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ROWAN UNIVERSITY POLICY

Title: Gift Card Policy
Subject: Finance
Policy No: FIN:2020:01
Applies: University-wide
Issuing Authority: President
Responsible Officer: Senior Vice President for Finance and CFO
Adopted: 10/01/2020
Last

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Revised:

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11/

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2023
Last Reviewed:

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11/

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27/

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2023

I.    PURPOSE

To establish guidelines for the procurement, distribution, accounting, and reconciliation of gift cards to meet the needs of the University community while facilitating the University’s tax compliance reporting and internal cash control requirements.  The purchase and use of such items requires strict accountability – gift cards may only be used for prizes and awards or to compensate human subject research participants.

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1. 1. The University pays business expenses by using appropriate Procurement methods (refer to the procurement and accounts payable policies listed in section V. References).  Gift Cards may not be used to pay vendors or research collaborators for goods and/or services received and/or rendered or pay any type of wages for services rendered. For example gift cards may not be used to pay University suppliers, independent contractors, guest speakers, consultants, honorariums or stipends at any time.  As such, gift cards should only be used as stated in this policy.
   2. Employees may not be reimbursed for out-of-pocket purchase of gift cards. 
   3. University places strict restrictions concerning the purchase and distribution of gift cards. Therefore, gift cards may only be allowed in situations where it is determined that the expenditures are in the best interest of the University and promote the overall mission of the University. For example, gift cards may be utilized:
      1. As an incentive to encourage participation in Rowan University research studies, as authorized by the IRB.
      2. Prizes or awards, with prior approval from the requestor’s Dean or AVP.
   4. The determination of whether a gift card is an allowable prize or award is dependent upon the selection of the recipient, the reason for the distribution and the recipient’s affiliation to Rowan University. For example:
      1. Gift cards/gift certificates may not be purchased with university funds for the purpose of giving an employee or student worker compensation for work or education-related activities (e.g. gift, bonus, incentive, reward, expression of recognition, special occasion, social function or meals) outside of participation in IRB-sanctioned research.
      2. When the incentive to encourage participation involves enrolled students, the department should utilize the RowanCard system instead of a gift card when feasible.
   5. The University must comply with Internal Revenue Service (IRS) regulations as it pertains to gift cards and gift certificates at all times. Under Internal Revenue Code Section 132, a gift card, gift certificate, store-value card, or a prepaid credit card, collectively referred to as a gift card, is considered a cash or cash equivalent that is subject to taxes regardless of the face value.  The value of gift cards given to non-employees is taxable and reportable income on IRS form 1099 if the value of gift cards plus any other non-W2 compensation received by an individual from the University as a whole aggregates to an amount of $600.00 or more per calendar year. If an employee or student worker participates in IRB-sanctioned research, the value of the gift card distributed will be added to their W-2 for tax reporting purposes. As such, pertinent information must be collected from the recipient (recipient’s full name, TIN, address) prior to distribution of the gift card. The Gift Card Request must be completed and submitted to giftcards@rowan.edu.
   6. Any and all collection of an individual’s social security number/TIN by the custodian/study coordinator is kept secure. Physical information is kept locked in a cabinet with access restricted to the custodian/study coordinator. Electronic information is stored on a secured server and is not stored nor maintained on a local desktop, laptop or other electronic device.
   7. Gift card face values are limited to the denominations authorized by an approved IRB study, or $100.00 per card for gift cards procured for gifts or awards outside of the IRB approval process. Payment must be made by Accounts Payable via Banner for amounts greater than $100.00 per participant.
   8. Principal Investigators are responsible for ensuring that human subject research participant payments are being processed through the ClinCard system and managed according to this policy.
   9. Principal Investigators are responsible for ensuring that human subject research participant payments are being processed through the ClinCard system and managed according to this policy.
   10. The authorized Gift Card Request Form must be submitted to giftcards@rowan.edu The authorized Gift Card Request Form must be submitted to giftcards@rowan.edu at least two weeks prior to the requested gift card delivery date.
   11. All gift cards are to be distributed within a reasonable time once received:
       1. Gift cards procured as allowed by an IRB-sanctioned research study, unless pre-authorized by Finance.
       2. One month for gift cards procured for gifts or awards outside of the IRB approval process.
