Giving a Gift to UMW
If you are interested in giving a gift to UMW, please contact University Advancement.
The UMW Procurement Services department is responsible for the policy that governs UMW employees receiving gifts from outside sources. Please see Procurement Services 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
- Recognizing a UMW STUDENT for achievements obtained or volunteering
- A token of appreciation for participation in an academic research project
- A door prize at a UMW event (primarily pertains to SAE 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).
Form Of Gifts
- Gift cards (up to $100)
- Gift certificates (up to $100)
- Physical gifts (i.e., book, T-shirt)
Not allowed gifts:
- Gifts of cash
EXCEPTION #1: A cash PAYMENT may be made for the purpose of paying a subject to participate in an academic research study (see Research Participant Payment).
EXCEPTION #2: Non-employee cash AWARDS are allowed only as defined on the Direct Pay Table.
EXCEPTION: Donations MIGHT be allowed when the donation is the method by which the purchase of a product is made. For example, if a company or organization calls the purchase of an item a “donation” (whereby the product that is purchased can be made only by a “donation”), this information must be documented, and the product must remain the property of UMW. Contact 540-654-1226 to determine compliance.
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. (NOTE: A full Banner ID number can be given in place of the social security number.) The potential recipient can avoid providing this information only by NOT accepting the gift.
- All cash gifts–including gift cards/certificates–of any value 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 Associate Vice President for Finance and Controller.
- 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 firstname.lastname@example.org 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 (or FULL Banner ID 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 (of any value), or a gift certificate (of any value). 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 Procurement Services 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:
The Accounts Payable (AP) Manager’s SPCC – ONLY the AP Manager’s SPCC can be used to purchase gift cards/gift certificates that are purchased using state funds. If you wish to purchase gift cards/certificates using a state fund, please contact the AP Manager at 654-1226.
UMW Bookstore Charge - Gifts cards/certificates or physical gifts that are purchased through the UMW Bookstore as a Bookstore Charge must follow this UMW Gift Giving Policy and a Gift Log Form must be completed. The completed Gift Log Form, along with original, detailed, itemized receipt, MUST be forwarded to the Accounts Payable Manager in Eagle Village, Suite 480.
UMW Finance Card – Use the UMW Finance Card when items are charged to local/non-state 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 paperwork on which the gifts were purchased. Accounts Payable will receive the original Gift Log and receipts that are attached to the UMW Finance Card paperwork 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 paperwork is sent to Accounts Payable, the original Gift Log should be HAND-DELIVERED to Accounts Payable in Eagle Village, Suite 480 within 15 days from 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.
Contact Accounts Payable at email@example.com 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.