ADMIN 080 - Gifts, Awards, And Incentives
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. De Minimis benefits are excluded under IRS Code Section 132(a)(4) and it has previously ruled that items with a value exceeding $100 could not be considered de minimis. 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
REGULATIONS
State of Idaho Controller’s Office, Idaho State Board of Examiners.
Federal Uniform Grant Guidance. See https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-E/subject-group-ECFRed1f39f9b3d4e72/section-200.475
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
- Employees 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 applicable law, as well as IRS tax rules. Examples of work related events are as follows:
- Retirement or Separation Gifts – Can be given in recognition of the employee’s service upon leaving or retiring from his/her position.
- Employee Appreciation or Recognition Awards – Can be given as an acknowledgment to an employee of work-related accomplishments. Employee recognition awards are intended to be occasional.
- 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.
- Program Incentives – CWI will reimburse or pay the costs of program incentives distributed to encourage participation in a CWI event. Cash and cash-equivalent (gift cards) are not allowed. Incentives must be approved in advance by the appropriate manager and must be for a documented business purpose.
- 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.
- Non-Employees 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 for non-employee work related events are the same as 1a-e noted above.
- 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.)
- Other Limitations:
- Cash or cash equivalent awards such as gift cards and gift certificates are not an allowable purchase for employees, including work study or other student workers. Some exceptions for student emergent situations may be granted and will require additional VP approval.
- Rush handling or express shipping fees are not allowed unless approved in advance by the Vice President of Finance.
- Certain gifts, awards, and incentives have tax implications for the recipient and additional reporting requirements for CWI. (e.g., all cash awards such as contest winnings received by employees are considered taxable and CWI will be required to report the amount as income).
- 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, or 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.
- President Approval: The President of the College has the right to grant exceptions to this policy.
- Dean or Vice President Approvals: Approvals and prior approvals must follow CWI’s policies and procedures for any of the programs referenced in this policy.
- For further instructions refer to: GiftPrizeorAwardPriorapproval.
REFERENCED
Forms and other documentation associated with this policy can be found on CWI’s internal Business Office site under Payables and Purchasing.
Referenced
Finance and Administration Policies
- ADMIN 000 - Contract Administration and Management
- ADMIN 010 - Cash Handling Policy
- ADMIN 020 - Business Ethics
- ADMIN 030 - Post-Issuance Tax Exempt Bond Compliance Policy
- ADMIN 040 - Sponsored Programs
- ADMIN 050 - Accounts Payable
- ADMIN 060 - Travel and Meeting
- ADMIN 070 - Food And Entertainment
- ADMIN 080 - Gifts, Awards, And Incentives
- ADMIN 090 - Investments
- ADMIN 100 - Procurement Policy
- ADMIN 110 - Fixed Asset Acquisition & Management
- ADMIN 120 - Debt Management Policy
- ADMIN 130 - Change Funds/Petty Cash Funds Policy
- ADMIN 140 - Audits Policy
- ADMIN 150 - Authorized Signature
- ADMIN 160 - Independent Contractors Policy
- ADMIN 170 - Purchasing Card Policy
- ADMIN 180 - Uniforms and Logo Apparel
- ADMIN 190 - Procurement of Public Works Construction