Accounting Services Policies and Procedures

Policy
Effective: June 1, 2008
Revised: October 31, 2018

Clemson University will collect payment for goods and services in a timely manner. University departments that extend credit by invoicing will use the University’s billing and accounts receivable system or another preapproved billing and accounts receivable system to allow prompt collection and accurate reporting of the University’s accounts receivable transactions. Invoices should be entered into the system in a timely manner.

Discussion
The Accounts Receivable office of the Office of Accounting Services is responsible for monitoring, processing and recording the collection of all payments due the University for goods or services rendered by departments. The billing processes of all departments that extend credit are subject to the review and approval of the chief financial officer or his designee through Accounting Services.

All approved departments must use the CUBS Web invoice as a standard invoice. Attachments may be included with the standard invoice and should be indicated in the description of charges as deemed appropriate by the billing department.

No invoices for amounts less than $10 should be issued. Departments with charges less than the minimum amount should require payment at the time the goods/services are provided, create a minimum order amount or accumulate charges for a specific customer until the minimum amount is reached.

Interdepartmental invoicing through the receivable process is not advised. All interdepartmental transactions resulting from providing goods and services to University departments should be processed by interdepartmental orders (IDO).

At the department’s request, invoices older than 110 days may be placed with a state-approved outside collection agency. When an account is deemed uncollectible, approval to write off the outstanding debt must be obtained from the controller or associate controller. This will be coordinated by the Accounts Receivable office after all normal collection actions have been taken. Departments will be notified by Accounts Receivable of all pending write-offs. Upon execution, the write-off will offset previously accrued departmental revenues associated with the uncollectible invoices.

High-volume departments with established subsystems may be authorized by the chief financial officer or his designee through Accounting Services to process and collect their own invoices. However, these departments will provide a quarterly summary (as of September 30, December 31, March 31 and June 30) of aged accounts receivable and a report on collection efforts for past due accounts to the University's Accounts Receivable office. These departments must follow the same general collection procedures that are followed by Accounts Receivable. Invoices that are written off must have department head/manager approval, with proper documentation that shows where collection efforts were made. All invoices written off within the quarter must be sent to the Accounts Receivable office as a part of the quarterly aging report. Any invoices that are sent to collections must be placed with a state-approved outside collection agency.

The University Accounts Receivable office will periodically monitor departmental accounts receivable processes to ensure the prompt collection of payments, accurate accounts receivable reporting and adherence to University policies and procedures.

Procedure
Effective: March 1, 2003
Revised: October 30, 2018
Requirements for Invoicing External Customers
All Clemson University departments are required to receive approval prior to extending credit of the University through the invoicing process. Approval must be obtained whether the department intends to invoice through the Accounts Receivable office or within its own department. Departments intending to invoice external customers are required to submit a Department Approval Form to the Accounts Receivable office. The form must be signed by the department head or dean and mailed/interoffice/emailed along with any attachments to the following address:

Accounts Receivable
391 College Ave., Suite 302
Clemson, SC 29634

The Accounts Receivable office will review all submitted approval forms and either approve or deny the request. Each department will be notified once their request has been processed.

Billing Procedures
Once authorization has been received, departmental billing personnel must receive training for invoicing on the University's web invoice system before bills can be created. All invoices must be created using the CUBS web invoice.

When an invoice is finalized, departmental personnel will be responsible for printing and mailing the invoice along with all necessary attachments in a timely manner. Invoices are due upon receipt. Aging for all invoices begins at the time the invoice is submitted for processing. An automatic accounting entry crediting the appropriate revenue account and debiting the department’s accounts receivable account will be posted as a BI journal at that time. Back-up and supporting documentation of the invoice must be retained in the billing department for reconciliation purposes.

Departments will not extend credit/invoice customers with outstanding charges over 60 days old. Monthly aging reports will be available for departmental monitoring of outstanding accounts receivable through the Business Data Warehouse.

The Department of Grants and Contracts Administration is responsible for invoicing all externally funded sponsored projects. Special approval by Grants and Contracts Administration is required for departments to bill Fund 20 projects. If a department is approved to invoice Fund 20 projects, they must use the CUBS web invoice and/or have an approved interface with CUBS.

Receipt of Payments
All invoice payments will be processed through the Accounts Receivable office.

Payments received by departments that are for an account recorded as a receivable must be forwarded immediately to the Accounts Receivable office for processing. An entry crediting the billing department's accounts receivable account will be posted when the payment is received. Invoice payments may be monitored by using system-generated daily payment reports through the Business Data Warehouse.

Corrections to Invoices
Every effort should be made by the billing department to ensure invoices are correct before they are finalized. Any correction/adjustment to the bill amount must be made in writing to the Accounts Receivable office by completing the Invoice/Void/Adjust/Write-Off form within PeopleSoft Finance. Once approval is received, Accounts Receivable will make the necessary correcting accounting entries. These entries will be reflected on the billing department’s monthly revenue report and must be included in monthly revenue reconciliations.

Collections Procedures
If a receivable is not paid within 30 days, the University’s Accounts Receivable office will send a reminder letter to the customer. If the account remains outstanding after 60 days, the Accounts Receivable office will send a second letter informing the customer of the past-due status. A third letter will be sent for accounts outstanding 90 days or more informing the customer that if payment is not received within 20 days, the account may be placed with a state-approved outside collection agency where they may incur collection charges of up to 33.33 percent. Letters are system generated and will be sent on all past-due accounts unless the item is in dispute or with an outside collection agency.

Departments will be notified of any invoices older than 90 days that were not paid within the 20-day period following final notices being mailed. It then becomes the department’s responsibility to request that the account be written off or sent to a collection agency. If no response is received by the department after the invoice reaches 270 days old, it may be deemed uncollectible and be written off. Departments will be notified in writing by the Accounts Receivable office when a write-off is going to take place.

If debts are not collected by the collection agency, they will be submitted to the controller or associate controller for write-off approval. Any remaining balance of all accounts sent to a collection agency may be written off if no payments are received within a 90-day period. Accounts Receivable will make the necessary accounting entries to CUBS for the write-off and notify the department. A debit to the department’s original revenue account and a credit to the department’s accounts receivable account will be posted. Write-offs will be reflected in the billing department’s monthly revenue report and must be included in the monthly reconciliation of revenue.

The Accounts Receivable office also sends past-due letters on behalf of the Grants and Contracts Administration. Letters are sent at the standard interval of 30-60-90 days for nonfederal-sponsored research projects and an interval of 60-90-120 days for federal projects. Collection actions are conducted in accordance with the project agreement and are dependent on the sponsor (customer) and previous payment history.

In general, collections proceed as follows:

• After 60 days, Grants and Contracts Administration will notify the appropriate principal investigator (PI), department chair, college contact and associate dean of research (ADR) regarding nonpayment.
• After 90 days, Grants and Contracts Administration staff will notify the department chair, college contact, associate dean of research (ADR), the vice president of research (VPR) and Accounts Receivable office and coordinate appropriate action, e.g., suspend work, suspend PI’s and/or department’s indirect return or other course of action. Grants and Contracts Administration will continue to coordinate with the college, PI and the sponsor for past-due payments.
• After 180 days, Grants and Contracts Administration staff will send a final notification as indicated for the 90 days and note that in 30 days, the invoice will be deemed uncollectible, and the department/college will be responsible for the debt. The department/college will notify Accounts Receivable of the chart field that will cover the debt.
• Grants and Contracts Administration will distribute an aging report to the ADRs on a monthly basis.

If deemed uncollectible, corrections or a transfer journal will be required in coordination with Grants and Contracts staff and Accounts Receivable office. The invoice will be submitted to the controller or associate controller for approval to be written off.

Departments Authorized to Invoice and Receive Payments
High-volume departments with established subsystems may be authorized by the chief financial officer or his designee through the Accounts Office to process and collect their own invoices. However, these departments will provide a quarterly summary of aged accounts receivable and a report on collection efforts for past due accounts to the Accounts Receivable office. This report must accurately reflect the department’s outstanding receivables. Failure to comply with certification requirements will result in decertification. These departments must follow the same general collection and aging procedures that are followed by the Accounts Receivable. Invoices may not be written off without prior approval from the controller. Invoices that are written off must have department head/manager approval with proper documentation that shows where collection efforts were made. All invoices written off within the quarter must be sent to the Accounts Receivable office as part of the quarterly aging report. Any invoices that are sent to collections must be placed with a state-approved outside collection agency.

The Accounts Receivable office will periodically monitor departmental accounts receivable processes to ensure the prompt collection of payments, accurate accounts receivable reporting and adherence to University policies and procedures.

Departments certified to process and collect invoices will also be responsible for making entries in CUBS, crediting the appropriate revenue account(s) in accordance with the University's Receipting Policy.

Management of Outside Legal Counsel
The Office of General Counsel is available to provide legal services and counseling to all University units and personnel for matters related to the operation of the University. In some instances, either special expertise is necessary or timing dictates that outside legal services be engaged. The following “tips” are provided to assist you in initiating the engagement of outside legal counsel and to offer suggestions on the effective management of those services:

1. All use of outside counsel must be approved by the S.C. Attorney General. It is against S.C. law to use counsel that has not been approved in advance. This is true regardless of the source of funds. CUF, CURF, et al. are private not-for-profit corporations and they can engage these services without AG approval. However, they cannot contract for legal services to be provided to the University or for a University function. The Office of General Counsel will process and assist you in obtaining the necessary approval from the Attorney General. Please contact Beth Newton at (864) 656-3414. She will provide instructional information and assistance in this process. It typically takes 30-45 days to obtain approval.
2. Attorneys’ services are professional services exempted from State procurement regulations. Nevertheless, prudent stewardship demands that we seek to get the best price for outside legal services. The OGC will generally not question the request to appoint a particular attorney. However, in cases where the expertise in question is readily available or there is an existing approval that would suit the needs being addressed, we will discuss these alternatives with you. In some cases, an RFP may result in significant savings. Our goal is to work with you to ensure that you have quality legal services at the greatest savings to the University.
3. Once approved, the outside counsel will be notified of their appointment and the terms of their engagement by a letter from the OGC. A copy of this letter will be sent to you; and, upon its receipt, you may begin utilizing the services of the outside counsel.
4. Once appointed, outside attorneys are required to submit regular bills, on a monthly basis, for their services to the Office of General Counsel. These bills will need to be submitted, along with an AG form which will be provided to you by Beth Newton. Attorneys will be approved for a specified, maximum hourly rate and a monetary ceiling, neither of which can be exceeded for the period of time they are retained. The OGC will not authorize reimbursement for any invoice that exceeds the approved hourly rates or ceilings. You should review each bill carefully to ensure that it is accurate. For instance, if a charge for a meeting with you or your staff is included, be sure that your calendar confirms that such a meeting took place. Any unusual or apparently inaccurate charges should be brought to the attention of the OGC. All bills will be sent directly from the firm to the OGC for approval for payment, where they will be checked to make sure that the ceiling is not exceeded and hourly rates are accurate. The bills will then be sent to your department for payment. At that point, it becomes the department’s responsibility to review the bills and make sure they are accurate before making payment. Any discrepancies or issues identified should be brought to the attention of the outside attorney and an explanation requested.
5. As pointed out earlier, there is a monetary ceiling that is approved by the AG’s Office for the period of time the outside attorney is retained. The OGC will monitor invoices as they come in. If we notice that the amount being paid to the attorney is approaching the ceiling limit, you will be notified and a decision will be made on whether or not to request that the ceiling be increased. Someone in your department should also monitor payments. No invoices will be paid that exceed the approved ceilings.

The OGC is available at any time to consult with you on any facet of the management of outside counsel. Please do not hesitate to contact us at (864) 656-3414 or by email to ogc-l@clemson.edu.

Policy
Effective:  04/15/07
Revised:  04/15/07

Responsible Office: Controller
The University Billing Rate process is required of departments or divisions that provide goods or services to internal and/or external customers on a recurring basis. Annual billing rates and changes to existing billing rates must be submitted to the Controller’s Office following the steps listed in the “Billing Rate Procedure”. Any new billing rates or significant changes to existing billing rates must be submitted to the Controller’s Office and approved by the Administrative Council.

Discussion
The University Billing Rate process is designed as a mechanism for communication, review and approval of University department billing rates for use in budgeting and effective planning. As rates are being developed department or business office staff should communicate with University customers any significant changes. All rates must be documented with a cost or market basis.

When rates are established for goods or services that may be charged to federal programs, government cost principles, as defined in Office of Management and Budget Circular A-21, must be followed. Circular A-21 helps ensure the federal government bears its fair share of total costs.

Legislative appropriations and student fees provide a level of support for the Educational and General (E&G) and Public Service Activities (PSA) of the University. These resources are used to pay salaries, operating costs and build many of our facilities. It is not appropriate for E&G and PSA units to recharge other similar funded units for services and space.

Billing rates that result in a major change in philosophy or have a significant impact on campus users will be forwarded to the Administrative Council for review and resolution.

Billing rates will be posted on the Controller's website for all users.

This policy does not apply to general student fees that require the Administrative Council and the Clemson University Board of Trustees approval.

Procedure
Effective:  04/15/07
Revised:  04/15/07

Annual Scheduled Submission and Approval Dates
To provide adequate time for users of services to plan their budgets, rates should be submitted, approved, and posted based on the following schedule:
November 1 - Telecommunications, Motor Pool, Utilities and Facilities Shop rate charges must be submitted to the Controller’s Office for review and posting.
December 15 –Rates are posted to the Controller’s website.
April 1 - Other billing rate charges for departments not specifically listed above must be submitted to the Controller’s Office for review.
May 15 –Rates are posted to the Controller’s website.

Billing Rate Review and Approval Routing Process
Approval for annual and interim billing rates should be obtained using the following steps:

1. Each Department is responsible for annually calculating and preparing rates for review by their Business Officer and/or Dean or Department Head. A template will be made available each year and will be located at P:/CUBSRPT/Billing Rates FYxxxx departments and within the appropriate folder.
2. A Departmental or Business Office staff member is responsible for assuring that a discussion is held with internal University customers prior to rate approvals for any anticipated billing rate changes.
3. After final calculation and review each Business Officer should submit the rates to the Controller’s Office by the established deadlines listed below. Proper justification should be part of the submitted information for any rate changes or rate additions.
4. After review by the Controller’s Office and, if necessary, approval by Administrative Council, the rates will be posted to the central website.

Submission Guidelines
For existing rates, a template will be made available at P:/CUBSRPT/Billing Rates FYxxxx departments and within the appropriate folder.

• A blank template will be provided by the Controller’s office and will be available at P:/CUBSRPT/Billing Rates FYxxxx departments/Blank Copy FYxxxx . This template can be used by any area that does not already have an existing template.
• Any rates that are based on and justified by current market values will generally not require Administrative Council approval. These types of rates will be posted after the Controller’s Office review.
• A Departmental or Business Office staff member is responsible for assuring that a discussion is held with internal university customers prior to rate approvals for any anticipated billing rate changes.
• Other helpful information for establishing a billing rate can be found under “Billing Rates” on the Clemson University Controller's Office website.
• Detailed documentation should be available, upon request, of the costs and revenue estimates that were used as a basis for the proposed rate. Periodic reviews will be completed by the Controller’s Office.

Additional questions regarding billing rates can be directed to the Controller’s Office.

Guidance
General Discussion
The University Billing Rate process is designed as a method for communication, review, and approval of University department billing rates for use in budgeting and effective planning. As rates are being developed, department or business office staff should communicate with University customers concerning any significant changes. All service center/billing rate activity must either support or relate to the University’s mission.

Rates are developed in order to recover some or all of the federal allowable costs associated with providing a particular recurring good or service. (Because Clemson is an institution that receives federal funds we are required to consistently apply federal costing regulations and guidelines.)

All rates must be justified and documented with a cost or market basis. The requirement is to match revenues and expenses over a break-even period. Usage of a break-even period permits the development of more stable billing rates, and avoids significant billing rate increases and decreases.

