OCFO Policies

The purpose of this policy is to establish the rules for the University’s accountable plan and outline the tax treatment of cash advances and expenses reimbursements.

To ensure that the cost of a sponsored agreement is comprised of the allowable direct costs incident to its performance, plus the allocable portion of the allowable F&A costs of the institution, less applicable credits (OMB A-21 Section C), the University developed Policy FA 174 to address the accounting treatment for credits (i.e., refunds, rebates, incentive payments, and other credits) that are applicable to specific projects or to cost pools used in the development of the University’s Facilities and Administrative rate proposal.

Policy FA 135 explains how the University applies conversion rates and fees to cost centers when the University receives deposits or makes payments in foreign currencies. 

Policy FA 180 specifies the University’s accounting for and recording of pledges receivable in the general ledger, which is processed on a quarterly basis.

This policy applies toall University employeesand covers both authority to sign agreements with third parties and to approve financial transactions inthe GMSFinancial System (“GMS”).

The policy applies to all University departments that use University bank accounts, foreign currency, wire transfer or ACH (automated clearing house) payments, and accept credit card paymentsor online payments.

This policy provides guidance to the Campuses when a budget amendment(s) needs to be made to the Current Approved Budget (CAB) in the University’s Financial System (GMS)

This policy provides guidance related to the review and reconciliation of transactions posted to the University’s general ledger in the various organization worktags, e.g. Cost Centers, Grants, Gifts, Projects, etc., to enhance internal controls, ensure timely adjustments/cost transfers, and prevent overdrafts.   The Budget to Actual Reports (BAR) should be used for the review and reconciliation of the financial transactions

Policy FA 160 provides guidance related to the review and reconciliation of transactions posted to the University’s general ledger in the various organization worktags, e.g. Cost Centers, Grants, Gifts, Projects, etc., to enhance internal controls, ensure timely adjustments/cost transfers, and prevent overdrafts. 

Policy FA 130 outlines specific responsibilities and procedures for acquisition, use and disposition of capital equipment, and maintain an accurate inventory of movable capital equipment for financial reporting and department management purposes.  Equipment is considered a capital asset if the equipment has a useful life of one year or more and has an acquisition cost of $5,000.00 or more. This policy is also issued to conform to the Office of Management and Budget (OMB) Uniform Guidance (2 CFR 200), section 200.313 Equipment and its predecessors, OMB Circular A‐110 and OMB Circular A‐133 (for federally sponsored projects issued prior to December 26, 2014). 

The purpose of this policy is to describe the parameters around travel arrangements for University business and for the reimbursement of such travel expenses.

University Services ONLY. Use FA-112 for other campuses. The purpose of this policy is to describe the parameters around travel arrangements for University business and for the reimbursement of such travel expenses.

This policy addresses payments for and reimbursements of business travel expenses. To be in compliance with IRS Publication 463, the employee must adequately account for expenses within 60 days after the expense was paid or incurred.

Policy FA 166 describes the guideline and appropriate procedures to capitalize and depreciate expenditures associated with capital projects including construction, technology, and software projects.

FA 133 states that The University recognizes its legal obligation to make payment to the employee on pay day. To accomplish this, the University encourages employees to subscribe to direct deposit. For employees that do not subscribe to direct deposit, the University will print paper checks, and those checks will be made available to employees on pay day.

Georgetown University (the University) receives contributions from various donors in the form of cash, pledges, securities, and gifts-in-kind. The purpose of the gift processing policy is to ensure that all gifts are deposited and recorded by the Office of Advancement (OA) in a timely fashion and within the order in which the gifts are received as well as to ensure that the University is spending the donated funds for purposes intended by the donor.

As outlined in the Employee Mobile Device Tax Compliance Policy (FA 129), a University-provided mobile device is considered to be part of an employee’s gross income unless it is used primarily for business purposes. Immaterial and incidental personal use is permitted. Prior to issuing a device to an employee, please read UISO’s University-Provided Mobile Device Policy as well.

This policy establishes the requirements for the University’s accounting for endowment funds in accordance with the Financial Accounting Standards Board Accounting Standards Codification (FASB ASC), Not-for-Profit Entities.

