Category: ADMIN-FIN POLICY & PROCEDURE Subject: Associate Recognition and Achievement Awards Classification: Management Approved Policy Owner: Chief Financial Officer Senior Vice President, Human Resources Approved by: WFH President and CEO POLICY: Effective: October 1, 2008 Wheaton Franciscan Services, Inc. (d/b/a Wheaton Franciscan Healthcare – “WFH”) organizations and associates must follow specific guidelines when recognizing their fellow associates for an achievement in connection with his or her employment. This recognition can occur either formally or informally and has historically taken on many different forms. The purpose of this policy is: (a) to provide examples of different types of associate recognition and awards (b) to provide the times where associate recognition or an award may be appropriate and allowable (c) to identify both suggested and prohibited types of associate recognition and award items (d) to provide monetary limits on such items to ensure that adequate cost controls are in place; (e) to provide guidance on the associate recognition policy so consistency amongst regions can be achieved (f) to provide guidance on the appropriate tax treatment of such items, and finally (g) to provide the processes for requesting, approving, and reporting associate recognition and awards items. Please refer to Exhibit A at the end of this policy for a summary of Employee Recognition items and limits, presented in a table format. RATIONALE: Wheaton Franciscan Healthcare encourages the recognition of outstanding performance and achievement through the use of rewards that are creative and meaningful. When administered and communicated effectively and within compliance guidelines, rewards and recognition are an important part of a total compensation program. Our Value of Respect calls us to value each person as sacred, and recognizes the good work and accomplishments of others. Our Value of Development combines the physical, emotional, spiritual and relational aspects of life and work, and values the professional and personal accomplishments of others. Our Value of Excellence strives to exceed the expectations of those we serve, and values superior performance in our work and service. Therefore, WFH recognizes that department leaders and other associates may desire to formally or informally recognize a fellow associate or a volunteer for a superior achievement or accomplishment, and acknowledges this recognition can occur in a variety of ways. SCOPE: This policy applies to all associates who are employed by Wheaton Franciscan Healthcare or any affiliated entity, and applies to all Tier I, II, III and IV institutions owned and managed by Wheaton Franciscan Healthcare. This policy deals with items given by an employer to an employed associate, and refers to these items as either “gifts” or “awards”. These awards can include items given to a specific associate in recognition of some act, or a randomly given item (such as in a “raffle”). For items received by, or given to associates from vendors, patients, business associates, and others, please reference Gifts, Gratuities and ADMIN-FIN Associate Recognition and Achievement Awards Page 1 of 6 Business Courtesies, and Conflict of Interest Policy. This policy and the related guidelines do not apply to customary work-related expenses such as travel, conference attendance, and memberships in professional organizations. For guidelines related to business-related reimbursements, please reference the policy Reimbursement for Business Travel and Seminar Expenses. PROCEDURE: Wheaton Franciscan Healthcare will consider the use of budgeted departmental funds to purchase certain categories of Associate Recognition and Achievement Awards, subject to the guidelines and procedures set forth under each section below. Please cross reference Exhibit A, which summarizes this information in a table format. 1. Cash Equivalents (Gift Cards, Gift Certificates, and/or Cash) Any form of cash equivalent given by an employer to an employed associate is fully taxable regardless of the amount. This includes all forms of gift cards, gift certificates, and/or cash, where a readily determinable cash value is apparent, even if a cash value is not printed directly on the face of the item. Examples of Cash Equivalents that are fully taxable, regardless of amount, include: Department Store Gift Certificates or Gift Cards Food Store Gift Certificates or Gift Cards Mall Gift Certificates or Gift Cards Restaurant Gift Certificates or Gift Cards Home Improvement Store Gift Certificates or Gift Cards Wheaton Franciscan Healthcare recommends seeking out other forms of recognition. However, in those rare instances where a cash equivalent is given, the following procedure should be followed: A. Call or email your WFH Tax Contact OR your local Payroll Department, and include the following information: Associates full name Entity where the associate/recipient is employed Type of cash equivalent Amount of cash equivalent Date of recognition item (Example: Mary Smith, WFH-St. Joseph, 10/01/08, $50 Department Store gift certificate) B. Tax or Payroll will forward this information to the appropriate associate. C. Payroll will add the value of the cash equivalent or other taxable item to gross income, and subtract the required withholding from the associate’s next paycheck. Depending on the