Finance Policies

Anti-Money Laundering (PDF)

It is the policy of the George Washington University to comply with anti-money laundering obligations imposed by the federal government, including applicable provisions of the Money Laundering Control Act of 1986, the Bank Secrecy Act, the USA PATRIOT Act of 2001, the rules and regulations overseen by the United States Treasury Department’s Office of Foreign Assets Control and Financial Crimes Enforcement Network, and other legal requirements.

Categorization of External Funding (PDF) 

This policy identifies and categorizes funding received from sources outside the university (External Funding) and identifies specific criteria for each category, including authorized signatories.  Any External Funding that is not identified as a Gift or Vendor Contract falls under Sponsored Project Agreements and will be processed through the Office of Sponsored Projects within the Office of the Vice President of Research.

Deposit of Checks, Cash, and Credit Card Receipts (PDF) 

All cash, checks and credit card receipts must be deposited on the same day they are received at the university. All check payments must be made payable to “George Washington University,” “GWU,” or “GW.” Cash deposits will be accepted on a case-by-case basis.

Establishment of Departmental Funds (PDF) 

All requests for the establishment of departmental funds must have the approval of the appropriate Dean or Vice President prior to submitting the request to the University Budget Office (UBO). All requests must meet the requirements outlined in this policy.

Financial Management Responsibility (PDF) 

All university faculty and staff are accountable for processing and recording financial transactions in a timely and proper manner.

Financial Transactions Adjustment (PDF) 

It is the policy of the university to record all financial transactions to the proper organization, funding source and account in a timely manner.

Fixed Asset Management (PDF) 

It is the policy of the George Washington University to safeguard and maintain effective internal controls to manage its Fixed Assets, and to maintain proper records regarding the use and disposition of those assets. This policy applies to Fixed Assets acquired with funding originating from the university, the Federal government or other external sources, and by gift or loan.

Foreign Gifts and Contracts Disclosure (PDF) 

Departments, offices, schools or other units receiving gifts of any value from a foreign source must promptly report such gifts to the Office of the Vice President for Development and Alumni Relations in accordance with the Gift Processing Policy, and must promptly report all contracts of any dollar value with foreign sources to Financial Reporting in the Office of the Comptroller.

General Ledger Charts of Accounts Maintenance (PDF) 

Any requested modifications (additions, deletions or changes) to the general ledger chart of accounts must be submitted to the Comptroller via the General Ledger Chart of Accounts Maintenance Form and accompanied by a statement justifying the business reason for the change.

Opening Bank Accounts (PDF) 

It is the policy of the university that only the Executive Vice President and Treasurer, Senior Associate Vice President for Finance, Chief Budget Officer, and Assistant Treasurer shall have the authority to open bank accounts with university funds or to open bank accounts in the name of the university.

Payment Card Acceptance and Data Security Policy (PDF) 

Credit card and debit card (“payment card”) information is regulated information that must be appropriately secured. University units may not collect, process, store, transmit or display payment card information without advance written approval from Treasury Management. This requirement applies to all payment card transactions whether conducted in person, via telephone, facsimile, mail, internet, or through a university approved third party vendor on behalf of a unit.

Petty Cash Policy (PDF) 

The university strongly discourages the establishment and/or use of petty cash funds. However, when a department provides a documented showing of need, the Financial Operations Office may approve establishment of a small departmental petty cash fund. Any petty cash fund established is subject to the use and management requirements set forth in this policy and in the Petty Cash Manual.

Reporting Financial Irregularities (PDF) 

All members of the George Washington University community have a responsibility to report known or suspected financial irregularities to the university’s Compliance and Privacy Office.

Surplus University Property (PDF) 

All surplus university property should be properly identified, recorded and disposed of when no longer needed. The Materials Management Department has primary responsibility for this function.

Accounts Payable Payment Method (PDF) 

The preferred method for making payments to commercial suppliers, and for issuing reimbursement to employees, is via electronic payment (i.e., Automated Clearing House (ACH)). At the university’s discretion payments may be made by wire transfer. Paper check distribution is available, though subject to restrictions.

Check Replacement and Cancellation (PDF) 

The university will replace a lost or stolen check after the university has placed a stop payment and receives confirmation from its bank that the original check has not cleared the bank. A check is considered lost or stolen when the payee has not received the check within ten (10) business days from mailing or if the payee has misplaced the check and has not been able to locate the check after a reasonable effort. The university will replace a damaged or stale dated check (except those that have been escheated) once the check has been returned to the university. A check will be considered damaged if the condition of the check has deteriorated to the extent that will preclude a bank from honoring it. A check is considered stale dated if it is over 90 days old.