The purpose of this policy is to outline:

1.Responsibilities of cardholders and departments using the ProCard.

2.Criteria for allowable and unallowable ProCard expenditures.

3.Requirements for the allocationand approval of ProCard expenditures.

This policy illustrates the use of approved Cash Advances either by University Procurement card or by Special Check

In accordance with the University’s bylaws and general principles of good governance and fiscal responsibility, the University has authorized specific employees to commit University funds for expenditure or to receive funds from third parties in exchange for services.

The purpose of this Payment Card Industry Data Security Standard (“PCI DSS”) Policyis to secure payment card transaction data in order to protect account and personally identifiable information on payment cards (e.g. credit cards or debit cards). This policy (the “Policy”) defines and describes the responsibilities and required practices of Georgetown University (the “University”) with respect to the receipt, use, storage, processing, and retention of payment card data.

Formerly FA-102. There are three (3) primary means of purchasing products and services at the University -Purchase Order, Procurement Card, and online via the Georgetown Management System (GMS) Punchout catalog.

Georgetown University is committed to the responsible stewardship of the financial assets entrusted to it. A transparent set of standards delineating prohibited financial activity and describing responsibilities for the reporting and investigation of such activity helps to achieve this goal.

The purpose of this policy is to provide guidance related to the review and reconciliation of FederalWorkStudy(FWS)Program accounting review and reconciliation process.

This policy provides guidance related to the review and reconciliation of Federal Work Study (FWS) Program accounting review and reconciliation process.

The Gift Policy (FA 162) provides guidance to departments giving gifts to employees and non-employees, as well as guidance to employees receiving gifts from external parties in their role as a GU employee. Departments should have the applicable form completed, complete the Georgetown University Gift Form and maintain completed and signed forms in their University department. 

To ensure that the University conducts the necessary tax and legal review of potential joint ventures.

To ensure credit card deposits are recorded timely and accurately.

Each contribution is reviewed for donor’s restriction or lack thereof to ensure it is assigned to the appropriate net asset classification for reporting in the University’s financial statements. Gift Accounting in the Office of Advancement works closely with the departments receiving the contributions and the General Accounting Office in the Division of Financial Affairs to determine the type of contributions (i.e., basic gift, plant gift, and endowment gift) as well as restrictions imposed by the donors.

The purpose of the New Entities and Presence Policy (FA 623 formerly FA 177) and Procedure (includes map of approved teleworker states) is to identify and monitor financial, legal, employment, risk, and tax compliance components as the University (a) develops new entities (b) develops a new or expanded legal presence in US or non‐US jurisdictions, or (c) enters into international agreements.

This is the procedure to accompany FA-623, New Entities and Presence Policy

FA 109 states that If a payroll check is lost, stolen, or has incorrect information on it, Georgetown University ensures that Payroll issues a replacement check timely to the employee in the correct amount and with the correct information. 

To facilitate the process of completion of Federal and Local payroll withholding forms.

ThisPolicy applies to all Georgetown University departments and employees who engage or utilize Suppliersthat accept, process, and/or maintain payment cards, e.g. credit or debit cards. Contracts with Suppliers that accept, process and/or maintain payment cards must contain terms that are consistent with this Policy.

This policy covers the creation, administration, reconciliation, transfer, and closing of petty cash and imprest checking accounts.

FA 141 states that a department can be approved to establish a petty cash account to reimburse employees for miscellaneous operational expenditures not greater than $75 per item and not purchased through other procurement methods. Examples of expenditures for which departments may use the petty cash accounts are postage, taxi fares, refreshment for meetings, mileage reimbursement, tolls, parking, and supplies. This policy covers the creation, administration, reconciliation, transfer, and closing of petty cash and imprest checking accounts.

Policy 107 outlines guidance when Participant Costs are applicable to Sponsored Programs. Indirect cost allocations attributable to Participant Costs are the main focus of the policy.

Policy 113 establishes the requirements for recording cost transfers on the financial accounting records of the University. The accounting practices are performed in accordance with internal financial controls and federal regulations.

