Life sciences travel and expense policy: a template

1. Purpose and scope

This policy covers how [Company name] pays for and repays business expenses, including travel to conferences and research sites, and how employees handle meals and other dealings with healthcare professionals. It applies to [all employees] [employees and contractors who spend on the company’s behalf]. It is meant to be an accountable plan under IRS rules, so reimbursements under it are not wages unless it says so.

It doesn’t cover payments to clinical trial participants, investigator or site payments under a clinical trial agreement, grants, or fees and honoraria for healthcare professionals, which follow [the clinical operations procedures] [the compliance procedures].

Note: An accountable plan has three rules: each expense is for the business, it’s accounted for within a reasonable time, and any excess is returned. Payments under one stay out of income and W-2 wages (Treas. Reg. 1.62-2).

2. Ask before you book or spend

Ask [your manager] before you book any trip, register for any conference, plan any meal with healthcare professionals, or buy anything this policy doesn’t approve automatically. An approval covers only the amount, supplier, purpose and dates approved.

Note: In Illinois an employer generally owes only expenses it authorized or required, unless it failed to follow its own written expense policy.

3. Trip approval and budgets

3.1 Every trip is approved before anything is booked. The request gives the purpose, with the conference agenda or the study’s protocol number, site number and visit type; the destination and dates; the [study] [project] [department] that pays; who else is going; and an estimate for registration, airfare, lodging, meals and ground transport.

3.2 The approval sets the trip’s budget. Travel and meals within the trip’s dates and budget need no further approval; anything above the budget, outside the dates or of another kind, such as a meal with healthcare professionals, is approved on its own.

3.3 Extra personal days are [allowed at your own cost] [allowed with [title]’s approval]. The company pays the fare [up to what the business dates alone would cost] and the business days only.

3.4 Spouses, family and guests travel at their own cost.

Note: For travel away from home, IRS rules ask for each expense’s amount, dates, destination and business purpose, and a conference agenda generally shows the purpose. On a trip in the United States that is primarily for business, the fare to and from the destination is a business expense even if you stay on, but the vacation days aren’t. A companion’s travel isn’t deductible unless the companion is an employee traveling for a bona fide business purpose (IRC 274(m)(3)).

4. Airfare

4.1 Book economy at the lowest logical fare, the lowest fare that fits the schedule with a reasonable routing, at least [14] days ahead [and [21] for international flights] when you can, through [booking channel].

4.2 [Premium economy] [Business class] is allowed on flights longer than [X] hours [with [title]’s approval].

4.3 Change fees the trip’s business causes are repaid; personal changes and upgrades are yours. [Airline miles and points are yours to keep.]

Note: On a federal contract, airfare above the lowest priced airfare available during normal business hours is unallowable unless a listed condition is documented and justified (FAR 31.205-46(b)); federal awards have a similar rule (2 CFR 200.475(e)). See section 14.

5. Lodging and conference hotels

5.1 Hotels are repaid up to [$[X] a night before taxes] [each city’s going rate plus [X]%] [the federal lodging rate for the city and month].

5.2 The conference hotel block is [allowed when it’s within 5.1’s cap] [allowed up to $[X] a night with [title]’s approval]. Book the block only when it’s in line with the city’s rates for those dates.

5.3 Submit the itemized hotel bill for every stay. Personal charges on it are yours.

Note: IRS rules require a receipt for every night of lodging; a hotel bill showing the hotel’s name, location, dates and separate charges for lodging, meals and phone is enough. GSA’s lodging rates exclude taxes; say whether your cap does.

6. Ground transport and mileage

6.1 Use transit, taxis or rideshare where practical; rent a car [mid-size or smaller] when it costs less or the trip needs one.

6.2 Driving your own car for business is repaid at [the IRS business standard mileage rate in effect on the date of the drive] [[X] cents a mile], plus business parking and tolls. Record each drive’s date, start and end, purpose and miles.

6.3 Driving between home and your regular workplace is commuting and isn’t repaid. [The drive between home and the airport for a business trip is repaid.]

Note: The 2026 IRS rate is 72.5 cents a mile through June 30 and 76 cents from July 1; anything above it is taxable wages.

7. Meals while traveling

7.1 Your own meals on days away are repaid: [choose one]

• [Option A: at actual cost, against receipts, up to $[X] a day.]
• [Option B: as a per diem at [the federal meals and incidentals rate for the city] [$[X] a day], [75%] on the days you leave and return, without meal receipts.]

7.2 Don’t claim meals that a conference registration or hotel rate already includes.

7.3 Alcohol with your own meals is [not repaid] [repaid with dinner up to $[X]].

Note: A per diem counts as substantiated only up to the federal rate for the place, and travelers still record the dates, place and purpose; anything above the rate is wages. From October 1, 2026, the standard federal meals and incidentals rate is $68 a day. If you pay a meals per diem, repaying the traveler’s own share of a business meal on top of it makes that share wages. Business meals are generally 50% deductible.

