Hi Tammy - 

I have worked in units that work with adolescents under 18 in native american communities and have been able to successfully justify a W9 waiver based on the fact that not doing so significantly impairs study recruitment and participation. I don't think my institution has the added complication of not issuing gift cards for <18 y.o., though - is that a policy or some sort of limitation of the system?

This is not a super helpful response as I don't know how our finance office (which is the central office that approves our gift card programs) documents and determines that a W9 waiver is warranted/approved. If no one has a better answer/guidance I can reach out and ask what our university relies on policy or documentation-wise to allow these sorts of situations if that is helpful. 

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Sarah M. Trimmer, MPH | Finance and Grants Administrator
Lifecourse Epidemiology of Adiposity and Diabetes (LEAD)
Colorado School of Public Health, University of Colorado  
AMC Campus, 1890 North Revere Court
Room P12-1020Q, Box F426
Aurora, CO 80045-7464