CCDHB Sensitive Expenditure Policy June 2018 to June 2022.pdf

Document facilitator: Financial Controller Senior document owner: Chief Financial Officer
Document number:   1.8410   Issue Date 25 June 2018   Review Date 25 June 2022
Version 2.1

Type:     Policy

Name:    Sensitive expenditure

Purpose
This policy provides a set of principles and rules for managing expenditure, which
by its very nature creates financial and reputational risk for Capital and Coast
District Health Board (CCDHB).
Spending by a public organisation that may be perceived as providing some private
beneﬁt to a staff member, such as overseas travel, can be contentious. This type of
spending is referred to as ‘sensitive expenditure’.
Sensitive expenditure is expenditure that:
  may be perceived as providing some additional private benefit to staff
  is unusual
  may be perceived as contentious

The aim of the policy is to ensure that:
  the expenditure  is  incurred  for  business  purposes  only  and  does  not
provide any private benefit to a staff member;
  the expenditure can withstand audit, parliamentary and public scrutiny;
  the decisions  in  approving/incurring  such  expenditure  are  made  in  a
sound manner which are able to withstand scrutiny;
  a culture of probity/integrity is encouraged within CCDHB.

Scope
This policy applies to:
  staff at all levels in CCDHB, including temporary employees, contractors and
the executive management team (EMT)
  Board and committee members while acting in a CCDHB capacity

The policy applies irrespective of whether the sensitive expenditure is paid by
CCDHB direct or by reimbursement, or funded by special funds or external
organisations.

Sensitive expenditure
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Document facilitator: Financial Controller Senior document owner: Chief Financial Officer
Document number:   1.8410   Issue Date 25 June 2018   Review Date 25 June 2022
Version 2.1

Contents
Page
Definitions
3
Policy statement
4
     Key policy requirements
4
     Policy on specific issues
4
Credit cards
5
Travel and accommodation expenditure
5
     Air travel
6
     Air points and other travel related loyalty schemes
6
     Travel insurance
7
     Accommodation
7
     Food and beverage
7
     Motor vehicles
8
     Other travel associated costs
9

Entertainment and hospitality expenditure
9
Goods and services expenditure
10
Gifts, prizes, benefits, hospitality received & loyalty reward scheme
10
     Private use of CCDHB suppliers
11
     Private use of CCDHB assets
11
     Private assets used by CCDHB
11
Sale of surplus assets to staff
11
     Communications technology
11

Staff support and welfare expenditure
12
     Recognition and achievement including staff gifts
12
     Staff social functions and Christmas parties
12
     Farewells and retirements
12
     Clothing
12
     Continuing medical education (CME)
12

Sponsorship of staff and others
13
Other types of expenditure
13
     Donations
13
Koha / Whakaaro Aroha
14
Gifts paid
14

Sensitive expenditure
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Document facilitator: Financial Controller Senior document owner: Chief Financial Officer
Document number:   1.8410   Issue Date 25 June 2018   Review Date 25 June 2022
Version 2.1

Definitions
Continuing  m edical education (CME)
It refers to senior medical officers (SMO) CME contractual entitlements. Registered
medical officers (RMO) CME entitlements are not intended to fall under this CME
definition. Any specific exceptions for CME, within this policy, relate to SMO CME
only.
Conflict  of  interest
It arises where a person is compromised when their personal interests or
obligations conflict (actual, potential or perceived) with the responsibilities of their
job or position. It means their independence, objectivity or impartiality may be
called into question.
Controls
They are the means to promote, direct, restrain, govern and check various
activities.
Credit card
It has the normal meaning and, in the context of this policy, also includes vehicle
ﬂeet cards, purchase cards and any similar cards used to obtain goods and
services before payment is made.
Donation
It is a payment, in money or in kind by way of goods or services, made voluntarily
and without expectation of receiving goods or services in return.
Koha  /  Whakaaro  Aroha
It is a specific type of gift, token or a contribution given to provide a symbolic or
cultural recognition of a relationship.
Proper and prudent behaviour
In relation to expenditure, includes identifying and managing conﬂict of interest (or
any situation with the potential to be perceived as conﬂict of interest), being fair,
honest, transparent, circumspect,careful to avoid undesired consequences and
being accountable for complying with organisational controls over expenditure.
Sensitive expenditure
It is expenditure by CCDHB which provides, has the potential to provide, or has the
perceived potential to provide, a private beneﬁt to an individual staff member that
is additional to the business beneﬁt to CCDHB of the expenditure. It also includes
expenditure by CCDHB that may be considered unusual for the organisation’s
objectives and/or functions.
Staff
For the purposes of this policy, has a wide meaning and includes: all special fund
signatories, office holders (such as board and committee members), managers at all
levels and employees of CCDHB.

