Compliance Corner

Compliance Corner: Understanding the Business Expense (BEX) Policy

Jaclyn Lindabury — Mon, 01 Jun 2026 19:42:19 +0000

Compliance Corner: Understanding the Business Expense (BEX) Policy Jaclyn Lindabury Mon, 06/01/2026 - 13:42

Welcome back to Compliance Corner, your go-to spot for clear, practical explanations of university policies that affect your daily work. This edition focuses on the Business Expense Substantiation & Tax Implications (BEX) policy, a straightforward set of rules designed to keep everyone compliant while protecting you from unexpected tax bills.

A Bit of Background

The University of Colorado operates under what the IRS calls an “Accountable Plan.” In plain English, this means the university can reimburse you (or pay directly via university cards) for work-related expenses without treating the payment as wages on your paycheck.

The IRS requires clear proof that every expense was for university business. That’s where the BEX policy comes in. It applies to:

Procurement Card (P-Card) purchases
Travel Card and Airfare Card charges
Cash advances
Out-of-pocket reimbursements

The university rules have been in place for many years, with the most recent system-wide procedural statement effective January 31, 2025. The goal is simple: document the expense properly and on time so it stays non-taxable.

Why Does This Matter to You? (The “Why” in Everyday Terms)

Imagine you use your P-Card to buy supplies for a research lab. The university pays the bill because it’s official CU business.

Without timely substantiation (a clear “business purpose,” receipts where required, and repayment of any personal portion), the amount is required to be treated as additional taxable wages. That means:

It shows up as income on your pay advice and W-2.
You owe income taxes, Social Security, Medicare, and applicable state taxes on it, which will reduce your take-home pay.

Your Responsibilities

You must:

Create and submit an expense report in Concur within 90 days of the purchase date (or the end of the trip for travel-related expenses). If you have a delegate, your delegate can create the report but you must submit it yourself.
Clearly explain the business purpose (who, what, when, where, and why it was expended).
Attach required receipts.
Repay the university for any personal charges or unused advance funds.

Pro tip: Concur sends you (and your supervisor/delegate) reminders at 30, 60, and 75 days for transactions made on a university issued card. Don’t wait for the final notice—submit early! Creating the report or handing receipts to a delegate does not count as submission. You must hit “Submit” in Concur before the 90-day clock runs out.

Consequences of Non-Substantiation

Continue Your Professional Development

We encourage you to visit the Finance Procedural Statement: Business Expense Substantiation & Tax Implications page to:

Watch the quick look video.
Review the procedural statement.
Review out the overview slide deck.

Customized Training: We offer customized training sessions designed specifically for individual departments across campus. Find out more.

Questions: Need help with a specific report or want to discuss an unusual situation? Reach out anytime to fiscalcompliance@colorado.edu. We’re happy to walk you through it.

If the 90-day deadline is missed, the expense is flagged as taxable.

If you do not meet the conditions of the university’s Accountable Plan by complying with the above procedures, you will have the amount of the related expense(s) (commercial credit card transaction, cash advance, reimbursement) reported as taxable income on your subsequent pay advice and on IRS Form W-2. This may result in decreased take-home pay in your subsequent paycheck, due to additional taxes withheld to cover the reported additional income.

If you made a demonstrable and good-faith effort to comply but experienced exceptional circumstances outside of your influence or control that prevented the expense report from being processed as non-taxable in the appropriate time, contact us right away at fiscalcompliance@colorado.edu. Forward the “Taxable Expenses Notification” email you received from Concur (with the attached list of transactions), and explain the situation. Include any documentation that will help confirm the facts. Exception requests must be received within 3 months after an expense is flagged as taxable for review.

We review the situation and, in rare cases, escalate your request for an exemption to the Director of Tax in the CU System Office.

Bottom Line

Timely expense substantiation keeps your business expenses tax-free and protects the integrity of the university’s Accountable Plan.

Fiscal Compliance Team
Campus Controller’s Office
fiscalcompliance@colorado.edu

Timely expense substantiation keeps university business expenses compliant and tax-free. Read this month's edition of Compliance Corner to learn the basics of ��ӽ紫ý’s BEX policy, including common pitfalls and how to avoid them.