Carry Forwards
All operating revenues and expenses associated with running the service center should be accounted for within the unique operating unit/project. A carry forward is the surplus or deficit resulting from the over or under estimating of billing rate expenses or units (calculated on a fiscal year basis). Generally, a positive carry-forward should be equal to no more than 2 months’ worth of operating expenses. Operating surpluses should not be transferred out to subsidize other activities.

Changes to Rates
Billing rates that result in a major change in philosophy or have a significant impact on users (as determined by the Controller’s Office) will be forwarded to the Administrative Council for review and approval. If questions or concerns arise during the Administrative Council’s review, the Controller’s Office will be in contact with Business Officers to discuss possible resolution.

Donated Equipment
The fair market value of donated equipment may be recorded in a service center’s account. Annual depreciation can be determined by dividing the fair market value at the time of the donation by the remaining useful life of the equipment.

*** Equipment originally purchased by a federal project or grant cannot be included in any billing rate.

Equipment
Only depreciation on equipment recorded in a service center’s account can be included in a billing rate. The purchase price is not allowed to be recovered through a billing rate; a capital asset purchased for more than $5,000 must be depreciated over its useful life.

External Users
Separate rates can be established for goods and services that will be offered to external users (non-CU users).

Internal Users
When rates are established for goods or services that may be charged to federal programs (internal users), government cost principles, as defined in Office of Management and Budget Circular A-21, must be followed. Circular A-21 helps insure the federal government bears its fair share of total costs.

Mid-Year Submissions
Submitting billing rates at times other than the dates stated in the billing rate procedures may be considered under the following exceptions:

• beginning a new and necessary service;
• changing due to a significant change in cost; or
• resulting from departmental or service center changes/restructuring.

Changes that result in a major change in philosophy or have a significant impact on users (as determined by the Controller’s Office) will be forwarded to the Administrative Council for review and approval.

New Submissions

• Submission - Any billing rates that have not been previously submitted or approved must be reviewed by the Controller’s Office prior to implementation. These will be forwarded to the Administrative Council for review, discussion, and approval. If questions or concerns arise during the Administrative Council’s review, the Controller’s Office will be in contact with Business Officers to discuss possible resolution.
• Calculation – The costs to be included in a new billing rate must not have been included in the current facilities and administrative cost recovery rate calculation. If you are unsure, contact the Controller’s Office for assistance in determining which costs are appropriate to include in the rate calculation.

Posting/Publishing Rates
Approved billing rates will be posted on the Controller’s website for all users.

Student Fees
General student fees that require the approval of the Administrative Council and the Clemson University Board of Trustees are approved through a separate process coordinated by the Office of Budgets and Financial Planning.

Subsidies
In certain instances, the Provost, budget center, or department may determine that it is appropriate to provide funding to a service center to subsidize all or a portion of the charges to users. Such subsidies are utilized to either reduce one or more of the service center rates charged to all users or to provide reduced rates to a particular group of users (i.e., students). Subsidies should be officially recorded through a non-mandatory transfer to the service center.

In the absence of subsidies, service centers are operated as break-even entities. All operating revenues and expenses associated with running a service center should be properly accounted for within the unique operating unit/project.

Submissions
All billing rates must be submitted to the Controller’s Office for review following the established billing rate procedures and timeline.

Clemson University, South Carolina
Post-Issuance Tax Compliance Policies and Procedures
For Tax-Exempt Bonds
February 28, 2012
The purpose of these Post-Issuance Tax Compliance Policies and Procedures (these “Policies and Procedures”) is to establish policies and procedures in connection with the issuance of tax-exempt bonds (the “Bonds”) issued by Clemson University, South Carolina (the “University”) from time to time to maximize the likelihood that all applicable post-issuance requirements of federal income tax law needed to preserve the tax-exempt status of the Bonds are met. Capitalized terms used herein and not otherwise defined shall have the meanings set forth in the Internal Revenue Code of 1986, as amended (the “Code”) and the Treasury Regulations promulgated thereunder (the “Regulations”).

The University reserves the right to use its discretion as necessary and appropriate to amend or supplement these Policies and Procedures as circumstances warrant.  All such amendments and supplements shall be reviewed by nationally recognized bond counsel (“Bond Counsel”).

The general policy of the University is to comply with the requirements of the Code, the Regulations, and South Carolina law to preserve the tax-exempt status of the Bonds.  The University intends to implement and carry out the procedures set forth herein to ensure such compliance. To the extent additional procedures are required, the Associate Controller of the University (the “Responsible Official”) will be responsible for development and maintenance of such additional procedures to ensure and demonstrate such compliance. The Controller of the University (the “Controller”) shall, as necessary, designate one or more other individuals to assist the Responsible Official.

The Bonds are not and will not be part of any transaction or any series of transactions that attempts to circumvent the provisions of Section 148 of the Code and the Regulations, enabling the University to exploit the difference between tax-exempt and taxable interest rates to obtain a material financial advantage and overburdening the tax-exempt bond market. No device will be employed in connection with the issuance of the Bonds in order to gain a material financial advantage (based on arbitrage) apart from savings attributable to lower interest rates.

Generally, the Responsible Official and anyone designated by the Controller to assist the Responsible Official shall consult with Bond Counsel and other legal counsel and advisors, as needed, throughout the Bond issuance process to identify the use of the proceeds of the Bonds, the expected schedule for the expenditure of such proceeds, the expected compliance, if any, with any exemptions from arbitrage rebate requirements, and all other matters related to the information to be represented or certified by the University in all tax certificates (referred to herein as a “Tax Certificate”), Internal revenue Service (“IRS”) forms, and/or other documents finalized at or before the issuance of the Bonds. 

Training
The University will provide training for the Responsible Official and anyone designated by the Controller to assist the Responsible Official. Training may be in the form of a conference call with Bond Counsel to report on issues and questions that have arisen in connection with these Policies and Procedures and to receive a report on developments affecting the Code and Regulations and their enforcement that may be relevant to the development and implementation of these Policies and Procedures.

Consultation with Auditors
The Responsible Official shall provide a copy of these Policies and Procedures and any amendments or supplements to the auditors of the University and shall instruct such auditors to report to the Controller and the Responsible Official any matters the auditors believe relevant to the matters addressed herein.

No Authority
Nothing herein shall authorize the Responsible Official to bind the University in any way.

Privilege to be Preserved
Nothing herein shall require or authorize the Responsible Official or anyone else to consult with any lawyer unless such consultation is protected by the attorney-client privilege.

More specific policies and their implementing procedures are as follows:

Policy Number 1: General Recordkeeping - The University will retain sufficient records to support the continued tax-exempt status of any tax-exempt bonds it issues, including books, records, and other informational documents supporting the Bonds continued compliance with federal tax requirements.

Implementing Procedures:
The Responsible Official will maintain all records relating to the requirements of the Code and the representations, certifications and covenants set forth in any Tax Certificate executed in connection with any series of Bonds until the date three (3) years after the last principal amount of such series of Bonds has been paid.

If any series or a portion of any series of Bonds is refunded by tax-exempt obligations (“Refunding Obligations”), the University will maintain all records required to be retained until the later of the date three (3) years after the last principal amount of such series of Bonds has been paid or the date three (3) years after the last Refunding Obligations have been retired. 

For all Bonds, the records that will be retained include, but are not limited to:

(a) Basic records and documents relating to the Bonds;
(b) Documentation evidencing expenditure of the proceeds of the Bonds, including, without limitation, construction contracts, purchase orders, invoices, trustee requisitions and payment records, as well as documents relating to costs reimbursed with proceeds of Bonds and record identifying the assets or portion of assets that are financed or refinanced with proceeds of Bonds, including a final allocation of Bond proceeds (see section entitled, “Final Expenditure of Bond Proceeds” herein);
(c) Documentation sufficient to show that all returns related to Bonds submitted to the IRS are correct;
(d) Documentation evidencing use of any projects financed with proceeds of the Bonds by public and private sources (i.e., copies of management contracts, output contracts, research agreements, leases, etc.);
(e) Documentation evidencing all sources of payment or security for the Bonds; and
(f) Documentation pertaining to any investment of proceeds of the Bonds (including the purchase and sale of securities, SLGs subscriptions, yield calculations for each class of investments, actual investment income received from the investment proceeds, guaranteed investment contracts, and rebate calculations).

Policy Number 2: Investment and Arbitrage Compliance – The University will not take any action or fail to take any required action which will cause Bonds to be “arbitrage bonds,” as defined in the Code, and it will comply with the requirements of Section 148 of the Code regarding the investment of the Gross Proceeds of the Bonds and the rebate of excess earnings to the United States Government as required under the Regulations throughout the terms of the Bonds.

Implementing Procedures:
Investment of Bond Proceeds
The Responsible Official shall oversee the investment of any proceeds of the Bonds in accordance with the directions set forth in the Tax Certificate with consultation and direction from the Controller. The Responsible Official will consult with Bond Counsel prior to entering into any guaranteed investment contracts.

Arbitrage
If the proceeds of any issue of Bonds (other than a minor portion and other than proceeds held in a reasonably required reserve fund) are not reasonably expected as of the date of issue to be spent on capital projects within a temporary period of three years, the Responsible Official will ensure that the proceeds are not invested at a yield materially higher than the yield on such issue of Bonds.

If the proceeds of any issue of Bonds are expected as of the date of issue to be spent on capital projects within a three-year temporary period, the proceeds may be invested at an unrestricted yield. The Responsible Official will ensure that such proceeds remaining on hand after the expiration of the three-year period will not be invested at a yield more than .125% (or 1/8^th of a percentage point) above the yield of the Bonds.

The Responsible Official will maintain records documenting the allocations, earnings and investments relating to proceeds of the Bonds.

The Responsible Official will follow generally accepted accounting principles (“GAAP”) to track investments of Bond proceeds.

For each investment acquired with Gross Proceeds of the Bonds or otherwise allocated to the Bonds that was not acquired to carry out the governmental purpose of the Bonds, the Responsible Official shall record its purchase date, its purchase price (reduced by broker or dealer commissions or other administrative expenses, which shall also be stated), its Fair Market Value, accrued interest due on its purchase date, its face amount, its coupon rate, the frequency of its interest payments, its disposition price, accrued interest due on its disposition date, and its disposition date.

Rebate
The Responsible Official shall at least annually consider whether any rebate calculation and/or payment is required. The University will retain the services of a rebate analyst (the “Rebate Analyst”) or other professionals who are necessary, in the judgment of the Responsible Official, to ensure that the requirements of the Code and Regulations regarding arbitrage rebate are met. 

The Responsible Official will ensure that records of investment and expenditure of the proceeds of Bonds are timely delivered to the Rebate Analyst and that the Rebate Analyst prepares annual computation reports which advise the University of any rebatable arbitrage accrued with respect to such Bonds.

The Responsible Official will ensure that the Rebate Analyst timely prepares returns relating to payment of arbitrage rebate (currently on IRS Form 8038-T) and that such forms and any rebatable arbitrage are timely paid to the United States as required under Section 148(f)(4) of the Code. A rebate installment payment must be paid no later than 60 days after the end of every 5^th bond year throughout the term of an issue of Bonds. The payment must be equal to at least 90% of the amount due as of the end of that 5^th bond year. Upon redemption of an issue of Bonds, the University will make a payment of 100% of the amount due no later than 60 days after the discharge date.

Annual Examination and Report
In addition, the Responsible Official shall, within one hundred twenty (120) days of the end of each fiscal year, prepare a written report on matters occurring within such fiscal year relevant to these Policies and Procedures. This report shall in reasonable detail set forth any issues relevant to these Policies and Procedures that occurred in such fiscal year, including calculation and payment of rebate, any defeasance or other payment of Bonds other than in the ordinary course of business and any review of contracts related to the sale, lease or use of Bond-financed property.

Monitoring Reserve Funds
If at any time any trustee or other fiduciary holds a debt service reserve or similar fund in connection with any Bonds, the Responsible Official shall annually review the status of such fund, including the use of any investment earnings thereon.

Policy Number 3: Expenditures and Assets - The University will not take any action or fail to take any action which will cause Bonds to be to be “arbitrage bonds,” as defined in the Internal Revenue Code (the “Code”), and it will comply with the requirements of Section 148 of the Code regarding the expenditure of the Gross Proceeds of the Bonds and the use of assets financed or refinanced with Gross Proceeds of the Bonds as required under the Regulations throughout the term of the Bonds.

Implementing Procedures:
Expenditure of Bond Proceeds
The Responsible Official will monitor all expenditures of Bond proceeds (including investment earnings). Within 150 days of the issuance of any Bonds and at least once each six months thereafter until the delivery of the final report described in the section entitled “Final Expenditure of Bond Proceeds” herein, the Responsible Official shall prepare a report on the expenditures to date of all proceeds of the Bonds, noting all material departures in both schedule and use from the original expectations for such expenditures as set forth in the Tax Certificate delivered upon the issuance of such Bonds, including whether or not any appropriate spending benchmarks for arbitrage rebate exceptions have been met. The Responsible Official will consult as appropriate with Bond Counsel.

Final Expenditure of Bond Proceeds
The Responsible Official shall be responsible for determining when all proceeds of any issuance of Bonds have been spent (other than those held in qualifying reserve or debt service funds) and shall take steps to close out with reasonable promptness all project and similar funds holding the proceeds of Bonds. If any proceeds together with investment earnings thereon (together “Remaining Proceeds”) remain after paying all expected costs of the projects financed, the Responsible Official shall consult with Bond Counsel as to possible ways to apply such proceeds and their investment and use, with the goal of spending all Remaining Proceeds as promptly as is required by law.

Within 60 days of the final expenditure or other disposition of all Remaining Proceeds, the Responsible Official shall prepare a written report on the expenditure of all proceeds of the Bonds (inclusive of investment earnings), including the use of such proceeds and the schedule of such expenditures, together with any allocations or elections made in connection therewith. Such report also shall address whether rebatable arbitrage must be calculated and paid and on what schedule.

If a particular facility is only partially financed with proceeds of Bonds, the Responsible Official shall indicate in the report the percentages of each such facility attributable to equity, the proceeds of Bonds or other sources, including any permitted allocations or reallocations (which, to be valid, must be made within 12 months following completion of such facility).

Use of Bond Financed Facilities
An important goal of these Policies and Procedures is to ensure that there is no threat to the tax-exempt status of any Bonds because of impermissible private business use or private payment or “security” under the Regulations. Such threat can occur if more than 5% of the proceeds of any Bonds are utilized for facilities that are owned by or otherwise impermissibly used by any entity that is not an “Exempt Entity”. An Exempt Entity is an entity that is either a state or local governmental entity or an entity described in Section 501(c)(3) of the Code. The federal government is not an Exempt Entity. Such private business use can be created by sales, leases, special entitlements, management contracts and sponsored research agreements.

The Responsible Official shall prepare and regularly update a list of all facilities and equipment that have been financed in whole or in part with the proceeds of Bonds (“Bond Financed Facilities”).

At least annually, the Responsible Official shall review all uses of Bond Financed Facilities, including any sales, leases or other conveyance of rights to another person to use or control any portion of any Bond Financed Facility, contracts for sponsored research to be conducted in any Bond Financed Facility, management contracts with respect to any Bond Financed Facility or portion thereof, other uses known of any portion of a Bond Financed Facility by any person other than the University; or any amendments to or other changes in any of the foregoing.

The Responsible Official shall review and consult as appropriate with Bond Counsel as to whether any arrangement discovered pursuant to the preceding paragraph may create any private business use. If it does, the Responsible Official shall so advise the Controller, who shall, in conjunction with the Responsible Official, take such steps as are within his or her power and which he or she judges appropriate either (1) to alter the proposed contractual arrangement to eliminate any private business use, or (2) to monitor such private business use going forward.

The Responsible Official shall maintain a list of all Bond Financed Facilities determined to be subject to private business use and shall annually determine if such use is within permitted amounts. The Responsible Official shall consult with Bond Counsel if the Responsible Official believes that any such private business use has exceeded or may exceed permitted amounts and shall report such excess to the Controller with a recommendation of steps that may be taken to limit the private business use or the consequences thereof (including, but not limited to, potential participation in the Voluntary Closing Agreement Program of the IRS or any successor or additional such programs (collectively, “VCAP”)).

