Accounts Payable Policies

1099 Tax Reporting

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 a 1099 form. Any payments for legal and medical services to U.S. corporations are also reportable to the IRS on a 1099 form.

The university (i.e., Accounts Payable, and/or originating department) is responsible for obtaining the correct vendor name, address, social security number/employer identification number and type of organization for tax reportable payments to new vendors prior to making the first payment. This information should be captured upon completion of the W-9 form. If the supplier does not complete the W-9 form, the IRS requires that W&M withhold 28% tax on payments to the vendor, therefore the university will not do business with a vendor who does not provide the a W-9 form.

Accounts Payable is responsible for mailing 1099 forms to the vendor and submitting the electronic file of the 1099s to the IRS.

Advance Payments

Advance Payments are those that are made prior to receipt of goods or services. After an agency or institution makes an advance payment, there is no absolute guarantee that the vendor will deliver the goods or perform the requested services, placing the Commonwealth's assets at risk. 

However, advance payments are allowed for expenditures normally prepaid as a standard industry practice or where such prepayments are considered cost beneficial to the Commonwealth. Documentation should be retained within the agency and made available for review upon request to substantiate the decision to make advance payments.

The following describes those payments, which under certain terms and conditions, may be prepaid. These lists are not all inclusive. All allowable miscellaneous advance payments are subject to a maximum prepayment period of 90 days. 

1. Legal Services
2. Media Services
3. Specialized Pharmaceutical Supplies and Rare Medical Drugs
4. Mechanical, Electrical and Equipment Repair & Maintenance Contracts
5. Computer Hardware and Software Maintenance Contracts
6. Licensing Agreements
7. Specialized Equipment Purchases
8. Real Property & Equipment Rentals
9. Insurance Premiums

 In addition, Allowable advance payments pursuant to written contracts, leases, or agreements are subject to a maximum prepayment period of one year, where delivery, performance, or refund is assured based on written obligations. Vendors should be encouraged to invoice the agency on a monthly or quarterly basis in the absence of a sufficiently reduced annual pricing arrangement.

Allowable and Appropriate

Expenditures charged to all William & Mary accounts must be both allowable and appropriate. Department designees are ultimately responsible for ensuring that charges to accounts are allowable, appropriate, and in the best interest of the department and the university as a whole. 

ALLOWABLE expenditures that are charged to W&M accounts must have a business purpose and be adequately documented.

APPROPRIATE expenditures should be charged when they are necessary and beneficial to the university.

Comptroller's Debt Set-off

The Comptroller’s Debt Set-Off (CDS) Program intercepts vendor payments to offset debts owed by vendors to State agencies. The State provides agencies with the tax-id number for vendors with debts to the Commonwealth. William & Mary is required to reduce a vendor payment by the Debt Set-Off amount and remit the payment to the Virginia Department of Taxation.

The Virginia Department of Taxation verifies the Debt Set-Off amount for the university prior to payment being issued. Three payment instances may occur:

1. Partial payment is taken, the vendor will receive the remaining balance. The ACH or Check remittance will indicate the amount taken for the debt owed.
2. Full amount of payment is taken, the vendor will not receive any amount of the payment.
3. None of the payment is taken, the vendor will receive the full amount of the payment.

The AP office will always mail a letter to the vendor indicating any amount intercepted by Debt Set-Off. A vendor with questions about Debt Set-Off must contact the Virginia Department of Taxation customer service line at 804-367-8045. W&M staff are not able to provide information to the vendor (taxpayer) about any money owed to the Commonwealth of Virginia.

Accounts Payable Documentation

One of the most important underlying principles for allowable and appropriate expenditures is ensuring transactions are adequately documented. Adequate documentation includes an invoice or receipt that identifies:

1. Who purchased it?
2. What was purchased?
3. When it was purchased?
4. Where it was purchased?
5. Why it was purchased?

When exceptions are requested they must be properly justified with additional documentation. 

Expenditure Accounting Codes

The expenditure structure is a mechanism designed to classify the different expenditure categories and collect expenditure information in a systematic manner. The information is used for accounting control, financial management and budgeting purposes

Level of Expenditure Codes

Operating Expenditures

• Personal Services                  611XX0
• Contractual Services              712XX0
• Supplies and Materials           713XX0
• Transfer Payments                 714XX0
• Continuous Charges               715XX0

Fixed Assets Expenditures

• Property and Improvements   721XX0
• Equipment                              722XX0
• Plant and Improvements        723XX0

Debt Service Expenditures

• Obligations                             731XX0

 Most Frequently Used Expenditure Codes (pdf)

Honorarium Policy

Improper Expenditures

Agency purchases must be considered essential to the operation of the agency and in support of the agency’s mission to justify the use of State funds. Since all State-funded expenditures are subject to public scrutiny, agencies should consider the appearance of unusual purchases in general prior to authorization. Since individual circumstances vary widely, adequate documentation for unusual purchases should always be included with the voucher.

