MCVP Guide for Professional Expense Reimbursement - Virginia ...

VCU Health System
MCV PHYSICIANS
GUIDE FOR PROFESSIONAL EXPENSES AND
EMPLOYEE REIMBURSEMENTS
(BASED ON THE INTERNAL REVENUE SERVICE PUBLICATION 463)
Effective for Purchases after June 30, 2004

PROFESSIONAL EXPENSES AND EMPLOYEE REIMBURSEMENTS
I. General Overview
General Overview pg(s). 3
Ramifications of Non-Compliance pg(s). 3
Reimbursement pg(s). 4
Substantiation Requirements pg(s). 4
II. Submitting your reimbursement pg(s). 5
III.
Policy
Cell Phone Usage pg(s). 6
DEA Registration pg(s). 7
Business Meals pg(s). 8
Entertainment pg(s.) 9
Gifts/Prizes/Awards pg(s). 10
Internet Access pg(s). 11
Medical Professional License Renewal pg(s). 12
Mixed Use Property pg(s). 13
Moving/Relocation pg(s). 14
Subscriptions/Dues pg(s). 15
Travel Expenses pg(s). 16&17
Key Person Life Insurance pg(s). 18
Appendix A: Examples of Reimbursement Forms to be used
Travel Authorization Form
Travel Reimbursement Form
Mileage Reimbursement Form
2

General Overview
This guide is intended to provide a general overview of Internal Revenue Service
regulations relative to reimbursable employee business expenses of “professional
expenses”. This guide is not intended to provide a comprehensive interpretation of the
Internal Revenue Code nor should any information presented in this guide take precedent
over Internal Revenue Service regulations. We recommend the use of the Internal
Revenue Service publications 463 Travel, Entertainment, Gift and Car Expenses as
supplements to this guide.
Ramifications of Non-Compliance
The penalties for failure to comply with Internal Revenue Service guidelines are
potentially severe. Tainting rules apply to reimbursement plans. In other words, the IRS
can disallow an employee’s entire reimbursement plan if any expenses are
unsubstantiated or unallowable.
If this were to occur, individuals would be liable for all income taxes. In addition, MCV
Physicians would be liable for all employment taxes (employer and employee portions of
FICA and Medicare-15.3percentage).
Why is MCV Physicians so concerned about documentation Material non-compliance
or lack of diligence in enforcing substantiation requirements could result in the
disqualification of the reimbursement plan for the entire organization. Further, patterns
of abuse might be construed to be private inurement and could jeopardize our not-forprofit
status.
3

Reimbursement
A good rule of thumb for determining whether an expense is reimbursable is as follows:
If you derive any personal benefit from the expense in question, it probably is not
reimbursable.
Common Examples of Expenses not Considered Business Related or Reimbursable:
Home Phone Lines
Commuting Expenses
Business Suits
Medical Expenses
Gifts/Bonuses to State Employees
Spousal Travel Expenses
Parking Tickets
Kennel Fees/Pet-sitting
Home Office Expenses
Personal Dry Cleaning
Tuition for employee family
Immigration fees
Personal Usage of Cellular Phones
Home Personal Computers
Briefcases
Political Contributions
Safety Deposit Boxes
House-hunting Expenses
House-sitting Expenses
Software for home use
Vehicle Property Taxes
Car Payments
Will preparation
Personal Aircraft
Substantiation Requirements:
Employees must adequately substantiate all qualifying expenses, and MCV Physicians
must take reasonable measures to ensure that these requirements are enforced. The
Travel Expense Reimbursement Voucher form is located in Appendix A and must be
used to apply for reimbursement.
1. Submit Original Receipts – Original receipts are required for hotel bills,
airplane tickets, meals and any unusual authorized expense. Inability to
provide original receipts will cause the reimbursement to be a taxable event
reported on the employee’s W-2.
2. State Business Purpose and Business Relationship – Do not assume that the
business purpose is obvious. Be specific and descriptive. Listing of the
attendees and the business purpose of expense must be stated.
3. Provide Proof of Payment – A canceled check, together with a bill from the
payee ordinarily establishes the cost. However, a canceled check by itself
does not prove a business expense with other evidence to show that it was for
a business purpose. Other forms of proof of payment are credit card receipts
and receipts of payment from the payee.
NOTE:
ALL reimbursements, which are not adequately substantiated, will be
reported as taxable income. Non-deductible reimbursements will also be
reported as taxable income. MCV Physicians will notify you of
deficiencies in substantiation and provide you with an opportunity to
correct the problem.
4