   12. Failure to follow this policy and procedure and to maintain appropriate supporting documentation can result in the suspension of the privilege to procure and distribute gift cards.
   13. Rowan University may terminate the use of gift cards at any time. Termination of the use of gift cards may result from, but is not limited to: abuse, failure to follow the policy and guidelines, use of gift card funds for personal reasons, or lack of funding.
2. Tax Limitations for Gift Cards:
   In order to ensure University compliance with the laws and regulations requiring tax reporting for certain payments to individuals, the following rules must be followed when distributing gift cards:
   1. If the employee or student worker participates in IRB-sanctioned research, the value of the gift card will be added to their W-2 for tax reporting purposes.
   2. The value of gift cards given to non-employees is taxable and reportable income on IRS form 1099 if the value of gift cards plus any other non-W2 compensation received by an individual from the University as a whole aggregates to an amount of $600.00 or more per calendar year.
   3. Gift cards, regardless of value, may not be given to anyone considered a non-U.S. person for tax purposes.
   4. A waiver of tax compliance obligations (collecting names, TINS, and addresses) may be pre-authorized by General Counsel with a formal request made only from Finance in rare instances where the study is based on populations in which there is no reasonable collectability of this required information – i.e., homeless populations, undocumented immigrants, adults with severe intellectual disabilities. This waiver authorization is dependent on the targeted population of the study, the limited dollar amount of the compensation associated with the study, the ability to exclude University employees or students, and must be requested four weeks in advance to allow for multiple levels of review and authorization. This waiver will not be granted retroactively.
3. Authorized Method for Purchasing Gift Cards:
   Only the following gift card purchasing option is available upon approval of the Gift Card Request Form. ClinCard is the University’s preferred method of purchasing gift cards. All other gift card purchasing methods will be reviewed to determine if ClinCard is more suitable.
   1. ClinCard
      1. ClinCard – The University has partnered with ClinCard in order to facilitate a secure electronic method of collecting participant information and distributing payments. The ClinCard payment mechanism provides prompt and efficient payment to individuals once approved by Finance. Approved payment can be immediately accessed by the recipient to be used as a pre-loaded electronic (virtual) Visa card or Visa card (physical). By centralizing the recipient payment through ClinCard, the University can streamline its processes in order to operate in compliance with Internal Revenue Service (IRS) reporting regulations. Additionally, the ClinCard system will increase security and decrease liability to both the University community and recipients by eliminating the use of the paper-based process. Furthermore, ClinCard is the University’s preferred method of purchasing gift cards.
         Note: See Attachment 2 for procedures.
   2. Please note, the required authorization on the gift card request form is as follows:
      1. IRB sanctioned studies will require documentation of the IRB sanctioned study noting the approval of the study.
      2. Gift cards purchased with external grants will require authorization from the Grants and Contracts Accounting Director noting the allowability of the expense against the grant funds.
      3. Gift cards purchased outside of external grants require the authorization of the requestor’s Dean or AVP.
      4. The Gift Card Request Form will require final authorization by the Finance Division.
4. Non-Allowable Gift Card Purchases:
   The following gift card expenditures are prohibited:
   1. Gift cards/gift certificates may not be purchased with university funds for the purpose of giving an employee or student worker compensation for work or education-related activities (e.g. gift, bonus, incentive, reward, expression of recognition, special occasion, social function or meals).Gift cards/gift certificates may not exceed the denominations authorized by an approved IRB study, or $100.00 for gift cards procured for prizes or awards outside of the approval process. Payment must be made by Accounts Payable via Banner for amounts greater than $100.00 per participant.function or meals).
   2. Gift cards may not be used to incentivize participants in human subject research studies unless pre-authorized by the IRB.
   3. Gift Cards may not be purchased through the University’s Barnes and Noble account.
   4. Gift cards may not be purchased using the University’s Procurement Card system.
   5. Employees may not be reimbursed for out-of-pocket purchase of gift cards. Reimbursement for out-of-pocket gift card purchases may be denied if proper justification and approval by one of the following: Provost, Sr. Vice President and CFO, Sr. Vice President or appropriate Divisional Vice President were not obtained in advance. 
   6. Gift Cards may not be used to pay vendors for goods and/or services received and/or rendered or pay any type of wages for services rendered. For example, gift cards may not be used to pay University suppliers, independent contractors, guest speakers, consultants, honorariums or stipends at any time.
   7. Gift cards may not be purchased as gifts to graduating students.
   8. Gift cards may not be used to compensate collaborators in a research study.