Sensitive expenditure
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Policy statement:
Sensitive expenditure decisions need to be made with a strict adherence to the
principles and rules set in this policy, reflecting recognition among all office holders
and staff of the risks inherent in sensitive expenditure and possible conflicts of
interest.
Sensitive expenditure decisions should endorse the following principles:
  be lawful
  subject to high standards of probity and financial prudence
  be able to withstand audit, parliamentary and public scrutiny
  have a justifiable business purpose
  be impartial
  moderate and conservative having regard to the circumstances
  be transparent
  be appropriate in all respects

Key policy requirements:
  Staff is expected to exercise proper and prudent behaviour and
judgement with regards to all business expenditure.
  Sensitive expenditure must be authorised as per CCDHB delegations of
authority policy unless this policy specifically requires approval to occur at
a higher level.
  Sensitive  expenditure  will  only  be  approved  and  paid  if  it  is  deemed  to
be reasonable,  actual,  and  has  been  incurred  in  relation  to  CCDHB
business  in accordance with this policy.
  Where  ever  possible  CCDHB  preferred  suppliers  should  be  used.  If
alternative  suppliers  are  used  the  costs  incurred  should  not  be  higher
than CCDHB’s preferred suppliers.
  Claims relating to sensitive expenditure must follow the staff
reimbursement procedure.  In  particular  claims  must  clearly  state  the
business  purpose  and be  accompanied  by  adequate  original  supporting
documentation  e.g.  a  tax invoice.
  To  determine  the  appropriateness / reasonableness  of  sensitive
expenditure the following questions should be considered:
-
does the expenditure support CCDHB objective and functions?
-
can the expenditure be justified to the public?
-
can publicity  about  the  expenditure  or  occasion  adversely  affect
CCDHB?
  Where this policy is inconsistent with the provisions of the employment
agreement or MECA, the employment agreement or MECA will apply.
Policy on specific issues
This policy is intended to provide clear instructions to staff, which make sensitive
expenditure decisions and approvals, of their compliance obligations. The specific
issues are not an exhaustive list of all the ranges of sensitive expenditure. They list
issues and principles in the main areas of sensitive expenditure relating to
CCDHB.
Sensitive expenditure
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This policy should assist staff to exercise good judgement in sensitive expenditure
decisions and ensure the decisions are also compliant with the principles and
requirements outlined in this policy document.
Credit cards
While the use of credit cards and purchase cards (hereafter referred to as ‘cards’)
is not a type of sensitive expenditure, it is a common method of payment for such
expenditure and the use of cards involves potential financial and reputational risk.
To mitigate these risks the following principles and rules shall apply:
  Cards as a general rule are not permitted except by  the express
approval  of the CEO. Currently the only card types approved for use by
CCDHB are:
o
Fuel cards – issued and managed by the transport team
o
Taxi cards – issued and managed by procurement team
o
Petty cash credit cards – issued to mental health services
      located in Auckland, Hamilton, Dunedin, Christchurch.