associate’s federal and state income tax bracket, in combination with FICA taxes (Social Security and Medicare), this withholding is estimated to be approximately 30% of the value of the item (Example: On a $50 gift card there would be approx $15 in taxes withheld). D. Payroll must receive the information in a timely manner in order to complete the proper reporting in the same tax year as the gift was given (based on a calendar year). Thus, information regarding gifts given in December must be sent directly to payroll department so the associate is taxed in the same year as the receipt of the gift, per IRS guidelines. ADMIN-FIN Associate Recognition and Achievement Awards Page 2 of 6 2. Non-Monetary Associate Recognition Items Non-monetary items can be given freely with no tax implications, and are encouraged over the use of cash or cash equivalents. These items include such things as letters of commendation, letters of recommendation, or a special thank you in the form of a letter, card, email, or other written correspondence. 3. Voucher or Coupon for Holiday Item A voucher or coupon for a specific tangible gift at holiday time, such as a turkey, ham, pie, or other similar item are acceptable and carry no tax implications, as long as the voucher or coupon has no readily determinable cash value, and can only be exchanged for a specified tangible item of nominal value (a turkey, ham, pie, or similar item). A gift certificate or gift card to a food store would not be a voucher or coupon; rather it is considered to be a cash equivalent that is fully taxable. A cash equivalent can not be converted to a non cash equivalent by instructing the associate to use the cash equivalent only for the specified item. Vouchers or coupons typically must be arranged directly with the vendor to ensure the voucher and invoicing is in the proper form. The voucher or coupon should specifically identify the item to be redeemed with no cash value (Example: “This holiday voucher good for one Jennie-O Turkey of up to 15 lbs, redeemable until November 15, 2008 at selected food store”). Other holiday giving, such as an annual Christmas party and any related giving at the party itself, are acceptable and carry no tax implications, provided the monetary limits and other guidelines in this policy are followed. 4. Other Tangible Non-Cash Items To recognize an associate for an achievement, tangible items of nominal value can be given with no tax implications. The value of the item should be de minimis ($20 or less) and can be awarded for wellness initiatives (such as a walking, weight loss, or stop smoking program), annual events (such as Nurses Week or Administrative Professionals Day), prizes or awards for contests (such as holiday door decorating, or a department initiative or goal that was reached), at a holiday or department function (such as at a facility anniversary or Christmas party), or for an outstanding accomplishment or achievement by an associate or volunteer. Examples of appropriate recognition items of $20 or less in value would include: Water Bottle or Pedometer Beach Towel Clock, Lamp, or other item for work space Tee Shirt, Sweatshirt, or Fleece Gift shop pens or other items of small value Other similar nominal items Items that bear the “Wheaton Franciscan Healthcare” company logo may be imprinted on the item but is not required. If the company logo is imprinted on the item, and the cost per item exceeds the internal policy limit of $20, WFH will treat this item as being non taxable, provided the value of the item does not exceed $50. However, all other items without a company logo and greater than $20 in value will be considered taxable, including items donated to Wheaton Franciscan Healthcare that exceed these values. ADMIN-FIN Associate Recognition and Achievement Awards Page 3 of 6 EXAMPLE OF GIFT: Jen is the Surgery Dept Manager and held a contest to determine the most cost effective way to sterilize some of the department’s instruments. Ray came up with a great idea for the department, and Jen would like to reward him with a small gift, using budgeted dept funds. Jen gives Ray a $15 gift certificate to a local restaurant. The gift certificate is fully taxable, regardless of amount, because it is a cash equivalent. Jen must follow the procedure outlined under #1 to report the amount to payroll. Jen should also attach to any related check request, a copy of the communication showing that the item was appropriately reported to the payroll department. Jen gives Ray a $20 desk lamp. The desk lamp is completely tax free because it is not a cash equivalent, and is under the internal policy limit of $20 or less. Jen only needs to document, on any related check request, that the gift is under the $20 limit and therefore is not taxable to the associate. Jen gives Ray a $25 desk lamp. The desk lamp is fully taxable, because it exceeds the internal policy limit of $20. Jen needs to report the entire $25 to the payroll department, following the procedure outlined under #1. Jen should also attach to any related check request, a copy of the communication showing that the item was appropriately reported to the payroll department. Jen gives Ray a $40 Fleece. Imprinted on the fleece is the Wheaton Franciscan Healthcare logo. The fleece is completely tax free because the company logo is imprinted on the item, and the item’s value is $50 or less. Jen only needs to document, on any related check request, that the gift is under the $50 policy limit and contains the company logo, and is therefore not taxable to the associate. 