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Compliance Corner: Custom Training Built for Your Department

Jaclyn Lindabury — Fri, 01 May 2026 15:09:21 +0000

Compliance Corner: Custom Training Built for Your Department Jaclyn Lindabury Fri, 05/01/2026 - 09:09

Fiscal Compliance reminds you that we offer customized training sessions designed specifically for individual departments across campus. Our team will work directly with a lead member of your finance team to create targeted training that addresses your department’s unique operational processes, pain points, compliance risks, or day-to-day realities.

Whether your team is small or large, central or decentralized, we tailor every session to match how your department works—so the training is practical, relevant, and applicable.

Examples of Custom Training We Deliver:

Procurement & Purchasing – We can work with your team to master the nuances of business justifications, official functions, or allowable expenses, ensuring your daily operations remain accurate and compliant.
Travel & Expense Reimbursement – Customized training focused on your department’s most frequent travel scenarios (e.g., international conferences, field research, or multi-day site visits) and how to avoid common audit issues.
Internal Controls – Partner with us to workshop and refine your finance team’s internal processes and guidelines. We can help your core fiscal staff establish best practices that keep your department’s operations efficient, organized, and consistently compliant.

Ready to get started? Reach out to Fiscal Compliance (fiscalcompliance@colorado.edu) and we’ll schedule a 20-minute discovery meet-up to understand your department’s needs and propose a custom training plan.

Our team will work directly with a lead member of your finance team to create targeted training that addresses your department’s unique operational processes, pain points, compliance risks, and day-to-day realities.

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Compliance Corner: Employee Clothing

Jaclyn Lindabury — Wed, 01 Apr 2026 20:07:16 +0000

Compliance Corner: Employee Clothing Jaclyn Lindabury Wed, 04/01/2026 - 14:07

At ��ӽ紫ý, prioritizing employee safety, professional branding, and fiscal responsibility guides our approach to job-related clothing, including personal protective equipment. This article provides ��ӽ紫ý–specific guidance on how these items should be purchased.

What clothing expenses does ��ӽ紫ý reimburse?

��ӽ紫ý reimburses essential job-related clothing at no cost to employees when:

Employees are required to wear the clothing while conducting official university business; and
The clothing is not suitable for everyday wear, or the department prohibits the wearing of such clothing during personal time (when the employee is not representing the university and its business).

Examples of clothing which may be provided or reimbursed:

Uniforms and Work Clothes: Daily branded workwear required by a department. For example, branded T-shirts, hoodies, jackets, or pants required by the Department to assist in proper identification as a CU employee.
Personal Protective Equipment (PPE): PPE for hazard-exposed employees, per OSHA and EHS standards. This may include safety glasses, goggles, gloves, hard hats, vests, lab coats, hearing protection, and more. In other settings, it may include steel-toe boots, harnesses, insulated gloves, and fall protection
Police and Security Gear: Standardized uniforms, belts, boots, and protective items (e.g., vests, helmets), as may be necessary to perform security functions effectively.

Personal Use Reminder: Items over $75 (e.g., boots) resembling casual attire may be taxable employee reimbursements, unless personal use is prohibited by department policy. In those cases, please document job necessity in Concur requisitions and expense reports.

How is graduation regalia covered at ��ӽ紫ý?

The University of Colorado does not reimburse individual employees when they procure regalia.

What can departments do?

Academic departments, schools, and colleges may choose to establish their own regalia resource pool by purchasing regalia using departmental funds. Departments taking this approach assume full responsibility for purchasing, storage, maintenance, tracking, and equitable distribution to their faculty.

For the latest details ahead of the Spring 2026 Ceremony, faculty should monitor colorado.edu/commencement/faculty or email commencement@colorado.edu.

For additional details, please consult the following:

Procedural Statement on Sensitive Expenses, for information on allowability.
Procedural Statement on Business Expense Substantiation and Tax Implications, for information on documentation.
Procurement Card Handbook, on the procurement process.

Questions?

For procurement questions, please reach out to the PSC or Campus Controller’s Office.
For regalia questions, please consult the Commencement Office.

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Compliance Corner: Navigating Food & Beverage at ��ӽ紫ý Events

Jaclyn Lindabury — Mon, 02 Mar 2026 17:20:29 +0000

Compliance Corner: Navigating Food & Beverage at ��ӽ紫ý Events Jaclyn Lindabury Mon, 03/02/2026 - 10:20

Now is a great time to review how to host events featuring food and beverages. At ��ӽ紫ý, we value fostering community through shared meals and refreshments, all while upholding safety, legality and fiscal accountability. This guide addresses a key aspect of event planning: purchasing food and beverages for official university functions.

