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Scope

This policy outlines the process for authorization, documentation, and physical security over Gift Cards.

Reason for Policy

To ensure proper controls are in place for the appropriate authorization, documentation, and safe keeping of Gift Cards.

Policy Statement

Gift Card purchases are allowed to the extent they are governed by an established program and the expense is reasonable and necessary to carry out the mission of the University. Gift Cards may only be purchased, received, and distributed through an established program.  The use of Gift Cards outside of the below programs is prohibited unless approved by the campus accounting office.

• Employee awards
• Payments to research subjects
• Awards and prizes

Gift Card purchases must be approved by the Program Administrator with a purchase plan.  All Gift Card purchases will be routed and fulfilled through the Show-Me Shop or made through a campus bookstore.  Gift Cards may not be purchased by any other method, unless approved by Supply Chain (in advance of the purchase).  Each program will maintain up to a maximum Gift Card inventory sufficient to fund a 60 day cycle of payments or $500, whichever is greater.  When purchasing through a campus bookstore, documentation must be provided to the bookstore of the approved Gift Card program.  The campus accounting office shall be notified of any purchases of Gift Cards on a Gift Card program.

Each program maintaining cards should designate a Gift Card Custodian responsible for the card’s safekeeping.  Cards should be treated as cash, and kept in a locked and secure location until they are distributed.  The Custodian should only distribute cards upon request of the Program Administrator for within the guidelines established for the applicable program. 

A separate person from the Program Administrator and card Custodian should keep a record of all card purchases and distributions by individual card.  The log should have a separate line for each card.  Once purchased and received, the cards should be logged with the following information:

• Date received or purchased
• Vendor
• Amount of card
• Card serial number or other unique identifying number

If the Gift Cards are mailed to the recipient, the Record Keeper and Custodian (separate individuals) should verify the card is mailed to the proper address for the recipient. 

Once distributed, the following information should be logged for employees:

• Employee ID
• Name
• Dollar amount of card
• Date of distribution
• Card serial number or other unique identifying number

Upon distribution, the following should be logged for non-employees (unless confidentiality is required): 

• Tax ID number
• Name of Recipient
• Permanent Mailing Address
• Date of distribution
• Dollar amount of card

An exception is made for confidential payments.  The confidentiality exception only applies to Institutional Research and Planning (IRB) approved programs where confidentiality is necessary for the study, and the total value of the Gift Card must be below the IRS reportable income, which is currently set at $600.  Exceptions are only granted by the campus accounting office.  Upon distribution of Gift Cards given for confidential research, the following should be logged:

• An assigned unique identifying number for the participant
• Date of distribution
• Dollar amount of card

The Gift Card Log & Receipts Form can be used to assist with the documentation requirements.  All logs should follow University security policy related to retention of Tax ID number and other private information.  On a monthly or more frequent basis, the list of Gift Cards given to employees should be sent to the central payroll office or ¾ÅÉ«ÊÓƵ Health Care payroll office, as appropriate, so the appropriate earnings and payroll taxes can be recorded.  On a quarterly or more frequent basis, the list of Gift Cards given to non-employees should be provided to the AP Shared Services.  If the amount of Gift Cards issued to a single payee is $600 or greater, an IRS Form 1099 will be issued. 

For non-confidential IRB studies, the requirement to report payments to non-employees along with the detailed logs may be waived by the campus accounting office.  The department is still responsible for maintaining logs to prove the number of cards distributed matches the number of participants in the IRB approved study.

At a minimum of a monthly basis, an individual separate from the Record Keeper and card Custodian must perform an inventory of the current cards on hand and compare to the log.  At least once per year, a surprise review of the log and inventory must be performed by the Program Administrator.  Any discrepancies between the log and actual card inventory must be resolved with the Program Administrator.  This reconciliation should follow the purchase of the cards to the distribution, and ensure the completeness and accuracy of the log and the current card inventory.  The reviewer must sign or otherwise authenticate the log as evidence of review. 

Definitions

Gift Card - Gift Cards and gift certificates redeemable for a stated dollar value at a retailer or bank.

Program Administrator - individual responsible for overseeing a Gift Card granting program at the department-level.  Responsible for authorizing transactions (purchases and distributions of cards) within program guidelines.  Administrator must be separate from Custodian and Record Keeper.

Custodian - individual responsible for the safekeeping of the Gift Cards.  Ensures Gift Cards are appropriately stored and distributed to proper individuals.  Custodian must be separate from Administrator and Record Keeper.

Record Keeper - individual responsible for maintaining records of card purchases, inventory, and distributions in compliance with this policy.  Record Keeper must be separate from Administrator and Custodian.

Reviewer – individual responsible for performing a monthly comparison of the actual Gift Card inventory to the log maintained by the Record Keeper and documenting evidence of that review.

Accountabilities

UM System:

• Supply Chain is responsible for granting exceptions for the purchasing of Gift Cards
• Central Payroll will record earnings and payroll taxes for Gift Cards given to employees

Campus Accounting Offices:

• Review all Gift Card program purchase plans for approval
• Monitor the Gift Card program
• Grant exceptions to the program if determined necessary
• Provide the appropriate payroll office with a list of Gift Cards given to employees at least monthly

Program Administrator:

• Review log and inventory at least annually
• Approve Gift Card program purchases and distributions

Record Keeper:

• Maintain inventory of cards purchased
• Maintain a log of cards distributed and on hand

Custodian:

• Ensure safekeeping of all Gift Cards
• Properly distribute Gift Cards to recipients approved by Program Administrator

Reviewer:

• Audit the inventory of cards distributed and on hand and compare to the Record Keepers log 
• Report Discrepancies to the Program Administrator
   

Additional Details

Forms

Gift Card Log and Receipts UM 100: www.umsystem.edu/ums/fa/management/records/forms/finance/

Related Information

Contact UM Supply Chain for more information regarding purchasing Gift Cards from the Show-Me Shop: www.umsystem.edu/ums/fa/procurement

Policy 22307 on Awards, Gifts & Prizes
Policy 25701 on Cash Security

History

Formerly Business Policy Manual 220 – Gift Card Policy (12/15/2015)

Procedure