The following lists contain examples of expenditures considered to be improper uses of State funds. These lists are intended to provide general guidance to agencies in judging the appropriate use of State funds. However, any State-funded expenditure may be questioned, even those which are not included on the following lists.

Employee personal expenses such as—

1. Books for classes (unless they remain property of the State)
2. Snacks or refreshments (only allowed as a business meal, please refer to the Travel website)
3. Baby sitting
4. Non-business related newspapers or magazine subscriptions
5. Personal articles that are lost or stolen
6. Tuxedos or other formal wear
7. Clothing (non-uniform) or repairs to clothing damaged in the work- place
8. All expenses related to personal negligence of the employee, such as traffic fines.

Agency-sponsored event expenses incurred which do not clearly support the agency mission such as (please refer to the Local Fund Expenditure Policy for these types of purchases).

1. Retirement parties or employee going away parties
2. Holiday decorations
3. Alcoholic beverages
4. Charitable contributions
5. Gifts and flowers

Prompt Payment Compliance

State agencies that acquire goods and services, or conduct business through contractual agreements with nongovernmental and privately-owned businesses, to pay by the "required" payment due date for delivered goods and services.

 The required payment due date is established by the terms of the contract; or if a contract is not in existence, thirty calendar days after the receipt of a proper invoice, or thirty days after the receipt of goods or services, whichever is later.

• All payments to nongovernmental and privately owned businesses for the purchase of goods and services must be due dated. Departments should assign a payment due date of 30 calendar days after the receipt of the goods, services, or invoice whichever is later; or the due date specified in the vendor's contract.
• However, in circumstances where an invoice has already been delayed more than 30 calendar days, and a contractual agreement exists with the vendor, or vendor relations are in jeopardy, an earlier due date may be assigned to expedite the payment.
• In the event an original invoice has not been received, the agency should contact the vendor and request a copy of the original invoice. The agency should annotate the invoice copy as "Certified Copy." The "required" payment date should be calculated from the date the invoice copy is received from the vendor.
• Disputed Invoices- Disputed invoices must be documented in writing by the agency. The vendor must be contacted within 15 calendar days after the receipt of the vendors invoice. Payments are due 30 days from the resolution date of the dispute.
• The Code of Virginia, Section 2.2-4354 requires contracts awarded by State agencies to include a special payment clause which directs individual contractors to provide their SSN, and sole proprietors, partnerships, and corporations to provide their EIN. Invoices for vendors who refuse to provide such information are considered in dispute under the provisions of the Prompt Payment Statutes.

Virginia Sales Tax and Use Tax Exemptions

William & Mary (W&M) and the Virginia Institute of Marine Science (VIMS), as public institutions of the Commonwealth of Virginia, qualify for the Virginia retail sales and use tax exemption on purchases of tangible personal property for the use or consumption by W&M and VIMS (with certain exceptions). Therefore, all purchases made on behalf of W&M or VIMS must be made using a Commonwealth of Virginia Sales and Use Tax Certificate of Exemption (Form ST-12), regardless of the method of payment or institutional funds used. It is the responsibility of the individual initiating the purchase to alert the vendor to our tax-exempt status at the time of purchase, otherwise sales tax may be charged and the vendor is not required to provide a refund after the sale has occurred.

Reimbursements to employees for purchases made with personal funds or a personal credit card should only occur in emergency situations or for situations in which the procurement process or small purchase charge card cannot be used (please refer to the list of allowable reimbursements). In these instances, reimbursements of Sales tax is prohibited.

For additional information please click on the link below:
VA Sales Tax Exemption

Compliance

Remittance Address Audit and Tracking

Ensuring the Remittance Address is correct on vendor payments guarantees vendors are paid in a timely manner in accordance with the Prompt Pay Act as well as removing the administrative burden from Accounts Payable staff when having to manually correct errors. Individuals who do not comply with ensuring the remittance address utilized matches the vendor invoice may have system access suspended or permanently removed. Disciplinary action will be enforced by the Quality Assurance Director and/or Supply Chain Services based on the violation. Typical suspension periods for failure to comply with policy will be 15, 30 or 60 days. Multiple policy violations during a single fiscal year may result in revocation of system access.

Policy

1st Occurrence – courtesy email warning
2nd Occurrence – 15-day system suspension
3rd Occurrence – 30-day system suspension
4th Occurrence – 60-day system suspension

2nd- 4th Occurrence - in conjunction with the system suspension, the department will also be responsible for the payment of any stop payment fee (if applicable) along with the administrative burden of correcting the address error.

Occurrences will re-set at the beginning of each Fiscal Year