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Gift Giving Policy and Procedures

GIVING A GIFT TO UMW
If you are interested in giving a gift to UMW, please contact University Advancement.

RECEIVING GIFTS
The UMW Purchasing department is responsible for the policy that governs UMW receiving gifts from outside sources. Please see Purchasing for policies.

GIFT GIVING FROM UMW FUNDING SOURCES (both agency and non-agency funds)
Gifts are allowed to be given —AS LONG AS the reason for giving the gift supports the mission of the university and as long as UMW is in compliance with IRS and state regulations.  In order to be in compliance with IRS and Commonwealth of Virginia regulations, UMW has the following policy for giving gifts. This policy pertains to ANY gift that is provided to ANY person or entity when using UMW funds, including both agency and non-agency funds. Both the IRS and the state have VERY detailed and specific guidelines regarding gifts—and UMW will strive to be in compliance. 

Instead of implementing a policy that would simply not allow gifts to be given, the UMW administration feels that as a competitive institution of higher education, it is important and worth the administrative work to allow gifts to be given based on the details within this policy. 

IRS regulations require reporting on an individual who receives a total VALUE of $600 or more from UMW in a calendar year.  The only way to know whether an individual, in the aggregate, has received $600 or more in a calendar year is to track gifts and payments by requiring the recipient’s name, address and social security number.  The potential gift receiver can avoid providing the information by NOT accepting the gift.  Remember:  This is not a UMW or Commonwealth of Virginia regulation; it is an IRS regulation.  Please see your respective Congressperson for discussion of IRS regulations. 

Before giving any gift, use prudent and good judgment, especially consider the fact that you are spending taxpayer money.  The expense must be reasonable and must be able to sustain the test of public review.   Think about how the situation would look in the newspaper and make every effort to avoid possible embarrassment to UMW and to the Commonwealth of Virginia. 

The reason for giving the gift:

  1. MUST support the mission of the university,
  2. MUST be reasonable, and
  3. MUST be able to sustain the test of public review. (Before giving a gift, think about how the situation would look in the newspaper and make every effort to avoid possible embarrassment to UMW and to the Commonwealth of Virginia.)

THIS POLICY SPECIFICALLY PERTAINS TO A GIFT THAT IS:

  1.  A token of appreciation for participation in an event, such as for judging a poetry, writing or science contest; or 
  2. A NON-CASH award for winning a competition; or
  3. A token of appreciation for participation in an academic research project; or
  4. For door prizes at a UMW event (mainly pertains to Student Activities Office OSACS). 

THIS POLICY IS NOT TO BE USED FOR EMPLOYEE JOB PERFORMANCE RECOGNITION, including student employees.  You may NOT give a gift for employee recognition (for job performance) using this policy; contact Human Resources for information regarding employee recognition.  This policy is also NOT to be used for donations—unless the donation is the method by which the purchase of a product is made, which must be documented.

Gift cards (up to $100), gift certificates (up to $100) and physical gifts (such as a book or T-shirt) are allowed.  CASH GIFTS ARE NOT ALLOWED AND CANNOT BE GIVEN.  EXCEPTION:  A cash gift payment can be given for the purpose of paying subjects to participate in an academic research study.  Click Research Study Payment for information. Non-Employee cash AWARDS are allowed but do NOT fall under this policy.  See the title "Non-Employee Cash Awards" on the Direct Pay Table.

ALL cash payments/gifts are reportable to the IRS—regardless of dollar value.  Gift cards and gift certificates can be redeemed for cash (either directly or indirectly) and are considered the SAME AS CASH by the IRS; therefore, ALL gift cards and gift certificates are reportable—regardless of dollar value—and will be tracked and reported in accordance to IRS 1099 MISC regulations and IRS W-2 regulations.  In addition to IRS regulations, the Commonwealth requires the serial number of the gift card/certificate to be tracked with the recipient’s name, address and social security number. The gift card or gift certificate MUST have a serial number. If the card/certificate does not have a pre-printed serial number, assign sequential numbers on the cards/certificates for recording (to be in compliance with Commonwealth regulations).

The reason for giving ANY gift must be documented.  (Think about how it would look in the newspaper.)  UMW has a Gift Log Form that will serve as documentation to show:

  1.  The reason for giving the gift(s); and
  2. That the gift purchased was not kept and was not used for personal use by the purchaser or department; and
  3. That the gift was not provided to any family member or friend.  (Any exception to this certification must be documented on the Gift Log Form and approved by the area vice president.)

