College Policies

OP 60.001 Meals and Refreshments for College-Sponsored Meetings and Events

  • Date: September 3, 2025
  • Purpose: To outline the step-by-step process for authorizing, providing, and reimbursing meals and refreshments for College-sponsored meetings, events, and official functions. This policy ensures compliance with Oregon Government Ethics Law (ORS 244), applicable federal tax provisions (IRC §§ 119, 132, and 274), and Portland Community College’s (PCC) fiscal accountability standards. When provided in accordance with this policy, such meals and refreshments may qualify as non-taxable to employees under federal law, subject to facts and circumstances, and are considered part of the employee’s official compensation package under ORS 244.040(2)(a).
  • Review: This Operating Policy will be reviewed every two years by the Vice President and Chief Financial Officer, with revisions approved by the President via the President’s Cabinet.
  • RACI:
    • Responsible: Requesting department/budget authority
    • Accountable: Associate Vice President, College Operations Vice President, Chief Financial Officer, Finance and Business Services
    • Consulted: Legal counsel, auditors
    • Informed: Employees
  • Policy advisor: Associate Vice President, Financial Operations and Compliance
  • Related policy: Not applicable

Policy

  1. Scope: Applies to all PCC employees, departments, and affiliated entities using College funds to provide or reimburse meals and refreshments in connection with official College business. Additional restrictions may apply to the purchase of meals and refreshments when federal, state, or local grant money is being used. This does not apply to elected officials, eg board members (per ORS Chapter 244).
  2. General policy:
    1. Determine eligibility:
      1. Confirm that the planned meal/refreshment serves a documented and legitimate institutional purpose, is modest and reasonable, and aligns with budget and College Policies.
      2. Verify that the expense meets at least one of the permissible use cases listed below.
    2. Permissible use cases:
      1. Business meal: Meal expense meeting the ordinary and necessary business purpose test under IRC § 274, with employee and outside parties present and cost not lavish or extravagant.
      2. Meals for convenience of employer: Meals provided on PCC premises for substantial business reasons under IRC § 119.
      3. De minimis fringe benefit: Infrequent, low-value benefit excluded from taxable income under IRC § 132. Business connection required.
    3. Restrictions – meals and refreshments are not permitted for:
      1. Internal meetings without compelling business justification.
      2. Personal social gatherings or celebrations.
      3. Expenditures that appear excessive or inconsistent with public expectations.
      4. Restaurant meals for internal-only staff without compelling business justification
    4. Approval process:
      1. The Cost Center manager must review and approve the expense as part of the reimbursement or payment process.
      2. Budget Approval Authority includes ensuring:
        1. Justification under permissible use categories.
        2. Date, time, location, business purpose, and expected attendees (names and affiliations) are clearly documented.
    5. Documentation and submission:
      1. Submit expense report to Finance and Business Services Accounts Payable for reimbursement or as part of p-card reconciliation.
      2. Provide itemized receipts, proof of payment, attendee list, and agenda. A credit card receipt missing itemized details is not sufficient.
      3. Incomplete or undocumented requests may be denied and subject to repayment.
    6. Compliance and tax treatment review:
      1. When submitted for payment, Finance will assess each expenditure to ensure that they are consistent with prudent stewardship of public funds and public expectations (modest and reasonable) and consistent with at least one of the following Internal Revenue Codes and Accountable Plan Rules:
        1. IRC § 119: Meals for the convenience of the employer (must be on campus and connected to employment function).
        2. IRC § 274: Business meals (ordinary, necessary, not lavish, and with employee present). The employee must have actively engaged in a business meeting, negotiation, or discussion to further college interests such as obtain new business, meet with industry peers or to encourage the continuation of an existing business relationship with outside parties.
        3. IRC § 132: De minimis fringe benefits (infrequent, low value).
    7. Audit and monitoring:
      1. Finance and Business Services will monitor for compliance with ethical standards, budget constraints, and federal and state law.
      2. Noncompliance may result in corrective action or repayment required.
  3. Definitions:
    1. Operating Policy: A formal document that outlines the step-by-step process for authorizing, providing, and reimbursing meals and refreshments for meetings and events at Portland Community College (PCC). This policy ensures compliance with Oregon state law, federal tax provisions, and PCC’s financial standards.
    2. College-Sponsored Meetings and Events: Any official meeting, event, or function directly related to PCC business.
    3. Oregon Government Ethics Law (ORS 244): The state law that governs the ethical conduct of public officials and employees, which this policy is designed to comply with.
    4. Internal Revenue Code (IRC): The federal law that governs U.S. tax provisions. This policy specifically references three sections:
      1. IRC § 119: Defines meals that can be considered non-taxable when provided “for the convenience of the employer” on the employer’s premises and for substantial business reasons.
      2. IRC § 132: Defines “de minimis fringe benefits,” which are infrequent, low-value benefits that can be excluded from an employee’s taxable income.
      3. IRC § 274: Outlines the rules for deducting business-related expenses, including meals. A meal expense must meet the “ordinary and necessary business purpose” test and not be “lavish or extravagant.”
    5. RACI (Responsible, Accountable, Consulted, Informed): A model for defining roles and responsibilities in a project or process. In this policy, it specifies who is Responsible for completing a task, who is Accountable for the outcome, who needs to be Consulted for input, and who needs to be Informed of the final decision.
    6. Permissible Use Cases: Specific categories under which providing meals and refreshments is allowed by this policy. They are:
      1. Business meal: A meal where an employee and outside parties are present, and the expense is for a legitimate business purpose (e.g., meeting with a vendor or partner).
      2. Meals for convenience of employer: Meals provided to employees on PCC premises for a substantial business reason (e.g., working through lunch to meet a deadline).
      3. De minimis fringe benefit: Small, infrequent benefits that have a business connection and are of low value (e.g., coffee and donuts for a short staff meeting).
    7. Documentation: The required paperwork to support an expense, including an itemized receipt, proof of payment, a list of attendees, and a meeting agenda.
    8. Cost Center manager: The individual responsible for reviewing and approving expenses within a specific budget.
    9. P-card reconciliation: The process of matching a business credit card statement with receipts and other documentation to account for all purchases.
    10. Accountable plan rules: IRS rules that allow an employer to reimburse employees for business expenses without the reimbursement being considered taxable income to the employee, as long as the expenses are properly documented and have a business connection.
  4. Roles and responsibilities:
    1. Employees: Ensures purchase is permissible per budget approver, initiates requests, ensures justification, and submit complete documentation, including itemized receipts.
    2. Supervisors and Budget Authority: Ensures staff making purchases understand requirements and restrictions. Review for compliance, approve eligible expenses, ensure budget availability.
    3. Finance and Business Services: Audit submissions, ensure alignment with College fiscal policies and tax rules, provide training. Advise on ethics and compliance implications as needed.
  5. Forms: Not applicable
  6. Authoritative references:
    1. ORS Chapter 244 (Oregon Government Ethics Law)
    2. Internal Revenue Code §§ 119, 132, 274
  7. Resources and supporting documents:
    1. Quick Guide
    2. Catering Order Form
  8. Right to change policy: The College reserves the right to interpret, change, modify, amend, or rescind this policy, in whole or in part, at any time, without prior notice.
  9. Approval date: September 3, 2025
  10. Past revisions: Not applicable