Submitting your reimbursement
ALL reimbursement documentation must be completed and submitted to the Department
of Finance within one hundred twenty (120) days. Reimbursements not submitted within
guidelines will be disallowed. The employee’s supervisor must approve the voucher and
submit to Accounts Payable for processing within five (5) business days of receipt from
employee. See Appendix A for the Travel Expense Reimbursement Voucher form. All
reimbursements must be submitted on the appropriate form.
References
IRS Publication 463 Travel, Entertainment, Gift and Car Expenses, 2003.
IRS Publication 1542 Per Diem Rates revised February, 2003.
5

MCV Physicians of the VCU Health System
CELL PHONE/BLACKBERRY USAGE REIMBURSEMENT
POLICY
Effective Date: 01/21/04
Revision Date: 10/18/06
Purpose: To define reimbursement guidelines for cellular telephone/blackberry service acquired by
employees of the VCU Health System. To clarify that monthly base fees and business related calls are
reimbursable; however, personal calls are not. To establish that actual cellular telephone, and/or related
equipment are not reimbursable under any circumstance.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for cellular telephone/blackberry service. Also, this policy will encourage the procurement of
minimal monthly base fees.
Reimbursement Requirements: An original bill and proof of payment must be submitted with the
reimbursement request. Also, the following criteria must be met.
1. Contracted base fee for cellular/blackberry service may not exceed $40 for faculty and
staff. Contract base fee for Chairmen may not exceed $80.
2. An itemized billing from the cellular/blackberry service must be provided for all business
calls to be reimbursed. If an itemized bill is not provided only the base fee will be
reimbursed on a pre-tax basis.
3. All personal calls must be subtracted from the total bill.
4. The cellular telephone/blackberry must be a required condition of employment.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
6

MCV Physicians of the VCU Health System
DEA REGISTRATION
Effective Date: 01/21/04
Purpose: To define proper processing of DEA registrations. To ensure the fact that the responsibility of
renewing the DEA license prior to the renewal date is solely that of the individual requiring the DEA
license.
Rationale: To establish the consistency of processing DEA registrations and to control funds
unnecessarily spent by the VCU Health System for DEA licenses. To enforce Title 21 CFR – Section
1301.21 which states “any hospital or other institution which is operated by an agency of the United States,
of any State, or any political subdivision or agency thereof” is exempt from DEA renewal fees.
Reimbursement Requirements: When submitting an application to the DEA the department
administrator or MCVP Director of Finance must sign under section 7 of the application. Section 7
designates exemption from fee. No payment is to be sent with the application. If an individual pays the
DEA not knowing of fee exemption, he must provide proof of payment and/or receipt from the DEA along
with the check request to MCV Physicians for reimbursement.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
7

MCV Physicians of the VCU Health System
BUSINESS MEALS REIMBURSEMENT POLICY
Effective Date: 01/21/04
Revision Date: 08/02/06
Purpose: To define reimbursement guidelines for business meals acquired by employees of the VCU
Health System.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for business meals.
Business Meals: Business meals are only reimbursable if the expenses are directly related to your
business. The following factors must apply for reimbursement to take place:
The main purpose of the combined business and entertainment was the active
conduct of business.
The employee actually conducted business and entertainment during the
entertainment period.
The employee had more than a general expectation of obtaining income or some
other specific business benefit at some future time.
Reimbursement amount must not exceed $90 per person. Any exception must
be approved in advance.
Reimbursement Requirements: An original bill and proof of payment must be submitted with the
reimbursement request. A list of attendees must be submitted with the check request.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
8

