What about offsite meals with internal staff only—do churches need to exercise more caution then?
They need to be careful—again, they must make sure meals are not on a consistent basis and there are reasons for them. For instance, why did a lunch have to take place outside of the church? Was it a meeting that could have taken place inside? It may be that it’s simply a periodic benefit to the employee: e.g., a performance evaluation was done outside the church as a matter of employee morale. But if that is being done on a consistent basis, then you go back to that “reasonable person” standard to see if it’s inappropriate.
How should church staff document these expenses?
Staff should create an expense report that is part of an accountable reimbursement plan the board has approved: one that lays out the criteria for expense reports. The report needs to be completed and submitted in a timely fashion, with receipts attached. If the lunch expense is on a corporate credit card, you still need to turn the receipts in and have the documentation. The documentation should include who participated, the business purpose of the meeting, and usually the receipt will have the “when” and “how much” and “where." If there is an individual expense reimbursement for it, it should be submitted and reimbursed within 60 days as a general guideline.
For expense reimbursements and charges on corporate credit cards, one of the most important things is that a supervisor needs to review and approve them. For a staff pastor, that supervisor may be the executive pastor or the senior pastor. For a senior pastor, a member of the board should be reviewing and approving those at least on a periodic basis—quarterly, for instance. That allows the “reasonable person” standard: if the supervisor looks at it and asks, “Why did you take the same person to lunch three times a week and submit it for expense reimbursement or put it on the corporate card?” that’s going to help cut down on that.