Memorandum #219 Gift Card Policy

Effective : January 3, 2018
Date of Issue: December 12, 2017

Purpose

The purpose of this Policy is to set forth the guidelines and procedures for the purchase, use, distribution, and secured storage of gift cards and/or gift certificates purchased with College funds, grant funds, Community College of Philadelphia Foundation (“Foundation”) funds, and/or donated to the College to ensure compliance with the College’s tax withholding and reporting obligations. 

Scope of Policy

This policy applies to all College faculty, employees, students, volunteers, and third parties.  This policy applies to the purchase, use, and distribution of gift cards/certificates that are purchased using College funds, grant funds, Foundation funds, or that are donated to the College.

Prohibited Uses

Distribution of gift cards/certificates within the scope of this policy is prohibited in the following circumstances:

• Gift cards/certificates may not be distributed to volunteers as appreciation for volunteer work, regardless of whether the volunteer is a student, employee, or a third party.
• Gift cards/certificates may not be distributed as compensation for services performed (i.e., by students, employees, or independent contractors).
• Student workers may not be given gift cards/certificates for work-related activities, or for any reason related to their employment with the College.

Tax Treatment

Gift card/certificate recipients will be required to sign an acceptance form acknowledging the potential tax implications of accepting the gift card/certificate.

Employees

Gift cards/certificates distributed to employees, regardless of value, are subject to federal, state and employment tax withholding, and will be reported as wages on the employee’s Form W-2.

Non-employees

If the total value of gift cards/certificates provided to non-employees in a calendar year exceeds $600, the individual will receive a Form 1099-MISC.   

Nonresident Aliens

Gift cards/certificates distributed to nonresident aliens may be subject to federal tax withholding. Nonresident aliens who receive a gift card/certificate must contact the Controller’s Office at (215) 751-8827 or .

Gift Card Purchasing and Distribution Procedures

College employees are only permitted to distribute gift cards/certificates covered by this policy if they follow the procedures below. 

• Any employee who wishes to purchase gift cards/certificates must submit an Authorization to Purchase and Use Gift Cards/Certificates Form (Appendix A) for approval to the appropriate Dean, Senior Administrator, Associate Vice President, or Vice President, as applicable, before making the purchase and/or distributing the gift cards/certificates.
• Individual gift cards/certificates may not exceed $100 in value, and a total gift card/certificate purchase may not exceed $2,000.  Exceptions must be approved by the Vice President of Business and Finance.
• An employee who has obtained the appropriate approval for the purchase and use of gift cards/certificates must maintain a Gift Card/Certificate Disbursement Log (Appendix B) to record the disbursement of the gift cards/certificates.  The employee distributing the gift cards/certificates will be responsible for updating the log each time a gift card/certificate is dispersed.
• The department must obtain executed Gift Card/Certificate Acceptance Agreements (Appendix C) for each gift card/certificate recipient. 
  • Note: if gift cards/certificates are being distributed to students as a financial aid resource, the student should complete the Gift Card/Certificate Acceptance as Financial Aid Form (Appendix D), not the Acceptance Agreement in Appendix C. 
• A copy of the complete Disbursement Log, Authorization Form, and Acceptance Agreements must be submitted to the Controller’s office, along with a copy of the proof of purchase.
• No department will be permitted to purchase gift cards/certificates if the department has outstanding issues with prior gift card/certificate purchases (i.e., prior gift cards/certificates are unaccounted for) until those issues are resolved with the Controller’s Office.
• All gift cards/certificates must be stored in a College safe until needed for distribution.  Any unused gift cards, or those not distributed as expected, must be returned to one of these departments for safekeeping.  Safes are located in the Controller’s Office and in the Foundation Office.  No other storage will be permitted.
• Gift card/certificate purchases and related logs and documentation will be subject to periodic audits by the Controller’s Office, the College’s Internal Auditor, and the public accounting firm retained for the annual audit of the College’s financial statements.
• Missing gift cards/certificates must be reported immediately to the Vice President of Business and Finance, and to the College’s Internal Auditor.

Policy Violations

Violation of this policy, including misappropriation or misuse of gift cards/certificates will be subject to the applicable disciplinary process, up to and including expulsion or termination.

AUTHORIZATION FOR THE PURCHASE OF GIFT CARDS/CERTIFICATES
GIFT CARD/CERTIFICATE DISBURSEMENT LOG
GIFT CARD/CERTIFICATE ACCEPTANCE AGREEMENT
ACCEPTANCE OF GIFT CARD/CERTIFICATE AS A FINANCIAL AID RESOURCE