Policy handbook
Copy, edit and adopt. Adjust the limits to your own spend history before rollout.
1.0Purpose and scope
This policy governs travel, meals and other business expenses for all employees, including clinical specialists who support procedures, medical affairs staff and commercial teams. It is written to meet IRS accountable plan rules and to capture every payment or transfer of value to a covered recipient so the company can file accurate CMS Open Payments reports. Where this policy and the compliance code differ, the stricter rule applies.
2.0Roles and approvals
Managers approve their direct reports' expenses for business purpose and policy fit. Any expense that involves a physician, physician assistant, nurse practitioner or other covered recipient is also routed to Compliance before payment. Accounts Payable confirms receipts and coding, and the controller approves reports above $3,000. Compliance owns the Open Payments data set and may hold any report until recipient details are complete.
3.0Booking and lodging
Air, hotel and rental cars must be booked through the company travel tool. The company will reimburse a standard room up to the nightly caps, including taxes, with the itemized folio attached. Clinical specialists on case coverage may extend a stay when a procedure is rescheduled, noting the case date on the report. Hotels or travel paid for a clinician are transfers of value and must be booked through Compliance.
4.0Employee meals
While traveling overnight, employees may spend up to the daily meal allowance on their own meals. Meals in the home city are personal unless a business guest is present. When employees eat together, the most senior person pays and lists every attendee. Coffee or snacks bought for an operating room team are not employee meals: they count as an HCP meal and need recipient details.
5.0Meals with healthcare professionals
Meals with clinicians must be modest, occasional and held in a setting that suits an educational or scientific exchange, such as a hospital conference room or quiet restaurant. Employees must record each attendee's full name, credentials and NPI, plus the product or topic discussed. The cost is divided across everyone who ate. Spouses, guests and office staff who did not attend are never paid for.
6.0Open Payments capture
Every payment or transfer of value to a covered recipient must be captured, even when it falls below the CMS annual reporting threshold, because small amounts are aggregated per recipient across the year. This includes meals, travel, consulting fees, honoraria and educational items. Employees must not split a meal across reports or cards to lower the per-person value. Compliance reconciles captured data to the general ledger monthly.
7.0Alcohol
The company will not reimburse alcohol at any meal or event where a covered recipient is present, whether or not the clinician drank. At meals with non-clinician business contacts, two drinks per person are allowed and must be itemized separately. Alcohol on solo travel and from hotel minibars is personal. Reports that combine food and alcohol on one line will be returned for an itemized bill.
8.0Ground transport and mileage
Employees should use standard ride-share, taxis or hospital shuttles. Personal vehicle use is reimbursed at the IRS standard mileage rate, with each trip logged by account name and address. Normal commute miles between home and the regular office are personal. Hospital garage parking is reimbursable with the gate receipt, but parking tickets and towing are not, even when a case ran late.
9.0Entertainment and gifts
Entertainment and recreation for clinicians, including sporting events, golf, concerts and spa visits, is prohibited regardless of who pays. For non-clinician business contacts, entertainment needs VP approval in advance and is nondeductible under the Tax Cuts and Jobs Act of 2017. Gifts to covered recipients are prohibited. Gifts to other business contacts are limited to $25 per recipient per year and must be logged.
10.0Personal and mixed expenses
Personal expenses, including companion travel, upgrades, in-room entertainment and personal items left on a hotel folio, must be removed before submission or repaid. When an employee extends a conference trip for vacation, the company pays only the airfare and lodging a business-only itinerary would have cost. Medical conference registration for family members is never reimbursable, even when the employee is presenting.
11.0Receipts, timing and returning excess
Employees must submit expenses within 60 days after they are paid or incurred, with the amount, date, place and business purpose for each item. Itemized receipts are required for all lodging, any expense of $75 or more, and every HCP meal. Travel advances are issued no more than 30 days before travel, and unspent advances must be returned within 120 days after the expense was paid or incurred.
12.0Corporate card and exceptions
Corporate cards are for business expenses only, and personal charges must be flagged within 10 days and repaid. Exceptions require written approval from the controller before the expense, and exceptions involving covered recipients also need Compliance sign-off. Emergency exceptions, such as a case that runs overnight, must be explained on the report within five business days. Each exception covers one event only.
13.0Audit, pushback and consequences
Accounts Payable reviews every report, and every flag raised by audit software is reviewed by a person before anything happens. The software may draft clarification requests, such as asking for an attendee list on an HCP meal, but finance and Compliance approve each message before it goes out. Violations involving covered recipients are escalated to Compliance and may lead to disciplinary action up to termination.