Tax Exemptions for Official University Purchases

One common question in event planning is how to manage sales tax on food and beverages bought for official ��ӽ紫ý functions. Good news: As a constitutionally recognized state institution of higher education, ��ӽ紫ý qualifies for Colorado's governmental purchase exemption, which applies to all sales—including prepared food, non-alcoholic drinks, and even alcohol—when purchased in our official governmental capacity.

According to a 2022 General Information Letter (GIL 22-005) from the Colorado Department of Revenue, sales to state institutions like ours are exempt from state sales tax under C.R.S. § 39-26-704(1). This exception covers the full spectrum of event essentials, from catered buffets to boxed lunches, if the purchase meets these four key conditions:

Purchaser is a Governmental Entity: ��ӽ紫ý, as a state institution, qualifies.
Acting in Official Capacity: The purchase must support allowable university business, such donor reception, not personal use. If you are not sure whether an expense supports allowable university business, please contact us for guidance.
Proper Documentation: Use a university purchase order or, procurement card (p-card or travel card). For additional guidance on documentation needs, please consult our Expense Documentation information session.
Paid with University Funds: To fully secure the exemption and maintain clear compliance, the payment must be made directly from official university accounts—such as SpeedType 20/29 for auxiliaries or fund 34 with Gift Purpose Code "Y" for no-charge events.
1. Using personal funds (cash, personal credit card) does not meet the exemption criteria, as it will result in the tax being applied, even if you present exemption documentation from the University – it is critical that a university payment method is utilized to secure sales tax exemption on a purchase. Opting for university payment methods from the start helps avoid any unexpected costs and keeps our processes straightforward and audit ready.

Pro Tip: Always provide vendors with your university tax-exempt ID and retain receipts showing the exemption was applied. This ensures compliance and is helpful in the event of an audit. Taxes are not reimbursable if you forget to claim the exemption upfront. Vendors must collect them otherwise.

By claiming this exemption correctly, you save university resources. Remember, this applies to direct purchases from licensed retailers or caterers, not retail sales where you are just a customer at a restaurant without official documentation.

Best Practices for Purchasing Food & Beverages

Food and beverages can elevate any event, from casual coffee hours to formal banquets. ��ӽ紫ý's procurement policies emphasize sustainability, inclusivity, and value. Here is how to source them compliantly:

Event Classification and Approval: Start early. Consult the On-Campus Activity Planning Materials and submit the any required forms via DocuSign at least 15 days in advance. Include details on menu, dietary accommodations (e.g., vegan, gluten-free), and sustainability goals (aim for local, low-waste options).
Approved Vendors: Use the CU Vendor or the Buy Local lists for caterers and suppliers. Procurement Cards work for most food & beverage bills (except direct liquor store purchases) under $5,000; for larger orders, and direct purchases from liquor stores, issue a purchase order through the Procurement Service Center. Direct buys from grocery stores or liquor outlets are fine for small events but require itemized receipts or invoices.
Budgeting and Reporting: Allocate via account 550102 (Official Functions with Alcohol) when using gift funds and an expense account that most appropriately describes the conference when using auxiliary funds (note that 550102 should not be used on auxiliaries). For conferences, build costs into registration fees. Track all expenses for year-end audits—exempt purchases still need documentation.
Inclusivity Focus: Offer diverse options to ensure everyone feels welcome, including non-alcoholic beverages and allergen-free choices.

Consult the How to Buy: Official Function Food & Beverage for full details.

A Note on Incorporating Alcohol

Alcohol is permitted at approved events. The governmental exemption applies here, too. Purchases of alcoholic beverages for official functions are tax-exempt if documented properly.

For events with alcohol, you may need to secure a Special Event Permit (SEP) from the Colorado Department of Revenue 60 days ahead via campusalcoholagent@colorado.edu. Review our Alcohol Service on Campus Policy for safeguards like over-service prevention and CUPD consultation.

Stay Safe, Stay Compliant

Hosting compliant events keeps our community thriving. For tailored advice, reach out to Events Planning & Catering, and Compliance, Ethics and Policy.

