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Expense Reimbursement Policy (Accountable Plan)

Status: Proposal draft for Ganjier Guild (pre-formation). Adopt by board resolution before any reimbursement is paid. Authority: Treasury Regulation §1.62-2 (Accountable Plans). Owner: Treasurer (policy); Administrator (intake & first approval); Bookkeeper (payment & records).

1. Why this matters

Reimbursements paid under a written Accountable Plan are not income to the recipient. They are not reported on a W-2 or 1099, do not count as wages or earnings, and do not create FICA or income-tax withholding obligations. (Treas. Reg. §1.62-2, IRS Pub. 463 ch. 6)

Reimbursements that fail Accountable-Plan rules are treated as taxable wages or non-employee compensation and may also count as earnings for SSA/SSDI purposes. The Guild will not pay any reimbursement outside this policy.

The three Accountable-Plan tests (all required):

  1. Business connection. The expense must be incurred while performing services for the Guild.
  2. Substantiation. Receipts and a written purpose must be submitted within a reasonable time.
  3. Return of excess. Any advance not actually spent must be returned within a reasonable time.

"Reasonable time" safe harbors used by the Guild: substantiate within 60 days of incurring the expense; return excess advances within 120 days. (Treas. Reg. §1.62-2(g))

2. Who is covered

This policy applies to:

  • Board members and officers
  • Committee chairs and committee members
  • Staff (employees and contractors)
  • Volunteers
  • Members traveling on Guild business with prior written authorization

Anyone receiving a reimbursement is referred to in this policy as a claimant.

3. What is reimbursable

Reimbursable, with receipts and a business purpose:

  • Vehicle fuel and parking for travel on Guild business (see §4 — actuals only, no per-mile rate)
  • Tolls
  • Public transit, ride-share, taxi, and intercity bus/rail fares for Guild business
  • Lodging when overnight travel is required and pre-approved
  • Meals during pre-approved overnight travel, capped at the federal per-diem M&IE rate for the locality (or actual cost if lower) (GSA per diem)
  • Event supplies, printing, signage, and consumables purchased for a specific Guild activity
  • Software, subscription, or platform fees pre-approved in writing by the Administrator or Treasurer
  • Postage and shipping for Guild materials
  • Background-check fees for board, key staff, and volunteers in trust roles
  • Conference or training registration pre-approved as a development expense

Not reimbursable:

  • Personal items, personal meals not part of approved travel, personal phone or internet
  • Alcohol, cannabis, or any controlled substance (regardless of legality in jurisdiction)
  • Fines, penalties, parking tickets, traffic citations
  • Spousal, partner, or family travel
  • Tips above 20%
  • Charitable contributions made in the Guild's name without prior board approval
  • Any item already paid by the Guild or by a third party
  • Any expense that would exceed the claimant's approved budget without prior written variance

4. Mileage and personal-vehicle use

The Guild reimburses actual fuel and parking only. The Guild does not pay the IRS standard mileage rate and does not pay a per-mile allowance.

Why: simpler bookkeeping, no need to track odometer logs, and the reimbursement matches actual out-of-pocket cost. Claimants who would prefer the IRS standard rate are welcome to deduct it on their own return where allowed by tax law; the Guild's policy is unchanged.

To claim fuel: submit the fuel receipt (pump receipt or station receipt showing date, gallons, total) along with the trip purpose and date. Fill-ups not tied to a specific Guild trip are not reimbursable.

To claim parking: submit the parking receipt or app confirmation showing date, location, and amount.

Tolls follow the same rule — submit the receipt or transponder statement line item.

5. Approval ladder

Amount per claim First approver Final approver
Up to $250 Administrator Administrator (final)
$250.01 – $1,000 Administrator Treasurer
Over $1,000 Administrator + Treasurer Board (consent agenda or motion)
Any claim by the Administrator Treasurer Board Chair (final)
Any claim by the Treasurer Board Chair Vice Chair (final)
Any claim by a Board member or Chair Treasurer Board Chair if Treasurer; otherwise Chair

No one approves their own reimbursement. Family members do not approve each other's claims.