8. Meals and other dealings with healthcare professionals

8.1 For this policy, a healthcare professional is [anyone licensed to prescribe, recommend, purchase or administer our products, and their staff] [anyone on the list [compliance] keeps].

8.2 A meal with healthcare professionals needs a business purpose, such as [a scientific or educational presentation] [a business meeting] [study work at a research site], and a company employee present. Never: take-out or “grab-and-go” meals, a meal for a whole office when not everyone attends, or meals for spouses and guests.

8.3 Per-person limits, [including] [excluding] tax and tip: [choose limits]

• [Breakfast: $[X] a person]
• [Lunch: $[X] a person]
• [Dinner: $[X] a person]
• [Refreshments at a meeting: $[X] a person]

Where a state’s limit is lower, the state’s applies.

8.4 Alcohol: [never with healthcare professionals] [never at speaker programs, and [rule] otherwise].

8.5 Venues are modest and suited to the discussion[; meals with sales presentations are in the office or hospital]. Never luxury resorts, high-end restaurants or entertainment venues.

8.6 Record everyone who ate, staff included: each person’s name, [title, institution and specialty], [NPI or license number and state], and the purpose, [on the expense] [in [the compliance system]] within [X] days.

8.7 Travel, lodging, fees or honoraria for healthcare professionals are paid only under a written agreement [compliance] approves, and never for healthcare professionals who attend a conference without speaking or teaching at it.

8.8 Before a meal with healthcare professionals in [Vermont, Minnesota, Massachusetts, New Jersey, California and [other states]], check [compliance]’s state rules.

Note: The limits in 8.3 are your company’s choices, not amounts any law allows. The PhRMA Code, a voluntary code drug companies adopt, keeps meals modest as judged by local standards, limits meals with sales representatives’ presentations to occasional ones in the office or hospital, and says companies should not pay for or provide alcohol at speaker programs. The AdvaMed Code, its device counterpart, allows occasional modest meals subordinate to a bona fide presentation, strongly encourages meal policies, which may include a per-meal limit, and bars entertainment and recreation in any form.

Note: The HHS Inspector General’s 2020 Special Fraud Alert lists alcohol, meals exceeding modest value, venues not suited to education, such as restaurants, and repeat attendees among the suspect characteristics of speaker programs under the federal anti-kickback statute.

Note: Open Payments reporting applies only to applicable manufacturers, which report payments, meals included, to covered recipients, and applicable group purchasing organizations, which report physicians’ ownership in them; both are defined in 42 CFR 403.902. A company that makes no drug, device, biological or medical supply that Medicare, Medicaid or CHIP pays for, and supports none under common ownership, generally isn’t one. The reporting is your compliance team’s work. Covered recipients are physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists and anesthesiologist assistants, certified nurse-midwives and teaching hospitals. In 2026 a payment under $13.82 is excluded unless the recipient’s total for the year passes $138.13 ($14.31 and $143.01 in 2027); a shared meal whose individual costs can’t be separated is divided by everyone who ate; data is collected all year and submitted between February 1 and March 31.

Note: State rules differ, and some apply to drug makers only. Vermont bars most gifts, food included, from manufacturers of prescribed products to Vermont health care providers, with listed exceptions. Minnesota bars drug manufacturers’ and wholesalers’ gifts to practitioners beyond listed exceptions, including items worth no more than $50 in total a year. New Jersey caps the modest meals its prescribers may accept from drug makers and adjusts the caps each year ($19 for breakfast or lunch and $40 for dinner in 2024, the latest published, not counting tax or service charges). Massachusetts allows only modest meals with an informational presentation and a company representative present, never for spouses or guests, with quarterly reports for those outside the office or hospital. California requires drug companies to set a specific annual dollar limit on items for each medical or health professional and to post an annual declaration of compliance. Other states have rules too.

9. Events and gifts

9.1 Never provide or pay for entertainment or recreation, such as tickets, golf or trips, for healthcare professionals, whatever it costs.

9.2 No gifts to healthcare professionals or their staff, including branded items, flowers, food baskets, gift cards or cash. Educational items for patients or professionals only through [compliance][, up to $[X] each].

9.3 Team events and offsites follow a budget [title] approves in advance, coded apart from meals with healthcare professionals[; alcohol [not repaid] [up to $[X] a person]].

9.4 Gifts to anyone else, such as suppliers or partners, are [not allowed] [up to $[25] a person a year with [title]’s approval].

