1. Broader Public Sector Directives and Impacts
Presented to Thunder Bay Regional Health Sciences Centre Senior Support Team
September 26, 2011
Eila MacLean, Manager, Financial Services

2. Background
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
TBRHSC expense policy revised January 2011
New form FIN 14 Business Plan for Provision of Hospitality or Alcohol at a Proposed Event introduced
Presentation to Managers March 2011
Expense claim form FIN 10 revised and detailed expense accounts introduced August 2011
FAQ for TBR management compiled

3. BPS Accountability Act 2010
Ban on using public funds to pay for consultant lobbyists effective January 2011
New directives setting out rules for procurement and expenses effective April 2011
New directive setting out rules for perquisites effective August 2011
Requirements specific to hospitals and Local Health Integrations Networks (LHINs) for reporting and publicly posting expense information
Bringing hospitals under freedom of information legislation.
Additional measure 10% Executive Office Reduction

4. BPS organizations in scope include:
Hospitals
School boards
Universities
Colleges
Community Care Access Centre (CCAC)
Children’s Aid Society (CAS)
Corporations controlled by BPS for purpose of purchasing
Organizations receiving more then $10M in government funds

5. Implications for TBRHSC and for Support Staff engaged to have documents “signature ready”
Principles and accountability framework
Posting for the public
Alcohol
Hospitality
Consultants
Documentation
Perquisite policy required
Executive office reporting
Additional direction for management

6. Principles and Accountability Framework
Everyone must understand the authority for approval
Principles of accountability, transparency, value for money and fairness were incorporates into our revised policy (FIN 05)
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

7. 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

8. Posting for the Public
Expense rules (policies) are required to be posted on the hospital’s public website
Board approved attestations to LHIN June 30th of each year and on public website by August 31st
Annual report to LHIN on consultant use 1st report due June 30, 2012 for year
Expenses of board members, CEO and senior management to be posted semi-annually, November 30th & May 31st with 5 days notice to LHIN prior to posting

9. Posting of Expenses Form
Name
Title
Date
Amount
Expense Category
Description
Registration
Conference
Air Travel
Taxi
Mileage
Board Meeting
Meals
Accommodation
Incidentals
Hospitality
Out of country delegate

10. Alcohol
Rules must be very specific about the circumstances of when alcohol can be claimed and reimbursed and by whom
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

11. 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
Expense details may be made public
New TBR form FIN 14 Business Plan for Provision of Hospitality or Alcohol at a Proposed Event developed as there should be a business case for the provision of either
Remember approvers are accountable and must be compliant with policy

12. 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:
The hospital
Designated BPS organizations or
Ontario government ministries, agencies and public entities (covered by the OPS Travel, Meal and Hospitality Expenses Directive)
Hospitality may never be offered solely for the benefit of anyone covered by these directives.
Activities involving only people from the organizations listed above cannot be considered hospitality and reimbursed as such
Staff must refer to their own respective organization’s policies for what is reimbursable and not cover and claim the expenses of anyone else covered under BPSAA or OPS

13. 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

14. 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

15. 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 staff 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 – must code according to MIS
Expenditures may be audited and made public
For ease or reporting and/or audit we need to centralize all reimbursed expenses in individual files

16. Perquisites Policy Required
Perk or privilege not generally available to all and provides a personal benefit
Only allowable if they are business related for individual’s job
Rules must expressly prohibit club memberships, season tickets, clothing allowance, access to private health clinic and personal advisory services by any means; employment contract or reimbursement
Summary information to be available annually without disclosing personal information
Benefits per employee contracts may not be considered personal information

17. 10% Executive Office Reduction
Reduce office costs by 10% over two years, and with minimum of 5% in first year
Determine positions and office considered “executive”
Baseline is budget
Annual compliance report to include baseline and amount reduced
Engage support staff to reduce office supply costs and sundry expenses where possible and/or introduce economical innovation

18. Additional Management Direction
Senior management still needs to provide more direction on:
Management discretion
Memorial donations
Gifts
Honourariums
Catering
Hospitality provided by vendors or others to employees
Following FAQ Appendix illustrates some questions and direction senior support staff could give to inquiring directors or managers in their respective divisions

19. FAQ Appendix FAQ examples: Memorial donations
Gifts to tour persons at other sites
Honourariums to conference speakers
Meals/beverages during staff meetings – internal versus external catering
Vendor gifts or hospitality to employees
LCBO and grocery receipts

