Julie referenced the current Program Incentives policy, attached to the staff report, and
reviewed the most common findings of noncompliance by County departments as
identified by the County’s Internal Audit Division, which periodically audits the use of
gift cards.
Julie provided a summary of the responses from an informal survey of high utilization
departments regarding their authorization of contractors to purchase and distribute gift
cards. Departments reported 38 current or recent contracts involving gift cards. She
noted that while many service contracts did not specifically mention the purchase and
distribution of gift cards as program incentives, departments indicated that payment
demands were supported by receipts, logs with card details, and sometimes beneficiary
confirmations.
Julie summarized the recommendations, which were to clarify that the current policy
applies to County programs whether administered by County staff or indirectly through a
contractor, to require a set of special conditions be incorporated into contracts that
authorize the purchase and distribution of gift cards as program incentives, and to direct
the CAO to update the County's policy to be consistent with the Committee's direction.
Vice Chair Burgis emphasized accountability and efficient use of public funds. She
raised concerns about repeat incentives going to the same individuals and non-county
residents, suggesting in-person verification for reliability. Chair Andersen highlighted
that this approach could be unfair to those with disabilities or busy parents. Vice Chair
Burgis proposed requiring contractors to specify their methods for ensuring incentives
reach the intended audience.
Deputy County Counsel Andrew Mainardi advised the Committee to avoid strict
quid-pro-quo transactions and instead require clients to make a good faith effort to
complete tasks for program incentives.
Anissa Basoco-Villarreal from the County’s Employment and Human Services (EHS)
Department commented that EHS issues gift cards for emergency needs of juveniles in
custody, a use not directly addressed in the policy recommendations, and that the
Workforce Development Board issues incentives for specific and verified achievements.
Jamie Schecter from the County’s Health, Housing and Homeless Services program
stated that incentives for online participation are rarely used by Health Services. When
they are, IP addresses are verified to exclude those outside of the target community based
on location or frequency. Digital gift cards are utilized for their added security. She also
mentioned that HSD staff already adhere to the guidelines outlined in the County’s
program incentives policy, so the recommended actions can be implemented with
minimal additional effort.
The Committee staff will enhance the language regarding the eligibility determination
for program incentives and present updated recommendations to the Committee in
September.