  Cards will be issued:
o  based on specific on-going requirements to achieve staff duties
o  to a named individual for accountability and tracking
o  to employees only as cards cannot be issued to a contractor
o  Under  no  circumstances  are  cards  to  be  used  for  personal
expenditure  or credit.
  Cards cannot be used to obtain cash advances.
  All  card  expenditure  must  be  supported  by  original  tax  invoices  that
provide detail of the transactions date, value, business purpose and the
name of the individual(s) who have incurred the expenditure.
  Card  payments  over  the  internet  must  be  to  established  reputable
suppliers known to CCDHB. The card holder must keep a copy of any
online order form and tax invoice as evidence. The transaction must
comply with CCDHB procurement policy.
  Cards must be destroyed and made unusable and the appropriate
providers advised to cancel the card when a staff member leaves
employment or authority  to  use  a  card  is  withdrawn.  When  cards  are
lost  the  appropriate authorities must be advised immediately to cancel the
card. Authority to use a card shall be cancelled if a CCDHB card is
misused.
Travel and accommodation expenditure
Travel and accommodation expenditure should be reasonable, most economical
and cost efficient option taking into account the travel: purpose, distance, time,
urgency, security and safety considerations. The principles of a justified business
purpose, moderate and conservative expenditure are particularly relevant.
Refer to specific CCDHB procedures:
  Staff travel procedure (including CME travel). All travel and accommodation
bookings must be arranged through CCDHB’s preferred travel. management
Sensitive expenditure
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company - Orbit Corporate Travel Wellington (‘Orbit’), in order to take
advantage of preferential rates. The only exception to this (and not preferred)
is travel funded through SMO CME entitlements which may be booked
individually by other means.
  Transport – CCDHB vehicle usage policy.
Air travel
  Travel should be reasonable and most economical option taking into account
all possible discounts, departure/arrival times and stopovers to reduce cost.
  Travel must be economy class at all times unless the criteria for business
class travel is met. Business class travel is limited to:
o  travel funded through a SMO CME entitlement; or
o  when an individual has work or conference attendance duties within
36 hours  of  a continuous journey  of  at  least  eight  hours  (post
any stopover) and CEO or General Manager Hospital & Health
Services (GM HHS) or General Manager Mental Health Addictions
and Intellectual Disability Services (GM MHAIDS) approval has been
granted in advance and evidenced in writing or email.
  First class travel is not permitted. There are no exceptions.
  Air New Zealand is the preferred carrier for CCDHB.
  CCDHB expects the cost of any planned stopover to have a clear business
purpose.
  CCDHB will not be responsible for any costs incurred for excess baggage.
Please check with the relevant airline for information (including costs) before
travel.
  There is often an additional cost for changing flights for some types of fares.
Careful planning and flexibility needs to be considered at the time of the
original travel request to minimise changes and the resultant costs for
CCDHB. Changes that give rise to additional charges for CCDHB must have
a justifiable business reason and not just for convenience reasons.
Air points and other travel related loyalty schemes
  Domestic, Trans-tasman and other overseas travel.
CCDHB is party to  the ‘all of Government’ preferred supplier contract.
Only individuals can receive status points. Airlines cannot assign  s t a t u s
points  to  organisations  such  as  CCDHB.  While travelling  overseas on
CCDHB business, staff may  earn airpoints to  their individual  credit.  This
creates  a  personal  benefit,  which  is  contrary  to  the principles of this
policy, and is permitted provided it is not to the detriment of the travel cost
which CCDHB pays.
  Club memberships
Memberships to Koru club or other clubs, will not be paid by CCDHB effective
1st July 2018.
Sensitive expenditure
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Document facilitator: Financial Controller Senior document owner: Chief Financial Officer
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Travel insurance
  CCDHB travel cover is provided by Allianz. Staff have to register their travel
on the Allianz website in order to be covered for insurance. If you are not
registered then not covered. Insurance Website link -
https://www.ctisales.co.nz/dhb/login.aspx?PN=999914358.
  Staff must not arrange their own travel insurance for CCDHB related business
or  CME  activity  as  this  will  cause  CCDHB  to  incur  additional
unnecessary costs. Any separately arranged travel insurance reimbursement
claims will be rejected.
