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Incentive Cards
Policy
Effective: January 1, 2014
Revised: May 14, 2024- Overview
Incentive cards may be used as a tool to meet the business purposes of the University. They can be used to support research study subjects and for awards or prizes to support student activities. As cash-equivalent instruments, incentive cards are governed by internal control requirements and may be subject to tax reporting. They must be distributed in accordance with the guidelines set forth in this policy. - Policy General
Incentive cards must be purchased through buyWay$ from the Blackhawk Network. (Exemptions may be available in situations in which external funding predated this policy or required purchases cannot be accommodated by the Blackhawk Network.) Personal reimbursements and direct purchases outside of the established buyWay$ process are not allowed. Incentive cards must only be requested when disbursement of such funds is expected to occur within 90 days from the time the cards are received. If the project or need to distribute continues beyond that time frame, multiple incentive requests must be made to provide for a reasonable and timely accounting of funds.- Research Subjects: An incentive may be offered to research subjects, provided it was included as part of the grant award and Institutional Review Board (IRB) approval was obtained. This policy is intended to provide guidance as to the appropriate acquisition and distribution of research subject incentives.
- Non-Research Subjects: It is also common, based on the specific mission and goals of specific areas of the University, to utilize incentives to encourage or award individuals for participating in certain events. Unlike with research subjects, these incentives are not bound by grant awards and IRB approval. This policy is intended to provide guidance as to the appropriate acquisition and distribution of non-research subject incentives.
III. Allowable Uses and Limits
Incentive cards may only be distributed for the following purposes:- Incentive for research subjects in studies approved by the University’s Institutional Review Board (IRB).
- Prizes, recognition awards or tokens of appreciation for students.
- Prizes, recognition awards or honorarium for volunteers or visitors.
- Incentive for employees participating as a volunteer in a research study or event unrelated to their job.
Individual incentive cards should be valued at $100 or less. They cannot be used as a bonus, awards, honoraria or other means of compensation to employees. These payments must be processed through the payroll system. If there is any question about a particular situation, please consult with the Office of Human Resources.
Ensuring proper controls is important in the use of incentive cards, and IRS reporting is critical in compliance with IRS and federal reporting requirements. For any individual that is disbursed $600 or more in a calendar year, the department’s responsible person must follow the steps identified in section E.2 of the Related Procedure to ensure the proper tax treatment is performed by Clemson University.
IV. Internal Controls
Incentive cards must be safeguarded at all times and accounted for as if they were cash. The person accountable has primary responsibility for safekeeping, maintenance and proper usage and for advising faculty, staff or students of proper handling policy and procedure. For grants, the principal investigator (PI) must maintain all records regarding the research subjects.The following controls are required at a minimum:
- Custody: The person accountable holds custody over the cards and should always know where they are located. Custody may be transferred temporarily from the person accountable to other departmental personnel for disbursement purposes, but the person accountable still holds primary responsibility for the safekeeping of the cards.
- Physical Access: Incentive cards must be secured at all times (e.g., in a locked box in a locked cabinet or drawer) with limited access. They must not be taken home for safekeeping.
V. Lost Cards
- The person accountable will be held liable for any incentive cards in their possession that are lost or misplaced. Any shortage must be reported immediately to their business officer. The business officer will then notify the Office of Internal Auditing. Depending on the circumstances, punitive action, including loss of ordering privileges, termination and prosecution could result.
VI. Definitions
- Incentive card: A stored-value or similar instrument issued in lieu of cash or check. For purposes of this policy, “incentive card” includes gift certificates, cash cards, and online e-incentive cards (e-cards).
- Person accountable: The faculty or staff member in the department disbursing the incentive cards that is responsible for the documentation, internal control and other requirements of this policy. For research purposes, the person accountable is the principal investigator (PI).
- Research subject: An individual with whom an investigator conducts research and obtains data through intervention or interaction with the individual.