Change in Use and Remedial Action.
In carrying out responsibilities outlined herein, the Responsible Official shall take steps, including conferring with Bond Counsel if appropriate, to determine if the University has taken any “deliberate action” with respect to the use or ownership of any Bond Financed Facilities resulting in a use of such facilities in an unqualified manner and, if so, to determine and implement on a timely basis appropriate remedial action under Section 1.141-12 of the Regulations.

Reimbursements
The Responsible Official will ensure that all reimbursement allocations to the University for expenditures made prior to any issue of Bonds will be made within eighteen months after the date the expenditure was made or, if later, eighteen months after the date on which the property resulting from the expenditure was placed in service, but in any event, within three years after the date the expenditure was paid.

Within one year after a reimbursement is made, the Responsible Official will not use the reimbursed funds to create a sinking fund without consulting with Bond Counsel prior to the creation of such sinking fund.

Policy Number 4: Any violations of the Code and/or the Treasury Regulations discovered by the University will be resolved on behalf of the University’s bondholders as quickly as possible through remedial measures or VCAP.

Implementing Procedures:
Upon discovering a violation of the Code, the Responsible Official will consult promptly with Bond Counsel and other legal counsel and advisors to determine a course of action to remediate such violation, if such counsel advises that a remedial action is necessary. If remedial action is available, the University will undertake to timely implement such remedial action. If remedial action is not available or the time limits for such remedial action have lapsed, the University will undertake to remedy the noncompliance pursuant to VCAP.

Policy
Effective: 11/01/82
Revision No. 2
Revised: 5/9/01
 
General
Bookstore services are provided for all University students, employees, and campus visitors.These services are provided for student and employee convenience and to ensure quality products and quality service are available at competitive prices.University personnel are encouraged to utilize the University bookstore for all products and services which can be obtained from this department.

Department Purchases in the Bookstore
The University Athletic Department should use a University Requisition (CUBO 220) for scholarship purchases from the Bookstore.All other University departments should use the Departmental Purchase Card (VISA).

Office Supplies
Although standard office supplies should be obtained through the State contract, there are many products for emergency needs and specialty office supply items available at the Bookstore. Items not stocked by the Bookstore can be ordered and are usually received within three to five days.

Desk Copies
Faculty members should obtain desk copies of textbooks by writing directly to the publisher in advance of the need for the text. Format request forms, as well as a directory of publishers, are available at the Bookstore.

Desk copies may be purchased from the Bookstore when time does not permit direct ordering from the publisher. In these cases, a copy should be ordered from the publisher and, when received, taken to the Bookstore for credit. Neither the department, nor the Bookstore, should bear the expense of desk copies.

Required Course Materials
Required course materials, other than textbooks, will be handled in the same manner as all other bookstore items. Faculty members must place orders for these items with the bookstore staff in sufficient time for the items to be ordered and received from suppliers, prior to the time needed in the classroom.

Policy
Effective:  January 1, 2009
Revised: April 17, 2019

Clemson University expects employees assigned with budgetary authority to plan and regularly review spending patterns to ensure they are spending within their budgetary authority, as well as review transactions to ensure proper approval for each expenditure transaction that has been charged to their budget, as defined in the University Disbursement policy.

Departmental expenditure and revenue transactions are to be reviewed monthly to help ensure the validity of financial transactions by comparing supporting documents to the transactions listed on the monthly budget status reports. Budget Status detail expenditure and revenue reports are provided monthly for review within the Data Warehouse system.

Certain transactions, including payroll, p-card, employee travel (electronic submission) and buyWays expenditures are separately approved in accordance with University payroll and disbursement policies. For these transactions, no further approval action is required.

Other transactions charging their budget authority may originate from other areas without proper approval. Departments shall review and reconcile these types of other transactions to assure proper budgetary approval has taken place. Required transactions are those that have not been previously reviewed and approved pursuant to other University policies.

This policy provides direction for the entire University, however, each department - after considering risks and efficiencies - may also establish their own policy detailing specific transactions that need to be reviewed based on a dollar threshold or using sampling criteria for their specific area. Individual departmental policies may be less restrictive than this University policy, with proper justification.

Policy
Effective: 09/18/17

I. Purpose
The purpose of this policy is to ensure that Clemson University complies with Internal Revenue Service (IRS) rules, regulations and accountability surrounding the issuance of complimentary and discounted University event tickets or passes (including all-access and circulation passes), the receipt of which is considered taxable income unless an exclusion exists in the Internal Revenue Code.

All supplemental policies adopted by University Departments or Units related to complimentary and discounted event tickets and passes must comply with the scope, guidelines and operating procedures outlined in this Policy.

II. Policy Statement
Clemson University is required to report complimentary event tickets or passes (including all-access and circulation passes) as taxable income (and will withhold federal and state income tax at the supplemental rate, including the applicable amount of FICA) unless one of the following Internal Revenue Code exceptions under Section 32 apply:

(A) Working Condition Fringe Benefit: Complimentary tickets and passes (including all-access and circulation passes) provided to carry out bona fide University business are not considered taxable income. Examples of bona fide University business include but are not limited to the following:

1. Discussing a specific University issue
2. Oversight of University events
3. Job duties required to be performed at a University event (rather than attendance primarily for an individual's own entertainment)
4. Acknowledging donors for a specific prior contribution
5. Recognizing donors for a particular service to a University program
6. Cultivating current and future support for a specific University activity
7. Strengthening alumni support for the University
8. Advancing the goals, objectives, and mission of the University
9. Entertaining persons having a business relationship with the University
10. Promoting intergovernmental relations and collaboration between the University and other public agencies
11. Promoting civic engagement and community outreach
12. Attracting or rewarding volunteer service
13. Recruitment of prospective students
14. Public relations and other similar reasons that would be beneficial to the University or a specific Department
15. Other unforeseen activities that may occur in future years.

Spouses, partners, and guests may also receive complimentary tickets and passes (including all-access and circulation passes) under this exception if the expectation or requirement is the spouse, partner, or guest will also be part of representing the University to outside constituents.

(B) No-Additional-Cost Services: The no-additional-cost services exclusion applies to a service provided by the University if (a) the University-provided service does not require the University to incur any substantial additional costs, including labor expenses and lost revenue (i.e. the event is not sold out), (b) the service is offered on a nondiscriminatory basis, and (c) documentation is maintained to support the number of tickets sold versus the tickets or passes available. When event tickets (including all-access and circulation passes) are provided and the University incurs no substantial additional cost, the value of that ticket or pass can be excluded from taxable income.

This exception applies to complimentary single event tickets and passes only. Giving single, individual event tickets or passes to the same employee repeatedly to avoid IRS reporting is not allowed. In addition, if reserved tickets or passes are issued well in advance of the event, this exclusion cannot apply since at the time it is not known if the event will be sold out.

For sold-out events only, if one of the other exceptions to taxing a complimentary ticket or pass does not apply, 80% of the total value of the complimentary ticket or pass received by an employee will be reported as a taxable benefit. The IRS Regulations allow an employee to receive a 20% discount without it being taxed. This benefit will be separately identified on the employee's paycheck. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld. If events are not sold-out, there is no taxable benefit to the employee.

Any complimentary season tickets or passes and tickets to sold out events (including all-access and circulation passes) which are provided for personal use will be considered taxable income. Personal use includes spouses, dependents and relatives using the tickets or passes. The personal use amount will be included as taxable income to the employee whose spouse, dependents or relatives used the tickets. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.

(C) De Minimis Fringe Benefit: In general, the IRS considers a de minimis fringe benefit to be one for which, considering its value and the frequency with which it is provided, is so small as to make accounting for it unreasonable or impractical. Occasional personal use of University sponsored event tickets or pass by employees is not considered taxable income to the employee. Occasional use is defined as four or fewer times in one calendar year to be non-taxable.

(D) Volunteers: For purposes of this policy, a volunteer is a spouse, dependent, guest of an employee, or other individual who, without compensation, provides services for the University. The volunteer may be providing services helping to promote the University or helping in various fundraising activities, including meeting prospective students or donors, conferring with legislators or others of the University community. Meetings may take place at various University functions such as alumni gatherings, fundraising events, theatrical performances, or pre- and post-game athletic event receptions.

The value of additional complimentary tickets or passes (including all-access and circulation passes) provided to the volunteer will be subject to "non-employee" taxation rules which require that a Form 1099-MISC be issued if the total cumulative value of complimentary tickets or passes from all University sources exceeds $600 or more per calendar year.

(E) Other: Trade, advertising, sponsorships and contractual complimentary tickets or passes that are required by contract, conference, association, etc. will be handled as zero valued tickets or passes and the Ticket Office must have a copy of the signed contract authorizing the complimentary tickets or passes before they will be released. This transaction is not reportable to the IRS as taxable income.

An employee and their immediate family members or guest who receives tickets or passes to events at University venues as part of an established reward or recognition program will not incur a taxable benefit

III. Scope
This policy applies to recipients of complimentary tickets or passes to University events, including:

• The Board of Trustees and Trustee Emeriti,
• President, Past Presidents and Vice Presidents,
• Deans, Directors and Departmental Heads,
• Area Managers and Supervisors,
• Faculty and Staff,
• Members of the Athletic Council,
• NCAA Faculty Athletics Representative,
• IPTAY Board of Directors and Director Emeriti,
• Charitable and not-for-profit organizations,
• Students, Visitors and Guests (in accordance with NCAA and ACC rules, as applicable),
• Players and Prospects, and
• Others, as determined, based on future circumstances.

This policy does not apply to events that do not charge for admittance. In addition, event tickets or passes cannot be given in lieu of being paid for services performed by an individual.

Allotment of complimentary tickets is provided in Appendix A and in the Athletic Department Post-Season Policy, which will be updated, as needed, based on future circumstances.

IV. Guidelines and Operating Procedures
The following procedures provide the guidelines for reporting personal use of a Clemson University sponsored event ticket or pass (including all-access and circulation passes) purchased with University funds. A University sponsored event is one which is sponsored by a University department, including athletic and non-athletic events, such as exhibits displayed at the Sikes Hall Showcase, performances at the Brooks Center for the Performing Arts, etc.

Once a complimentary ticket or pass has been distributed in accordance with this policy, the ticket or pass may not be transferred to any other person. Any Department issuing a complimentary single or season ticket or pass (including all-access or circulation passes) must properly account for the ticket whether reporting to the Controller is required or not.

The "value" of the complimentary event ticket or pass to be included in taxable income is determined by the posted retail price of the ticket and not by any alternative market value.

(A) Athletic Tickets, Passes and Events:

1. Regular Season Home Game Tickets and Passes: When issuing tickets or passes (including all-access and circulation passes) for regular season home games, the athletics department is only forgoing potential revenue if the tickets or passes could have been sold to the general public. As a result, complimentary regular season home tickets or passes picked up by an employee on a per-game basis are not taxable under either the de minimis fringe benefit exception or the no-additional-cost services exception, provided the event is not sold-out. This includes excess tickets or passes distributed to employees for their personal use or for distribution to family (including children) and friends. In this instance, such distribution must be a) for the purpose of increasing attendance at an event where attendance is not expected to be at least 85% of capacity, (b) announced to all University employees no earlier than 10 business days preceding the event, (c) the distribution must be infrequent or non-regular in nature and no employee may receive more than two tickets or passes to an individual event.
   
   Home game complimentary tickets or passes picked up by an employee on a season-ticket basis are a taxable fringe benefit and will be reported as taxable income, unless a bona fide business purpose as defined in Section II (A) is documented. Appendix B is to be completed, unless otherwise noted, to document the business purpose.
   
   For regular season home tickets and passes, 80% of the total value of the complimentary ticket or pass will be reported as a taxable benefit. The IRS Regulations allow an employee to receive a 20% discount without it being taxed. The 80% benefit will be separately identified on the employee's paycheck. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.
   
   Complimentary Regular Season Home tickets or passes provided to non-employees are not taxable provided one of the specified Internal Revenue Code exceptions outlined in Section II (B) are met. Otherwise, the use of the complimentary ticket or pass will be considered personal and the value will be subject to "non-employee" taxation rules which require that a Form 1099-MISC be issued if the total cumulative value of complimentary tickets or passes from all University sources exceeds $600 or more per calendar year.
   
   Any complimentary season tickets or passes and tickets to sold out events which are provided for personal use will be considered taxable income. Personal use includes spouses, dependents and relatives using the tickets or passes. The personal use amount will be included as taxable income to the employee whose spouse, dependents or relatives used the tickets or passes Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.
   
   
2. Regular Season Away Game Tickets or Passes: For away games, there is an actual expense to the athletics department since the department must pay the visiting team for all tickets or passes over the complimentary ticket or pass allotment provided for in the game contract. As a result, complimentary regular season away tickets or passes issued to "working staff" who are making the trip for a specified business reason are considered a working condition fringe benefit and, therefore, not taxable income. In all other circumstances, individuals who want to attend regular season away games shall purchase tickets or passes which will not be reimbursed by the University.
   
   If complimentary tickets or passes are provided by the University without meeting one of the specified Internal Revenue Code exceptions outlined in Section II (B), the value of the ticket or pass will be considered a personal use amount and will be reported as taxable income to the individual. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.
3. Post-Season Athletic Event Tickets or Passes: Complimentary Post-Season tickets or passes (including all-access and circulation passes) issued to "working staff" who are making the trip for a specified business reason are considered a working condition fringe benefit and not taxable income. In all other circumstances, individuals who want to attend regular season away games shall purchase tickets or passes which will not reimbursed by the University.
   
   If complimentary tickets or passes are provided by the University without meeting one of the specified Internal Revenue Code exceptions outlined in Section II (B), the value of the ticket or pass will be considered a personal use amount and will be reported as taxable income to the individual. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.

(B) Non-Athletic Tickets, Passes and Events:
Complimentary tickets and passes provided to non-athletic events sponsored by the University shall be regulated based on the Athletic Tickets, Passes and Events requirements outlined in Section IV (A). Appendix B is to be completed, unless otherwise noted, to document the business purpose.

(C) Unused Tickets or Passes:
In order to avoid taxes on any unused tickets or passes, it is important that any unused tickets or passes be returned before noon of the game/event day or noon the Friday preceding a weekend game/event in order for these to be returned in time for sale to the public, unless earlier notice is required by the employee's department.

(D) Complimentary Tickets or Passes Allowed under NCAA and ACC Regulations:
Single or season tickets or passes given to athletes as allowed by the NCAA must be accounted for, but are not reported on a W-2 or 1099-MISC to the athlete because Clemson University is not required to report scholarships to the IRS in this manner. It is the responsibility of the athlete to determine what is reported on his/her tax return.

(E) Badge or ID, including All-Access and Circulation Passes:
A badge or ID (including all-access and circulation passes) typically allows entrance into an event for work purposes, not a seat for the event. As a result, individuals working at events or venues and gaining admittance with a badge or ID (including all-access and circulation passes) will not incur a taxable benefit.

If a Badge, ID or pass (including all-access and circulation pass) is provided by the University without meeting one of the specified Internal Revenue Code exceptions outlined in Section II (for example, issued to working staff as a working condition fringe benefit), the value of the ticket or pass will be considered a personal use amount and will be reported as taxable income to the individual. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.

(F) Block Ticket Purchases:
Certain University Campus Units or Groups may purchase event tickets in "blocks" of more than one ticket. A block of tickets may be purchased for both athletic and non-athletic events and distributed internally by groups such as the Development Office, Dean's Office, Student Affairs and the CIO's Office, etc... It is the responsibility of the purchasing Unit or Group to maintain adequate documentation in accordance with the procedures outlined in this Policy.

If complimentary tickets are distributed from the "block" of purchased tickets without meeting one of the specified Internal Revenue Code exceptions outlined in Section II, the value of the ticket will be considered a personal use amount and will be reported as taxable income to the individual. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.

(G) Required Documentation:

1. Personal Use: If it is determined that a ticket or pass is includable as taxable income, then the retail price of the ticket or pass will be used to value the personal use amount. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.
   