5. Special Occasion Gifts Wheaton Franciscan Healthcare acknowledges that there are times when associate life events occur, and fellow associates may want to send a gift item as a measure of well wishes or concern. These occasions can include, but are not limited to the following: Associate Birthday or other special day, such as Wedding, Anniversary, or Baby’s Birth Associate Life Crisis, such as Illness, Injury, or Death in the Family Newly Hired Associate or Resignation/Retirement of an Associate A Facility Anniversary or other Milestone Wheaton Franciscan Healthcare’s normal policy would expect associates to contribute their own funds to purchase such items. However, in the case of an associate life crisis, there may be an appropriate reason to grant an exception. Department heads have discretionary authority to expend budgeted funds for special occasion gifts if deemed appropriate. Rewarding or recognizing an associate or group of associates for an accomplishment by taking the associate(s) out for lunch or dinner at employer expense is acceptable, as long as it is undertaken as special occasion giving that does not occur with any degree of frequency, and is not lavish or excessive. 6. Associate Discounts Discounts granted to associates to purchase items in the gift shop or cafeteria can be allowed with no tax implications, as long as the discounts are occasional and ADMIN-FIN Associate Recognition and Achievement Awards Page 4 of 6 reasonable in amount. 7. Cafeteria Vouchers Cafeteria Vouchers can be awarded with no tax implications, as long as no cash value is readily determinable on the face of the voucher. Cafeteria vouchers should be used to award a specified item, such as “redeemable for one 20 oz bottle of soda” or “redeemable for one pizza”. 8. Formal Associate Recognition Annual Event – Associate Achievement Awards An annual event to recognize and reward associates for years of service is acceptable and has no tax implications, as long as certain guidelines are followed. Both full time and part time associates are eligible for such awards. The following guidelines must be met: Event must occur with regular frequency and be part of a meaningful presentation or ceremonial observance emphasizing the recipient’s years of service or an achievement in the area of safety. The event must not award associates within the first five years of their employment (but can be awarded beginning on the 5 year anniversary, and each 5 years thereafter). The associate must not have received a similar award within the current year or within the preceding four years. The value of such item must not exceed $400 per associate and must not be a cash equivalent (if the item awarded is a cash equivalent, it is fully taxable to the associate, and must be reported to the Payroll Department using the procedure outlined under #1). The associate will normally be presented with a gift catalog where one item can be selected in a specified category. Associates may also receive a certificate, and in special cases of 25 years or more, may also be presented with a plaque. Replaces: Service Recognition policy Cross reference: Gifts, Gratuities and Business Courtesies policy Conflict of Interest policy Reimbursement for Business Travel and Seminar Expenses policy Review Period: Two (2) years Original Policy Date: October 1, 2008 Dates Updated: ADMIN-FIN Associate Recognition and Achievement Awards Page 5 of 6 Exhibit A - Summary of Associate Recognition Awards and Related Information For any items that exceed the following limits or are otherwise determined to be taxable, the procedure under #1 above should be followed to report the item to the Payroll Department. Reward Type Approval Needed Department Head and One Level Above None Frequency Taxable? Does not apply No No, provided structured correctly No, provided value does not exceed $20 No, provided value does not exceed $50 No 1 Cash, Gift Certificates, Gift Cards, or other “Cash Equivalents” Cash 2 No Monetary Value (Thank You Card or Letter of Commendation) 3 Holiday Item (Turkey, Ham, or Pie) Non Cash Non Cash Department Head Once per Year $20 4 Other Tangible Items of Personal Property with Nominal Value (Water Bottle, Beach Towel, T-Shirt, etc.) Items Bearing Wheaton Franciscan Logo (Fleece, Coffee Mug, Golf Item, Baseball Hat, etc.) 5 Special Occasion Gifts Non Cash Department Head As appropriate $20 Non Cash Department Head and One Level Above As appropriate $50 Non Cash Department Head and One Level Above Department Head and One Level Above As appropriate Does not Apply As appropriate Department Head of Gift Shop or Cafeteria Department Head Department Head and One Level Above As appropriate Does not No apply, provided reasonable in amount $10 No As appropriate $10 No Once every 5 Years $400 No, provided value does not exceed $400 Special Occasion Dinners or Lunches Non Cash 6 Associate Discounts Non Cash 7 Cafeteria Vouchers Non Cash Non Cash 8 Associate Achievement Award Presented at a Formal Recognition Event As appropriate, but discouraged As appropriate Monetary Limit Does not apply Yes, regardless of amount ADMIN-FIN Associate Recognition and Achievement Awards Page 6 of 6