MCV Physicians of the VCU Health System
ENTERTAINMENT REIMBURSEMENT POLICY
Effective Date: July 16, 2003 Board Approved
Purpose: To define for what purposes and to what extent departments may use specific funds for
entertainment expenses. To further define the circumstances under which MCVP Board approval is
required.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for entertainment and business meals.
Celebrations: See sanctioned policy guidelines below:
1. Allowable celebrations that utilize MCVP dollars include: Resident/Fellow graduation,
Holiday parties, receptions, and celebrations of the Academic Mission. All others must
receive special permission from the MCVP Board.
2. Celebrations noted above do not require MCVP Board approval as long as the Department
has a positive operating margin and is not in receivership.
3. Expenses are capped at $90 per person. Exceptions must be approved in advance.
4. Any exceptions to the above must be approved by the MCVP Board.
Reimbursement Requirements: An original bill and proof of payment must be submitted with the
reimbursement request. A list of attendees must be submitted with the check request.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
9

MCV Physicians of the VCU Health System
GIFTS /PRIZES/AWARDS
REIMBURSEMENT POLICY
Effective Date: 01/21/04
Purpose: To define reimbursement guidelines for gifts, prizes, and awards received by employees of the
VCU Health System.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for gifts, prizes, and awards; and to comply with IRS guidelines.
1. Gifts: To state that the Internal Revenue Service allows reimbursement for gifts,
which are equivalent to $25 or less per employee per year. State policy expressly
prohibits Commonwealth of Virginia employees from receiving cash gifts and noncash
gifts greater than $25. Gifts to any employee, regardless of funding source, are
deemed a personal expense, unless: The gift is in connection with a sanctioned
employee incentive program and is under $400 in value.
2. Awards & Prizes: Awards and prizes to all employees must be in connection with a
program approved by VCU Health System Human Resources Department. All
awards and prizes must be reported to VCU Health System Payroll Department
along with the recipient’s social security # so that the award/prize can be reported on
the employee’s W-2 as income.
Reimbursement Requirements: An original bill and proof of payment mu st be submitted with the
reimbursement request. The recipient’s name and social security # are to be provided with the payment
request. The following rules apply equally to non-cash gifts as well. Also, the following criteria must be
met.
1. The gift value is less than $25.
2. The payment is reported as taxable income to the recipient of the gift.
3. Gift certificates are considered cash, regardless of amount, unless specific item is listed
for purchase.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
10

MCV Physicians of the VCU Health System
INTERNET ACCESS REIMBURSEMENT POLICY
Effective Date: 01/21/04
Purpose: To define reimbursement guidelines for internet access acquired by employees of the VCU
Health System.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for internet access. Also, to encourage the use of the VCU internet access account.
Reimbursement Requirements: Each department is advised to acquire internet access through the
account offered by VCU. If an individual opts to go elsewhere for service, the individual will only be
reimbursed the VCU rate of $9.95 per month. An original bill and proof of payment must be submitted
with the reimbursement request.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
11

MCV Physicians of the VCU Health System
MEDICAL PROFESSIONAL LICENSE RENEWAL
Effective Date: 01/21/04
Purpose: To define payment and reimbursement guidelines for licenses paid by Medical Professionals
employed by the VCU Health System. This includes (but is not limited to) MD’s, LPN’s, and RN’s. To
ensure the fact that the responsibility of renewing the license prior to the renewal date is solely that of the
Medical Professional.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for medical licenses. This policy states that the maintenance of out-of-state medical licenses is the
responsibility of the individual. Out-of-state medical licenses will be reimbursed to the department
Chairmen only, and for all other medical professionals it is a personal expense.
Reimbursement Requirements: The Medical Professional requiring a license to practice is to submit the
payment to the state prior to the renewal date. A reimbursement request then should be submitted to MCV
Physicians along with a copy of the application and proof of payment.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
12

MCV Physicians of the VCU Health System
MIXED USE PROPERTY REIMBURSEMENT POLICY
Effective Date: 01/21/04
Purpose: To define reimbursement guidelines for Mixed Use Property acquired by employees of the VCU
Health System. And, to clarify what is considered Mixed Use Property.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for Mixed Use Property. To define Mixed Use Property as any tangible item, which is used for, or
has the capability of being used for, both business and personal purposes. In order to qualify for business
reimbursement, the property must be required as a condition of employment and must be for the
convenience of the employer not merely for the convenience of the employee. The Internal Revenue
Service takes a very aggressive position on their interpretation of this code section.
Non-Reimbursable Mixed Use Property: The following categories of property, in most cases, will not
qualify as a business reimbursement even if used entirely for business purposes. The IRS takes the position
that the following items are for the convenience of the employee, not required as a condition of
employment.
Home use Computers
Primary or secondary home phone lines
Home Office
Non-business software
Reimbursement Requirements: An original bill and proof of payment must be submitted with the
reimbursement request. Also, the use of the item must be clearly defined. No reimbursement will be made
for items such as computers, and digital cameras unless the item will remain at the business location and
the use is clearly defined as business purpose only. Items deemed reimbursable will be reimbursed at a pretax
rate.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clin ical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
13