  CCDHB travel insurance policy only covers staff for business related
international travel. Domestic travel is not covered. Any staff claims for
domestic travel insurance will be declined.
  Insurance  cover  will  not  be  paid  or  available  for  any  personal  travel. This
includes  any  personal  portion  of  travel  at  the  start  or  end  of  any
business related travel.
  Employees and their family members may arrange their own insurance
cover for personal travel directly, at their own cost, leveraging the same cover
as the DHB  travel  s cheme.
Accommodation
  Accommodation should be modest and cost-effective taking into account:
the geographic location of the accommodation relative to where the staff
member is  working,  length  of  stay,  standard  of  accommodation,  safety
and  security considerations.
  The standard of accommodation should be 3-4 star, travel lodge, rating.
First class or 5-star accommodation should be avoided.
  A  maximum  $ 200  (incl.  GST)  per  n i g h t   limit applies  for
accommodation in New Zealand.  Any accommodation  above  this  maximum
rate  requires  pre-approval,  before travelling, from management in
accordance with the delegated authority limits.
  CCDHB  will  not  meet  any  costs  beyond  the  standard  room  cost.
Personal costs such as: mini bar charges, video rental, in-room movies, dry
cleaning or laundry services are paid personally, upon check-out, and are not
chargeable to  CCDHB  under  any  circumstances.  CCDHB  accepts  no
responsibility  for damage caused to a hotel room or premises by CCDHB
staff.
Food and beverage
Reasonable  costs  for  meals  will  be  paid  when  the  staff  member  is  out  of  town  on
CCDHB business, subject to the requirements specified below:
  Generally the cost of meals paid for by CCDHB should be modest in
respect of the eating establishment concerned and the menu of the
establishment.
  Food and beverage claims will not be reimbursed for day trips, snacks,
morning or afternoon teas while travelling. Staff needs to provide for lunches
at their own cost whether they are travelling or not.
Sensitive expenditure
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  If away on business  greater than 24hrs a maximum $90 (incl. GST) per
day limit for meals (assuming 3 meals: breakfast, lunch and dinner) may
be claimed  provided  that all  tax invoices  are  supplied  to  support the
claim.  This limit is neither an allowance nor an entitlement; it is a
maximum level per day and should be used modestly and not abused.
  Under  no  circumstances  will  CCDHB  reimburse  staff  for  alcoholic
drinks even if the claim is within the maximum $90 per day above. If
alcoholic drinks are included on an invoice this needs to be deducted from
the amount claimed or paid by CCDHB and be incurred as personal
expenditure.
  For  international  meals  the  general  principles  of  modest  and
economical spending should be observed  at all times. The  domestic
maximum of  NZ$90 equivalent  per  day  should  be  observed  where
possible  mindful  that  some countries may be more expensive than others.
Motor Vehicles
  Where ever possible and cost effective to do so (i.e. considering parking,
taxi and rental costs) a CCDHB pool car should be utilised for local travel.
  The most economical type and mid-size rental option should be used,
consistent with the requirements of the trip including: the distance, terrain
and the number of people and goods.
  The maximum allowable rental vehicle size:
o  For  out  of  town  use  (greater  than  100kms)  is  a  mid-sized  1.8
litre capacity,
o  For around town use is a small sized 1.3 litre capacity.
  Personal accident and collision damage should not be purchased for
rentals.
  Private use of a rental car is not  permitted, except in exceptional
circumstances, such  as reasonable out-of-work hours use when the staff
member is away from home and undertaking work for CCDHB. In such
cases the  staff  member  must  reimburse  CCDHB  for  any  excessive
costs  arising from the private use.
  CCDHB will not pay for travel by private motor vehicle where travel by
other means  is  more  practical  and  cost  effective.  Regular  use  of  private
vehicles must  have  pre-approval  before  costs  can  be  claimed.  Private
vehicle  costs can  be  claimed  a t   4 0   c e n t s   p e r   k m   o r   t h e   r a t e
o t h e r w i s e   s t i p u l a t e d   i n   t h e   e m p l o y m e n t   a g r e e m e n t   t h a t
c o v e r s   t h e   w o r k   o f   t h e   e m p l o y e e .  All  claims  for  private  vehicle
mileage  must  detail:  the  business  purpose,  kilometres  claimed  and
travel details. Please use the mileage claim form for this purpose.
  All  fines for  parking  and  traffic  offences  incurred  by  staff  while  using  a
pool vehicle,  rental  or  private  motor  vehicle  on  CCDHB  business  will  be
paid  by staff. Under no circumstances will fines or other penalties be paid
by CCDHB.