Departmental Returned Checks (PDF) 

Departments that receive and process checks are responsible for the follow-up and collection of any checks returned from the bank uncollected (bounced).

Disbursement by Cashier's Check (PDF) 

It is the policy of the university to make all payments by check in U.S. dollars issued by the university’s Accounts Payable department. The university will make payments by cashiers’ check in exceptional circumstances upon payee request. However, the university strongly discourages use of cashiers’ checks because cashiers’ checks are considered “near cash,” are extremely difficult to replace, and require very careful handling by both university employees and the payee.

Disbursements in Non-U.S. Currency (PDF) 

It is the general policy of the university to make all payments in U.S. currency. In certain circumstances, the university may make a payment outside the United States in a non-U.S. currency in accordance with the requirements of this policy.

Electronic Funds Transfer (EFT) (PDF) 

Payments issued by Accounts Payable are made by Automated Clearing House (ACH). Under special circumstances payments may be made by Electronic Funds Transfers (EFT).

Unclaimed Property (PDF) 

On an annual basis, the university reviews its records and identifies, reports and turns over any unclaimed property to the District of Columbia’s (DC) Office of Finance and Treasury’s Unclaimed Property Unit.

Service Centers and Recharge Centers Charging Sponsored Projects (PDF) 

It is the policy of the university to comply with federal regulations regarding the permissibility of charging costs to federally sponsored projects for specialized service facilities. Service Centers and Recharge Centers may provide specialized services to federally sponsored projects and other users. The establishment of Service Centers and Recharge Centers and their schedules of rates or charging methodology must be approved in advance of charging sponsored projects by the Budget Office and the Office of the Comptroller.

Categorization of External Funding (PDF) 

This policy identifies and categorizes funding received from sources outside the university (External Funding) and identifies specific criteria for each category, including authorized signatories.  Any External Funding that is not identified as a Gift or Vendor Contract falls under Sponsored Project Agreements and will be processed through the Office of Sponsored Projects within the Office of the Vice President of Research.

Federally-Debarred Suppliers (PDF) 

When acquiring goods and services under federally sponsored programs, the university will not contract with a vendor who is currently either debarred or suspended from doing business with the federal government.

Signing of Contracts and Agreements (PDF) 

The Bylaws of the George Washington University authorize the president and the executive vice president and treasurer to execute all written agreements required to conduct business operations on behalf of the university. The Bylaws also authorize the president and provost and executive vice president for academic affairs to execute all written academic agreements for the university. These officials may delegate their signature authority, but any such delegation must be made in writing and in accordance with the Contract Process Guide.

Supplier Registration (PDF) 

Individuals, sole proprietors, companies and organizations interested in becoming or maintaining their status as a supplier of goods and/or services to the university must register with the university by completing and signing certain forms, and must agree to abide by the university’s Standard Purchase Order Terms & Conditions. Payments cannot be made to a supplier until the applicable Supplier Registration forms have been received by Supplier Maintenance for processing.

Worker Classification and Payment (PDF) 

Each service provider (“worker”) must be properly classified as an employee or independent contractor in accordance with federal and state tax and employment laws. Departments that engage service providers must submit the required documentation for determination of each service provider’s status before any services are performed or payment requests are processed. All individuals who perform services for the university are presumed to be employees unless the relationship satisfies Internal Revenue Service (IRS) and related common law standards for independent contractor status. This policy applies to payments to individuals, partnerships and sole proprietors for services. This policy does not apply to payments made to a corporation for an individual’s services or to payments for goods/merchandise.

Categorization of External Funding (PDF) 

This policy identifies and categorizes funding received from sources outside the university (External Funding) and identifies specific criteria for each category, including authorized signatories.  Any External Funding that is not identified as a Gift or Vendor Contract falls under Sponsored Project Agreements and will be processed through the Office of Sponsored Projects within the Office of the Vice President of Research.

Foreign Gifts and Contracts Disclosure (PDF) 

Departments, offices, schools or other units receiving gifts of any value from a foreign source must promptly report such gifts to the Office of the Vice President for Development and Alumni Relations in accordance with the Gift Processing Policy, and must promptly report all contracts of any dollar value with foreign sources to Financial Reporting in the Office of the Comptroller.