MCV Physicians of the VCU Health System
MOVING & RELOCATION REIMBURSEMENT POLICY
Effective Date: 1/21/04
Revision Date: 12/6/06
Purpose: To define reimbursement guidelines for moving and relocation by employees of the VCU Health
System.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for moving and relocation. To specify that only reimbursement or payment for the actual moving
of the employee, family, household goods, and persona effects is allowed. Also, the responsible Vice
President and VCU Health System Human Resources must approve the offer of reimbursement for
moving and relocation expenses before the offer is formally made to the employee or any expenses are
incurred.
Eligibility: The employee must be a salaried full-time employee of MCV Physicians. The employee must
have an agreement to work document. If employment is terminated prior to completing two years of
service, the relocation/moving expense must be reimbursed by the employee. The move must have been a
requirement for hire, and the distance from new job location to former residence must be at least 50 miles
more than the distance from former job and former residence.
Reimbursement Requirements: Original bills and proof of payment must be submitted with the
reimbursement request. The following criteria must be met:
The expenditure must be reasonable and necessary; and must have been incurred after
official acceptance of employment.
Reimbursement must be requested within twelve months of employee start date.
The total reimbursement cannot exceed $10,000.
Reimbursement for driving a personal vehicle to new residence will be awarded at the
current IRS allowable rate.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
14

MCV Physicians of the VCU Health System
SUBSCRIPTIONS/DUES REIMBURSEMENT POLICY
Effective Date: 01/21/04
Purpose: To define reimbursement guidelines for subscription/dues paid for by employees of the VCU
Health System.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for acquiring subscriptions and dues.
Subscriptions: Subscriptions to professional journals are generally reimbursable. Subscriptions for
newspapers and popular magazines (i.e. Time, People, National Geographic, PC World) are reimbursable if
purchased for the benefit of the patients. Billing for these magazines should be addressed to the clinic and
the bill should be submitted to the MCV Physicians Accounts Payable for payment.
Dues: Dues for membership in professional organizations are generally reimbursable on a pre -tax basis.
Dues for memberships in country clubs, athletic associations, travel clubs, airline clubs, credit card fees,
etc. are not reimbursable. Original bills must be submitted in order to be reimbursed.
Reimbursement Requirements: An original bill and proof of payment must be submitted with the
reimbursement request. Dues must be for business purposes only and subscriptions solely for the benefit of
the MCVP missions or patient waiting areas.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
.
15