Policy 119 ensures that revenue from industry sponsored clinical trials at the University is properly recorded. Additionally, it assigns responsibilities associated with the accounting of such trials.

Policy 122 provides guidance regarding Service Centers; including Specialized Service Facilities (SSFs) and Recharge Center Units (RCUs). Additionally, this policy establishes general guidelines for proper rate development and review of federally sponsored awards.

Policy 130 ensures proper accounting of university and externally funded capital equipment. It provides guidance in reporting to sponsoring agencies, planning and formulating budgets, screening for redundant or excessive purchases, and ensuring accuracy of inventory valuation and depreciation expenses. Additionally, this policy ensures that accurate property reports are filed with government and sponsoring agencies at the close of a grant or contract.

Policy 131 provides guidance regarding: 1) effort commitments for sponsored projects, 2) payroll allocations to sponsored projects, 3) certification of effort to sponsored projects; and 4) to conform to OMB Uniform Guidance (2 CFR 200), section 200.430 Compensation for Personal Services and its predecessor, OMB Circular A-21 (for federally sponsored projects issued prior to December 26, 2014) – for which the University follows the prescribed Plan Confirmation method for effort reporting.

Policy 132 provides guidance regarding Cost Sharing; which is the portion of total project costs not paid by the sponsor. Cost Sharing may be required by the funding agency (i.e. Mandatory Cost Sharing) or voluntarily proposed by the University (i.e. Voluntary Committed Cost Sharing).

Policy 143 provides guidance regarding: (1) subrecipient eligibility determinations, (2) assessing and managing risk when passing federal funds to subrecipient organizations, and (3) ongoing subrecipient monitoring activities.

Policy 146 provides guidance related to the monitoring and transfer of unobligated balances in the financial accounting records of the University. This guidance is in accordance with a proper system of internal financial accounting controls, federal regulations, and specific sponsors requirements. Additionally, it ensures that transfers of unobligated balances do not affect award amount, grant and contract revenue, and budgeted indirect revenue collected by the University.

Policy 149 provides guidance related to the timely monitoring, classification and resolution of sponsored projects in the overdraft status.

Policy 158 sets the expectations for proper Financial Reporting and Closeout for sponsored projects. It reinforces the roles and responsibilities of individuals involved in the process, and addresses circumstances that may arise during the award closeout.

Policy 160 provides guidance related to the review and reconciliation of transactions posted to the University’s general ledger. It enhances internal controls, ensures timely adjustments/cost transfers, and prevents overdrafts. Note – the Budget to Actual Reports (BAR) should be used for the review and reconciliation of financial transactions.

Policy 163 states that all university units with material grant activity are required to have a reserve for actual or potential losses arising from sponsored projects activity. To ensure that activities from sponsored projects have sufficient and sustained reserves, the adequacy of the reserve is evaluated quarterly and, when necessary, adjustments to the reserve are posted.

Policy 172 provides guidance regarding Program Income. Program Income is directly generated by a federally sponsored project occurring during the period of performance of that project. Note – Gross income related to licenses or royalties on patents and copyrights are exempt from this policy.

Policy 179 outlines the appropriate procedures for establishing an Advance (at Risk) Grant Account. This is done in anticipation or the finalization of a sponsored award. The creation of an Advance (at Risk) Account aids in the allocation/ assignment of expenses, and reduces the need for a cost transfer.

Policy 186 provides guidance regarding allocating costs to sponsored projects, thus, conforming to OMB Uniform Guidance (2 CFR 200), section 200.405 Allocable Costs, and its predecessor, OMB Circular A-21 (for federally sponsored projects issued prior to December 26, 2014).

Policy 190 establishes the University’s requirements for small business subcontracting plans. Certain percentages of the direct cost expenditures must be spent with suppliers certified under the various Small Business Administration programs:

Policies enforced by Financial Affairs should be easily found, understood, reviewed and approved by appropriate stakeholders on a regular basis, and administered fairly and consistently. A transparent and replicable approach to crafting Financial Affairs policy helps to achieve these goals.

