Compliance Corner

Compliance Corner: Costco and Business Purchases

Jaclyn Lindabury — Mon, 02 Feb 2026 18:00:17 +0000

Compliance Corner: Costco and Business Purchases Jaclyn Lindabury Mon, 02/02/2026 - 11:00

Key Resources

Before you head to the warehouse, read our latest announcement on the complexities of making business purchases at Costco.

Does the University of Colorado prohibit business purchases at Costco?

Short Answer: No, but it’s complicated. Read on to find out more.

Important to Understand

The university allows business purchases at Costco using a personal membership.
The university does not allow the purchase of Costco business memberships using university funds.
- The university prohibits Costco business membership agreements. If your department currently maintains a Costco business membership, please do not renew it. For more information on vendor contracting policies and procedures, please consult with the Procurement Service Center.

Why is it complicated?

Recent fieldwork by the Campus Controller’s Office at Boulder found that Costco warehouses do not issue a tax-exemption for business purchases made with a personal membership. This is Costco policy.

�鶹��Ѱ��Boulder is a constitutionally-recognized state institution of higher education, and is exempt from Colorado state and local sales taxes on purchases made in its official governmental capacity. Generally, tax should not appear on P-Card transactions, and we discourage the use of vendors who do not apply appropriate tax exemptions for university purchases.

Final Word

It will be difficult for employees to make Costco purchases that comply with both university and Costco policies. Therefore, we encourage employees to use alternative vendors.

Before you head to the warehouse, read our latest announcement on the complexities of making business purchases at Costco.

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Compliance Corner: Key details to understand about honoraria

Jaclyn Lindabury — Mon, 01 Dec 2025 18:14:18 +0000

Compliance Corner: Key details to understand about honoraria Jaclyn Lindabury Mon, 12/01/2025 - 11:14

Before accepting that speaking fee or payment for outside work, �鶹��Ѱ��Boulder employees need to know the rules. While the university doesn't have a blanket ban on honoraria, strict adherence to the Fiscal Code of Ethics is required to prevent conflicts of interest or "private gain." Learn the key restrictions and additional disclosure requirements, plus state-level ethics and tax considerations.

Question 1: Does �鶹��Ѱ��Boulder prohibit employees from accepting honoraria?

Answer: Sometimes.

The University of Colorado does not specifically prohibit employees from receiving honoraria from outside entities. However, under the Fiscal Code of Ethics, the University does prohibit any “private gain” from an employee’s association with the University. This includes situations where an employee is:

receiving substantial [external] compensation for performing university duties;
using university resources for personal gain; and
giving rise to the “appearance” of having a conflict of interest.

As it relates to honoraria, Fiscal Compliance understands the Fiscal Code of Ethics requirements to mean that:

(1) an employee should not be performing tasks for an outside organization during their scheduled work hours;
(2) an employee should not be using University property or resources to support outside tasks;
(3) the tasks performed for an outside organization cannot overlap with the employee’s official work for �鶹��Ѱ��Boulder;
(4) the employee should not accept an honorarium if the outside organization is a �鶹��Ѱ��vendor;* and
(5) an employee should not accept an honorarium from a non-vendor if it is more than what peers receive for similar work.

For more details on gifts or payments from �鶹��Ѱ��Vendors, please visit our FAQ on the subject.

If the honorarium payment is appropriate under the Code of Ethics, some types of employees are subject to additional requirements.

Research Employees

If the employee is responsible for the purpose, design, conduct, or reporting of research, then they may have to disclose:

Any gift or honorarium valued at more than $5,000
If the outside organization is a foreign entity

This list is not exhaustive. For more information on the relevant disclosure requirements and process, please review this FAQ, or consult with the Research and Innovation Office.

Officers

If the employee is a designated officer, they will have to disclose any gift or honorarium valued at more than $5,000, or certain unremunerated commitments to outside entities. For more information, please contact the Fiscal Compliance team.

