Gift cards, regardless of the value, are considered cash equivalents by the Internal Revenue Service (IRS) and are subject to tax reporting. As gift cards are a high business audit risk, the District seeks to minimize the purchase and distribution of gift cards and associated risks. Programs distributing gift cards are responsible for compliance with IRS regulations, this gift card policy, and other District policies. This is the first known gift card policy for the District.
Aims of proposed policy (Exhibit A):
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Establish limits on individual gift card value
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Establish approved purposes for gift card purchase and use
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Establish chain of custody records management.
Legal review was completed by Weed, Graafstra & Associates, INC., P.S. on September 8 with minor comments. Procedures are under development consistent with this proposed policy.
The Program Policy Committee reviewed the draft policy at their Sept. 17 meeting and moved it to the Administration and Executive Committees at their next meetings for potential action.
The Administration Committee moved the item forward to the Board for consent; however, the Executive Committee recommended it move to the full Board for action.