1 august nashville, tennessee - citigroup august nashville, tennessee don consolidated card program...

APC Questions/Answers

for

GSA CONFERENCE 2012

1 August

Nashville, Tennessee

DON CONSOLIDATED CARD PROGRAM MANAGEMENT DIVISION (CCPMD)

Session Objective

To provide answers to questions regarding

the DON Purchase Card Program received

from APCs.

2

Approach

Grouped the Q&As according to the lay-out

of the new NAVSUPINST 4200.99B and

answered them as simply as possible.

3

Question Roles and Responsibilities

Who is the proper Appointing Authority?

4

Answer Roles and Responsibilities

The Head of Activity (HA) or their designee is

the proper Appointing Authority for each

Agency.

5


Must appointments be redone when the

Appointing Official that signed it leaves?

6


Change of Appointing Official does not require that a

new appointment document (i.e. DD 577, Letter of

Delegation, Letter of Appointment) be issued.

The only time an appointment document must be

redone is when the authority changes.

For example, if a CH‟s authority is going to be changed

to include using their card to pay for training authorized

using a SF-182, then their letter of delegation should be

reissued. Similarly, if an AO/CO receives authority to

certify purchases for an activity that‟s different from the

one on their current DD 577, a new DD 577 should be

made to reflect the new authority.

7


When a GCPC participant leaves the program,

is there a requirement for Section IV of the DD

577 to be completed?

8


Yes. All DD 577 appointments must be terminated by

completing Section IV of a copy of the original DD 577.

Approving Official/Certifying Officials: The A/OPC must

notify DFAS that the appointment has been terminated by

mailing the DD 577 to DFAS and putting a copy of the DD

577 in the AO/CO‟s personal file. If the AO/CO is not

available to initial the termination, indicate N/A in box 19.

Cardholders: The A/OPC DOES NOT need to notify DFAS,

but must put the completed DD 577 in the CH‟s personal

file.

9


If an employee is nominated to become a CH

and the employee was a poor AO, can the

A/OPC refuse to accept the nomination?

10


Supervisors are responsible for nominating

trustworthy and competent personnel to fill

GCPC program positions.

Supervisors are responsible for taking

disciplinary action when poor performance is

demonstrated.

The A/OPC should work to develop a good

relationship with supervisors and managers and

inform them of any performance problems with

personnel the supervisor nominates.

11


How are the below forms used?

Letter of Delegation

Appointment Letter

DD 577

12


Letter of Delegation (LOD) – Involves Contract

Authority. Only A/OPCs and CHs are issued

contract authority.

A/OPC LOD - Delegates the authority to manage the

GCPC program and issue Letters of Delegation to

CHs .

CH LOD – Delegates authority to commit the

government using the GCPC. Should include limits

to what can be purchased and amount. Documents

pecuniary liability, has DD 577 attached.

13


Appointment Letter – Used to appoint an AO/CO.

Indicates duties and limits. Documents

pecuniary liability, has DD 577 attached.

DD 577 – Form serves two purposes. Attached

to AO/CO Appointment Letter and CH LOD.

1) Notify DFAS of appointment to certify invoices for

payment, contains signature specimen (AO/CO

only)

2) Appointment and acceptance of pecuniary liability

AO/CO and CH

14


Does a AO/CO really need to submit a DD 577

with a wet signature if they do not manually

certify vouchers?

15


Yes, the original DD 577 with a handwritten

signature of the AO/CO is required to be on file

at DFAS. It is required whether using manual

or electronic certification.

A manual certification may be needed to

correct a billing account error and a signature

must be on file at DFAS.

16

Question GCPC Program Management

What if an AO refuses to provide their

SSN for DD 577?

17

Answer GCPC Program Management

If an AO refuses to provide their SSN, DFAS

could refuse to make a payment and the

command could take disciplinary action.

18


Why does the DD Form 577 require a

complete SSN?

