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Gift Giving Policies 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 employees receiving gifts from outside sources. Please see Purchasing for policies.

GIVING A GIFT FROM UMW FUNDING SOURCES
This policy pertains to ANY gift provided to ANY person or entity when using UMW funds. UMW funding sources include both agency and non-agency funds as well as grant money awarded from both University and non-University sources. You should assume that this policy applies to your funding source unless specifically told otherwise by Accounts Payable.

Gifts are allowed to be given ONLY IF:

  • The reason for giving the gift supports the mission of the university
  • UMW is in compliance with IRS and Commonwealth of Virginia regulations

The IRS and the Commonwealth have very detailed, specific guidelines regarding gifts. 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 detailed policy below.

REASON FOR GIVING THE GIFT

Before giving any gift, use prudent judgment and especially consider the fact that you are spending taxpayer money. All gifts:

  • Must support the mission of the University
  • Must be reasonable, and
  • Must be able to sustain the test of public review (think about how it would look in the newspaper)

Appropriate reasons for giving a gift include:

  • A token of appreciation for participation in an event (i.e., judging a contest, jurying an exhibition, etc.)
  • A non-cash award for winning a competition
  • A token of appreciation for participation in an academic research project
  • A door prize at a UMW event (primarily pertains to OSACS events)

Inappropriate reasons for giving a gift include, but are not limited to:

  • Employee job performance recognition, including student employees (see Human Resources for employee recognition programs.)

FORMS OF GIFTS

The following types of gifts are allowed:

  • Gift cards (up to $100)
  • Gift certificates (up to $100)
  • Physical gifts (i.e., book, T-shirt)

The following types of gifts are not allowed:

  • Gifts of cash
    NOTE: A cash PAYMENT may be made for the purpose of paying a subject to participate in an academic research study (see Research Participant Payment).
    NOTE: Non-employee cash AWARDS are allowed only as defined on the Direct Pay Table.
  • Donations (unless the donation is the method by which the purchase of a product is made, which must be documented.)

PROPER DOCUMENTATION AND REPORTING OF THE GIFT

To ensure and demonstrate to the IRS and the Commonwealth that UMW is striving to be in compliance and that fraud has not been committed, UMW has developed a Gift Log form to document the following:

  • The reason for giving the gift
  • That the gift purchased was not kept and was not used for personal gain by the purchaser or department
  • That the gift was not provided to a family member or friend (see "Gifts cannot be given to family members or friends unless..." below for EXCEPTION)

Click on Forms to access the Gift Log form. The ONLY exception to completing the Gift Log is where the gift itself was donated to UMW, whereby UMW did not expend any money to obtain the items being given away.

IRS regulations require reporting of any individual who receives a total VALUE of $600 or more from UMW in a calendar year. The only way to know when an individual--in the aggregate--has reached this total is to track gifts and payments by requiring the recipient’s name, address and social security number. The potential recipient can avoid providing this information only by NOT accepting the gift.

  • All cash payments/gifts (including gift cards/certificates) are reportable to the IRS, regardless of dollar value. Since gift cards/certificates may be redeemed for cash (either directly or indirectly), the IRS considers these the same as cash, making all gift cards/certificates reportable under 1099-MISC and W-2 regulations. In addition, the Commonwealth of Virginia requires the serial number of each gift card/certificate to be tracked along with the recipient’s name, address and social security number. For gift cards/certificates that do not have a pre-printed serial number, the gift giver must assign sequential numbers to the cards/certificates for recording on the Gift Log.
  • All physical gifts valued at $50 or more must be tracked according to IRS regulations and must be included on the Gift Log just as the gift cards/certificates. If the individual physical gift is valued at $49.99 or less, only the first page of the Gift Log is required, thereby avoiding the need for the social security number and address of the recipient.
  • Gifts cannot be given to family members or friends unless the reason for giving the gift is based on the purpose listed on the Gift Log Form.  The distributor of the gift must certify that ALL gifts were distributed for the purposes listed on the Gift Log Form. Distribution of gifts to family members or friends must be disclosed and then approved by the appropriate Vice President of the distributor.  Note: Accounts Payable reserves the right to deny the approval through the Assistant Vice President for Finance.
  • Gifts must be distributed within 15 days of the date the gift was purchased.  Gifts should not be purchased and held for distribution at a later date.  Any potential exceptions (such as a research project which extends for months) 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.
  • The completed Gift Log, along with DETAILED, ITEMIZED RECEIPTS, must be submitted to Accounts Payable within 15 days of the date the gift was purchased.  (REASON:  The Accounts Payable office is responsible for reporting to the IRS and Payroll. Commonwealth Payroll regulations require timely reporting of gifts received. If Payroll receives gift information late, UMW could owe for both the employee and employer portion of the FICA tax if the employee leaves before the gift is properly recorded.) 

Remember: A name, full social security number and full address are required on the Gift Log for any recipient of a physical gift valued at $50 or more, a gift card, or a gift certificate. If the recipient of one of these gifts refuses to provide his/her information, the gift CANNOT be given. If appropriate information is not provided on the Gift Log, the distributor of the gift will have to reimburse UMW for the cost of the gift.

Note: If the distributor is an employee who refuses to pay back the cost of the gift, the funds will be withheld by Payroll. If the distributor is a student who refuses to pay back the cost of the gift, the charge will be applied to the student’s account.

PROPER PROCUREMENT OF GIFTS

All procurement policies and procedures must be followed. (Contact the Purchasing Department for assistance.)

Use the following account codes:

  • 71412G for physical gifts valued at $50 or more
  • 71412G for all gift cards or gift certificates--regardless of dollar value
  • 71412 for physical gifts valued at $49.99 or less

The following payment methods may be used for gifts:

Small Purchase Credit Card (SPCC) - Preferred payment method which should be used to procure gifts whenever possible. Attach the original Gift Log and detailed, itemized receipts to the SPCC log. Send a copy of the completed Gift Log and copies of the receipts to Accounts Payable within 15 days of the date the gift was purchased.

Reimbursement - An employee or student may purchase gifts (following all UMW procurement policies) and request reimbursement for the expense if a UMW purchasing tool is not available. See Reimbursements for procedures. Attach original, detailed, itemized receipts and the completed Gift Log to the reimbursement request.

UMW Finance Card - May be used to procure gifts only when the SPCC cannot be used. (The SPCC cannot be used when items are charged to 8 funds; use this UMW Finance Card when items are charged to 8 Funds.) The UMW Finance Card may NOT be used to give cash gifts. The original Gift Log and original, detailed, itemized receipts must be attached to the UMW Finance Card log on which the gifts were purchased.  Accounts Payable will receive the original Gift Log and receipts that are attached to the UMW Finance Card log when it is sent to Accounts Payable at the end of every month.  If the gift is purchased near the end of the billing cycle and the gifts have not been distributed by the time the UMW Finance Card log is sent to Accounts Payable, the original Gift Log should be HAND-DELIVERED to Accounts Payable in Centre Court, Suite 104 within 15 days from the date the gift was purchased.

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

Please remember that UMW is trying to comply with IRS regulations. Please contact your respective Congressperson for a discussion of IRS regulations.