INTERNAL OPERATIONS COMMITTEE
Meeting Date: JULY 28, 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.
There is a risk of fraud, waste, and abuse when converting grant or contract funds into gift cards because of the difficulty in tracking and monitoring their use. Without strong oversight, these costs may be questioned during audits. In 2009, the County Administrator established a policy (Administrative Bulletin 615, attached) for purchasing and distributing gift cards as incentives for County programs, as authorized by the BOS.
This report outlines the County's policy on using incentives like gift cards and vouchers across departments and special districts, provides examples from major departments, and presents findings. Unless otherwise noted, the data was compiled from information extracted from past BOS agendas.
Findings
From July 2009 through June 2025, there were 142 BOS actions relating to gift card programs administered by County departments, either directly or through a contractor, totaling about $3.5M or, on average, about $220,000 annually. Most of the incentives authorized by the Board of Supervisors since FY 2009/10 were related to programs administered by the Health Services Department, as shown in the following table.
The next table summarizes the most common uses of gift card incentives a...
Click here for full text