Non‑Employee Expense Reimbursements Submitted After 60 Days

For UND to comply with IRS accountable plan requirements (IRS Publication 463) non‑employees (including students) who submit expense reimbursement requests more than 60 days after the date of return from travel or the date the expense was incurred (whichever is later) will be required to provide a completed IRS Form W‑9 before reimbursement is issued. UND will not withhold any taxes from the reimbursement; however, the payment will be considered tax reportable and may result in the issuance of a Form 1099 to the payee.

The 60‑day timeliness requirement is already in place in NDUS procedure 806.1 and UND Travel policy for employees; the requirement for a W9 will allow UND to appropriately report on untimely non‑employee reimbursements for calendar year 2026 and onward.

Example: If travel ends on March 1, the reimbursement request must be submitted in UND Marketplace no later than April 30 to avoid IRS reporting requirements and the need for a Form W‑9.

To avoid additional steps for the payee and to ensure UND remains compliant with federal reporting rules, please take all possible steps to make sure non‑employee reimbursements are submitted within 60 days. If individuals are non‑responsive to department requests for substantiating documentation (receipts, signed student travel worksheets, etc.), departments have the discretion to decline reimbursement for expenses submitted after the 60‑day period (NDUS 806.1 sub. 7d).

If you have questions about this update or need assistance, please contact the Procurement & Payment Services team at und.pps@und.edu.
Thank you for your attention to this update and for helping ensure compliance with federal reporting requirements.