V. Contact Information
Safekeeping of Cards: Cash and Treasury Services
Order Cards and Tax Reporting: Procurement and Business ServicesResearch Reporting: Internal Review BoardProcedure
A. General Procedure
Incentive cards must be purchased through buyWay$ from the Blackhawk Network. (Exemptions may be available in situations in which external funding predated this policy or required purchases cannot be accommodated by the Blackhawk Network.)Advanced planning by the person accountable is necessary to ensure that no more than a 90-day card supply should be ordered. If the project continues beyond that time frame, multiple incentive requests must be made to provide for a reasonable and timely accounting of funds. Accountability for the cards will be required by providing a list of recipients or research subjects within a 90-day period.
Unused incentive cards cannot be returned to the supplier. The person accountable should contact their business officer if there are any remaining cards left over at the end of the project. If charged to a sponsored project (Fund 20), the business officer will process a journal to move the expenditure off the project and to a college/departmental chart field string for appropriate documented use. Departments must maintain internal controls over the cards and continue to document their use until they have all been expended.B. Incentive Card Procedure
- Research Subject Incentive Card Request
The following items are required to be included as an internal attachment to the buyWay$ requisition to successfully place an incentive card order. A person accountable must sign all forms submitted.- Incentive Card Statement of Responsibility Form (with budget justification)
- IRB approval letter
To allow time for shipping, cards should be ordered three to four business days before they are needed. The appropriate account code to use for research incentive cards on most sponsored research projects is 7312 (Incentive Cards). In cases where projects have participant support costs (PARTSP) specifically budgeted for research participants, the account code is 7550 (Part Supp Incentive Cards). If you are unsure of which account code to use, please check with your college post-award contact.
- Non-Research Subject Incentive Card Request
The following item is required to be included as an internal attachment to the buyWay$ requisition to successfully place an incentive card order. A person accountable must sign all forms submitted.
To allow time for shipping, incentive cards should be ordered three to four business days before they are needed. The appropriate account code to use for non-research incentive cards is 7312.
C. Incentive Card Restrictions
Clemson University has established certain restrictions as to the use of incentive cards.
- Under no circumstances are research incentive cards to be purchased for a purpose other than paying research subjects participating in an approved study outlined in the IRB approval letter.
- An employee is not allowed to receive incentive cards for research incentive participation related to their job.
- Incentive cards are not returnable to the supplier. All sales are final.
- Incentive cards should not be acquired for the purpose of making routine purchases for business needs
D. Subject Payment
E. Tax Reporting
An Incentive Card Distribution Log must be maintained by the department for which the study was performed. For non-research, this is the department that disbursed the incentive cards. A copy of the completed distribution log must also be attached to the requisition/purchase order in buyWay$ within 15 days of disbursement of all incentive cards, completion of the study/activity or by January 15 if the study/activity exceeds one calendar year. If any individual received $600 or more in incentive cards during the calendar year, section E.2 below also applies. When necessary, the log will maintain subject confidentiality by the use of identifiers. Due to the nature of the data collected on the Incentive Card Distribution Log, it must be treated as confidential information. Failure to provide adequate documentation and adhere to this policy will jeopardize the researcher’s/requestor’s ability to use incentive cards in the future.
- University Employee
The IRS considers incentive cards to be tax reportable as compensation when issued or awarded to the recipient, regardless of value. The value of the incentive cards will be included on the employee’s annual W-2 in taxable income. (Note: This may not apply if the employee is participating in research dissimilar to their normal job functions or does not meet the $600 threshold.) It is the duty of the person accountable to make the employee aware of the tax implications of the incentive. - Nonemployee
For subjects or individuals who receive incentive cards over $600 on a single or cumulative basis during a single calendar year, the total of the cards will be reported to the IRS via Form 1099. The subject’s name, address, Social Security number, date of payment and payment amount must be hand delivered to Procurement and Business Services, 391 College Ave., Suite 203, Clemson, SC 29631 no later than January 15 of the subsequent calendar year. All personal identifying information should be kept secure and should not be emailed or sent via interoffice mail.
F. Inventory
Responsible personnel holding more than one card must perform physical inventory on cards yet to be distributed, at least on a weekly basis. Incentive cards remaining after 90 days must continue to be inventoried on a weekly basis. Inventory must be performed by someone other than the person accountable but in the presence of the person accountable. Both employees must sign off on the inventory log each month and maintain the record for auditing purposes. Any discrepancies must be reported immediately to the appropriate business officer. - Overview
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