MCV Physicians of the VCU Health System
TRAVEL EXPENSE REIMBURSEMENT POLICY
Effective Date: 01/21/04
Revision Date: 08/28/06
Purpose: To define payment and reimbursement guidelines for all local, out-of-state and out-of-country
travel. To clarify allowable and non-allowable travel related expenses.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for travel. To ensure that travel expenses incurred by VCU Health System employees on official
business must be reasonable, necessary and represent an efficient use of resources. Any falsification of
expenditures constitutes fraud and will be treated as such. To enforce incremental expenses for travel, food
or lodging associated with a spouse accompanying and employee on a business trip will not be reimbursed.
No expenditures for personal pleasure or entertaining are allowed.
Travel Authorization: The travel authorization form showing estimated expenses must be pre-approved
by the department chair 2-4 weeks prior to travel. Out-of-Country travel must also have prior written
approval of the VP for Health Sciences. Department Chairs must have written approval by the Dean of the
School of Medicine and the VP of Health Sciences.
Transportation: Personal automobiles may be used and expenses will be reimbursed at the current IRS
mileage reimbursement rate. Maintaining appropriate automobile insurance is the responsibility of the
traveler. Neither the option to purchase additional insurance for rental cars nor any damage to personal
or rental vehicles is reimbursable. Travelers must ensure that rental vehicles are refueled before returning
the vehicle. Reimbursement will be based on the fuel usage and receipts provided.
Original receipts are required for airline, taxi, shuttle, and all other forms of public transportation when the
cost is greater than $10. Rates must not exceed those for tourist or coach class accommodations. If first or
business class accommodations are submitted, the traveler will only be reimbursed for the coach fare as
determined by the MCVP Finance department. The traveler will not be reimbursed for airline/rail tickets
until the trip is completed and receipts are submitted with their travel voucher.
Meals: Expenses for social guests, e.g., spouses or friends are non-reimbursable. If meals are provided by
the conference, separate reimbursement will not be approved. Expenses should be reasonable and are
subject to review (in general meals less than $75 for physicians and less than $50 per all other employees
would be considered reasonable). Receipts must be submitted for all meals over $10.00. Meals over $10
not substantiated with receipts will cause the entire reimbursement to default to the IRS per diem for meals.
Reasonable amounts of beer and wine will be reimbursed.
Lodging: Original hotel bills showing a “0” balance obtained at the time of checkout and other supporting
receipts for lodging expenses must be submitted with the travel voucher. Resort fees, movies, and any
other personal expense will not be reimbursed. Stays at conference hotels will be reimbursed at the single
room rate. Stays at non-conference hotels are subject to IRS per diem rates (IRS Publication 1542 or
www.policyworks.gov/perdiem). When lodging used is other than hotels and motels, e.g., apartments, a
comparison statement including authorization by the traveler’s supervisor must be submitted with the travel
voucher. The comparison statement should show the following:
Total cost for using the alternate accommodations and length of contract
Cost of the usual accommodations
Net savings
16

Non-Canceled Reservation Charges are not reimbursable.
Registration Fees: An employee attending a conference for business purposes will be reimbursed for
registration fees incurred. The attendee must submit proof of payment and original receipt.
Business Calls, Telegrams and Facsimiles: Business calls, telegrams and facsimiles are reimbursable
only if for business purposes and submitted on the Travel Reimbursement form.
Reimbursement Requirements: The VCU Health System employee must submit all travel related
reimbursements on the sanctioned MCV Physicians Travel Reimbursement form. The form must be
approved by the traveler’s immediate supervisor. All original receipts must be submitted with the Travel
Reimbursement form. The purpose of the trip must be clearly stated. Travelers must complete, sign, and
date the Travel Reimbursement Voucher within thirty (30) days of completion of trip. Reimbursement not
submitted within sixty (120) days will be disallowed.
Note: Any payment to the traveler (i.e. Honorariums, vendor payments, reimbursement for travel from
outside groups and/or royalty payments) will be deducted from total reimbursement before use of
professional expense allowable. Failure to declare payments will result in disciplinary action.
Disclaimer: MCV Physicians will deny reimbursements for reimbursable expenses that are not submitted
to the Department of Finance within one hundred twenty (120) days. Reimbursements for parking must be
submitted within 365 days of occurrence. Every effort should be made to insure that reimbursements are
reported in the fiscal year that the expense occurred. Also, the clinical department can deny reimbursement
for reasons other than those specified in this sanctioned policy.
.
17

MCV Physicians of the VCU Health System
Key Person Life Insurance
Effective Date: July 16, 2003 Board Approved
Purpose: To define under which conditions a department may choose to obtain life insurance on a key
faculty member.
Rationale: To establish the consistency of reimbursements and to control funds spent by the VCU Health
System for key person life insurance.
Conditions: See sanctioned conditions below:
1. The death of a faculty member would cause significant difficulty for the Department
because of (a) his/her unique contributions, (b) other people/programs in the
department/university are critically dependent upon him/her and (c) it would be difficult
to replace him/her.
2. The beneficiary of the insurance should be the Departmental account in the MCV
Foundation. The funds must be used for either recruitment of the replacement for the key
person or for establishing an endowment to support the position vacated by the death.
Such endowment can be named for the key person if h/she wishes. Any other name
chosen should be at the discretion of the key person.
3. The key faculty person must have agreed to have his/her life insured by the Department.
4. The cost of the insurance will be paid by the Department, and should not be undertaken if
the Department is in receivership or imminent receivership.
5. Must be approved by the MCV Board.
18

APPENDIX A
Forms
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