Sensitive expenditure
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Other travel associated costs
  Taxi  use  should  be  moderate  and  cost  effective  relative  to  other  forms
of transport available to staff.
  CCDHB will not pay for taxis to be used for travel between the staff
member’s home and their usual place of work unless the staff member
has worked past a reasonable hour or there is a safety concern or similar
justification and prior approval has been given where practical.
  Uber is an acceptable alternative to taxi and its use should be moderate
and cost effective relative  to  other  forms  of transport available to staff. An
invoice should be provided as appropriate supporting documentation.
  Tipping in New Zealand is not claimable. Tipping overseas is claimable
where it is local practice, however it must be modest.
  All  work  related  telephone  calls,  email  and  any  other communications
made  by  staff  while  travelling  on  CCDHB  business  will  be claimable.
The  most  cost  effective  communication  method  is  expected.  For
overseas travel pre-approval is required before incurring global roaming
costs.
  Personal telephone calls on hotel landlines are permitted when on
business to a maximum of one  10  minute  phone  call  per  day  when
staying  overnight.  The  most  cost effective method of communication is
expected i.e. avoid expensive hotel/motel phones.
  Personal  costs  incurred  by  a  staff  member  while  on  work  related  travel
or conferences  are not  paid by CCDHB. This includes (but is not limited
to) the cost of: optional recreational activities associated with a conference,
any expenses  incurred  by  family  or  travel  partners  who  accompany
staff,  gym fees,  luggage  or  briefcases,  suit  hire,  recreational  activities,
sightseeing  and private  travel  while  on  a  business  trip. In  addition
CCDHB  will  not  reimburse costs incurred through being away from home
such as: babysitting costs, pet care or garden care.
  Staff members may undertake private travel before, during or after
business travel provided there is no additional cost to CCDHB and the
private travel is incidental to the business purpose of the travel. All costs
associated with the private  travel,  including  travel  insurance,  must  be
paid  by  the  staff  member. Any  time  used  for  private  travel  must  be
taken  as  annual  leave  by  the  staff member.
  No  costs  can  be  claimed  by  an  accompanying  spouse,  partner  or
family members  except  in  rare  pre-approved  circumstances,  by  the  CEO
or  GM HHS or GM MHAIDS, where the involvement of the spouse or partner
directly contributes to a clear business purpose.
Entertainment and hospitality expenditure
Catering and other entertainment related costs incurred in connection with
hospitality or stakeholder liaison, with parties external to CCDHB, must be modest
and have an appropriate business purpose such as:
  building relationships that are important to CCDHB;
  representation of CCDHB;
Sensitive expenditure
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  reciprocity of hospitality where this has a clear business purpose and is
within normal business scope;
  building revenue.
All hospitality expenditure over $200 must have the prior approval of the
CEO/GM HHS/GM MHAIDS.
In keeping with the principles of a ‘dry campus’ and prudent use of the health
dollar, CCDHB will not pay for any alcohol component of costs associated with
entertainment or hospitality expenditure unless specifically approved by the
CEO/GM HHS/GM MHAIDS.
The  hospitality  expenditure  should  record  the  name(s)  of  CCDHB  and  external
colleagues being entertained, the reason for the entertainment (either on the
invoice or the expense claim form), together with the invoices/receipts attached.
Goods and services expenditure
Goods  and  services  expenditure  applies  to:  obtaining,  disposing  of  or  using
goods and services that are not covered by terms and conditions of employment.
Gifts, prizes, benefits, hospitality received and loyalty reward schemes
Any  money  received  should  be  treated  as  a  donation  received  and  becomes
the property of CCDHB and must not be retained by any individual.
Non monetary staff gifts, prizes, benefits and hospitality received from external
parties may be accepted and retained by staff, for personal use,  provided  it  is
done so in a moderate and fully transparent manner (refer below) and there is no
expectation on the part of the provider for anything in return. Examples may
include a prize while attending a conference, free access to a community/sporting
event, free samples or free travel and accommodation connected with a
conference or activity.
All such non-monetary  gifts and hospitality  received and retained by staff for
personal use:
  must be disclosed and approved by their manager;
  if greater than $100 in value must be recorded in the staff gift register
(access from the CCDHB intranet);
  there must be no possible conflict of interest or reputational risk to CCDHB
created by accepting the gift;
  Those  involved  in  procurement  activity (the  process  of  selection,
negotiation and engagement of CCDHB suppliers for goods and services,
including tenders, RFPs and contract negotiations; and request for
service/goods prior to engagement with a non standard supplier) should
not accept gifts or hospitality to avoid any perceived conflict of interest.
All supplier loyalty reward schemes are the property of CCDHB. If supplier loyalty
reward schemes accumulate under a staff name they are transferred (where
practical) to CCDHB or used for the benefit of CCDHB or the staff member shall
reimburse CCDHB for the value received. Exceptions exist for air points and Koru
Sensitive expenditure
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Club, please refer to the travel and accommodation section above. Also refer
conflict of interest and fundraising, sponsorship and donor interaction policies.
Private use of CCDHB suppliers
Staff must not seek or receive an advantage or a discount from a supplier simply
because a supplier provides a service or materials to CCDHB. An exception exists
for, CEO approved, CCDHB wide employee benefits or discounts which are
available to all staff. Private use or benefits from suppliers must not be taken into
account when choosing CCDHB suppliers to avoid any possible perception of
conflict of interest.
Private use of CCDHB assets
As a general principle CCDHB’s physical assets or resources are not to be used
for any  personal  purpose.  Staff  shall  pay  for  costs  of:  personal  toll  calls,  local
calls, photocopying  or  any  other  costs  where  personal  usage  is  more  than
incidental  or modest. Personal usage must be discussed with your manager and
an agreed value determined. The staff member can pay either directly or by payroll
deduction. For motor vehicle use refer to the transport – CCDHB vehicle usage
policy and fringe benefit tax procedure.
Private assets used by CCDHB
Staff may be reimbursed for the use of a private asset for a business purpose, where
purchasing a similar asset would not be warranted. The value of reimbursement must
not inappropriately benefit the provider of the asset. Examples are motor vehicle, cell
phone, and private computers. Use should be incidental and agreed in advance with
managers. For motor vehicle use refer to transport – CCDHB vehicle usage policy
and fringe benefit tax procedure.