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1. Gift Card Request Form
1. Study Coordinator completes request form
2. One form must be completed per study
3. All sections of the form must be completed
4. Ensure funding is available and all ClinCard fees are included. For example, ClinCard charges a fee per card and a fee to load each participant payment
5. All approvals are required. Each approver is certifying that they are in agreement with the request, knowledgeable and compliant with university policies and regulations
6. Attach IRB documentation and authorization to the request form
7. Email the request form and all documentation to giftcards@rowan.edu
2. ClinCard Administrator
   1. Creating the study
   2. Maintaining Milestone Payment Schedule
   3. Add User (Study Coordinator)
   4. Add Study Coordinator to the new study
   5. Send User (Study Coordinator) logins
1. The Administrator is responsible for managing the ClinCard portal which will include managing the ClinCard system access and establishing all new studies within the ClinCard system. The Administrator will also maintain, track, and safe-guard an inventory of Visa cards (ClinCards).
2. Monitor the gift card inbox and review the requests
3. Audit Gift Card Request Form, documentation and ensure all documentation is in compliance with the gift card policy and guidelines
4. If request is approved, the Administrator will provide access to ClinCard by:
1. Creating the study
2. Maintaining Milestone Payment Schedule
3. Add User (Study Coordinator)
4. Add Study Coordinator to the new study
5. Send User (Study Coordinator) logins
5. provide access to ClinCard by:
6. Administrator contacts Study Coordinator via email for electronic or physical gift card distribution.
7. Final authorization is completed upon the Study Coordinator acceptance of the gift cards from the Administrator.
3. Study Coordinator
4. Study Coordinator is the individual responsible for safeguarding, disbursing and tracking the distribution of their gift cards in accordance with the University policies and procedures.
1. of the gift cards from the Administrator.
Once the Administrator provides access to ClinCard and the requested gift cards, the Study Coordinator can now begin the research:
5. Study Coordinator
6. 1. Access the ClinCard system using SSO, go.rowan.edu/clincard
   2. Verify the approved study and additional Study Coordinator is in the system
   3. Search the system for existing participants, if participant is not available;
   4. Register the study participant’s information into the system
   5. Monitor the research study
   6. Assign a ClinCard to study participants
   7. Can utilize the Gift Card Payment Acknowledgment Form when distributing ClinCards
   8. Disburse payments to a participant by requesting a milestone payment according to the research schedule
   9. Continue to disburse payment to research participant based on study guidelines 
   10. Informing the participant on usage and access of the ClinCard and its portal
1. Study Coordinator is the individual responsible for safeguarding, disbursing and tracking the distribution of their gift cards in accordance with the University policies and procedures.
2. Once the Administrator provides access to ClinCard and the requested gift cards, the Study Coordinator can now begin the research:
3. Study Coordinator will reconcile the gift cards against the study. The Gift Card Recipient Log may be used to assist with the reconciliation of cards issued versus un-issued cards.
4. When a study has been completed, the Study Coordinator must notify the ClinCard Administrator via email at giftcards@rowan.edu. The notification should indicate the remaining balance of ClinCards on hand at the end of the study and confirm no additional cards will be issued.
5. Return un-issued ClinCards to ClinCard Administrator by emailing giftcards@rowan.edu, include the number of un-issued cards, total remaining balance and attach a copy of the approved Gift Card Request Form.
7. ClinCard Administrator
1. Administrator will coordinate the returning of un-issued cards.
2. Provide the information to Accounting Services to facilitate a credit back into the funding account specified on the Gift Card Request Form.
3. Responsible for downloading the payment data from the ClinCard portal, assist with providing corresponding ledger entries in Banner, and maintaining a sufficient balance within the ClinCard pre-paid balance sheet account to accommodate the collective outflow of participant payments.
4. Responsible for the issuance of IRS Form 1099-MISC to participants when their total compensation is $600.00 or more per calendar year.
5. Employees and student workers who participated in a study and qualify for a gift card will have the value added to their W-2 through the Payroll department.                                                             

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