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AP 8-61d - College-Branded Promotional Items (SWAG)

Arapahoe Community College
Series 8 - Fiscal
AP 8-61d - College-Branded Promotional Items (SWAG)

Originated: June 16, 2025

Revised: July 1, 2025

Effective: July 1, 2025

References: State Board for Community Colleges and Occupational Education (SBCCOE) Board Policy (BP) BP 8-61 – Accounting and Internal Controls

Approved:

Stephanie J. Fujii, Ph.D.
President, Arapahoe Community College

PURPOSE

This Process is to establish guidelines for the purchasing of college-branded gifts.

This Process contains pertinent information affecting employees, current through the date of its issuance. BPs and SPs are subject to change throughout the year and are effective immediately upon adoption by the Board or System Chancellor, respectively. Employees are expected to be familiar with and adhere to the BPs, SPs as well as College directives, including but not limited to this Process.

Nothing in this Process is intended to create (nor shall it be construed as creating) an express or implied contract or to guarantee employment for any term. The College reserves the right to modify, change, delete or add to this Process as it deems appropriate. 

To the extent that any provision of this Process is inconsistent with State or Federal law, State Board for Community Colleges and Occupational Education Policies (BPs) or Colorado Community College System Procedures (SPs), the law, BPs and SPs shall supersede and control.

This Process incorporates the requirements established in BP 8-61 that apply and are referenced above.

SCOPE

This Process applies to all college departments using institutional general or grant funds to provide gifts to employees in the form of college-branded SWAG for use in:

  • Orientation

  • Commencement

  • Recruitment events

  • Community outreach

  • Other official events

  • School spirit or visibility purposes

DEFINITIONS

Gift -Something voluntarily given without expectation of return or compensation for services.

De Minimis Fringe Benefit - A benefit so small in value and provided so infrequently that accounting for it would be unreasonable or administratively impractical. ACC’s requirement for documentation is for any single item that is valued at $10 and higher. The cumulative total of all items received must be less than $100 per fiscal year.

Fiscal Year - July 1 through June 30 of the following year. (e.g., July 1, 2025- June 30, 2026).

Employee - Any person employed by CCCS within the last calendar year. This includes student employees.

W-2 - The IRS form reporting wages, tips, and other compensation for employees.

SWAG - Promotional items (i.e., apparel, onboarding/welcome items).

GUIDELINES

  • College-branded SWAG items are considered tangible non-cash gifts and may be subject to IRS taxable fringe benefit rules.

  • Items exceeding the $100 de minimis threshold for a fiscal year may be reported on the employee’s W-2.

  • SWAG must only be distributed in connection with official college events or activities as outlined in the SCOPE, not for personal gifts or everyday wear, UNLESS wearing the apparel is a required uniform for an employee to perform their job responsibilities. In that case, the apparel is not considered a taxable benefit to the employee.

PROCESS

If college-branded SWAG is purchased using any ACC Purchasing methods (Procurement card, Vendor Direct Pay or Purchase Order), proper documentation must be submitted with the invoice to include:

  • Employee Name and S#

  • Department

  • Event/Purpose

  • Description of item

  • Actual value per item

  • Date SWAG was distributed to employee

Fiscal Services will audit submitted documentation quarterly to determine if any employee has exceeded the $100 de minimus threshold during a fiscal year. Employees who exceed the threshold may have the value reported as taxable income on their W-2 forms.

REVISING THIS PROCESS

ACC reserves the right to change any provision or requirement of this Process at any time and the change shall become effective immediately.