G-31-7.1 Employee Gifts and Events
Approved: 11/22/2022; Revised: 11/17/2025
The College provides awards and gifts to qualified employee recipients, as determined by the Human Resources Department. Tangible awards and gifts (e.g., plaques, pen-sets, coffee mugs, clothing, etc.) generally do not exceed $250 and cannot be replaced with cash equivalents (e.g., gift cards) or other non-excludable awards (all considered taxable income by the IRS). Annual employee achievement awards have a cash value of $1,000, are paid to the employee through payroll, and are considered taxable income.
Staff or departments may want to recognize employees for outstanding achievement, or length of service with a reception, party or lunch. It is disallowed to expend college funds for these purposes. The Department may however, seek approval to use some or all of the $250 available for a retirement gift at an open retirement event.
De Minimis (Minimal) Benefits:
https://www.irs.gov/pub/irs-pdf/p15b.pdf
The IRS does not give specific rules or dollar amounts defining de minimus. COCC defines de minimus as employee awards, gifts, or giveaways valued at $100 or less. De minimus awards, gifts, or giveaways are excluded from payroll taxes. Cash and cash equivalent fringe benefits (e.g., gift cards, gift certificates) are never a de minimis benefit. Cash and cash equivalent fringe benefits, gift cards, gift certificates are always taxed.
For COCC events that include giveaways where entries are based on attendance or other non-financial entry, the total value of a prize awarded to a COCC employee is exempt from payroll taxes if the item has a fair market value of $100 or less. Any prize valued at $100.01 or more is non-exempt and will be taxed.
College employees may accept nominal gifts such as pens, notepads, or refreshments, valued less than $50, offered from external partners and vendors during meetings or events. However, they may not accept gifts, meals, or incentives intended to influence decisions, create a conflict of interest, or give the appearance of impropriety. When in doubt, its' best for the employee to politely decline or consult with their supervisor.
Gift Cards, Cash or Cash Equivalents:
IRS Publication 15-B (2025) states:
“Cash and cash equivalent fringe benefits (for example, gift certificates, gift cards, and the use of a charge card or credit card), no matter how little, are never a de minimis benefit.”
Departments may want to provide gift cards/certificates to non-employee individuals (e.g., volunteers, speakers, students, etc.) to acknowledge their contributions to the college. Gift cards issued using college funds must comply with the following guidelines:
- Must be for small amounts ($5.00 - $50.00).
- Must provide justification (college purpose) for gift cards issued
- Can’t be used in lieu of pay
- Departments must maintain detailed log for gift cards including:
- The number of cards purchased and denominations
- Cards issued (to whom and for what purpose)
Cards issued to employees must be reported to Payroll, as taxable income.