INTERNAL OPERATIONS COMMITTEE
Meeting Date: SEPTEMBER 22, 2025
Subject: GIFT CARDS AS PROGRAM INCENTIVES
Submitted For: MONICA NINO
Department: COUNTY ADMINISTRATOR
Referral No: IOC 25/9
Referral Name: GIFT CARDS AS PROGRAM INCENTIVES
Presenter: JULIE ENEA
Contact: Julie.Enea@cao.cccounty.us
Referral History:
At the March 2025 IOC meeting, Vice Chair Burgis inquired about contractors issuing gift cards under County-funded contracts after the Auditor-Controller's annual internal audit plan presentation. On May 13, 2025, the Board of Supervisors (BOS) tasked the IOC with reviewing the County's policy and procedures for purchasing and distributing gift cards as program incentives, especially by community-based organizations contracted by the County.
The CAO presented a report with findings and recommendations to the IOC at its regular meeting on July 18, 2025. Briefly, to recap, the County Administrator issued Administrative Bulletin 615 in 2009 to manage the purchase and distribution of gift cards, addressing risks of fraud, waste, and abuse. From July 2009 to June 2025, 142 Board of Supervisors (BOS) actions authorized about $3.5M for gift card programs, primarily for Health Services Department initiatives. Regular audits by the Internal Audit Division flagged issues like unauthorized gift card allocations by contractors without BOS approval. A survey found 38 contracts involving gift card distribution managed by various county agencies, with fiscal divisions overseeing transaction documentation. Only Employment and Human Services included specific contract language for handling gift cards.
The CAO suggested updating the gift card incentive policy to clarify that the policy covers County programs managed by staff or contractors, and to require the incorporation of special conditions for contracts involving gift card incentives.
Vice Chair Burgis raised concerns about repeat incentives for the same individuals and non-residents, suggesting in-person ...
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