Note: The PhRMA and AdvaMed codes bar entertainment and recreation for healthcare professionals and non-educational items such as branded pens and mugs; the PhRMA Code allows occasional educational items of $100 or less where the law permits. The federal tax deduction for business gifts is limited to $25 a recipient a year; that’s a deduction limit, not an allowance.

10. Software and equipment

10.1 Software and AI tools are repaid up to $[X] a month each. Anything recurring above that, and any tool that holds [GxP] [quality] [clinical trial] [patient] data, needs [IT] [QA] approval before the first charge.

10.2 Equipment is repaid up to $[X] an item. [IT] approves computers and phones first [and tags them]; lab instruments and anything used in [regulated work] go through [procurement] [QA].

10.3 Company data, study data and confidential documents stay out of personal accounts.

Note: Which tools need validation or a quality review is your quality system’s decision; name the reviewer here so requests reach them.

11. Receipts

Submit an itemized receipt or clear photo for every night of lodging and every expense of $[75] or more, with its business purpose, and for a meal with healthcare professionals, the record in 8.6 too. For a missing receipt, submit a signed statement of the amount, date, place and purpose[, approved by [title]].

Note: IRS rules require a receipt for lodging and for any other expense of $75 or more, except transportation charges when a receipt isn’t readily available. Illinois requires a signed statement for a missing receipt.

12. Deadlines and payment

12.1 Submit expenses within [30] days of the expense [or the trip’s end]. Claims more than 60 days old [are paid through payroll as taxable wages] [need approval from [title]]. Return any advance or overpayment within [120] days of the expense.

12.2 Submit meals with healthcare professionals within [X] days so [compliance] has the record in time.

12.3 Approved claims are paid within [X] days of approval.

Note: IRS rules treat 60 days to account and 120 days to return any excess as reasonable; Illinois allows 30 days to submit unless the policy allows more. Check state law before refusing a late claim.

13. Approvals

Expenses within this policy are approved [automatically] [by your manager]. Above these amounts, or outside this policy, approval comes first:

• [Trips up to $[X]: your manager; above that, [your department head]; above $[X], [the chief financial officer].]
• [Conference registration: [your manager] [medical affairs].]
• [Meals with healthcare professionals above 8.3’s limits: [compliance].]
• [Software that holds [GxP] data: [QA] and [IT].]
• [Anything over $[X] or outside this policy: [the chief financial officer].]

No one approves their own expenses or a trip they’re on. The chief executive’s expenses are approved by [the chief financial officer] [the board chair].

14. Federally funded work

14.1 A trip or purchase charged to a federal grant, cooperative agreement or contract follows this policy and the award’s or contract’s terms, whichever is stricter, and is coded to the award.

14.2 [On federal contracts] [On awards that apply the FAR cost principles], lodging, meals and incidentals are charged only up to the federal per diem for the place, each day; anything above is charged to [company funds] unless [an officer] approves a written justification for a special situation.

14.3 Airfare charged to an award or contract is [the lowest priced fare available] [the basic least expensive unrestricted class]; anything above needs a documented reason the rules list. On a contract with the Fly America clause, international flights use U.S.-flag airlines where available.

14.4 Alcohol and entertainment are never charged to an award or contract.

Note: These rules apply only where a federal award or contract pays: 2 CFR 200.475 for federal awards to the recipients it covers, FAR 31.205-46 for federal contracts. Agencies apply the Uniform Guidance to companies only as their regulations allow; NIH applies the FAR cost principles to for-profit organizations. Alcohol is unallowable under both (FAR 31.205-51, 2 CFR 200.423), and so is entertainment on contracts (FAR 31.205-14). From October 1, 2026, the standard federal rates are $113 a night for lodging and $68 a day for meals and incidentals, with 295 places at their own.

15. What isn’t reimbursed

Commuting, personal travel and extra days, companions’ travel, upgrades for comfort, fines, entertainment or gifts for healthcare professionals, alcohol outside sections 7.3 and 9.3, meals already included in a registration or hotel rate, and [other items].

16. Records

[Finance] keeps receipts, trip approvals and attendee records for [X] years[, and records for a federal award or contract as long as its terms require]. Employees who hand theirs in and are repaid generally don’t need to keep copies.

Note: The IRS generally asks for three years from filing the return, and at least four for employment tax records. Federal award records are kept three years from the final financial report, and federal contract records generally three years after final payment. Your compliance team may need attendee records longer.

17. State and local law

Where a state or local law gives employees more, such as reimbursement of all necessary expenses or a shorter payment deadline, that law applies. [List your states and cities.]

Note: California requires employers to indemnify employees for all necessary expenditures or losses in direct consequence of their duties, and an agreement to waive that is void. Illinois requires reimbursing necessary expenditures submitted within 30 days unless a written policy allows longer, and a policy’s limits can’t amount to no or de minimis reimbursement.