   In order to establish a prudent measurement period that will meet specific business-related time constraints, the individual or department head must report personal use of tickets or passes to the University Controller and Payroll Department based on a 12 month period beginning July 1^st and ending June 30th. The deadline for the 12 month report will be no later than August 31^st of each calendar year. The required amount of tax withholding (federal, state and FICA) will be spread over multiple pay-periods in order to avoid an unforeseen financial burden.
2. Business Use: Unless otherwise noted, documentation of the business use of complimentary tickets or passes will be provided using the "Complimentary Tickets and Passes Form" attached as Appendix B, which details the business purpose of attendance, benefit derived by the University, and the nature of any business discussion or activity. Also, indicate the business relationship between any guest in attendance and the University. Guests should be identified by name, profession, employment, or other designation that supports the purpose for which they were invited. The employee must sign, date, complete, and return the Form within ten business days after the event to the University Controller or the value of all tickets or passes will be reported as taxable income. Federal and state income tax at the supplemental rate, including the applicable amount of FICA, will be withheld.

(H) Determination of Taxable Income Inclusion:
The "value" of the complimentary event ticket or pass to be included in taxable income is determined by the posted retail price of the ticket and not by any alternative market value.

V. Responsible Office
All Athletic and Non-Athletic Departments in conjunction with the University Controller and Payroll Department

VI. Versions
Date of Initial Executive Leadership Team Approval: September 18, 2017

Procedure

Communication

• The Controller’s Office will send an email to all University employees explaining the new Complimentary and Discounted Event Tickets and Passes Policy
• The Controller’s Office will draft an Inside Clemson article to inform all people who may be impacted by the new Complimentary and Discounted Event Tickets and Passes Policy

Ticket Office – (Includes Athletics, Performing Arts events, and Student Affairs Concerts and Events)

• Issues complimentary tickets to games, concerts, and events.
• Each ticket office is responsible for gathering and submitting the following complimentary ticket information to the Controller’s Office: the name of the recipient; recipient’s contact information (i.e. email); and number of tickets distributed.

Controller’s Office

• Emails ticket recipients notifying them of Clemson University’s Complimentary and Discount Ticket Policy and the documentation they are required to provide to avoid taxation. Individual ticket recipients and offices with record-keeping responsibility will be asked to complete the Use of Complimentary Ticket Form and return to: COMPTICKETS@CLEMSON.EDU
• Receives Use of Complimentary Ticket Forms from individuals and offices with record-keeping responsibility.
• Compiles taxable fringe benefits for the measurement period July 1^st through June 30th during the month of July. Notifies employees of details and advises that withholdings will begin in August and will be spread over multiple pay periods depending on the face value of the benefits received.

Payroll Office

• Reports and withholds applicable taxes as needed beginning 8/15-10/31

Policy
Effective:  December 1, 2004
Revised:  November 16, 2018

Clemson University and the State of South Carolina enter into contracts with vendors to acquire favorable prices for many frequently used items or services, commonly referred to as State or agency contracts. Clemson University and the State of South Carolina have contracts with several hundred suppliers, covering thousands of items.

Departmental Responsibilities for State and Agency Contracts
All departments are required to purchase needed goods or services from the State or agency contracts, unless they are specifically exempted. Any questions related to the application of the contract or the services provide by the contract should be directed to Procurement Services.

Purchasing departments using State contracts are responsible for verifying that the goods or services ordered or received conform to the contract specifications and terms or each order prior to the authorization of each payment.

Each department is requested to address, document and report any issues related to the contractual terms or performance related to the state or agency contracts to Procurement Services.

Contract Links
Login to Clemson buyWays to view all Clemson, State and State IT contracts.

Policy
Effective:  February 20, 2003

The Principal Investigator (PI) of a sponsored program project is responsible for all fiscal and programmatic activities related to the project.  The Principal Investigator should authorize or approve all expenditures for sponsored program project activities.  The Principal Investigator and the Department Chair may agree on a designee with sufficient technical expertise that is knowledgeable of the sponsored project to authorize or approve the expenditure when a PI is not available.

Procedure
The Principal Investigator (PI) is designated to authorize or approve all expenditures for the sponsored program project activities.  A designee should be identified on the Clemson University Sponsored Programs Internal Processing Form or an attached memorandum as part of the preaward process.  Any further changes in delegation of authorization /approval should be retained on record in the official grant documentation file of the grants coordinator.  

Delegation of authorization/approval is allowed in the following circumstances:

• When the PI is not available (all day meeting, conference, out of town, etc.) there is a situation requiring authorization or approval of sponsored program expenditure(s)today, the Department Chair of the PI is authorized to sign or approve the expenditure.
• In the event that neither the PI nor the Department Chair is available and there is a situation requiring authorization or approval of sponsored program expenditure(s)/activity today, the PI will have a designee with sufficient technical expertise of the project authorized to sign or approve. Such delegation will be in writing and on file before expenditures will be allowed.
• If sponsored project activities are in multiple departments, the PI can budget funds in the appropriate department and designate signature responsibility to a co-investigator in that department. This delegation will be in writing and on file before expenditures will be allowed.  When the delegated co-investigator is not available (all day meeting, conference, out of town, etc.) and there is a situation requiring authorization or approval of sponsored program expenditure(s) today, the Department Chair of the co-investigator is authorized to sign or approve the expenditure.

Policy
Effective: 5/15/07

Discussion
Facilities and Administrative Costs:
F&A or indirect costs are costs associated with the conduct of sponsored activities that are incurred for common or joint objectives and, therefore are not readily identifiable with a specific project. Included are expenses related to Human Resources, Fiscal Affairs, the President’s Office, Dean’s offices, and costs related to the general operations and maintenance of the University. These costs generally fall into one of the following cost pools:

• Building Depreciation
• Equipment depreciation
• Interest
• Operations and Maintenance
• General Administration
• Department Administration
• Sponsored Programs Administration
• Library
• Student Services Administration
• F&A costs are real costs of institutional support for sponsored program activity.

Sponsored program budgets are expected to recover F&A costs at the maximum allowable rate.

Facilities and Administrative Rates:
F&A rates are federally negotiated and developed to recover the indirect costs associated with the conduct of sponsored activities. These rates are applied to modified total direct costs (MTDC) (see definition below).

The Controller’s Office is responsible for the development and negotiation of the F&A Cost Rate Agreement, which is applicable to awards for both Clemson University (CU) and Clemson University Research Foundation (CURF).

The current negotiated and approved rates are posted on the Controller’s website.

The approved indirect cost rates are expected to be applied to all contracts and grants. Exceptions are rare and must be approved by the Vice President for Research.

Definitions (listed alphabetically)

Instruction/Departmental Research (IDR) (circular A-21 definition) :
Instruction means the teaching and training activities of an institution. Except for research training as it is explained below, this term includes all teaching and training activities, whether they are offered for credits toward a degree or certificate or on a non credit basis, and whether they are offered through regular academic departments or separate divisions, such as a summer school division or an extension division. Also considered part of this major function are departmental research, and, where agreed to, university research.

(1) Sponsored instruction and training means specific instructional or training activity established by grant, contract, or cooperative agreement. For purposes of the federal cost principles, this activity may be considered a major function even though an institution's accounting treatment may include it in the instruction function.

(2) Departmental research means research, development and scholarly activities that are not organized research and, consequently, are not separately budgeted and accounted for. Departmental research, for purposes of this document, is not considered as a major function, but as a part of the instruction function of the institution.

Modified Total Direct Costs (MTDC):
MTDC is calculated by subtracting from total direct costs expenses such as the charges for capital equipment, renovation and alteration, tuition, rent, and each subcontract in excess of the first $25,000. See the Federal Office of Management and Budget circular A-21 for a complete list.

Off-Campus:
The off campus rate is applied to federally sponsored projects that are not conducted in space owned or controlled by Clemson University or Clemson University Research Foundation.

Organized Research (OR) (circular A-21 definition):
Organized research means all research and development activities of an institution that are separately budgeted and accounted for (This is in the perspective of external sponsors where the agreement states specific deadlines, deliverables, etc.). It includes:

(1) Sponsored research means all research and development activities that are sponsored by Federal and non Federal agencies and organizations. This term includes activities involving the training of individuals in research techniques (commonly called research training) where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instruction function.

(2) University research (cost share) means all research and development activities that are separately budgeted and accounted for by the institution under an internal application of institutional funds. University research, for purposes of this document (circular A-21), shall be combined with sponsored research under the function of organized research.

Other Institutional Activities (OIA) (circular A-21 definition):
Other institutional activities means all activities of an institution except:
(1) instruction, departmental research, organized research, and other sponsored activities, as defined above;

(2) F&A cost activities identified in Section F; and

(3) specialized service facilities described in Section J.47. Other institutional activities include operation of residence halls, dining halls, hospitals and clinics, student unions, intercollegiate athletics, bookstores, faculty housing, student apartments, guest houses, chapels, theaters, public museums, and other similar auxiliary enterprises. This definition also includes any other categories of activities, costs of which are "unallowable" to sponsored agreements, unless otherwise indicated in the agreements.

Other Sponsored Activities (OSA) (circular A-21 definition):
Other sponsored activities mean programs and projects financed by Federal and non Federal agencies and organizations which involve the performance of work other than instruction and organized research. Examples of such programs and projects are health service projects, and community service programs. However, when any of these activities are undertaken by the institution without outside support, they may be classified as other institutional activities.

Policy
Effective:  April 15, 2007
 
Fiscal Responsibilities
Clemson University’s business organization extends beyond the institutional financial area to encompass a network of personnel from colleges and administrative divisions who share responsibility of managing University financial resources. These areas work in partnership to achieve effective business practices. It is the collective and shared responsibility of these areas to work cooperatively in ensuring the financial integrity of the University.

Institutional Responsibilities
Institutional level fiscal responsibilities include developing basic control procedures and accountability through establishing, documenting, and communicating institutional policies, procedures and guidelines, monitoring programs for compliance, and developing and facilitating ongoing training programs. Responsibilities also include supporting the University through establishing best practices, effective processes and useful management information.

College or Division Responsibilities
The college or division level plays a critical role in ensuring the financial integrity of the University. The Business Officer function supports each division or college by identifying administrative needs and implementing specific processes within each area. Through delegated authority from central administration, the Business Officers exercise discretion and judgment within the framework established by central administration. In cooperation with central administration, the Business Officers supporting their Dean or Division Head and the department heads share in the responsibility of control functions such as: the communication of University policies, procedures and guidelines; the authorization for delegation of signature approval or accountability to the departmental level; allocation of resources; development of college or division level policies and procedures; establishment of monitoring control mechanisms; identification of training needs; and communication of identified related issues to the institutional level.

Departmental Responsibilities
The foundation for the financial integrity of the University is controlled at the departmental level. Within the framework of comprehensive and clearly documented policies and procedures, and effective training and monitoring, department heads are ultimately responsible for the University’s financial integrity and accountability at the transaction level.

Annual Confirmation Process
As part of the planning and review process for the fiscal year end, each Business Officer will be provided a Fiscal Year End Closing Review document as a communication and planning tool for review of basic fiscal control features within their college or division. This review document assists the Business Officer in identifying areas that may be problematic and issues that may need to be discussed with the Controller.

Each College or Division is to confirm receipt and review of the Fiscal Year End Closing Review document. The Business Officer or the dean/division head’s confirmation indicates that to the best of their knowledge, significant areas that may be problematic and would result in material financial audit or fiscal integrity issues have been discussed or disclosed to the Controller or the Controller’s staff.

Policy
Effective 07/01/07

The General and Administrative charge is assessed to fund institutional general and administrative support costs not funded by State appropriations and student fees and to contribute to Clemson University core mission initiatives.

General and Administrative costs are those expenses that have been incurred for the general executive and administrative offices of the University and other expenses which do not relate solely to any major function of the University, but benefit the institution.

Procedure
Effective 07/01/09

Auxiliary Operations, Public Service Activities and self-supporting operations may be assessed a charge to recover its share of institutional general and administrative support costs or to strategically contribute to the core mission areas of Clemson University.

Auxiliary Charge -
Auxiliary operations will be assessed a charge of  6% of the total revenues based on revenues generated two years prior to the charge (example – FY2008 revenues will be the basis for FY 2010 auxiliary charge).

Public Service Charge -
Public Service Activities will be assessed a public service charge for administrative support and a contribution to core mission support.  The current established charge is $1,871,651.  Changes in the charge may be addressed as part of the annual budget process and approved by the President.

Self Supporting Charge -
Self supporting activities may be assessed a charge as part of the annual budget process and approved by the President.

Policy
Effective: 7/1/2005

The Graduate Assistant Differential (GAD) will be budgeted and accounted as a student fee and an operational expense in the University’s budget process and accounting system.  Funding levels for the graduate assistant differential for teaching and research assistantships and for cost share for externally supported research will be established through allocations made by the Dean of the Graduate School based on the policy directions and strategic plans established by the Vice President for Academic Affairs and Provost, the Vice President for Research and Economic Development, and the Vice President for Public Service and Agriculture.  Assistantship differentials requiring funding in excess of the institutional allocations will be funded through sponsored programs, gifts, auxiliary, PSA, or departmental funding.  Eligibility criteria for graduate assistantship differentials will be determined by policies and procedures approved by the Dean of the Graduate school in accordance with the policy directions and strategic plans established by the Vice President for Academic Affairs and Provost, the Vice President for Research and Economic Development and the Vice President for Public Service and Agriculture.  Revenue collected as a result of this new policy will be deposited into the Graduate Assistant Differential Fund.  The Graduate Assistant Differential Fund will be managed by the Dean of the Graduate School based on the policy directions and strategic plans established by the Vice President of Academic Affairs and Provost, the Vice President for Research and Economic Development, and the Vice President for Public Service and Agriculture.

Policy
Effective: June 1, 2000
Responsible Office: Controller

Inventories are comprised of either of the following:

• items purchased explicitly for resale to external parties or other University departments,
• material used to produce items for resale to external parties or other University departments.

Items not meeting these classifications generally are not considered inventory. Items purchased that are not resold to external parties or other University departments should be considered supplies for that department. Generally, items that are purchased and consumed by the same department are considered to be supplies. Additional guidance and exceptions to this policy are made by the Controller's Office.

The department head is responsible to establish control and maintain security over an entire inventory of the department regardless of the location of the inventory. Responsibility also includes the proper valuation of inventory and for ensuring that detailed documentation is retained of the inventory valuation.

Procedures

Inventories should be recorded as an asset on the University's financial records. The department head is responsible for the proper valuation of inventory and for ensuring that detailed documentation is retained of the inventory valuation. Inventories include items owned by the department whether stored on site or off site. Departments that do not maintain a perpetual inventory system must take a mandatory inventory as close to the last day of the fiscal year (June 30) as possible. Inventories taken at other times would need to be adjusted for purchases and sales from the date of the inventory to June 30 in order to calculate the actual inventory balance at the end of business on June 30.

Departments that maintain a perpetual inventory system and cycle count their inventory may not be required to perform a year-end physical inventory. All inventory items must be counted at least once a year through the cycle count process. Approval to allow the perpetual system and its related cycle counts to be substituted for the fiscal year-end physical inventory count must be requested and obtained from the Controller or Associate Controller.

Inventories should be valued at cost using a generally accepted method of inventory valuation with consideration given for identifying obsolete or damaged goods. Obsolete or damaged goods should be valued at market value (lower of cost or market method) instead of at cost. No items should be valued at retail.

Contact Accounting Services if assistance is needed in determining if items should be recorded on the University financial system.

Guidelines

Either a perpetual or periodic inventory system can be used.