Gift Acceptance (PDF) 

The university will accept gifts that promote the university’s goals as an independent academic institution that is dedicated to furthering human well-being. The university seeks gifts that support a dynamic, student-focused community stimulated by cultural and intellectual diversity and built upon a foundation of integrity, creativity, and openness to the exploration of new ideas. The university solicits gifts that support the university’s commitment to excellence in the creation, dissemination, and application of knowledge.

Gift Processing (PDF) 

All Gifts to the university must be processed, recorded and receipted by the Gift Recording office in the university Division of Development and Alumni Relations (DAR GR). All information and correspondence regarding the acceptance of any Gift to the university must be forwarded immediately to DAR GR and should be accompanied by a Gift transmittal form and\or a departmental memorandum outlining the details of the transaction.
 

Payroll Time Reporting (PDF) 

It is the policy of the university to pay employees for time worked in an accurate and timely manner, in accordance with applicable laws, and to maintain the required supporting documents and records. Employees have a duty to comply with university guidelines with respect to time and attendance. Supervisors have a duty to be familiar with those procedures as well as the basic provisions of the Federal Fair Labor Standards Act (FLSA) covering time reporting and record keeping. This policy applies to both exempt and nonexempt bi-weekly employees under the FLSA.

Labor Adjustment and Redistribution (PDF) 

It is the policy of the university to comply with applicable laws and regulations regarding labor adjustments and redistributions charged to sponsored projects. All requests for labor adjustments and redistributions charged to sponsored projects shall be made timely and include documentation to justify the need for the adjustment or redistribution.

Repayment of Overpaid Wages (PDF) 

Faculty and staff are responsible for reviewing their payment stubs or direct deposit notifications immediately upon receipt and notifying their supervisor and Payroll Services immediately of any overpayment so the appropriate action can be taken to repay the university in a timely manner.

Acquisition of Computer Hardware and Software Policy (PDF) 

University divisions and schools are authorized to purchase computer hardware and software in support of their mission provided that the purchases are coordinated with Division of Information Technology (IT) so that the technology is secure, compatible with existing Enterprise Systems, not duplicative of existing Enterprise Systems, and able to be supported on the university’s network.

Commercial Invoice Processing (PDF) 

Suppliers are requested to send all invoices directly to the Accounts Payable department for processing to facilitate prompt payment. If the invoice is sent to another organization within the university, that organization must forward the invoice to the Accounts Payable department for payment on a timely basis.

Disadvantaged Business Enterprises (PDF) 

It is the policy of the university, consistent with federal, state and local laws, to take affirmative action to optimize opportunities for business contracting with Disadvantaged Business Enterprises.

Emergency Procurement Policy (PDF) 

During a university Emergency it may not be advantageous or practicable for the university to use competitive bidding methods or to follow standard administrative processes that could delay expeditious response efforts. Therefore, the Executive Vice President & Treasurer, Deputy Executive Vice President and Treasurer, and Senior Associate Vice President for Finance may waive competitive bidding and approve expedited procurement of goods and services that are essential in the response to an Emergency.

Major Procurement Review and Authorization (PDF) 

All major procurements of goods and services will be subject to a review and authorization process that documents vendor competition and approval by university senior management.

Personal Purchases (PDF) 

The university prohibits the use of university funds, the university’s tax ID number or sales tax exemption number, or university resources for personal purchases.

Procurement Policy (PDF)

The purchase of goods and services from external sources on the university’s behalf shall be based on sound business practice, best value, accountability, and compliance with sponsor, donor and regulatory requirements, as appropriate.  All procurements of goods and services shall contain sufficient supporting documentation to justify the supplier selection, the competitive process, and the price charged to the university.  The Procurement and Travel Services Department (“Procurement”) has general responsibility for the university’s procurement system.  Further, individuals are expected to follow the principles of this policy as well as the applicable procedures and guidelines as set forth in the university’s Procurement Manual and Contract Process Guide.

Procurement Card (P-Card) (PDF) 

It is the policy of the university that the purchase of commonly ordered items should be made using the established agreements offered through the iBuy+ eProcurement system. If the iBuy+ system cannot be used for a given purchase of $3,000 or less because the item(s) to be purchased are not available through iBuy+, the Procurement Card (P-Card) may be used, subject to the restrictions in this policy. Any procurement with special purchasing restrictions must be ordered through the Procurement Department on a purchase order and recorded through the Enterprise Accounting System (EAS).

Receipt and Return of Goods (PDF) 

All goods received by a department must be inspected and verified immediately against the purchase order, packing slip, or receiving document by someone other than the requisitioner, buyer, or payment processor. Evidence of satisfactory receipt is required for all goods provided to the university. Defective goods must not be accepted.