The purpose of the Gift Log Form is to provide information that enables UMW to be in compliance with IRS and Commonwealth of Virginia regulations and to ensure fraud has not been committed.

The Gift Log Form can be found on the Accounts Payable "Forms" page. Click AP Forms Page and scroll down to the form labeled "Gift Log Form (Non-cash)."

All physical gifts (such as a T-shirt or book) valued at $50 or more must be tracked, according to IRS regulations.  Gift cards are considered the same as cash and are reportable to the IRS—regardless of dollar value.  A name, FULL social security number and FULL address are required on the Gift Log Form for ANY gift card, ANY gift certificate, OR physical gift valued at $50 or more. If the recipient refuses to provide his/her social security number and address, the gift CANNOT be given--unless the gift is a physical gift (T-shirt or book, for example) that has a value LESS THAN $50.  If the individual physical gift is LESS THAN $50 (that’s $49.99 or LESS) only the first page of the Gift Log Form is required.  If appropriate information is not provided on the form as per IRS and state regulations, the distributor of the gift will have to “pay back” UMW the cost of the gift.  If the distributor is an employee and refuses to pay back, the funds will be withheld by Payroll.  If the distributor is a student and refuses to pay back, the charge will be applied to the student’s account. 

Gifts cannot be given to family members or friends--unless the reason for giving the gift is based on the purpose that is listed on the Gift Log Form.  The distributor of the gift will have to certify that the gifts were not given to relatives or friends and that ALL gifts were distributed, i.e., none were kept.  If there are any exceptions to either of these, the reason must be documented and approved by the appropriate vice president of the distributor.  Accounts Payable reserves the right to deny the approval through the Assistant Vice President of Finance.

 The Gift Log Form, along with a DETAILED, ITEMIZED RECEIPT, must be submitted to Accounts Payable within 30 days from the date the gift was purchased.  (REASON:  The Accounts Payable office is responsible for reporting to the IRS and therefore needs the Gift Card Logs.)  Gifts that are purchased must be distributed within 30 days from the date the gift was purchased.  Gifts should not be purchased and held for distribution at a later date.  Any exceptions must be approved by Accounts Payable IN ADVANCE.  Email payables@umw.edu IN ADVANCE and attach the response from Accounts Payable to the Gift Log Form.  (An example of an exception would be an academic research project that extends for months.) 

ALL PROCUREMENT POLICIES AND PROCEDURES MUST BE FOLLOWED.  Contact the Purchasing Department with purchasing questions.  You may use the following methods to purchase gifts:

Department Credit Card (the SPCC) 
The SPCC can be used to purchase gift cards/gift certificates/physical gifts (such as a book or T-shirt).  (Use account code 71412G.) The ORIGINAL Gift Log Form must be attached to the credit card log when the gifts were purchased.  A COPY of the Gift Log Form must be sent to Accounts Payable, along with a COPY of the DETAILED, ITEMIZED RECEIPT.  The original receipt and original Gift Log Form MUST be attached to the departmental credit card log.  (REASON:  SPCC log must have original paperwork, such as receipt. The Accounts Payable office is responsible for reporting to the IRS and therefore needs a copy of the Gift Card Log and receipt .) 

Reimbursement
The employee or student can purchase gifts for reimbursement but MUST follow UMW Procurement policies.  Follow the reimbursement procedures found at http://www.umw.edu/ap/reimbursements/default.php.  In addition to a DETAILED, ITEMIZED receipt, the completed Gift Card Log must be attached.

National City VISA (held by certain individuals at UMW—OSACS and Athletics)
The National City VISA can be used to purchase gift cards/gift certificates/physical gifts (such as a book or T-shirt). (Use account code 71412G.) All procurement policies and procedures must be followed.  The ORIGINAL Gift Log Form, along with the ORIGINAL, DETAILED, ITEMIZED RECEIPT must be attached to the National City credit card log where the gifts were purchased.  Accounts Payable will get the original Gift Card Log and receipt that are attached to the National City credit card log when the credit card log is sent to Accounts Payable at the end of every month.  If the gift is purchased near the end of the month and the gifts have not been distributed by the end of the month when the National City credit card is sent to Accounts Payable, the original Gift Log Form should be HAND-DELIVERED to Accounts Payable in Centre Court, Suite 104 within 30 days from the date the gift was purchased.

Contact Accounts Payable at payables@umw.edu or 654-1226 with questions.