1. Perpetual Systems - Purchases at cost are recorded directly to an inventory asset account. Items expended are deducted from the inventory account and charged to a cost of goods sold account. The value of the inventory asset account should be the same as the value of the cost of the inventory on hand. As a control feature, spot counts should be made throughout the year and reconciled with the perpetual inventory records to help ensure the accuracy of the records. Cycle counts of all items should be made during the year to verify the validity of the perpetual records and to adjust for breakage, theft, obsolete items, etc.
2. Periodic Systems - Purchases at cost are recorded directly to the cost of goods sold account. The beginning of the year inventory balance remains in the asset account until a physical inventory count is taken. The asset account is adjusted to the physical inventory count balance at the end of the year.
   Prior to the year-end physical inventory, the Internal Audit Department and Accounting Services should be notified of the scheduled physical inventory date. Internal Audit and the University's external auditors may observe the actual physical inventory count.

All items included in inventory should have verification of beginning balances for the current accounting period. Individuals who are independent from the day-to-day receiving or issuing of the inventory items should perform the counts. If it is not practical for all individuals to be independent, the individuals should work in small teams where at least one individual is independent.

All inventory items should be counted with any damaged or obsolete items noted. Detailed inventory sheets should include the number of units, the unit costs and their extended value (quantity times unit costs). Upon completion of the physical count, management should:

• Review the inventory sheets for damaged or obsolete items. Costs for these items should be recorded at the lower of cost or market.
• Ensure that all items have been counted.
• Verify the accuracy of the quantity by recounting a sample of the items.
• Verify the mathematical accuracy of the extended values and the total inventory value.

The inventory value should be provided to Accounting Services within one week after the fiscal year-end

State Leasing Procedures
Please contact the internal office below to begin any process to lease non-state owned property. All leases that amount to over $25,000 per year require special state and Clemson University Board of Trustee approval. Any request should be submitted to the office below at least 6 months in advance of the date needed. Any decision to lease out University owned space follows a similar procedure and time frame as all such lease must have approval of State Leasing prior to any negotiations if the lease out is for more than 7 days and not exempted by the state.

Clemson University Leasing Procedures
Please contact the Capital Project and Property Management office located in Gentry Hall to obtain information concerning the leasing of non-state owned property. The following documents will need to be completed to start the leasing process:
1. A Space Request Form

2. A Budget Approval Form

These forms may be obtained by calling 656-5846.

At no time should a department solicit for or negotiate any lease of non-state owned property. All requests should come through the above office.

Policy
Effective: 1/1/1994
Last Updated: 9/24/2015
Revised: 3/12/2018

Regulatory Authority: 2018 State Appropriations Act, Section 117.20L, SC Code of Laws 8-11-135, IRS Revenue Code

Reimbursements of moving/relocation expenses for new and existing employees are allowed when such reimbursements are considered reasonable and necessary to successfully recruit a diverse and talented community of scholars, faculty and staff.

Reimbursement of reasonable and necessary moving/relocation expenses for existing employees are authorized when an employee's primary place of business is moved from one location or place to another location or place in the course of the business of the University and are subject College/Budget Center funding availability.

The hiring unit is responsible for identifying the source of funds and for determining the amount available for reimbursement. An HR representative is responsible for making the new employee aware of the moving/relocation amount offered as part of the official offer letter. If the offer letter does not specifically address moving/relocation expenses, a separate letter should be written indicating the amount available for reimbursement. The hiring unit will also advise the new employee on procedures for filing for reimbursement. Moving/relocation expenses, net of applicable withholding, will be made via the employee’s paycheck/direct deposit. Payments cannot be paid directly to a vendor on behalf of an employee.

Exceptions

• Vice-president of the hiring division or the University's Executive Leadership Team (ELT) are required to pre-approve all offers that include a moving/relocation expense in excess of $5,000 before the offer is proffered to the recruit.

Procedure
Effective: 1/1/1994
Last Updated: 9/24/2015
Revised: 3/12/2018

General Information

Effective January 1, 2018, moving/relocation reimbursements are taxable and subject to applicable withholding.

To be reimbursed for moving expenses, the principal place of work must be 50 miles farther from the former residence than the employee’s previous main job location. Individuals may be reimbursed for expenses that are reasonable and necessary.

Reimbursement of moving/relocation expenses should be accomplished as follows:

1)   Employee submits receipt documentation to support expenses to their supervisor

2)   Supervisor reviews receipt documentation to ensure that the requested reimbursement is reasonable and necessary and does not exceed $5,000 or, if an exception was made, the amount approved by the hiring department Vice President or the University Executive Leadership Team.

3)   Supervisor provides receipts and approval for processing to the business office representative.

4)   Business office representative reviews receipt documentation, retains in the College/Budget Center, and authorizes payment through the payroll system using the appropriate 5XXX account code.

5)   Payroll processor for the College/Budget Center keys the online CU Special Pay.

6)   Moving expenses are paid through the Payroll Office and are included in the employee’s next applicable paycheck/direct deposit. (Note: the amount reflected in paychecks/direct deposits will be net after applicable withholdings for FICA, Federal and State taxes).

FAQ

Q. Can moving/relocation costs be paid directly to a moving company either by an AP voucher or procurement card?
A.  No, reimbursements should be paid directly to the employee through the online CU Special Pay process

Q. Even though all moving expenses are taxable, do I need to provide supporting documentation for expenses?
A. Yes, you must provide receipts up to the full amount allowed for reimbursement. The receipts must support reasonable and necessary costs related to moving/relocation.

Q. Who is responsible for collecting and maintaining the supporting documentation?
A. The hiring supervisor will review receipts to ensure requested reimbursement is reasonable and necessary. Once the review is complete, documentation is forwarded to the business office representative who is responsible for retaining the documentation and for ensuring payment is processed via payroll.

Q. What information should be given to the payroll processor?
A. The payroll processor needs basic information for processing the online CU Special Pay: Name, Employee ID, Employee Record Number, Amount Due and the appropriate Chartfield. The payroll processor does not need the backup documentation, as that should be retained in the College/Budget Center.

Q. Why is my special pay less than my approved reimbursement amount?
A. The amount reflected in paychecks/direct deposits will be net after applicable withholdings for FICA, Federal and State taxes.

Q. If a new hire needs a reimbursement prior to their first paycheck, what can we do?
A. If necessary, an off-cycle payroll check can be requested using the Request for Off-Cycle Payroll Process form. A check can be available as early as the day after an employee’s hire date.

Policy
Effective: 10/1/1997

Clemson University is required to observe Internal Revenue Code and INS regulations regarding payments made to or on behalf of Non Resident Aliens including students, trainees, employees (dependent personal services), and independent contractors. When income taxes are due, taxes will be paid by the following methods: total tax due will be withheld from payments to Non Resident Aliens or the department will be charged the tax due based on a grossed up dollar amount of all expenses.

Procedure
Effective 10/1/1997
Last Update: 2/6/2006

Regulatory Authority:
IRS Revenue Code Sections, Immigration and Naturalization Service Regulations

Tax reporting and withholding for these individuals is different than procedures used for United States citizens and resident aliens. Non Resident Aliens must be identified at the initial point of contact with the university if they are being considered as an employee, consultant, or scholarship recipient or being paid or reimbursed for travel expenses.

Notify the Office of International Affairs to plan for proper immigration status relevant to the purpose of the trip. Some Non Resident Aliens may be ineligible to receive payments depending on immigration status/visa type.

If a Non Resident Alien (NRA) is eligible to receive payments or benefits, to satisfy withholding and reporting requirements the proper tax forms must be completed prior to any disbursement of funds. For assistance regarding tax forms and questions, notify International Tax Director in the Administrative Services Building, 108 Pearman Blvd. in advance of an NRA's visit to Clemson University.

Examples of payments to Non Resident Aliens include:

• S. source scholarships, fellowships, and athletic grants in aid credited to NRA students' accounts through the Office of Student Financial Aid.
• Payroll checks issued to NRA employees.
• Personal living expenses paid by departments through department voucher, procurement card, and IDO, either directly to or on behalf of NRA students, NRA trainees, or NRA employees.
• Travel expenses, consultant / speaker fees, honoraria, personal living expenses (rent, utilities, food, furniture rental , etc.) paid to or on behalf of NRA independent contractors through department vouchers, procurement card, and IDO.
• Reimbursements through department vouchers to employees who have incurred certain expenses on behalf of NRA individuals

Payment Types, Regulatory Authority, and Withholding Tax Rates:

Example 1
Payment Type: Scholarships, Fellowships, & Athletic Grants in Aid for NRA students - non compensation

Regulatory Authority: Internal Revenue Code 117, 1441, 7701, Rev. Ruling 89-67, Tax Treaties, Form W8-Ben - Certificate of Foreign Status of Beneficial Owner for US Tax Withholding.

Withholding Tax Rates: 14% of U.S. source non qualified amounts if the recipient is an enrolled NRA student present in the U.S. on an F, J, M, or Q visa. Otherwise, 30% withholding is required. Exception for withholding on per diem for subsistence if USAID training program grant and grantee training is in the U.S.

Example 2
Payment Type: University business travel expenses paid for or to NRA Clemson University employees.

Regulatory Authority: Internal Revenue Code 61, 274.

Withholding Tax Rate: 0%

Example 3
Payment Type: Consultant fees, or other amounts paid for services rendered, honoraria ,and travel expenses paid by Clemson University to or for NRA independent contractors.

Regulatory Authority: Internal Revenue Code 1441, 7701, Tax Treaties, W8-Ben - Certificate of Foreign Status of Beneficial Owner for US Tax Withholding, form 8843 Exempt Individual, form 8233 Exemption from Withholding, Revenue Procedures 87-9, 93-22, and 93-22A.

Withholding Tax Rate: 30% unless recipient is exempted under a tax treaty.

Example 4
Payment Type: Compensation to NRA employees

Regulatory Authority: Internal Revenue Code 1441, 3121, 7701, Rev. Proc. 88-24, form 8233 Exemption from Withholding, form 8843 Exempt Individuals Statement, Rev. Proc. 87-9, 93-22, 93-22A. W8-Ben - Certificate of Foreign Status of Beneficial Owner for US Tax Withholding

Withholding Tax Rate: Graduated withholding rates unless exempted by tax treaty.

Tax can be paid in either of two methods:
(a)  Total tax due is withheld from payments to the NRA. Contact the International Tax Director in the Administrative Services Building, 108 Pearman Blvd. prior to issuing disbursements or payments to or for the benefit of Non Resident Aliens.
(b) The department pays the tax based on a grossed up dollar amount of all expenses. If withholding applies, a departmental account will be charged.

Policy
Effective: 7/1/2009
Revised: 7/1/2009

Corrections to previously posted payroll transactions may be submitted, approved and posted as of the current date. Payroll transactions are presumed to have been approved on the “front end” and supported by timesheets, Principal Investigator certifications, and other written documentation.

Corrections should only be made to address errors that occurred in posting, or to adjust based on subsequent information that was not available as of the posting of the original transaction. Corrections submitted on or after 90 days from the original payroll transaction must be approved and supported by written permission from the mission Vice President (VP) or his or her designee. A copy of the VP approval is to be retained at the departmental level along with other supporting documentation for the correction.

Discussion
While payroll corrections are sometimes necessary, it is important to note that they cannot usually be processed in the same accounting period in which the original transaction occurred. Usually, the original accounting period, or fiscal year, will be closed. Audits, billing and other processes will have likely been based upon the originally posted transaction. For that reason, any correction to a previously posted payroll transaction must be posted in the current accounting period.

Payroll corrections may only be submitted through a custom “Payroll Correction Form” that may be accessed from the CUBS home page. This form requires employee id, journal id, and chartfield string information on a transaction-by-transaction basis. Submitted payroll correction (PRC) transactions are loaded to CUBS Financials for approval nightly. Individuals with approval status for PRC transactions must have sufficient knowledge of the reason for the correction, and, if necessary, must verify that mission VP approval has been obtained for corrections occurring 90 days on or after the original payroll transaction.

Procedure
Note: Online training for the "Payroll Corrections Form" and for "Payroll Correction Approval" may be accessed from the CUBS homepage.

Payroll transactions are presumed to have been approved on the "front end" and supported by timesheets, Principal Investigator (PI) certifications, and other written documentation. Corrections should only be made to address errors that occurred in posting, or to adjust based on information that was not available as of the posting of the original transaction.

Information Needed
Prior to processing a payroll correction (PRC) transaction, the following information will be needed:

• Employee id for the transaction being corrected
• Journal id for the transaction being corrected
• Chartfield strings being corrected and the "new" chartfield string and/or amounts to be charged (all of the above may be obtained from the Payroll Detail Report on the P Drive for respective Budget Centers)
• Detailed description for the purpose of the correction
• Mission Vice President approval for corrections occurring on or after 90 days from the original payroll transaction posting.

Payroll Correction Form

• Access the "Payroll Correction Form" from the CUBS home page. (CU employee authentication will be required)
• The cursor will be in the "Journal ID" field, beginning with a "PRC" prefix. Please enter a department number followed by a three-character identifier. Note: please confer with the individuals in your Budget Center who will ultimately be approving PRC transactions to determine which department number to enter. They may prefer the department number for the transaction being corrected, or, your department number, if different.
• Enter the "Run Control ID" for the transaction being corrected. Note: this will be the last three alpha characters in the originally posted Journal ID
• Enter the "Program", "Class", "Department", and "Project" chartfield string information from the originally posted transaction as requested.
• Enter a detailed description for the transaction. Note: avoid general statements, such as, "Correct from project 1500000". Please provide a sufficient description to subsequently allow approvers, PI's, auditors, and other individuals to fully understand the reason for the correction. As a rule, it is a good idea to include both the original and the destination chartfield string in the description.
• Enter the number of correcting lines needed. For example, if you are correcting an original transaction posted to one chartfield string, and wish to correct to another single chartfield string, select "1." If you wish to correct to two chartfield strings, select "2," etc.
• After line selection, the Form will be populated with the original transaction and amounts, and the number of selected lines. Note: you will not be able to change the previously posted account. Fringe distributions were based on this account and cannot be changed later.
• You will have the opportunity to change the other chartfield strings and amounts as needed.
• Note: the transaction is dated as of today, the date of the original transaction is included in the Journal Line Reference field.
• When complete, select "Verify". Account and Fringe distribution lines will appear on a subsequent screen. Note: you will not see debit and credits on this screen, but they will be presented correctly when uploaded into CUBS.
• If satisfied, select "Final Submit." You will receive a notice that your transaction will load to CUBS overnight and will be available for approval tomorrow.
• If not satisfied, select the backspace button on your web browser. You will note that your destination line has reset to the same chartfield string as the original transaction.

Payroll Correction Approval

• Payroll correction (PRC) transactions entered into the custom web module are uploaded to CUBS Financials nightly.
• Authorized approvers may view PRC transactions in CUBS Financials at: CU_CUSTOM - GENERAL LEDGER - UPDATES - WEB PAY CORRECTION
• PRC transactions should be identifiable by the "PRC" prefix in the first three characters, a four character departmental identifier, and then a unique three character identifier (ie., PRC 5308 001)
• Approvers should coordinate PRC naming conventions with individuals in your Budget Center to facilitate quick identification of transactions to be approved.
• Approvers select the PRC transaction(s) to be reviewed.
• When satisfied, Approvers select the "Approved" radio button in CUBS Financials to remove the transaction from "Hold".
• For PRC transactions on or after 90 days from the original payroll transaction, approvers should verify that mission Vice President approval has been obtained.
• Unapproved PRC transactions will remain on "Hold" status and will be deleted after three months of the current fiscal year.

General Rules/Comments

• Payroll corrections may "only" be processed with the "Payroll Correction Form", one transaction at a time. Access to payroll-related 5xxx compensation and fringe accounts in CUBS Financials is blocked to prevent original entry in the Journals panels.
• Provided mission VP approvals have been obtained for corrections submitted on or after 90 days from the original transaction, departments may enter corrections for transactions posted to previous fiscal years. Note: these corrections will be posted as of the current date.

Once approved and posted, PRC transactions are written back to the CU_PAYROLL_JRNL table in CUBS Financials with an "old" Run Control identifier but a current posting date.

Discussion
Clemson University allocates the employer portion of fringe benefit costs using a pooled fringe benefit rate. Annually pooled fringe benefit rates are determined through a process which takes all employee benefits by employee group and averages them into one fringe benefit rate for each group.