Pre-approval (in writing, email is fine) is required before incurring any single expense expected to exceed $250, and before any travel involving lodging.

6. How to submit a claim

  1. Use the form. Fill out template-library/finance/expense-reimbursement-form.md (web form via member portal will replace this once live).
  2. Attach receipts. Itemized receipts only — credit-card slips alone are not enough. Photos, PDFs, and screenshots are accepted.
  3. State the business purpose. One sentence per expense: what, why, who benefited, which Guild activity.
  4. Submit within 60 days of incurring the expense. Claims older than 60 days are reviewed case by case and may be denied; claims older than 120 days are denied unless the Treasurer documents an exception in writing.
  5. Send to navigators@ganjierguild.com (or the Administrator inbox during pre-formation), CC the approver per §5.

7. How payment is made

  • Default: ACH to the claimant's bank on file. Setup uses a void check or bank-routing letter; no W-9 needed for reimbursement.
  • Alternate: paper check, mailed to the address on file, on the next bookkeeping run.
  • Never: cash, gift card, or off-platform transfer (Venmo/Cash App/Zelle to a personal handle). These break the audit trail.
  • Target turnaround: 10 business days from approval to payment.

In QuickBooks Online, reimbursements are recorded as Expenses (not bills) coded to the matching expense category, with the claimant entered as a vendor of type "Reimbursable — not 1099." Reimbursements are excluded from 1099 totals because they are not compensation. (1099 process)

8. Advances

Advances are discouraged but permitted for travel and large pre-paid event costs.

  • Request in writing at least 10 business days before the expense.
  • Advances are issued only after the Treasurer or Board Chair signs off.
  • The claimant must reconcile the advance within 30 days of the trip or event using the standard form, attaching receipts and refunding any unspent balance by ACH or check.
  • An advance not reconciled within 120 days is reclassified as taxable income to the recipient and reported on Form W-2 or 1099 as applicable. (Treas. Reg. §1.62-2(g)(2))

9. Volunteers, members, and benefits-sensitive claimants

Reimbursements paid under this policy are not income and are not earnings for SSA purposes. Volunteers receiving SSDI, SSI, VA disability, or Medicaid-waiver supports may receive reimbursements under this plan without those payments counting as wages, provided every Accountable-Plan rule is met. (POMS DI 10505.001)

Volunteers should still keep a personal record of every reimbursement received and discuss their work pattern with a Work Incentives Planning and Assistance (WIPA) counselor if they have questions about their specific benefit. The Guild does not give benefits or tax advice. See programs/volunteers/benefits-aware-volunteering.md.

The Guild does not forgive expenses in lieu of reimbursement as a benefit. That is barter and undermines the Accountable Plan. If a volunteer wishes to donate the value of an out-of-pocket expense back to the Guild, they (a) submit and receive the reimbursement, then (b) optionally write a separate cash donation; the Guild issues an acknowledgment letter for the donation. The two transactions stay separate.

10. Records and retention

  • Reimbursement requests, receipts, and approvals are stored in the Guild's finance drive under Finance/Reimbursements/<year>/<month>/<claimant-lastname-first-initial>/.
  • Retention: 7 years from the end of the fiscal year, matching the IRS recommended retention for travel and expense records.
  • The Bookkeeper reconciles the reimbursement ledger monthly against bank statements and the QBO register.
  • Audit trail: every claim must have receipt → approval email or signature → QBO transaction ID → bank ACH or check number, all linked.

11. Audit, exceptions, and policy review

  • Random audit. The Treasurer pulls 5% of reimbursement claims (or at least 3 per quarter, whichever is greater) for documentation review each quarter and reports findings on the consent agenda.
  • Exceptions. Any deviation from this policy requires a written, signed exception by the Treasurer and Board Chair, retained with the claim.
  • Policy review. The Finance Committee reviews this policy annually, before fiscal-year-end, and proposes updates to the board.

12. Adoption

This policy takes effect on the date the board adopts it by motion, recorded in the meeting minutes. Until adoption, the Guild does not pay reimbursements.

Cross-references