Number: ADMIN 080
Effective: December 1, 2016
Last Reviewed: June 10, 2022
Department: Finance and Business
Last Revision: January 11, 2022

Purpose

To establish guidelines regarding the giving of gifts, awards, and the creation of incentive programs for CWI.

Scope

Applies to all approved gifts, awards, and incentive programs within CWI.

Definition

De Minimis: Any property or service the value of which is so small as to make accounting for it unreasonable or administratively impractical. CWI considers the value of any property or service which is less than $100.00 to be de minimis.

1099 Miscellaneous Income: Compensation given by CWI to a person(s) who is not an employee of CWI, including cash, prizes, gifts, awards, etc. that is reportable as income for tax purposes.

Policy

CWI understands the need to recognize the dedication and achievement of its staff and faculty for supporting the mission of CWI and exemplary performance of work done on behalf of CWI. Such recognition may be in the form of non-cash gifts, awards, and incentives. Cash awards are discouraged and have possible tax implications under the Internal Revenue Code and applicable state law. All programs that provide gifts, awards, or incentives to employees and non-employees utilizing CWI funds are required to be pre-approved by CWI. Failure to follow this policy will likely result in personal reimbursement to CWI and/or may be subject to disciplinary action up to and including termination and may have to reimburse the College.
 

REGULATIONS

State of Idaho Controller's Office, Idaho State Board of Examiners

Federal Uniform Grant Guidance

 

Guidelines

For audit purposes, purchases held prior to the latest revision of this policy are subject to that version of this policy in effect at the time the purchase process was initiated. Purchases made after the latest revision date of this policy are subject to this policy as amended.

GIFTS/AWARDS/INCENTIVES

  1. Gifts/Awards/Incentives/Promotional Items: A work related event may be acknowledged by a non-cash award and must be de minimis in value. Guidelines and limitations for all types of non-cash recognition must be consistent with appliable law, as well as IRS tax rules. Examples of work-related events are as follows:
    1. Retirement or Separation Gifts – Can be given in recognition of the employee’s service upon leaving or retiring from his/her position.
    2. Employee Appreciation or Recognition Awards – Can be given as an acknowledgement to an employee of work-related accomplishments. Employee recognition awards are intended to be occasional.
    3. Promotions or Door Prizes – Departments may use promotional or door prizes to encourage participation or as an incentive to complete surveys or questionnaires. CWI will reimburse or pay the cost of promotions or door prizes for official CWI functions with prior approval and where there is a documented business purpose.
    4. Program Incentives – CWI will reimburse or pay the costs of program incentives distributed to encourage participation in a CWI event. These incentives must be approved in advance by the appropriate manager and must be for a documented business purpose.
    5. Bereavement or Serious Illness– A token of sympathy, such as flowers, may be given in the event of death or illness of an employee, student, friend of CWI or a member of his or her family or household. A monetary contribution to an appropriate charitable organization may be considered as an alternative provided that the receiving organization does not serve a political or religious purpose.
  2. Non-Employee Gifts/Awards/Incentive/Promotional Items: Non-cash gifts, awards, or incentives of a de minimis value may be given on behalf of CWI when it can be established that the gift benefits CWI by enhancing the goodwill to the community and the citizens of Idaho. Examples of non-employee work related events are the same as 1.a-e noted above.
    1. If the gifts, awards, incentive, or promotional item surpass the de minimis amount for each non-employee, the business purpose of the gift must be documented and the President’s approval must be obtained before the purchase and presentation of the gift (e.g., bereavement gift given to a Board of Trustee member with a value of $100 or more.)
  3. Other Limitations
    1. Employees may not request cash reimbursement for gift cards or gift certificates received as a gift, award, or incentive.
    2. Rush handling or express shipping fees are not allowed unless approved in advance by the Vice President of Finance.
    3. Certain gifts, awards, and incentives have tax implications for the recipient and additional reporting requirements for CWI. See Appendix A to this policy, the Internal Revenue Code, and applicable state law.
    4. Gifts, awards, and incentives must be kept in a secure location and are the responsibility of the CWI employee who is the custodian of the gift/award/incentive. The loss or theft of a gift, award, or incentive must be promptly reported to the appropriate managers and Accounts Payable. Items that are lost or stolen due to negligence may become the personal expense of the responsible party.
  4. For further instructions refer to Gift, Prize, or Award Prior Approval Form.