Broader Public Sector Expenses Directives and TBRHSC Compliance Presented at Thunder Bay Regional Health Sciences Centre Manager’s Meeting March 2011 Eila MacLean, Manager, Financial Services
Background The Government of Ontario is raising the level of accountability and transparency for designated broader public sector (BPS) organizations aligning them with the standards expected in ministries and agencies of the Government of Ontario. Directives were issued under the authority of the Broader Public Sector Accountability Act, 2010 All “in scope” BPS organizations are to be compliant as of April 2011. All hospitals are in scope.
Background Continued BPS organizations include: Hospital School board University College Community Care Access Centre (CCAC) Children’s Aid Society (CAS) Corporation controlled by BPS for purpose of purchasing Organizations receiving more then $10M in gov’t funds Remember this list – All organizations covered by directive are prohibited from extending reimbursed hospitality to each other.
Implications for TBRHSC Principles Accountability Framework Posting for the public Alcohol Hospitality Consultants Documentation
Principles Accountability - Organizations are accountable for public funds used to reimburse travel, meal and hospitality expenses. All expenses support business objectives. Transparency - Organizations are transparent to all stakeholders. The rules for incurring and reimbursing travel, meal and hospitality expenses are clear, easily understood, and available to the public. Value for Money - Taxpayer dollars are used prudently and responsibly. Plans for travel, meals, accommodation and hospitality are necessary and economical with due regard for health and safety. Fairness - Legitimate authorized expenses incurred during the course of the business of an organization are reimbursed.
Accountability Framework Everyone must understand the authority for approval Approvers are accountable for compliance Approved request must be: able to stand up to scrutiny by the auditors and members of the public properly explained and documented fair and equitable reasonable appropriate
Accountability Framework continued Directives and expense rules apply to any person making an expense claim such as board members, employees, medical staff, volunteers, consultants and/or contractors Approvers are prohibited from approving their own expenses and, therefore, expenses for a group can only be claimed by the most senior person present e.g., an executive who reports to the CEO cannot submit a claim that includes the cost of the CEO’s lunch even if they were at the same event, as the CEO would thereby approve his/her own expenses Approvers must provide approval only for expenses that were necessarily incurred in the performance of organization business Provide approval only for claims that include all appropriate documentation e.g., detailed receipts required, credit card slips are not sufficient
Posting for the public Expense rules (policies) are required to be posted on the hospital’s public website The hospital’s policy is being revised to cover all “reimbursable expenses” for board, staff, consultants, contractors and other designates such as volunteers and physicians as applicable Management Board of Cabinet can determine requirements related to disclosure of reimbursed expenses will come More details to come
Alcohol Rules must be very specific about the circumstances of when alcohol can be claimed and reimbursed and by whom Although government ministries are more strictly prohibited, BPS organizations are not provided their policies specifically address the issue A decision to provide alcohol at a staff or any event should be approved at the highest level and be consistent with good judgment, business case, value for money and the principles of BPS expense directive and subject to the limitations and/or circumstances specified by the organization Other grant funding agencies may expressly prohibit
Alcohol continued Staff are encouraged to ask the restaurant for a separate invoice when having alcohol with their meals or deduct the amounts – including applicable taxes Remember approvers are accountable and must be compliant with policy Expense details may be made public Approval form being developed as part of the revised policy Directives suggest there needs to be a business case for the provision
Hospitality Hospitality is the provision of food, beverage, accommodation, transportation and other amenities paid out of public funds to people who are not engaged to work for: designated BPS organizations or any of the Ontario government ministries, agencies and public entities covered by the OPS Travel, Meal and Hospitality Expenses Directive (available on the Ministry of Government Services website). Activities involving only those people in the organizations listed above are not considered hospitality and cannot be reimbursed. This means that hospitality may never be offered solely for the benefit of anyone covered by this directive, or by the OPS Travel, Meal and Hospitality Expenses Directive.
Hospitality continued Examples not covered under hospitality are office social events, retirement/holiday lunches/parties Other examples of hospitality or “gifts” include meals, wine, gift baskets, In Memoriam donations Lunches, suppers and gifts of wine not covered under hospitality or reimbursable expenses Other board, staff, physician and volunteer recognition needs to be covered by other policies.
Consultants Subject to the Broader Public Sector (BPS) Expenses Directive, any contract between the hospital and the consultant will clearly specify any and all reimbursable expenses with a prohibition on reimbursement of meal and hospitality expenses Consultants must be made aware of the principles of accountability, transparency, value for money and fairness and any expense claims submitted per contract must include receipts as supporting documents
Consultants continued Consultants cannot claim or be reimbursed for such expenses, including: hospitality meals, snacks and beverages gratuities laundry or dry cleaning valet services dependant care home management personal telephone calls
Documentation Receipts required, message emphasized and repeated – credit card slips are not receipts, room services on hotel invoice still requires detailed receipts TBRHSC policy directs you to use Expense Form and designated travel agent for airfare Do not use Petty Cash vouchers Cost of meals reimbursed to a staff member is not catering or office supplies Expenditures may be audited and made public For ease or reporting and/or audit we need to centralize all reimbursed expenses in individual files
In Closing Remember: Principles; accountability, transparency, value for money and fairness Approvers are accountable Public scrutiny test Economical with business case Compliance with directive and other policies, budget and reporting standards