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Compliance Corner: Costco and Business Purchases

Jaclyn Lindabury — Mon, 02 Feb 2026 18:00:17 +0000

Compliance Corner: Costco and Business Purchases Jaclyn Lindabury Mon, 02/02/2026 - 11:00

Key Resources

Before you head to the warehouse, read our latest announcement on the complexities of making business purchases at Costco.

Does the University of Colorado prohibit business purchases at Costco?

Short Answer: No, but it’s complicated. Read on to find out more.

Important to Understand

The university allows business purchases at Costco using a personal membership.
The university does not allow the purchase of Costco business memberships using university funds.
- The university prohibits Costco business membership agreements. If your department currently maintains a Costco business membership, please do not renew it. For more information on vendor contracting policies and procedures, please consult with the Procurement Service Center.

Why is it complicated?

Recent fieldwork by the Campus Controller’s Office at Boulder found that Costco warehouses do not issue a tax-exemption for business purchases made with a personal membership. This is Costco policy.

��ӽ紫ý is a constitutionally-recognized state institution of higher education, and is exempt from Colorado state and local sales taxes on purchases made in its official governmental capacity. Generally, tax should not appear on P-Card transactions, and we discourage the use of vendors who do not apply appropriate tax exemptions for university purchases.

Final Word

It will be difficult for employees to make Costco purchases that comply with both university and Costco policies. Therefore, we encourage employees to use alternative vendors.

Before you head to the warehouse, read our latest announcement on the complexities of making business purchases at Costco.

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Compliance Corner: Key details to understand about honoraria

Jaclyn Lindabury — Mon, 01 Dec 2025 18:14:18 +0000

Compliance Corner: Key details to understand about honoraria Jaclyn Lindabury Mon, 12/01/2025 - 11:14

Before accepting that speaking fee or payment for outside work, ��ӽ紫ý employees need to know the rules. While the university doesn't have a blanket ban on honoraria, strict adherence to the Fiscal Code of Ethics is required to prevent conflicts of interest or "private gain." Learn the key restrictions and additional disclosure requirements, plus state-level ethics and tax considerations.

Question 1: Does ��ӽ紫ý prohibit employees from accepting honoraria?

Answer: Sometimes.

The University of Colorado does not specifically prohibit employees from receiving honoraria from outside entities. However, under the Fiscal Code of Ethics, the University does prohibit any “private gain” from an employee’s association with the University. This includes situations where an employee is:

receiving substantial [external] compensation for performing university duties;
using university resources for personal gain; and
giving rise to the “appearance” of having a conflict of interest.

As it relates to honoraria, Fiscal Compliance understands the Fiscal Code of Ethics requirements to mean that:

(1) an employee should not be performing tasks for an outside organization during their scheduled work hours;
(2) an employee should not be using University property or resources to support outside tasks;
(3) the tasks performed for an outside organization cannot overlap with the employee’s official work for ��ӽ紫ý;
(4) the employee should not accept an honorarium if the outside organization is a CU vendor;* and
(5) an employee should not accept an honorarium from a non-vendor if it is more than what peers receive for similar work.

For more details on gifts or payments from CU Vendors, please visit our FAQ on the subject.

If the honorarium payment is appropriate under the Code of Ethics, some types of employees are subject to additional requirements.

Research Employees

If the employee is responsible for the purpose, design, conduct, or reporting of research, then they may have to disclose:

Any gift or honorarium valued at more than $5,000
If the outside organization is a foreign entity

This list is not exhaustive. For more information on the relevant disclosure requirements and process, please review this FAQ, or consult with the Research and Innovation Office.

Officers

If the employee is a designated officer, they will have to disclose any gift or honorarium valued at more than $5,000, or certain unremunerated commitments to outside entities. For more information, please contact the Fiscal Compliance team.

Procurement

If the employee, within their official university role, would like to procure goods or services from the outside organization on behalf of ��ӽ紫ý, they must disclose any benefits received from the organization on future Marketplace orders using the Conflict of Interest Evaluation Form (see Procurement Rules and the Fiscal Code of Ethics).

Question 2: Should I be aware of other (non-CU) rules governing honoraria?

Answer: Yes.

