should reflect long-distance charges, and these charges should be shown on the expense sheet. It is strongly recommended that the 800 line be utilized during business trips to access voicemail and other employees. To speak with an employee, enter your extension, your voicemail password, *T, the extension number of the person with whom you wish to speak, and the #sign. Buffalo & Binghamton 1-800-760-2005 Albany 1-800-453-4990 CSCO Phones 1-888-489-1260 C. Hotel Internet Fees It is important to check with your hotel for any Internet related fees prior to use and to use discretion prior to incurring charges. IX. EXPENSE SHEET REPORTING REQUIREMENTS Business Expense and Travel Policy 12 of 14 All travel and business expenses must be reported on an expense sheet via the PeopleSoft Expense Module. Employees have the responsibility of ensuring that their expense reports are submitted timely according to the following timelines: Seven days after completion of a business trip or incurrence of a business expense by an employee Seven days after receipt of the corporate credit card statement by officer corporate credit cardholders Questions concerning expense report items or travel policies should be referred to the Travel and Expense staff. Forms referenced in these guidelines can be found on-line at the PeopleSoft Travel Information Website. A. Documentation/Receipts Original receipts and documentation must be submitted with an expense sheet. Photocopies or employee-written documentation are not acceptable. Improper documentation could result in denial of reimbursement and future advances and in additional personal income tax being levied on the employee by the Internal Revenue Service. 1) Documentation of travel expenses Include the following Costs of transportation, meals, lodging, and incidentals (telephone, tips, taxicab fares, parking, etc.) Date of departure and return Airline ticket numbers Number of nights spent at the hotel Place(s) of travel including the name or location of each destination Business purpose(s) of the trip Nature of the business benefit 2) Documentation of allowable (non-government related) entertainment expenses Include the following: A receipt for an expense Names of individuals, their titles and company name The name and location of the establishment where the meal or event took place The exact amount and date of the expense The specific business topic discussed 3) Receipts Employees must support their business expenses by obtaining and submitting original receipts. This documentation is necessary for the company to establish a business and tax deduction by substantiating that Business Expense and Travel Policy 13 of 14 the expenses incurred are either “directly related to” or “associated with” the active conduct of the company’s business. Original receipts must be attached to expense sheets. Photocopies or employee written documentation are not acceptable. Improper documentation could result in the IRS levying additional personal income tax and/or the denial of reimbursement or future advances. The receipts should be taped, in date order, to 8-½ x 11 sheets of blank paper with the “Sheet ID” noted on the receipt package. B. Shared Expenses Each employee should account for his/her expenses. However, if this is not practical, one employee should pay the expense and show the names of all others present. If portions of the expense are to be charged to different cost centers, appropriate changes should be made to the line accounting. X. EXPENSE SHEET APPROVAL All expense sheets must be approved on-line by management via the PeopleSoft Travel and Expense module. A “Quick Step Guide to Approving Expense Sheets” is available on-line at the PeopleSoft Travel Information Website. Original documentation and receipts must be forwarded to the Travel and Expense staff upon approval of expense sheets. XI. EXPENSE SHEET AUDITING The Finance staff thoroughly reviews all expense items to ensure they conform to all regulations, thus providing the Officers a service by enhancing their control over expenses. However, this secondary review does not relieve the approver of primary responsibility. It should be recognized that the Company is responsible for the stewardship of subscribers’ money and government funds. In this capacity, the Company is subject to regular audits by various authorities, including HealthNow Corporate Audit, the IRS, and FAR; and the Accounting Department/Travel and Expense Department is held responsible for the maintenance of appropriate documentation for all expenses claimed. XII. REIMBURSEMENT Once an expense sheet has been audited, a check or electronic reimbursement will be generated to the employee the next business day. Please note that electronic reimbursements are currently available to only those Buffalo, Binghamton and Albany employees (currently excluding the Foundation for Healthy Living) who use direct deposit for payroll. It should be further noted that expense reimbursements are posted to the “net” account on file with the payroll department. Notification of deposits will occur via email. This change is effective for payments made after March 3, 2008. Business Expense and Travel Policy 14 of 14