When planning beyond the current fiscal year, administrators should anticipate future employee benefit costs to increase from one year to the next.

Clemson has five (5) approved rates based on employee benefit program code (BPC):
9 Month
12 Month Administrator/Staff
Graduate Students
Undergraduate Students
Part Time/Temporary
(see below for employee/rate groups and corresponding benefit program codes, or BPC):
         
A pooled fringe benefit rate:

1. Provides a simpler approach process for administering budgets
2. Considered to be a best practice for leading research institutions
3. Reduces questions on specific benefits allowed under grant funding
4. Provides an opportunity to recover employee benefit costs currently funded and managed at the institution level

Benefits included in the Clemson’s rates are:

1. FICA
2. Unemployment Tax
3. Insurance - Health, Dental, Life
4. Retirement
5. Long-term disability
6. Worker's Compensation
7. Employee Tuition Remission
8. Termination Pay
9. Employee Assistance Program
   

Rates are calculated, federally negotiated and approved on an annual basis. A pooled fringe rate is based on actual two-year prior activity and includes any anticipated changes in cost for the period the rates are to cover.

The Controller’s Office is responsible for the development and negotiation of the pooled fringe benefit rate agreement, which is currently applicable to Clemson University (CU).

The currently approved rates are posted on the Controller’s Website. 

Employee Group and benefit program code:
Clemson’s five (5) rates are based on five (5) groups of employees grouped by employee benefit program code.  Each employee is assigned a benefit program code (BPC) by Human Resources.  The employee groups and their corresponding benefit program codes are:

Employee/Rate Groups and Benefit Program Codes

Policy
Effective: June 1, 2000
Revised: February 9, 2017

Departmental expenditure transactions are to be reviewed monthly to help ensure the validity of financial transactions by comparing supporting documents to the transactions listed on the monthly status reports.

Based on the Separation of Financial Administrative Duties policy, individuals assigned responsibility for performing these reviews should be independent of the expenditure transaction process. Where complete separation of duties and responsibilities is not feasible, the reconciliation should be reviewed and approved. The review and approval of the reconciliation is the responsibility of the department head or their documented designee. Employees should be adequately trained to perform the reconciliation procedures. The reconciliation and certification process is to be adequately documented in order to allow for future review and verification of the reconciliation. While printed documentation and certification is allowed, electronic documentation and certification is preferred. Reconciling items should be resolved in a timely manner.

Guidelines

1. After each month is closed, notification is sent out when the Budget Status Reports (BSR) are available.
2. Budget centers/departments may distribute these reports to the appropriate independent personnel for reconciliation of the University accounting records to the departments' source documents.
3. Ensure that documentation exists for each amount that is recorded in the accounting records, and the item is posted to the correct chartfield for the correct amount. Examples of supporting documentation follow:

• Payroll and related transactions should be verified and reconciled to the Monthly Payroll Report distributed by the Accounting Services office, which identifies all payments to employees by pay period.
• Other expense transactions should be verified to documentation, indicating supporting expenses and with an authorization by an employee with assigned responsibility for expending departmental resources.
• Exception: Based on volume of activity in an account, the department head may establish an internal policy that eliminates the need to reconcile amounts below a certain amount. If a department head has established such a policy, ensure that documentation exists for each amount above the established threshold.

4. Inquire about items for which there is documentation (i.e. invoice, voucher, etc.), but no accounting entry reflected.
5. Items that are identified as reconciling items should be cleared or resolved as soon as possible.
6. Upon completion of the reconciliation, document by indicating: "Reconciled by (reconciler's name) on (date)."
7. The reconciler should inform a responsible individual (Budget Center Director, Department Head, etc.) that the reconciliation(s) has been performed and that all items agree with the supporting documentation. This communication should be by paper copy memo or via e-mail. An example of the statement that the reconciler should make is: "I have reconciled all expenditure accounts for department numbers _____, ____, and _____. Accounting entries are in agreement with our documentation. Reconciler's Name _____________ and Date __________."
8. University procedures do not require a review of the reconciliations if adequate separation of duties is accomplished. However, if it is not feasible to have complete separation of duties an authorized individual should review and approve the reconciliation. With or without complete separation of duties, as indicated in step 7 above, a responsible employee should monitor to help ensure that reconciliations are being performed in a timely manner.

Policy
Effective: June 1, 2000
Revised: August 31, 2002

Departmental revenue and addition transactions are to be reviewed monthly to help ensure the validity of financial transactions by comparing original documents to the transactions listed on the monthly status reports.

Based on the Separation of Financial Administrative Duties policy, individuals assigned responsibility for performing these reviews should be independent of the revenue or additional transaction process. Where complete separation of duties and responsibilities is not feasible, the reconciliation should be reviewed and approved. The review and approval of the reconciliation will be the responsibility of the department head or their documented designee.

Employees should be adequately trained to perform the reconciliation procedures.

The reconciliation process is to be adequately documented (either in an electronic format or a paper copy) to allow for future review and verification of the reconciliation. Reconciling items should be resolved in a timely manner.

Guidance
Effective: June 1, 2000 
Revised: August 31, 2002

1. After each month is closed, a notification is sent out when the revenue detail reports are available. Budget centers/departments may distribute these reports to the appropriate independent personnel for reconciliation of the University accounting records to the departments’ source documents.
2. Ensure that originating documents (i.e., proof of goods or services provided with a related invoice, prenumbered receipt, cash register tapes) exist for each amount that is recorded in the accounting records and the item is posted to the correct chart field for the correct amount.
3. Inquire about items for which there is documentation (i.e., invoice, prenumbered receipt, bursar's receipt, etc.) but no accounting entry is reflected.
4. Inquire about items on the revenue detail report for which no documentation exists.
5. Items that are identified as reconciling items should be cleared or resolved as soon as possible.
6. Upon completion of the reconciliation, document by indicating, “reconciled by [reconciler’s name] on [date].”
7. The reconciler should inform a responsible individual (budget center director, department head, etc.) that the reconciliation(s) has been performed and that all items agree with the backup documentation. This communication should be by paper or via email. An example of the statement that the reconciler should make is: “I have reconciled all revenue accounts for department numbers _____, ____ and _____. Accounting entries are in agreement with our documentation. Reconciler’s Name _____________ and Date __________."
8. University procedures do not require a review of the reconciliations if adequate separation of duties is accomplished. However, if it is not feasible to have a complete separation of duties, an authorized individual should review and approve the reconciliation. With or without complete separation of duties, as indicated in Step 7 above, a responsible employee should monitor to help ensure that reconciliations are being performed in a timely manner.

Procedure
Effective: June 1, 2000

Departmental asset and liability accounts are to be reviewed monthly to help assure the validity of the University accounting records by comparing the University accounting records balance to the supporting departmental documentation.

There are some institutional level asset and liability accounts for which reconciliation responsibility is assigned at the institutional level (generally Accounting Services personnel). Refer to the appendix for assignment of responsibility, whether institutional or at the budget center/department level.

Based on the Separation of Financial Administrative Duties policy, individuals assigned responsibility for performing these reviews should be independent of the transactions related to the asset or liability. Where complete separation of duties and responsibilities is not feasible, the reconciliation should be reviewed and approved. The review and approval of the reconciliation is the responsibility of the department head or their documented designee.

Employees should be adequately trained to perform the reconciliation procedures.

The reconciliation process is to be adequately documented (either in an electronic format or a paper copy) in order to allow for future review and verification of the reconciliation. Reconciling items should be resolved in a timely manner.

Guidelines

1. After each month is closed, budget centers/departments should run appropriate queries to identify month-end balances and the monthly activity. Results of these queries should be distributed to the appropriate independent personnel for reconciliation of the University accounting records to the departments' source documents.
2. Ensure that the University accounting records balance agrees to the balance per the departmental documentation.
3. Common types of departmental documentation are: Inventory account: inventory listing by item, quantity and price. Receivable account: listing by customer and amount. Deposits Held for Others account: listing by individual and amount.
4. If the University accounting records balance does not agree to the balance per the departmental documentation, review for transactions for which there is departmental documentation (i.e. invoice to customer, voucher for purchase of inventory, deposit, etc), but no accounting entry reflected. Also, review for items that are recorded in the University accounting records but not recorded in the departmental records.
5. Any differences should be noted as reconciling items. These items should be cleared or resolved as soon as possible.
6. Upon completion of the reconciliation, place the following certification on the reconciliation hard copy: "Reconciled by (reconciler's name) on (date)."
7. The reconciler should inform a responsible individual (Budget Center Director, Department Head, etc.) that the reconciliation(s) has been performed. This communication should be by paper copy memo or via e-mail. An example of the statement that the reconciler should make is: "The balance of the asset/liability chartfield string _________________ agrees with our departmental records as of ___(month end date)__. All reconciling items are explained and documented. Reconciler's Name _____________ and Date __________."
8. University procedures do not require a review of the reconciliations if adequate separation of duties is accomplished. However, if it is not feasible to have complete separation of duties, an authorized individual should review and approve the reconciliation. With or without complete separation of duties, as indicated in step 7 above, a responsible employee should monitor to help ensure that reconciliations are being performed in a timely manner.

APPENDIX
Run a query to identify all asset and liability chartfield strings that contain your department number(s). The responsibility for reconciling these chartfield strings is assigned to your department or budget center, except for the account numbers listed below. The account numbers listed below are reconciled at an institutional level, even if they have your department number.

Institutional Level Accounts
1101 Cash Vendor Account
1102 Cash Payroll Account
1130 Cash State Treasurer
1131 Cash State Treasurer Appreciation
1132 Cash State Treasurer Perkins Loan
1202 Accounts Receivable Appropriations
1203 Accounts Receivable Grants and Contracts
1207 - 1229 Notes Receivable (Block)
1271-1280 SRS A/R (Block)
1601-1617 Investment in Plant (Block)
2001 Accounts Payable
2003 - 2031 Accounts Payable (Block)
2079 - 2097 Accounts Payable (Block)
2201 - 2373 Payroll Withholdings (Block)
2414 - 2429 Other Liabilities
2454 Procurement Card Clearing

Some chartfield strings have a unique account number that is applicable to a single department. Most of these chartfield strings should also carry your department number. Reconciliation of these accounts is the departments' responsibility. These account numbers are listed below.

Departmental Level Accounts (in addition to those identified with the query noted above)
1103 - 1116 Cash in Bank (Block)
1133 - 1179 Cash on Deposit (Block)
1180 - 1190 Petty Cash (Block)
1230 - 1231 Post Office
1234 - A/R Telecommunications
1401 - 1416 Inventories (Block)
2430 - 2526 Tax: Accommodations, Admissions, Sales (Block)

Policy
Effective: 07/01/2002

Maintenance of University Documents and Records
All documents and records within the University must be retained in a manner which provides for access by faculty and staff in carrying out their normal job assignments and responsibilities and reasonable protection against loss, destruction, or theft.  University records should remain on the premises at all times.  The Public Records Act, Code of Laws of South Carolina 1976, as amended, Sections 30-1-10 through 30-1-170, provides specific penalties for certain acts or neglect of duty by public officials or custodians of public records.

Responsibilities assigned to various University administrator are as follows: 

1. The President, vice presidents, deans, directors, and department heads are responsible for maintaining an adequate filing system and for coordinating with the Records Management Office to ensure the proper disposition of all records.
2. All entities (offices, departments, institutes, foundations, etc.) publishing any document, compilation, register, book, pamphlet, report, map, leaflet, order regulation, directory, periodical, magazine, or similar written material excluding interoffice communications should forward 2 copies of all publications to the University Archives and 15 copies of all publications should be mailed to the South Carolina State Library in Columbia within 15 days. The Address to the State Library is: S.C. State Library, P.O. Box 11469, Columbia, SC 29211.  (See Statutory Code SC Code, Sec. 60-2-30).  This policy may be waived if (1) the publication is of ephemeral value, (2) less than 10 copies are printed, or (3) the issuing agency requests a waiver.  
3. The Records Officer has the authority, as the agency representative, to act for the President of the University to authorize the disposition of records based upon records retention and disposition schedules approved by the State Department of Archives and History and the State Budget and Control Board.
4. Special Collections and Archives will be involved in the selection of historical records.

No records may be destroyed or discarded without the approval of the Records Management Office.

Policy
Effective June 1, 2002

Related Corporate Entities with a primary purpose, as documented in the bylaws or tax exemption, of benefiting Clemson University must have an approved cooperative agreement with Clemson University. A cooperative agreement should be signed and on file in the University Controller's Office. The cooperative agreement, at a minimum, must include:

• The primary purpose of the relationship
• A description of the related entity
• The transfer of funds between Clemson University and the entity
• Payments to, and on behalf of, Clemson University employees
• A current roster of board members and a listing of all Clemson University employees with responsibilities in the related entity
• Availability of access for internal auditor and or external auditors to these entities
• A requirement for an annual audit to be performed by an independent auditor
• A requirement for an audited financial statement to be delivered to Clemson University no later than September 30 of each year

The Clemson University Board of Trustees will periodically evaluate each cooperative agreement.

Policy
Effective: 10/1/1999
Revised: 11/1/2006
Responsible Office: Controller

Rental charges to University E&G and PSA funded activities are not appropriate when the facility is funded and maintained by legislative appropriation and/or general student tuition and fees with the following exceptions:

• Additional costs are incurred to provide a service such as overtime or hiring of additional employees.
• Specialized equipment maintained by departmental resources is required.
• Events are primarily social in nature.
• Events that are conducted in Conference or Auxiliary facilities. (i.e., Madren Center, Clemson House, Housing, Residence Life and Outdoor Research Laboratory.)

Approved rental rates may be charged for non-University use of facilities.

Proceeds are to be deposited in University departmental revenue accounts and should be used for maintenance or improvement of the facility and equipment. If additional costs are incurred by the department, these costs should also be paid from the rental proceeds.

The office with responsibility for scheduling use is authorized to waive rental charges when use promotes the mission and program of Clemson University. However, waivers should not be approved when any private individual will personally profit from free or discounted use of the facility. Waivers should be documented and available for review.

Scheduling departments are responsible for ensuring University activities are not displaced due to facility rental and the appropriate insurance coverage is provided by any external user. For assistance with insurance requirements, the department should contact the University Risk Management Office.

Please note this policy does not change existing policies regarding management or scheduling of classrooms. Classrooms should continue to be considered University Space.

All charges must be approved and published.

This manual is intended to provide basic information for Clemson University employees concerning property and liability insurance, bonding, and proper claims handling procedures.

The office of Risk Management is available to answer any employee questions concerning this manual or any other matter concerning insurance. The office telephone number is (864) 656-3354.

Risk Management
E-306 Martin Hall
Clemson University
Box 345339
Clemson, South Carolina 29634-5339

Risk Management
The goal of Risk Management is to coordinate efforts with all departments on and off campus to ensure the protection and preservation of Clemson University human, physical and financial assets.

This goal is accomplished by identifying potential human, physical, financial and natural losses and evaluating the best method for handling the risk whether it is risk avoidance, prevention, assumption or transfer.

Property-Liability Insurance and Bonding

A. Introduction

a) The Office of Risk Management is responsible for administering the property and liability insurance and surety bond programs for the University. In this capacity this office acts like an insurance agency for the University by soliciting quotations for property, liability, and/or surety coverage desired by the University and processing all claims. In addition, this office invoices the various departments for their respective pro rata share of the total premiums. In determining the department's premiums, consideration is given to the value of property assigned, number of departmental employees, liability exposures, etc.

b) The major insurance policies are: Building and Personal Property for on-campus buildings and equipment, off-campus buildings and those undergoing major renovation; business interruption protection against rental income loss for the facilities committed to the amortization of housing revenue bonds; inland marine floaters providing all physical risk damage coverage for the contents of both the Calhoun Mansion and the Hanover House, the band instruments and uniforms, TAPS camera equipment, agricultural equipment; a livestock mortality floater; aircraft hull and liability protection; automobile fleet coverage for the vehicles; physical damage and liability coverage for University watercraft; liability coverage for all University employees; medical employee professional liability; drones physical damage and liability insurance, commercial crime insurance on all University employees; state constable bonds, and public official bonds, Directors and Officers Liability Insurance and cyber insurance.