This policy applies toPosition Budgets for all Faculty, Fellow and AdministrativePosition Managementpositions.This policy applies to Roster Data Management for all Faculty, Fellow, Staff and Student positions and jobs in Position Management and Job Management organization

The scope of this policy includes all University Records and Non-records as defined in Appendix Ito this policy. It applies University-wide, including the Main Campus, Law Center, Medical Center, and University Services. It applies to allfaculty, staff, academic administrative personnel, consultants, temporary workers, and student employees.

The Reporting Cash Transactions Policy (FA 181) outlines how the University complies with its IRS Form 8300 reporting requirement. When the University receives of any single cash payment or series of payments on a related transaction within a 12-month period that exceed $10,000 it must be reported to the IRS. In a University setting, the most frequent payment of this type would be tuition. A single tuition payment or a series of payments exceeding $10,000 must be reported.

FA 181 states the IRS requires that the receipt of any single cash payment or series of payments on a related transaction within a 12-month period that exceed $10,000 must be reported to the IRS. In the University setting, the most frequent payment of this type would be tuition. A single tuition payment or a series of payments exceeding $10,000 must be reported.

Policy FA 137 outlines the procedures that are followed by the University when a payee’s bank returns checks made payable to the University

Revenue Generating Agreements Policy (FA 157) provides guidance on which types of agreement are routed through this review process. The Tax Department reviews revenue generating agreements to determine if the activity generates unrelated business income and/or private business use.

University policy and procedures for identifying, remedying and recouping salary overpayments to University employees.  

Through the Student Employees – Applicability of FICA Tax (HR 1012) Georgetown University has automated procedures that complies with IRC Section 3121 (b) (10), which provides an exemption from FICA tax for service performed by a student employed by the university in which he/she is enrolled and regularly attends classes.

The purpose of this policy is to address the frequency, timing, completeness, and accuracy of reporting enrollment status to the NationalStudentLoanDataSystem(NSLDS) via the National Student Clearing house (NSC).The University sends enrollment transmission to the NSC according to the guidance outlined below to maintain compliance with federal regulations.

The Tax and Reporting of Moving Expense for Employees Policy (HR 1014) addresses the tax treatment of Employee moving expenses. For tax years 2018 through 2025 are considered wages and will be reimbursed net of the required tax withholding.

The Tax Treatment and Reporting of University Provided Motor Vehicles Policy (FA 167) addresses the tax treatment of University vehicles by employees. Under the Internal Revenue Code, a motor vehicle provided to an employee by the University is considered a working condition fringe benefit and no portion of the value of the vehicle needs be included in the wages of the employee. However, if the vehicle is used for personal purposes, an allocation based on mileage will be used to determine the amount of personal use.

The Tax Treatment of Athletic and Other Event Tickets Purchased with University Funds policy (HR 1015) addresses the tax implication of receiving tickets to athletic or other events purchased with University funds. The occasional Georgetown University athletic or other Georgetown University event tickets provided to an employee for personal use is excluded from the employee’s income. Regular use of athletic or other event tickets by an employee for non-business purposes will result in taxable income to the employee subject to applicable tax withholding.

The Tax Treatment of Subsidized University Housing for Senior Administrators, Faculty, and Staff Policy (FA 169) addresses the tax implications of University provided housing, which is generally treated as income meaning that the subsidized portion of the housing is taxable to the employee who receives the benefit under the Internal Revenue Code. However, there are certain circumstances in which the value of the subsidized portion of the employer-provided housing is appropriately excludable from income.

The University offers an undergraduate and graduate level Tuition Assistance Program (TAP). The Tuition Remission Tax Liability for GU Employees Policy (FA 103) provides information on the taxation of tuition benefits.

As part of its normal business operations, Georgetown University (the University) receives funds electronically via wire transfers, Automated Clearing House (ACH) deposits, and credit card sales (collectively referred to as “electronic receipts” for purposes of this policy) for goods and services provided by the University. Policy FA 120 establishes the accounting requirements for unclaimed electronic receipts deposited to the University’s bank account(s).