INCENTIVE CARDS PROCEDURE
A. General Procedure
Incentive cards must be purchased through buyWay$ from the National Gift Card Company (NGC). (Exemptions may be available in situations in which external funding pre-dated this policy or required purchases cannot be accommodated by the NGC).
Advance planning by the person accountable is necessary to assure that no more than a ninety (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 ninety (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 of 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
1. 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 3-4 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.
2. 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 3-4 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
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 15th 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.
E. Tax Reporting
1. 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 do 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.
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 & Business Services, 391 College Ave, Suite 203, Clemson, SC 29631 no later than January 15th of the subsequent calendar year. All personal identifying information should be kept secure and should not be emailed or sent via interoffice mail.
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 ninety (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.