Recommended limits
| Category | Limit | Note |
|---|---|---|
| Domestic hotel (per night) | $264 in high-cost metros, $199 elsewhere | Hotels next to hospital campuses are often cheaper than downtown; book them for site visits. |
| International hotel (per night) | $295 in major European and Asian cities, $214 elsewhere | Clinical study monitors follow the study budget if it is lower. |
| Daily meals (traveling) | $79 per full travel day | Covers the employee only. Meals that include a clinician follow the HCP meal row. |
| HCP meal (per attendee) | $68 including tax and tip | Modest, occasional and tied to an educational or scientific exchange. Name and NPI recorded for every covered recipient. |
| Client meal (per attendee) | $95 for non-clinician business contacts | Hospital supply chain and finance staff who are not covered recipients still go on the attendee list. |
| Domestic airfare | Economy; extra legroom on flights over 3.5 hours | Clinical specialists covering cases may book refundable fares. |
| Ground transport | Standard ride-share, taxi or hospital shuttle | Parking at hospital garages is reimbursable with the gate receipt. |
| Personal vehicle mileage | IRS standard mileage rate | Log account name and hospital address for each visit; home to first account counts only beyond the normal commute. |
| Alcohol | Never with HCPs; two drinks with non-HCP business guests | Alcohol at any meal with a covered recipient is personal and never reimbursed. |
| Business gifts | None to HCPs; $25 per recipient per year to others (IRC § 274(b)) | Educational items for patients follow the compliance catalog, not this row. |
| Receipt required at | $75 (IRS threshold); every HCP meal at any amount | HCP meals need the itemized bill and a signed or electronic attendee sheet. |
IRS Accountable Plan clauses
Keep these in the handbook so reimbursements stay excluded from wages under IRC § 62(c) and Treas. Reg. § 1.62-2.
- A1The company reimburses only expenses with a clear business connection to the employee's work, and each report must state that connection, as Treas. Reg. § 1.62-2 requires for an accountable plan.
- A2Each expense must be substantiated with amount, time, place and business purpose within 60 days after it is paid or incurred, consistent with the fixed-date safe harbor in Treas. Reg. § 1.62-2(g)(2).
- A3For meals with clinicians or other business contacts, employees must also record the business relationship of each attendee, which Treas. Reg. § 1.274-5 requires in addition to the receipt.
- A4Itemized documentary evidence is required for every lodging expense and for any other expenditure of $75 or more, as Treas. Reg. § 1.274-5(c)(2)(iii) provides.
- A5Advances and amounts paid in excess of substantiated expenses must be returned within 120 days after the expense is paid or incurred, and unreturned amounts are reported as W-2 wages subject to withholding and FICA.
Common pitfalls in healthcare & life sciences
- Recording the HCP meal under the rep's name only. Without each clinician's name and NPI, Compliance cannot report the transfer of value and has to chase the field months later.
- Dividing a meal only among the clinicians who attended. The per-person value should reflect everyone who ate, and getting this wrong overstates what each recipient received.
- Buying coffee for an operating room team and coding it as a personal meal. That spend is a transfer of value to the clinicians present and belongs in the Open Payments data.
- Letting alcohol slip onto an HCP dinner bill. Even one bottle of wine creates a compliance finding, separate from the tax treatment.
- Ignoring small amounts because they fall under the CMS annual reporting threshold. Small items are aggregated per recipient, and the annual total can cross the threshold.
Questions
Yes. Nurse practitioners and physician assistants have been covered recipients since 2021, and small payments are aggregated per recipient across the calendar year. A coffee on its own may sit below the CMS annual reporting threshold, but several over the year can cross it. Recording every item with the recipient's name and NPI is far easier than rebuilding the history at year end.
Divide the total bill, including tax and tip, by everyone who ate, which is seven people in this case. A $412.37 lunch works out to about $58.91 per person, and that figure is attributed to each of the five clinicians. The two employees' shares are reimbursed as ordinary business meals and are not reported. Keep the signed attendee sheet with the receipt.
Not on their own card. Travel and lodging for a covered recipient is a transfer of value that must be arranged through Compliance, which confirms the training is legitimate, books the room and records the value for Open Payments. If an employee pays by mistake, they should flag it right away so Compliance can capture the recipient details before the month closes.
No. Supply chain, finance and administrative staff who are not covered recipients follow the client meal row, with a higher per-person cap and two drinks allowed. They still go on the attendee list for tax substantiation. If a physician joins the meal, the whole meal becomes an HCP meal, so the lower cap applies and alcohol is not reimbursable.