20. Q. Is a department allowed to make a memorial donation (to the Foundation) upon the passing of a physician or staff member?
A. The hospital policy on Allowable Expenses for Reimbursement does not address expenses such as memorial donations, gifts (outside of hospitality) or recognition.  
Many departments take up a department collection for fellow employees and/or managers make a personal contribution with no expense to the hospital.  
Department managers are allowed to incur expenditures for which they have a mandate and approved budgets. Otherwise, out of budget requests should be made to senior management for consideration. Senior management should define what level of management discretion, if any, is allowed and apply consistently across divisions.
Senior management and Human Resources could address and provide a guideline so there is some consistency across the organization for all employees and others as needs to be defined. For example, if hospital expenditures for memoriam donations are allowed:  
Should they only apply to current staff and credentialed physicians as opposed to former staff and physicians?
Should the salutation clearly state “On behalf of TBRHSC Management and Administration” if hospital paid versus giving personal name(s) when no personal contributions have been given?
Should it be mandatory to be a memorial donation to the TBRHSC Foundation? 

21. Q. If we tour a site, a site visit, and want to give the tour person a token gift, is that acceptable?
If the site is another hospital in Ontario, then they are covered under the BPS directive and you may not extend hospitality. Hospitality is defined as the provision of food, beverage, accommodation, transportation and other amenities.
Consider using TBRHSC stock thank you cards, TBRHSC caps or water bottles from Human Resources to give as gifts. 
In the case of BPS organizations, if the tour person is an employee, they are being compensated by tax payer dollars for giving you the tour.
TBRHSC needs to come up with some consistent guidelines for gifts and other honorariums.

22. Q. We have historically given honorariums to conference speakers, is this okay?
Honourariums (per approved budget) are in lieu of other compensation paid by TBRHSC such as paid worked hours through payroll or contractor/speaker invoicing for time and expenses.
If an employee is getting paid for worked hours an additional honourarium should not be given.
If an employee is utilizing vacation or banked time to participate then they would be eligible to receive an honorarium.
Also, consider utilizing TBRHSC’s Thank You cards and Thumbs Up blog.

23. Q. If meals or refreshments are being provided during a staff meeting do they have to be purchased through the cafeteria? Can we order from an outside source if the cost is cheaper and if so, can a staff member pay for it and then get reimbursed?
 A. The "allowable expenses policy" does not cover Catering.
For Catering, you must have specific budget approval for either Internal and/or External Catering. Check your approved budget workbooks.
If you are approved for Internal Catering refer to the Nutrition and Food Services policy NFS-02. You cannot substitute "unapproved" External Catering for "approved" Internal Catering. 
If you are approved for External Catering, the Caterer must invoice the hospital directly. Consider internal catering and in-house meetings before external meetings and/or external catering. There should be a business case/reason for incurring external expenses. If you are approved for External Catering you may substitute Internal Catering.
  In general internal catering rates reflect most market rates and if they appear higher than external sources than please discuss with the Manager of NFS to ensure a fair comparison is being made and then also remember that there is a benefit to TBR for using Internal Catering over External Catering.

24. Q. Do we need to formally declare a conflict of interest and document the value of the meals provided or supported by a drug company at an education event?
We have no formal process to declare a conflict of interest or document the value of a meal or gift provided by vendors for persons outside of evaluation committees.
However, physicians, managers and staff need to be cognizant of what is reasonable under the circumstances and should advise the Director of Environmental Services of any vendor hospitality or gifts that seem extravagant or of any situation about which they are unsure.
The Director will be aware of vendor relationships, current or potential tenders/contracts and can formally document/track vendor actions and provide further education, correction or recommendation under the Broader Public Sector procurement guidelines

25. Q. In the event of a recruitment dinner held at a private residence, may LCBO receipts be submitted for reimbursement along with grocery receipts?
A. Prior to the occurrence of Hospitality Events or events where alcohol will be provided a Business Plan for Provision of Hospitality or Alcohol (Form FIN-14) should be completed by the individual who will be incurring the expense and submitted for approval. 
At a minimum, the approval should be at a Vice President level or where the requestor is a Vice President then approval must be provided by the CEO or their designate or the Senior Vice President of Corporate Services. If the requestor is the CEO then approval must be provided by the Chair of the Board or their designate.“
Approvals should stand up to potential public scrutiny, freedom of information requests and provincial value for money audits

26. Questions - Discussion?