B. Policies

a) Purpose of Manual
The purpose of this section is to provide a convenient reference and a basic guide for the departments as to the types of property and liability insurance and bonds carried by Clemson University and to familiarize personnel with the correct procedures for requesting insurance and filing claims.

b) Request for Insurance or Filing a Claim
Whether a department has need for property or liability insurance, is seeking bond coverage or filing a claim against and existing policy, the department head or the research and education director should call 656-3354 or forward a memorandum directly to the Risk Manager, Office of Risk Management, with detailing the department's insurance requirements or giving details of the claim. In the event a claim or suit is brought against the University, the department head should immediately forward every demand, notice, summons, or other process received to the Risk Manager, Office of Risk Management.

c) Specific Coverage
Each of the University's major property and liability insurance policies and bonds will be briefly described in the following sections. Questions or comments relating to coverage should be directed to the Risk Manager, Office of Risk Management, by calling 656-3354.

 i) Building and Personal Property

(1) The Building and Personal Property policy written through the State's Insurance Reserve Fund protects University buildings and their contents against the direct physical loss of, or damage to, covered buildings and contents resulting from any covered cause of loss.

(2) All University buildings subject to damage from these perils and of a value warranting the cost of insurance will be insured at replacement value. All inventory items are insured under the contents portion of the policy. It should be noted that personal property belonging to any individual, employed or otherwise, should be insured by the owner. University departments are billed for their pro rata share of the premium annually.

(3) Reporting of Loss or Damage
Directors of Research Education Centers must notify the Risk Manager, Office of Risk Management, by telephone (864-656-3354) within twenty-four hours of any loss or damage and confirm this verbal communication immediately.

(2) The University currently uses this type of contract to insure the band instruments and uniforms, the historical furnishings in both the Calhoun Mansion and the Hanover House; TAPS camera equipment,, agricultural equipment and other moveable equipment.

(3) In the event of sickness, injury or death of an insured animal, immediately notify the Risk Manager, Office of Risk Management at 656-3354 and provide the following information:
(a) Name of animal
(b) Nature of sickness, injury or cause of death
(c) Date injury or sickness was first discovered
(d) Name and address of attending veterinarian

vi) Aircraft Hull and Liability

(1) The Aircraft Hull and Liability Policy is similar to automobile insurance in that it provides protection against physical damage to the hull, bodily injury and property damage liability, and medical payments for each passenger and pilot.

(2) University-owned aircraft, like other State aircraft, are insured under a master policy through the South Carolina Insurance Reserve Fund. Excluding any use for a charge made to others or operation by a non-certified and approved pilot. Some countries require additional insurance be purchased to fly into their airspace.  This will need to be checked at the time of the proposed flight.  This aviation policy provides all risk protection against direct loss or damage to the hull, third party liability coverage, and medical payments, including coverage for the pilot.

vii) Comprehensive Automobile Liability Insurance

The University's fleet of vehicles is covered by a Comprehensive Automobile Liability Policy, which contains essentially three parts:
- Bodily injury and property damage liability
- Medical payments
- Protection against uninsured motorists

All of the University's vehicles licensed for road use carry bodily injury and property damage liability insurance.

(1) Bodily Injury and Property Damage Liability

(2) Medical Payments

(3) Physical Damage

(a) There are several types of physical damage coverage, but they are all involved in protecting the owner's vehicle. The collision coverage applies to the owned vehicle. The comprehensive insurance covers damage caused by animals, birds and falling objects, wind, glass breakage and specific perils such as fire, lightning, theft, etc.

(b) This coverage should not be confused with property damage liability, which is the damage to the property of third parties for which the University may be held legally liable.

(c) While only a limited number of University vehicles are insured against comprehensive and collision, this type of loss is a good illustration of the concept of "subrogation". For example, if the University collects for damages (less the deductible) from an insurance company for one of the University vehicles, then our insurer may take over the rights to sue the responsible party and recover the payment made to the University. Whether or not the insurance company would actually bring suit depends on many factors, including the accident facts, the amount of the loss, etc.

(4) Uninsured Motorists

Uninsured motorists coverage protects the occupants of a University vehicle from bodily injury and the vehicle itself from property damage caused by a negligent, but uninsured, or hit-and-run driver. Our insurance company would pay for losses up to the limits specified in the financial responsibility law of South Carolina.

(5) Annual Review of Motor Vehicle Insurance

 viii) Watercraft Insurance

(1) Watercraft liability and physical damage may be carried on the departmental watercraft by forward full description and value of the equipment to the Office of Risk Management.

ix) Employees Liability
(1) Employee liability insurance has been secured by the University for the benefit and protection of the Board of Trustees, Faculty, Staff, and Student Employees who may be legally liable to third parties who are injured or killed as a result of actual or alleged negligence of the insured in the performance of his or her regularly assigned duties. Coverage provided by this insurance include, but are not limited to, such things as protection against false arrest, detention or imprisonment, libel, slander, violation of right of privacy, discrimination, violation of civil or constitutional rights, and use of non-highway licensed mobile equipment. Liability for University watercraft under 26' feet and non-licensed motor vehicles are also covered under this policy.

(a) This contract, better known as the Commercial Crime Policy, was developed to provide the broadest possible crime protection by combining burglary and fidelity coverage in a single contract.

(b) Clemson University's Commercial Crime Policy protects against employee dishonesty, loss of money and securities on the premises, loss of money and securities off the premises, depositor's forgery, robbery, safe burglary and computer fraud.

(2) Suretyship

(a) "Under the terms of s surety agreement, or bond, one party becomes answerable to a third party for the acts or neglect of a second party. The party holding himself responsible is the surety, and the one for whose debt or obligation the surety is responsible is the principle debtor, or more commonly referred to as the principal or obligor. The person protected by the agreement is called the obligee." In short, the surety agrees to answer for the nonperformance of the principal. However, the failure of the principal to perform a specified obligation may be occasioned by things other than dishonesty, such as incompetence or negligence.

(b) Bonding companies generally divide bonds into two classes: 1) fidelity and 2) surety. The basic difference between a fidelity and a surety bond lies in the nature of the obligation. "In the case of a fidelity bond, the obligation of the employee to be honest with his employer is implied rather than contractual." Under fidelity bonds, the bonding company reimburses the employer for dishonesty losses caused by his employees. "In the case of surety bonds, while a dishonest act may give rise to a loss, it is likewise true that negligence and lack of ability on the part of the principal may create a liability on the part of the surety."

(c) The treasurer of each institution in South Carolina is required by law to be bonded. Coverage under the bond requires the principal to faithfully perform the duties of the Office as required by law. The Vice President and Chief Financial Officer are currently bonded to the State.

 xiii) Workers' Compensation
State employees of Clemson University are protected under the South Carolina Workers' Compensation Law in the event that physical injury or occupational illness arises out of and while in the course of performing official University duties.

This law can provide the following benefits for work injured employees:

(1) All prescribed medical treatment and prescription charges necessary to resolve the injury or to bring about maximum medical improvement of a permanently impairing condition.

(2) Emergency medical transportation when needed. Also, travel mileage reimbursement for medical treatment more than five (5) miles from the employee's residence.

(3) Compensation for permanent impairment, serious disfigurement or death.

 xiv) Procedure in the Event of Employee Injury
(1) In case of accidental injury, it is an employee's responsibility to notify his supervisor or department head immediately. Any injury, no matter how slight, must be reported. In the event of loss time, the supervisor should contact the Workers' Compensation Coordinator, Office of Risk Management.

(2) Medical Treatment
If the injured employee or his supervisor judges that medical attention is needed, the supervisor or other designated person must call the University's first point of notification, CorVel, at 866-282-2674 and the employee will be directed to Redfern Health Center or another approved medical facility.

Policy
Effective: March 30, 2007

Access to Clemson University Business Systems (CUBS) Financials and Human Resources modules will only be granted upon the request of a University Business Officer, or designee, and upon the completion of training or, in emergency or temporary situations, an assertion that training will be provided.

Annually, Business Officers, or designees, will be provided an access profile for each employee in their Business Center for review. Upon completion of this review, the Controller’s Office (Financials) and the Office of Human Resources (Human Resources) will examine to verify that segregation of duties conflicts do not exist for users with multiple system profiles.

Policy
Effective: June 1, 2000

Departmental management is responsible for ensuring that financial administrative duties indicate clear lines of authority and responsibility. These duties are to be segregated so that one individual's work routinely serves as a compensating check on another's work. No one individual should have complete control over a financial transaction. Standards for separation of duties shall be implemented to the maximum degree possible.

When full separation of duties is considered not practical or feasible, (i.e. due to limited departmental staff) the variance from the standard and appropriate compensating controls must be documented in writing and approved by the college or division business officer.

Discussion
Clear lines of authority and responsibility must be established in order to segregate, where practical, the various steps of a transaction. An expenditure transaction consists of initiation of the purchase, receipt of goods, preparation of the payment voucher, authorization of the voucher, month-end reporting and reconciling. A revenue transaction consists of initiation of the sale, invoicing for the sale (if charged), collection and receipting of the funds, depositing the funds, month-end reporting and reconciling.

Guideline
Departmental management has a responsibility to ensure that financial administrative duties indicate clear lines of authority and responsibility. These duties are to be separated so that one individual's work routinely serves as a compensating check on another's work. No one individual should have complete control over a financial transaction. Standards for separation of duties are to be implemented to the maximum degree possible.
 
When full separation of duties is considered not practical or feasible, (i.e. due to limited departmental staff) the variance from the standard and appropriate compensating controls must be discussed with the dean or department head and the college or division business officer.

The departmental procurement/payment duties should be assigned to responsible staff so there is an adequate separation of duties.

A procurement/payment transaction consists of the following actions: initiation of the purchase, receipt of goods/services, preparation of the payment voucher, authorization of the voucher, and reconciliation of month-end reports.

A description of these actions follows:

• Initiation of the purchase - Goods and services should only be ordered when the request has been approved by a departmental authority or their designee. Ideally, the items requested should be documented in writing or electronically and may have a preauthorized chartfield distribution to avoid communication issues.
  
  
• Receipt of goods/services - The receiving duty requires a written or an electronic affirmation or knowledge that the delivery of goods or services provided are complete. Ideally, the receiving duty should be independent of the ordering responsibility.
  
  
• Preparation of the payment voucher - A payment voucher is not to be processed without supporting documentation (invoice or receipt and an acknowledgement of receipt of goods/or services) and authorization of the transaction (budgetary approval to charge specific chartfield distribution(s) and approval to pay).
  
  
• Authorization of the voucher - The Dean or Division administrative officer, may delegate budgetary approval to a business officer or a departmental employee. The designated officials, when approving an order or payment, are certifying that the funds are available from the budgeted chartfield distribution and that the procurements/payments are in compliance with established policies and procedures of Clemson University. An expenditure may be authorized when the purchase is initiated or at the time the request for payment is placed. Ideally, the purchase authorization is documented with either an approval signature or electronic approval.

When a transaction is entered in the CUBS system, the individual entering the transaction is assumed to be the designated official for authorization unless the transaction documentation indicates that responsibility for the transaction is assigned to another individual.

When an employee is being reimbursed for business expenses, the employee should not enter and release a voucher for payment to himself or herself. The reimbursement transaction must have a supervisory or supervisory designee written approval and be released for payment by someone other than the employee.

• Reconciliation of Month-End Reports - Departmental expenditure transactions are to be reviewed monthly to help assure the validity of financial transactions by comparing supporting documents to the transactions listed on the monthly status reports. Individuals assigned responsibility for performing these reviews should be independent of the expenditure transaction process. Where complete separation of duties and responsibilities is not feasible, the reconciliation should be reviewed and approved. The review and approval of the reconciliation is the responsibility of the department head or their documented designee.

Policy
Effective: 04/15/2007
Responsible Office: Controller

A service center is an operating unit that provides goods or services that are recurring, unique, not readily available from external sources, benefit the effectiveness of the University when available, and are subject to federal and/or state costing regulations and guidelines. A service center is essentially a small business operated by an academic department, interdepartmental laboratory or center to facilitate departmental/institutional research. Because Clemson University receives federal funding, the University is required to consistently apply federal costing regulations and guidelines. The costs associated with providing those goods or services are recovered from users through established and approved billing rates. All service center activity must either support or relate to the University’s mission. Billing rates are submitted to the Controller’s Office and the Office will review and either approve or forward the billing rates to the Administrative Council for approval.

A recharge center is a service center that provides goods or services only within a single budget center or department. A recharge center’s rates may not be officially posted but still require reviewing by the Controller’s Office.

All service centers are required to follow Billing Rates Policy and Billing Rates Procedures when establishing and changing billing rates.

Form Instructions:

1. Fill in the required information (up to 12 items per 206) - DO NOT attach spreadsheets or any other type of listing.
2. Obtain all required signatures and make 2 copies of the completed form
3. Contact Surplus Property by phone or by email for delivery instructions.

Surplus Property (surplus@clemson.edu)  864-656-2092

Departments Disposing of Surplus Property:
Any department desiring to declare University property in its custody as SURPLUS must submit a Declaration of Surplus Property Form (CUBO 206) to Procurement Services.

After receiving the Declaration of Surplus Property form, Procurement Services will return a copy of the original with a receipted stamp and the signature of a Procurement official to the originating department. The department should retain this form as authorization to dispose of the items and to delete the items from the movable equipment inventory.

Transfer to Other University Departments:
Procurement Services will, when feasible, determine if the property can be used elsewhere in the University. If so, the property will be transferred to another department.

Disposition of Computers:
Any computer tape, disk (hard drive, CD or floppy) or other storage medium used to store University data must be totally erased or rendered unreadable before it is disposed of through departmental transfer or Surplus Property. Employees should contact their TSP's or DCIT personnel for assistance if necessary.

Other Disposition Methods:
If the property cannot be used elsewhere in the University, it, upon recommendation of Surplus Property, Procurement Services, will be declared surplus and disposed of by Surplus Property or the State Surplus Management Office of the Division of General Services in the method most advantageous for the University in conformity with state policies.

The methods available for disposition of University surplus property are:

1. Auction, publicly advertised and held.
2. Sale under sealed bids, publicly advertised and held.
3. Trade-in under terms and conditions whereby the University replaces the surplus property.
4. Transfers to other State of South Carolina agencies or sale to eligible political subdivisions of the state or other government entities, such as non-profit volunteer fire, police, and rescue organizations operating for a public purpose and eligible, non-profit corporations whose activities are related to health and/or education.
5. Sold to a scrap contractor.
6. Taken to land fill.

Notice Requirement for Public Sale:
When Surplus Property, Procurement Services determines to dispose of surplus property by sealed bids, such proposed sales may be publicly advertised and publicly held. Surplus Property, Procurement Services may advertise the proposed sale in a newspaper of general circulation and will state the date, time, place, manner, and conditions of the sale.

Invitation to Bid Restrictions:
No person, firm, or corporation may be sent invitations to bid on proposed sales unless it has been determined from all circumstances there is no market for the property without requesting such bids. Prospective buyers for various types of surplus property may be sent copies of the public notice as published or notified that public notice has been published in a certain newspaper on a stated date.

Sale of Motor Vehicles:
All sales of surplus University motor vehicles will be conducted by the Materials Management Office of the State of South Carolina and all arrangements pertaining to these sales will be coordinated through that department in accordance with state policies.

Terms of Sale:
Purchase of surplus property by the general public shall be by cash or check.

Sale to State Agencies:
All sales of surplus University property to political subdivisions of the state and other governmental entities must follow the provisions of applicable state laws and University policies and procedures.