Sale of surplus assets to staff
When the assets have become obsolete, worn out or surplus to requirements,
CCDHB will from time to time dispose of assets. Any process for sale or disposal of
surplus assets to staff must have a fair and equal opportunity of participation and
should not be made with any expectation or undertaking of preferential treatment.

Communications technology
All communication technology (cell phones, telephones, email and the internet)
use must  have  a  justified  business  purpose.  Modest  personal  use  of  this
technology  is accepted provided there are only moderate costs  incurred. Where
any excessive or unreasonable  use  occurs  then  costs  will  be  recovered  where  it
is  practicable  to  do so. Downloading or emailing of unacceptable or offensive
material is not permitted. Note this is subject to the Code of Conduct and
disciplinary action may be taken.
Staff support and welfare expenditure

CCDHB may provide for staff support and welfare in a range of ways. The resulting
beneﬁts should be to both CCDHB and staff.

Recognition and achievement including staff gifts
Expenditure and/or staff gifts to recognise work related achievements of staff should
be appropriate to the circumstances (e.g. morning tea) and should not be
extravagant. The expenditure should be approved within delegated authority limits
and be moderate and conservative. Non work related achievements and associated
Sensitive expenditure
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recognition are a personal cost. Staff gifts may be subject to fringe benefit tax. Refer
to fringe benefit tax procedure.

Staff social functions and Christmas parties
Any expenditure in relation to staff social functions or Christmas parties will not be
paid by CCDHB or its special funds. The only exceptions are: events approved by the
CEO/GM HHS/GM MHAIDS or when a special fund purpose specifically states ‘staff
welfare’ and the costs incurred are reasonable in the circumstances. In keeping with
this policy, costs for alcohol will not be permitted. The expectation is that any such
costs will be met by staff member contributions as is the expected norm in the public
sector.

Farewells and retirements
Expenditure on farewells and retirements includes spending on functions, gifts and
other items when staff are leaving or retiring from CCDHB. Expenditure on farewells
and retirements should not be extravagant or inappropriate to the occasion and
should be appropriate to the length of service. The expenditure should be approved
within delegated authority limits and be moderate and conservative.

Clothing
CCDHB will pay for work related clothing and/or footwear, specifically uniform outer-
wear. This applies where CCDHB requires this to be worn in the workplace and/or
provision of clothing or footwear by CCDHB is specified under the relevant MECA.
Uniforms may identify CCDHB by displaying the organisation’s logo, name, or style.
Clothing must have a justified business purpose and not have any personal use
component.

Continuing medical education (CME)
CME in the context of this policy is a contractual entitlement of senior medical officers
(SMOs) to allow for the advancement of their continuing professional development
and learning. CCDHB contributes up to a set amount of money and a set number of
study leave days, per SMO, entirely for this purpose.