19


Per FMR Volume 5, Chapter 33, you must

include the appointee‟s full Social Security

number on the DD 577 to enforce pecuniary

liability if needed.

20


How is authority to use the GCPC above

the micro purchase threshold delegated?

21

A/OPCs can use a Letter of Delegation to provide

authority for a CH to:

1) Acquire commercial training up to $25,000

2) Acquire reproduction/printing services less than

$50,000 from DLA Document Services

3) As a method of payment for contract

actions/orders placed by a warranted Contracting

Officer or Ordering Officer

Any other authority to use the GCPC above the

micro purchase threshold must be provided by

SF-1402 issued per HCA procedures.


22

Question

GCPC Program Management

What are the rules governing a foreign

national performing GCPC program duties?

23


Currently the Financial Management Regulation

(Volume 5, Chapter 33) prohibits Indirect Hire

Foreign Nationals from performing CH, AO or

APC duties.

This prohibition is being reviewed by the OSD

General Counsel (GC).

Until the OSD GC rules, the DON policy will

allow Indirect Hire Foreign National to perform

CH, AO/CO or A/OPC duties.

24


With the recent emphasis on audit readiness, will

there be any changes to how the purchase card

program is currently managed?

25


No change to GCPC Program Management

Policy is anticipated.

Reason for new emphasis on audit readiness

is to validate the DON and DOD Financial

Statement.

The impact to GCPC program is uncertain.

Check with your comptroller before

destroying any GCPC supporting

documentation.

26


What is the connection between the Financial

Improvement and Audit Readiness (FIAR) and

the Government Purchase Card Program?

27


The Purchase Card Program is intended to

simplify small purchase methods, minimize

paperwork and streamline payment processes.

FIAR is an audit of financial processes.

Making payments using the GPC is considered

a financial process.

28


With the FIAR being put in place, is this going

to take the responsibility out of the hands of the

AO/CO or A/OPC, since the Command will not

be doing the scanning of documentation?

29


No, the AO/CO is still responsible for

maintaining the original supporting

documentation for six years and three months

(10 years for Foreign Military Sales funding).

Before destroying any GCPC supporting

documentation the AO/CO should check with

their local comptroller.

30


Where can I get training on Citi systems?

31

Citi recently introduced a new self service

training module accessible from CitiManager.

Training on CitiManager, CCMS, CCRS and PAT is

available using CITI Commercial Card Learning and

System Support (CLASS) from the Web Tools menu.

Citi always welcomes input from experienced

users to improve training offered from CLASS.

Suggest you visit the Citi computer lab or

attend a CitiManager training session while at

the conference. 32

Answer

GCPC Program Management


Can you walk through the process for updating

accounts with new fiscal year Lines of

Accounting?

33


The process is as follows: 1 LOAs are downloaded from CCMS and updated

with new FY information in the BFYEFY and Cost

Code segments.

2 Updated LOAs are disseminated via HL3 A/OPCs

to HL5 A/OPCs for local Comptroller

review/correction and return to CCPMD.

3 LOAs are validated in CCMS and bad LOAs

returned to HL5 A/OPCs for correction.

4 LOAs applied to accounts.

34

Answer (Cont‟d) GCPC Program Management

This year Citibank is automating the Fiscal Year

Rollover within CCMS. Within CCMS, FY

information will be automatically updated in

existing LOAs and then validated.

CCPMD will provide additional guidance

regarding HL 5 A/OPC responsibilities via PCAN.

Recommend that you attend the Citibank

training session on Thursday, August 2 from

8:00 – 9:10 in the Delta Mezzanine Bayou E

Room to see an overview of this new process.

35


Why do Convenience Checks need to be bulk

funded?

36


The last update to the Financial Management

Regulation (FMR) removed this requirement so

Convenience Checks no longer need to be

bulk funded.

37


38

The FPDS Reporting system is user UN-friendly

and asks for too much information that seems

redundant with data maintained by Citi.

Untrained personnel are inputting data they

don‟t understand. FPDS training is lacking, and

it‟s difficult to use.