Procurement

If the employee, within their official university role, would like to procure goods or services from the outside organization on behalf of �鶹��Ѱ��Boulder, they must disclose any benefits received from the organization on future Marketplace orders using the Conflict of Interest Evaluation Form (see Procurement Rules and the Fiscal Code of Ethics).

Question 2: Should I be aware of other (non-CU) rules governing honoraria?

Answer: Yes.

The State of Colorado bans public employees from accepting gifts worth more than $75 under Amendment 41. Public university employees fall under that ban. Please consult with the Colorado Independent Ethics Commission to determine whether your non-�鶹��Ѱ��honorarium payment would be appropriate under state public ethics requirements.

Additionally, external honoraria are taxable as supplemental income. Please discuss with a personal tax advisor how best to declare non-�鶹��Ѱ��payments.

Before accepting that speaking fee or payment for outside work, �鶹��Ѱ��Boulder employees need to know the rules. While the university doesn't have a blanket ban on honoraria, strict adherence to the Fiscal Code of Ethics is required to prevent conflicts of interest or "private gain."

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Compliance Corner: The right codes for food & alcohol at official functions

Jaclyn Lindabury — Mon, 03 Nov 2025 15:50:06 +0000

Compliance Corner: The right codes for food & alcohol at official functions Jaclyn Lindabury Mon, 11/03/2025 - 08:50

Got a question about expense codes? You're not alone! The Fiscal Compliance team is dedicated to providing clear, consistent guidance. To promote transparency and uniform practices across campus, we're taking some common inquiries and sharing the answers with everyone.

Question 1: What expense code should I use for food purchases associated with an official function with alcohol?

We advise campus to use separate codes for food and alcohol to ensure accuracy and compliance.

For expense type: Alcohol, use expense code 550102.
For expense type: Food, use expense code 550100.

Why the split?

The main reason is compliance and accurate reporting.

Policy Requirement: Expense code 550102 is required by policy for alcohol and facilitates the heightened review required for all alcohol purchases, such as ensuring alcohol is recorded in the correct fund type. (See: Finance Procedural Statement on Alcoholic Beverages Purchased for University Events)
Clear Data: Using a separate code for food ensures our alcohol expense reports are accurate and not inflated by food costs.

For more information, please review our previous articles: Mastering the art of completing your �鶹��Ѱ��official function form and An important reminder about official functions with alcohol expenses.

Question 2: Do I have to itemize food purchases in Concur if I use expense code 550100 instead of 550102?

No. Your documentation requirements under policy remain the same, regardless of which expense code you use.

Based on feedback from campus users, the System’s team recently introduced a new Concur itemization feature that copies information from the parent expense to help save you time and effort. However, this new feature does not change what you need to document to meet policy requirements.

Need Step-by-Step Guidance? Review these resources:

If you have questions about fiscal policies and procedures, please feel free to contact fiscalcompliance@colorado.edu. For questions related to alcohol approvals, please contact campus.accounting@colorado.edu.

Using the wrong code can complicate approvals and skew our reporting data. This month, we're clarifying when to use 550102 versus 550100 to keep your reconciliation process clean and compliant.

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Compliance Corner

Compliance Corner: Costco and Business Purchases

Does the University of Colorado prohibit business purchases at Costco?

Important to Understand

Why is it complicated?

Final Word

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Compliance Corner: Key details to understand about honoraria

Question 1: Does �鶹��Ѱ�����Boulder prohibit employees from accepting honoraria?

Question 2: Should I be aware of other (non-CU) rules governing honoraria?

Off

Compliance Corner: The right codes for food & alcohol at official functions

Question 1: What expense code should I use for food purchases associated with an official function with alcohol?

Question 2: Do I have to itemize food purchases in Concur if I use expense code 550100 instead of 550102?

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Question 1: Does �鶹��Ѱ��Boulder prohibit employees from accepting honoraria?