Notwithstanding that CME expenditure is a contractual entitlement it must:
  have a direct relationship to an SMO‟s medical education;
  Be utilised in such a manner that CCDHB does not incur any additional
costs (FBT/PAYE)  or  disadvantage  in  addition  to  the  CME allowance.
Guidance on reasonable and valid use of CME funds which are generally tax
exempt, unless stated  otherwise, are provided below. Examples include but  are
not limited to:
  courses or conferences of a medical education nature that ideally relate to
the SMOs field of work/specialty;
  reasonable / valid expenses that are incurred in relation to attending the
course  or  conference.  This  may  extend  to  travel  upgrades  or  travel
memberships where such travel is undertaken on a regular basis;
  professional qualifications and advancement;
  membership of professional organisations, magazine and other
subscriptions in furtherance of medical education;
Sensitive expenditure
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Version 2.1

  books, journals or other publications in electronic or print media in
furtherance of medical education;
  The purchase of laptops, iPads or similar for direct educational use. Refer
to the PAYE obligations in the next paragraph below.
CME is tax exempt when used to reimburse expenditure of the type that would
ordinarily be deductible to staff (such as conference fees, travel costs and
accommodation costs). However CME payments will not be tax exempt and PAYE
obligations will arise if the expenditure delivers more than an incidental private
benefit to the SMO (eg. laptop, iPad).

This  entire  policy  should  be  considered  when  making  decisions  about
the appropriateness of CME related costs.
All costs may be paid by the SMO initially who will seek reimbursement from
CCDHB. In order to be reimbursed SMOs should follow the staff reimbursement
procedure. Tax invoices are required. Business Managers/Service Managers should
give prior approval for the expenditure before an SMO books a course under
standard delegation authorities.

Sponsorship of staff and others
Staff may be sponsored by CCDHB if taking part in an activity that is not part of their
job, such as a community event. This may be through the provision of, or payment
for, goods or services (e.g. a t-shirt or an entry fee).

Sponsorship should have a justiﬁed business purpose which could include: publicity
for CCDHB and its objectives or organisational development. The cost to CCDHB
should be moderate and conservative. If the sponsorship does not have a justiﬁed
business purpose the cost is a donation. Whether it is sponsorship or a donation this
expenditure will need to be pre-approved by the CEO or GM HHS or GM MHAIDS.

CCDHB expects sponsorship of non-staff to be undertaken in a manner that is
transparent. It is also preferable that if non-staff are sponsored the sponsorship is
paid to an organisation rather than direct to any individual.
Refer to the fundraising, sponsorship and donor interaction policy for more
detail.
Other types of expenditure
Donations
A donation is a payment, in money or in kind by way of goods or services, made
voluntarily and without expectation of receiving goods or services in return.
Donations should be:
  approved in advance by the CEO or GM HHS or GM MHAIDS;
  for purposes that are consistent with CCDHB business;
  an appropriate size in the circumstances;
  lawful in all respects;
  made to organisations by normal commercial means (not to individuals);
not paid in cash (cheque or electronic payment should occur);
Sensitive expenditure
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Regard printed versions of this document as out of date – The CapitalDoc
document is the most current version

Document facilitator: Financial Controller Senior document owner: Chief Financial Officer
Document number:   1.8410   Issue Date 25 June 2018   Review Date 25 June 2022
Version 2.1

  Non-political.
Koha / Whakaaro Aroha
Koha / Whakaaro Aroha shall only be given when it has:
  been approved in advance by an Executive Director or higher;
  has a justified business purpose;
  is  modest  and  appropriate  to  the  circumstances  taking  into  account
the occasion;
  should not be paid in cash (cheque or electronic payment should occur).
Refer to the CCDHB koha/whakaaro aroha policy for more detail.
Gifts paid
A gift is usually given as a token of recognition of something provided by the recipient
such as long or outstanding service by a board member or staff. Gifts may be
tangible objects or intangibles such as free vouchers or privileged access to goods or
services.

Gifts must not imply any obligation or expectation of favour in return or be intended to
alter CCDHB or a staff member‟s decision making. Gifts paid by CCDHB to external
organisations or non-staff individuals must be pre-approved by the CEO or GM HHS
or GM MHAIDS and must have a justified business purpose and be modest.
References
  Code of conduct
  Conflict of interest policy
  Controlling sensitive expenditure: guidelines for public entities, by the
Office of the Controller and Auditor General
  Delegations of authority policy
  Fundraising, sponsorship and donor interaction policy
  Koha / Whakaaro Aroha policy (donation/unconditional gifting)
  Procurement policy
  Staff gift register policy
  Staff reimbursement procedure
  Staff travel procedure (including CME travel)
  Transport – CCDHB vehicle usage policy
Disclaimer: This document has been developed by Capital & Coast District Health
Board (CCDHB) specifically for its own use. Use of this document and any reliance
on the information contained therein by any third party is at their own risk and
CCDHB assumes no responsibility whatsoever.

Sensitive expenditure
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