If you have further questions, please contact:

Surplus Property          
Administrative Services Building                               
Silas N Pearman Blvd and Old Stadium Road 
Clemson, SC 29634
(864) 656-2092
surplus@clemson.edu

Effective: 11/1/1982
Revised: 1/31/2014

Information
Telecommunication Services, an operating unit of the Division of Computing and Information Technology (DCIT), is responsible for the coordination of the University telephone system. All requests for non-cellular telephone service should be submitted to Telecommunications on a Telecommunication Services Request Form, or on-line through the Telecommunications web site, and approved by the department head or director. Telecommunication Services personnel work with the telephone system users to determine their communications requirements, then develop the most economical and efficient systems, and coordinate all installation and change requests with the telephone company and other vendors. Telecommunication Services audits the communications vendor bills and prepares monthly internal rebillings to University departments utilizing the Monthly Telephone Invoice. Departments are invoiced for any installation charges, local service charges, and toll charges.

The Call Assistance Center (University switchboard) is manned between the hours of 8:00 a.m. and 12:00 midnight, seven days a week. It provides general campus information and locator service for all students, faculty, and staff.

Services provided by Telecommunication Services include campus departmental and student local access and long distance service, employee long distance authorization codes and cards, calling cards, the campus emergency telephones, telephone directories, electronic conference services, paging systems.

Policy
In December 1988, the State Budget and Control Board issued statewide regulations which established the proper use of South Carolina state government telephone services. The intent of these guidelines is to permit South Carolina state government employees to make reasonable use of the telephone system and simultaneously, to guard against abuse of telephone usage.

a. Calls to notify the family, physician, etc., when an employee is injured on the job.

b. Calls to notify family of a schedule change when an employee traveling on state government business is delayed due to official business or a transportation delay.

c. An employee, traveling in the United States for more than one night on state government business, makes a brief call to his or her residence (averaging not more than one call per day).

d. An employee is required to work overtime without advance notice and calls within the local commuting area (the area from which the employee regularly commutes) to advise his or her family of the change in schedule or to make alternate transportation or child care arrangements.

e. An employee makes a brief daily call to locations within the local commuting area to speak to a spouse or minor children (or those responsible for them, i.e., a school or day care center) to make certain of their well-being and/or safety.

f. The employee makes brief calls to locations within the local commuting area that can be reached only during normal working hours, such as a local government agency or a physician.

g. An employee makes brief calls to locations within the local commuting area to arrange for emergency repairs to his or her residence or automobile.

h. A call that reasonably could not be made at another time if it is of moderate duration and it does not adversely affect the performance of the state telephone systems (e.g., unauthorized calls, made in rapid succession, to call-in contests on radio stations are detrimental to telephone system service levels).

2. Personal calls that must be made during normal working hours may be made over the commercial long distance network if the call satisfies the guidelines in Section 1 and one of the following provisions:

a. It is charged to the employee's home telephone number or other non-state government number.

b. It is made to a toll-free number.

c. It is charged to the party being called if it is a non-state government number.

d. It is charged to a personal credit card.

e. It is charged to a personal account administered by Telecommunications and billed directly to the employee at his or her home address.

3. This policy applies to departmental cell phones, which are shared departmental cell/shift phones, and departmental cell phones that are issued to individual employees for unique circumstances, including specific purposes and/or for specified periods of time.

a. A shared departmental or shift cell phone is one that may be shared by multiple employees while on duty, does not leave the campus after duty and is turned in by each employee at the end of his/her shift.

b. A departmental cell phone that is issued to an employee individual under a special set of circumstances as determined by the supervisor may leave the campus with the employee.

c. Departmental cell phones are to be used primarily for business purposes. Due to the nature of cell phones, the occasional use of the cell phone for personal calls is allowed and should adhere to the basic guidance outlined in items 1 and 2 above where applicable.

d. Appropriate data usage, where costs are covered by the University, on a departmental cell phone or other telecommunication devises issued to employees (i.e. iPad) will be determined by the departments based on the business case. Data usage should be limited to business purposes only. If data is part of the departmental cell phone, usage will follow other University data policies.

e. Departments are required to periodically review call and data packages to ensure the most cost effective plan is being used and to determine whether a stipend would be more cost effective when there is consistent minimal business use.

f. Departments are required to monitor departmental cell phones for personal use and to arrange for reimbursement if excess costs are incurred. Departments are NOT required to print out monthly records, but may implement such measures if the situation dictates. Departments should consider access to electronic records when access to electronic records is available.

4. Other

a. Under normal circumstances, it will not be acceptable for an employee to use a university telephone account for long distance calls and then reimburse the University for the cost of those calls.

b. Departments are responsible for monitoring the reimbursement of long distance calls and determining reasonable use of phone service.

c. The disposal of any Clemson owned phone or related equipment should be handled through the current University surplus process.

5. Personal Communication Devices Used for Business Purposes

a. Clemson University under prescribed and agreed upon conditions will support the use of personal telecommunications devices to conduct business related activity.

b. Employees who qualify, have a business related need, and the employee’s department has agreed, may be eligible to receive a stipend to cover the business use portion of voice and/or data charges incurred by the employee on a personal communications plan.

c. Guidelines, requirements and regulations covering personal communication agreements and stipends are maintained on the Procurement website.

d. All contractual agreements between the employee and any telecommunications carriers are the sole responsibly of the employee and there is no guaranteed expectation for Clemson University to continue the telecommunication stipend service as it is subject to change at any time.

Policy
Effective: 7/1/2004

Costs of scholarships, fellowships, and other programs of student aid are allowable (for federal purposes) only when the purpose of the sponsored agreement is to provide training to selected participants and the charge is approved by the sponsoring agency.

Background
Besides the above-referenced exception for what are commonly referred to as “training grants”, federal OMB Circular A-21 establishes three conditions to be met in order to charge tuition and fees to sponsored research projects:

1. A bona fide employer-employee relationship between the student and the institution for the work performed must exist
2. The tuition or other payments are reasonable compensation for the work performed and are conditioned explicitly upon the performance of necessary work
3. It is the institution’s practice to similarly compensate students in nonsponsored as well as sponsored activities

At this time, graduate assistant tuition at Clemson is paid by the student, not from institutional, gift or sponsored project funds. Not until graduate assistant tuition is consistently paid for all graduate assistants, will the University be eligible to charge these costs to federal sponsored projects.

Policy
Effective: 10/1/1999
Revised: 11/1/2006
Responsible Office: Controller

Rental charges to University E&G and PSA funded activities are not appropriate when the facility is funded and maintained by legislative appropriation and/or general student tuition and fees with the following exceptions:

• Additional costs are incurred to provide a service such as overtime or hiring of additional employees.
• Specialized equipment maintained by departmental resources is required.
• Events are primarily social in nature.
• Events that are conducted in Conference or Auxiliary facilities. (i.e., Madren Center, Clemson House, Housing, Residence Life and Outdoor Research Laboratory.)

Approved rental rates may be charged for non-University use of facilities.

Proceeds are to be deposited in University departmental revenue accounts and should be used for maintenance or improvement of the facility and equipment. If additional costs are incurred by the department, these costs should also be paid from the rental proceeds.

The office with responsibility for scheduling use is authorized to waive rental charges when use promotes the mission and program of Clemson University. However, waivers should not be approved when any private individual will personally profit from free or discounted use of the facility. Waivers should be documented and available for review.

Scheduling departments are responsible for ensuring University activities are not displaced due to facility rental and the appropriate insurance coverage is provided by any external user. For assistance with insurance requirements, the department should contact the University Risk Management Office.

Please note this policy does not change existing policies regarding management or scheduling of classrooms. Classrooms should continue to be considered University Space.

All charges must be approved and published.

Last Update: March 20, 2020

1.0 Purpose
This policy describes the general guidelines for the analysis of unrelated business income.

2.0 Policy
Summary of the Unrelated Business Income Tax

2.1 Introduction
The Federal Income Tax laws have traditionally exempted from tax those organizations whose activities benefited society, a category which included colleges and universities. An entity which met the requirements for tax exempt status was not taxed on any income, even from business activities. However, Congress enacted legislation in 1950 which taxed the "unrelated trade or business income" of a tax exempt entity, although it did not prohibit tax exempt entities from engaging in business activities. This legislation was intended to prevent unfair competition by tax- exempt organizations with tax-paying, commercial enterprises. In fact, the impetus for the legislation was commercial activity by a state university.

2.2 Unrelated Business Income (UBI)
For the income from an activity of the University to be taxed, the income must be from an "unrelated trade or business." This is defined as any TRADE OR BUSINESS which is REGULARLY CARRIED ON and which is NOT SUBSTANTIALLY RELATED to the University's educational, tax-exempt purpose.

2.3 Trade or Business
The term "trade or business" means any activity carried on for the production of income from the sale of goods or the performance of services. This is a very broad definition which includes many University activities. Except for specific statutory exceptions, only investment activities (producing income in the form of rents, royalties, interest or dividends) escape this classification. Further, the University's operations are viewed as a "bundle of activities" which the Internal Revenue Service (IRS) can examine independently for the characteristics of unrelated business. Under this "fragmentation rule," an activity does not lose its identity as a trade or business merely because it is carried on within a larger aggregate of similar activities or within a larger complex of other endeavors which may be related to the exempt purposes of the University.

Although the policy behind the tax is the elimination of unfair competition between tax-exempt and taxable entities, demonstrating that an activity does not compete with a taxable business is not sufficient by itself to avoid application of the tax. Also, the activity need not actually generate a profit; only the PURPOSE of generating profit is required for the activity to be a trade or business.

2.4 Regularly Carried On
To be taxable, the trade or business must be "regularly carried on." The test of "regularly carried on" considers the FREQUENCY, CONTINUITY, and MANNER in which the activities are conducted compared with similar commercial activities carried on by taxable businesses. Activities normally conducted year-round in a commercial context are not "regularly carried on" if the University conducts them only for a few weeks. Intermittent activities are evaluated with special emphasis on the manner in which they are carried out, comparing the competitive and promotional efforts with those of comparable taxable businesses.

2.5 Not Substantially Related
A regularly conducted trade or business is subject to tax if it is also not substantially related to the exercise or performance of any charitable or educational function of the University. To be substantially related, the activity must have a substantial causal relationship to the achievement of an exempt purpose, other than the University's need for income.

Two other concepts are encompassed by the "substantially related" test. First, the activities should be conducted on a scale no larger than is necessary for the performance of the exempt functions. Activities in excess of the needs of exempt functions constitute the conduct of an unrelated business. Second, the University may sell a product or by-product of the performance of its exempt function without being considered to be engaged in an unrelated trade or business if the product is sold in substantially the same state it is on completion of the exempt function, and is not further used in a business activity.

2.6 Exempted Activities
The federal tax laws list several activities which are exempted from the UBI tax, even though they would otherwise have the characteristics of an unrelated trade or business. Two exempted activities are applicable to the University. First, any trade or business which is carried on by the University primarily for the convenience of its members, students, patients, officers, or employees is exempted from the UBI tax. An exemption also applies to all income derived from research performed by the University for any person. "Research" within the meaning of this exemption does not include activities of a type ordinarily carried on as an incident to commercial or industrial operations, such as the ordinary testing or inspection of materials or products or the designing or construction of equipment, buildings, etc. The IRS will scrutinize applied research funded by commercial sponsors, especially if the research involves a physical product, such as a drug. In these cases, it is important for the University to articulate its academic or educational interest in the performance of the research.

2.7 Reporting Requirements
Any tax-exempt organization which realizes unrelated business income must file a tax return with the IRS for the year involved, whether or not the income produced a net profit. The Tax Cuts and Jobs Act of 2018 changed how UBI is reported. Prior to this Act, income reported on the UBIT return could be aggregated for all of the unrelated trades or businesses engaged in by the University, so that gains from one business could be offset by losses in another business. The new guidelines require an organization subject to the unrelated business income tax, with more than one unrelated trade or business, to calculate unrelated business taxable income (UBTI) separately with respect to each trade or business. UBTI, including for purposes of determining any net operating loss (NOL) deduction, shall be computed separately with respect to each trade or business. UBTI with respect to any such trade or business shall not be less than zero.

2.8 University-specific Issues
There are several specific areas addressed by the tax law, regulations, court decisions, and IRS rulings which are applicable to current and potential University activities. The rules announced in these sources for several specific fact situations are summarized in the following paragraphs.

Athletics and Athletic Facilities:
A university's receipt of revenues from the sale of television and radio broadcasting rights to athletic events is not subject to UBI tax.

Money received by a university for leasing athletic facilities to a professional football team for summer camp, without providing meals or maid service, is exempt from UBI tax because it is rental income.

Money received by a school from a contract with an individual who conducts a summer tennis camp, under which the school furnished tennis courts, housing and dining facilities, and hired instructors, recruited attendees and provided supervision, is unrelated business income.

Campus Activities:
The operation of a music theater by a liberal arts college is not an unrelated trade or business.

Sponsoring professional theater companies and symphony orchestras that give performances to which the general public is invited does not create unrelated business income.

The conduct of conferences or seminars open to the general public is an activity related to a school's exempt purpose.

Travel Services:
The conduct of travel study tours that include courses on the culture of foreign countries and nature studies taught by certified teachers is exempt from UBI tax.

The operation of a travel tour program for alumni association members and their families is an unrelated trade or business.

General Policy
Effective: November 1, 1982
Revision No. 2
Revised: November 28, 2018

University policy does not permit the operation of any concession, including vending machine equipment or any other sales operation, the profits of which inure to the benefit of any private person or group, either student or faculty.

Vending Machines
The operation of vending equipment on the University's campus is a complex commercial operation and produces a significant amount of revenue for the University.  Examples of vending equipment include but are not limited to beverage and/or snack machines, ATMs, gumball machines, etc.  Efficiency in the administration and supervision of vending operations requires all departments, groups, and individuals comply with the following policies and procedures relating to vending equipment:

1. Vending machine equipment may be installed on University premises only under the terms of a formal contract between the vending company and the University. This contract is awarded after bids have been taken by the University Purchasing Department.
2. Deans, directors, or administrative heads desiring installation of vending equipment in their areas of operation should make a written request for the required equipment to University Housing & Dining.
3. Appropriate personnel from University Housing & Dining, Fire Department, and Facilities Maintenance and Operations will inspect the location and review the utility service requirements of such installations with the department. If all parties concur on the machine location and that the installation is warranted, University Housing & Dining will secure the desired equipment under existing or new contracts.
4. Vending equipment should be kept to a minimum in academic buildings, and should not be requested unless justified for service and convenience to students, employees, and visitors.
5. Revenue from vending equipment installations, other than those in regular revenue producing auxiliary enterprises, are credited to the vending fund of the University and used for the benefit of the University and its students.

Policy
Effective: February 1, 2003
Revised: October 31, 2018

Setup of all new incoming wire transfers and/or EFT payments must be coordinated with the Accounts Receivable area within the Office of Accounting Services to ensure all documentation is properly completed and funds are adequately accounted for. EFT enrollment forms must be completed by the Accounts Receivable office or the department that the customer is doing business with. Wire transfer and/or ACH instruction must be obtained from the Accounts Receivable office. In each case, the payor will be instructed to include identifying information for the payment, such as invoice number or beneficiary, to help ensure accurate processing of the payment. Monies will be receipted to the appropriate CUBS accounts once they are received.

Policy
Effective: February 1, 2003
Revised: November 19, 2018

Clemson University will accept wire transfers and/or electronic funds transfers (EFT) as payment for invoices and other debts owed to the University.  All such in-coming wire transfers and/or EFTs must be processed through the University's designated bank account.

Procedure
All new in-coming wire transfers and/or EFT payments must be coordinated with Accounts Receivable to ensure all documentation is properly completed and funds are adequately accounted for. Wire transfer instructions must be obtained from the Accounts Receivable Manager or designee. In each case, the payor will be instructed to include the student’s university identification number to ensure accurate processing of the payment. E-check (ACH) payments are initiated securely through iROAR for students or through TouchNet for students' authorized users. E-check (ACH) payments will be processed in accordance with current banking regulations.

A returned item fee of up to $30 is assessed for all E-check (ACH) tuition payments returned for any reason.

Policy
Effective: February 1, 2003
Revised: November 19, 2018

Clemson University offers and encourages direct deposit for all student refunds processed through the Student Receivables System based on the University's refund schedule. An e-refund enrollment must be completed by the student via iROAR.

All deposits are made in accordance with current banking regulations.