Meals and Travel Expenses

Am I required to disclose each payment for travel expenses on my financial disclosure statement, or can I add all the payments together and disclose only the total payment from each source?

You are required to disclose each payment of travel expenses from each source. For example, if you received four separate payments for travel expenses from the same source in a calendar year, you are required to disclose the source and amount of each payment in four separate entries on your financial disclosure statement. As noted on the FDS form, you can (if you wish) attach copies of travel expense reimbursement forms. If you do so, make sure all personal information (social security numbers, credit card numbers, account numbers) has been redacted or blacked out. R.C. 102.02(A)(2)(h); Advisory Opinion 2004-01.

Do I have to disclose conference registration fees as part of my travel expenses?

No. Registration fees are not travel expenses even if you travel to the conference. Advisory Opinion 2004-01.

If someone gives me a trip on a private plane, or allows me to stay at their private residence or vacation home, must I disclose that as travel or as a gift?

If the trip is in connection with your public duties, then you must report the source of the trip or lodging as payment for travel expenses on your financial disclosure statement. You are also required to disclose the amount of the trip.

If the trip is not in connection with your public duties, then you must report the provider of the trip or lodging as the source of a gift on your financial disclosure statement if the fair market value of the gift exceeds $75.00.

R.C. 102.02(A)(2)(g) and Advisory Opinion 96-003.

If I travel for my private job and my private employer pays the expenses, do I have to disclose the expenses as travel or a gift from my private employer?

No. You are only required to disclose travel expenses incurred in connection with the official duties of the public position for which you are required to file a financial disclosure statement. R.C. 102.02(A)(2)(h). The travel expenses would not be considered a gift from your employer.

You are, of course, required to disclose your private employer as a source of income.

If I personally pay dues to a professional organization, but travel to the conference as part of my public duties, do I have to list the source and amount of my travel expenses to that organization’s conferences?

Yes, you are required to disclose the source of travel expenses to the organization’s conferences, unless the organization is a state or national organization and your public agency or some other public agency pays membership dues to the organization. R.C. 102.02(A)(2)(h).

If my public employer pays my membership dues to a county or city organization, do I have to disclose the source and amount of travel expenses to the organization’s conferences?

Yes. The law states that you are not required to disclose the source and amount of travel expenses to travel to a conference of a national or state organization to which any public agency pays membership dues. However, the exception does not apply to county or city organizations unless they are affiliates of a state or national organization. You should contact the organization to determine if it is a state or national organization. R.C. 102.02(A)(2)(h). NOTE: Some organizations with “county” or “city” in their names are national or state organizations—i.e. the County Commissioners Association of Ohio (a state organization) and the National League of Cities (a national organization).

Do I have to disclose sources of travel expenses if they were reimbursed directly to me?

Yes. You are also required to disclose the amount reimbursed to you. R.C. 102.02(A)(2)(h); Advisory Opinion 2004-01.

Do I have to disclose payments for my travel made on my behalf to a third party? For example, if my public agency pays an airline directly for my plane tickets, do I have to disclose anything?

Yes. You are required to disclose the source and amount of travel expense payments made to you or on your behalf. Advisory Opinion 2004-01.

Do I have to disclose costs associated with my use of a vehicle owned or leased by the public agency I serve?

No. Advisory Opinion 2004-01.

If I traveled at the end of the year, but was not reimbursed for my expenses until the next year, which year do I disclose the travel expenses?

A filer is required to disclose the source and amount of every payment of expenses incurred for travel to destinations inside or outside of this state that is received by the person in the person’s own name or by any other person for the person’s use or benefit and that is incurred in connection with the person’s official duties. Therefore, you should disclose the travel expense reimbursements on your financial disclosure form for the year in which you received the reimbursements rather than the year in which you incurred the expense.