Standardization of Goods, Equipment, and Services Purchasing (PDF) 

Departments should purchase the goods, equipment, and services identified as standards. Procurement and Travel Services, in conjunction with other university functions and/or teams, will identify standards for certain goods, equipment, and services that lend themselves to standardization. Items should not be purchased if they are not supported by the university. Departments should consult with Procurement and Travel Services if any deviation from the standard is deemed appropriate.

Telephone and Wireless Communication Usage Policy (PDF) 

The university provides telephone and wireless communications services for faculty and staff in support of mission-related activities and to promote the cost-effective, appropriate and secure use of those devices.

Student Account Holds (PDF)

Student accounts that are past due are subject to financial encumbrance. If an account is financially encumbered, there is a hold that restricts future registration privileges, transcripts, diplomas, and other academic information until the account is settled.

Student Tuition Refund (PDF) 

It is the policy of the University to refund student tuition if notified of the class change, or dropped classes, within an appropriate period of time. Courses dropped prior to the first day of the semester will have 100% of the tuition charges cancelled. Courses dropped on or after the first day of the semester are subject to the attached refund schedules, which govern the prorated cancellation of semester tuition charges in cases of program adjustment or withdrawal.

Third Party Billing (PDF)

By the end of the third week of each semester, students whose charges are billed to a third party sponsor are required to provide to the Student Accounts Office (Third Party Billing and Collection Unit) documentation from their sponsor that authorizes the university to bill the sponsor. Failure to comply with this policy may result in charges being reversed back to the student for immediate payment.

1099 Tax Reporting (PDF) 

Payments for services to U.S. independent contractors, other individuals, or unincorporated businesses of $600 or more in a calendar year are reportable to the IRS on Form 1099. Any payments for legal and medical services to U.S. corporations are also reportable on IRS Form 1099. The university is required to withhold 28% tax from reportable supplier payments if a Taxpayer Identification Number (TIN) Social Security Number (SSN) or Employer Identification Number (EIN) is not provided in advance of payment.

Joint Venture (PDF) 

The university is committed to taking the action necessary in its business arrangements with for-profit entities so that such arrangements are consistent with Section 501(c)(3) of the Internal Revenue Code and do not jeopardize the university’s tax exempt status. The university will guard against arrangements that might be inconsistent with or overwhelm the university’s mission or nonprofit purposes.

Sales Tax Collection, Reporting, and Remittance (PDF) 

It is the policy of the university to comply with state sales tax regulations by collecting, accounting for, reporting and remitting the required sales tax in a timely manner. Departments engaged in the sale of taxable goods and services must collect the sales tax and must forward a monthly report to University Accounting Services in the Comptroller’s Office.

Taxation of Gifts, Prizes, and Awards to Employees (PDF) 

Payments made from university funds, or items of value given to employees, are considered compensation subject to federal, state and employment tax withholding, and reporting on Form W-2, unless a specific exemption applies. Any question concerning the taxability of a gift, prize or award should be reviewed with the Tax Department prior to processing the transaction.

Unrelated Business Income Taxation (PDF) 

The university must identify and report unrelated business income on its annual tax return, and remit any tax due in compliance with federal, state, and local tax laws and regulations. Departments, schools, divisions or other university units generating income that does not directly further the university's tax exempt purpose must contact the Tax Department to determine if such income is subject to unrelated business income tax.
 

International Travel Approval (PDF) 

Any student, faculty or staff member proposing to undertake university-supported or university-related international travel must follow the appropriate approval, insurance, and travel security and related requirements set forth in this policy.

International Travel Insurance (PDF) 

The university provides International Travel Insurance to university employees engaged in university business abroad, as well as to graduate and undergraduate students completing departmentally approved course work or research abroad. Prior to the start of a trip or assignment, employees and students must register their travel plans online. Instructions are located on the International Travel Insurance and Assistance section of the Office of Risk Management website.

Travel, Entertainment, and Business Expense Reimbursement (PDF) 

The university will incur or reimburse expenses that are: 1) actual and necessary; 2) for a university business purpose; 3) documented, approved and submitted properly; and 4) consistent with the university’s business objectives. This policy applies to all expenses incurred for a university purpose regardless of the account to which the expenditures are budgeted or recorded, the type of funding supporting such expenses, or whether incurred locally or during university travel. Employees should exercise economy when incurring business expenses on behalf of the university. Employees who submit expenses to Accounts Payable for reimbursement are responsible for complying with the provisions of the policy. Each approver is responsible for enforcing and adhering to this policy.