The State of Colorado bans public employees from accepting gifts worth more than $75 under Amendment 41. Public university employees fall under that ban. Please consult with the Colorado Independent Ethics Commission to determine whether your non-CU honorarium payment would be appropriate under state public ethics requirements.

Additionally, external honoraria are taxable as supplemental income. Please discuss with a personal tax advisor how best to declare non-CU payments.

Before accepting that speaking fee or payment for outside work, ��ӽ紫ý employees need to know the rules. While the university doesn't have a blanket ban on honoraria, strict adherence to the Fiscal Code of Ethics is required to prevent conflicts of interest or "private gain."

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Compliance Corner: The right codes for food & alcohol at official functions

Jaclyn Lindabury — Mon, 03 Nov 2025 15:50:06 +0000

Compliance Corner: The right codes for food & alcohol at official functions Jaclyn Lindabury Mon, 11/03/2025 - 08:50

Got a question about expense codes? You're not alone! The Fiscal Compliance team is dedicated to providing clear, consistent guidance. To promote transparency and uniform practices across campus, we're taking some common inquiries and sharing the answers with everyone.

Question 1: What expense code should I use for food purchases associated with an official function with alcohol?

We advise campus to use separate codes for food and alcohol to ensure accuracy and compliance.

For expense type: Alcohol, use expense code 550102.
For expense type: Food, use expense code 550100.

Why the split?

The main reason is compliance and accurate reporting.

Policy Requirement: Expense code 550102 is required by policy for alcohol and facilitates the heightened review required for all alcohol purchases, such as ensuring alcohol is recorded in the correct fund type. (See: Finance Procedural Statement on Alcoholic Beverages Purchased for University Events)
Clear Data: Using a separate code for food ensures our alcohol expense reports are accurate and not inflated by food costs.

For more information, please review our previous articles: Mastering the art of completing your CU official function form and An important reminder about official functions with alcohol expenses.

Question 2: Do I have to itemize food purchases in Concur if I use expense code 550100 instead of 550102?

No. Your documentation requirements under policy remain the same, regardless of which expense code you use.

Based on feedback from campus users, the System’s team recently introduced a new Concur itemization feature that copies information from the parent expense to help save you time and effort. However, this new feature does not change what you need to document to meet policy requirements.

Need Step-by-Step Guidance? Review these resources:

If you have questions about fiscal policies and procedures, please feel free to contact fiscalcompliance@colorado.edu. For questions related to alcohol approvals, please contact campus.accounting@colorado.edu.

Using the wrong code can complicate approvals and skew our reporting data. This month, we're clarifying when to use 550102 versus 550100 to keep your reconciliation process clean and compliant.

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Compliance Corner

Compliance Corner: Understanding the Business Expense (BEX) Policy

A Bit of Background

Why Does This Matter to You? (The “Why” in Everyday Terms)

Your Responsibilities

Consequences of Non-Substantiation

Bottom Line

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Compliance Corner: Custom Training Built for Your Department

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Compliance Corner: Employee Clothing

What clothing expenses does ���ӽ紫ý reimburse?

Examples of clothing which may be provided or reimbursed:

How is graduation regalia covered at ���ӽ紫ý?

What can departments do?

For additional details, please consult the following:

Questions?

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Compliance Corner: Navigating Food & Beverage at ���ӽ紫ý Events

Tax Exemptions for Official University Purchases

Best Practices for Purchasing Food & Beverages

A Note on Incorporating Alcohol

Stay Safe, Stay Compliant

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Compliance Corner: Costco and Business Purchases

Does the University of Colorado prohibit business purchases at Costco?

Important to Understand

Why is it complicated?

Final Word

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Compliance Corner: Key details to understand about honoraria

Question 1: Does ���ӽ紫ý prohibit employees from accepting honoraria?

Question 2: Should I be aware of other (non-CU) rules governing honoraria?

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Compliance Corner: The right codes for food & alcohol at official functions

Question 1: What expense code should I use for food purchases associated with an official function with alcohol?

Question 2: Do I have to itemize food purchases in Concur if I use expense code 550100 instead of 550102?

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What clothing expenses does ��ӽ紫ý reimburse?

How is graduation regalia covered at ��ӽ紫ý?

Compliance Corner: Navigating Food & Beverage at ��ӽ紫ý Events

Question 1: Does ��ӽ紫ý prohibit employees from accepting honoraria?