Is there a plan to simplify the use of FPDS?

FPDS was designed to be used by trained Contracting

Officers to capture, report and analyze contract actions.

Only CHs authorized by SF-1402 should be performing

contract actions that must be input into FDPS.

How to use FPDS should be part of training for being

issued an SF-1402.

Each Command has an FPDS subject matter expert to

answer FPDS questions or make suggestions to improve

FPDS.

Try: https://www.fpds.gov/fpdsng_cms/index.php/training


39


If we have a single instruction governing the

GPC program, should we now think about

establishing a standard IOP?

40

NAVSUPINST 4200.99B provides high level

overarching GCPC policy to allow

Commanders the flexibility to develop

operational procedures aligned to their

specific mission.

A “standard” Internal Operating Procedure

would not address the unique mission

requirements of each activity.

41



Since reviewing and advising on acquisition

policy is a major part of the job, is there any

thought to requiring all A/OPCs to be in the

DAWIA corps?

42


There is no plan to require GCPC A/OPC

positions to be part of the DAWIA corps.

There are specific personnel policies that

govern the establishment and filling of DAWIA

positions.

If an Activity wants to require their A/OPCs to be

DAWIA certified, they should discuss this with

their Command Personnel policy experts.

43

Question Using the GCPC

What are “terms and conditions”?

44

Answer Using the GCPC

Terms and conditions (T&Cs) are those special

requirements that apply to a purchase, and

because they are special requirements should

be stipulated in a contracting document.

T&C can be required by the Government or the

Vendor.

Government T&Cs include specification,

inspections, etc.

Vendor T&Cs include additional payments,

restrictions, penalties, etc.

45

Answer (Cont‟d) Using the GCPC

CHs should not sign vendor T&C. Ask the

vendor to waive their T&Cs or look for another

vendor.

Commercial products delivered with written

T&C that are not signed are OK.

Check with your local contracting office if you

have questions regarding T&Cs.

46


What can a SF-182 be used for?

Can it be used to reserve a space for a non-

training meeting?

47


When used with the GCPC, a properly completed

SF 182 authorizes payment of approved training

expenses under the following conditions:

Must be a single training event not to exceed $25K

Must be a fixed price event

Must be commercial off-the shelf w/no modification

resulting in extra cost to the government

The SF-182 is not used to purchase general

supplies, training equipment, or non-training

services. Therefore, it is not used to reserve

space for a training or non-training event.

48

Answer (Cont‟d) Roles and Responsibilities

The SF 182 is also used for requesting,

approving, and for attendance at meetings,

conferences, seminars, and symposia where the

primary purpose is to train an employee to meet

a performance improvement related need.

49


When purchasing training, is it necessary for

the purchase cardholder to update the

purchase log after it has been submitted for

approval to show that a course was received?

50


The purpose of the purchase log is to reconcile

the bank statement with what the CH purchased.

Many times training is purchased prior to the

student attending the course. In this case the

training could be paid using „pay and confirm‟

procedures.

Like any purchase, receipt of training should be

documented; procedures for documenting

completion of training can be included in the

Activity IOP. 51


What is the policy for using the purchase card

to pay for tuition fees or conference fee

associated with official TAD/TDY trips.

52


The common element between Tuition and

Conference Fees are they both usually need to be

paid in advance.

Tuition fees should be authorized using an SF-182

and paid for using the GCPC.

Conference fees may also be authorized using SF

182 and are usually paid for using the GCPC.

Conference fees may be placed on the travel card,

ONLY when feasible (low cost or at conference).

53


Why are CHs required to „screen‟ or check

FAR Part 8 Mandatory Sources?

54


FAR 13.201 states the requirements in Part 8

(Required Sources of Supplies and Services)

apply to purchases at or below the micro-

purchase threshold.

55


How should a CH ensure compliance with

requirement of FAR Part 8 ?

56


The easiest way to comply with FAR Part 8

requirements is to make purchases using a

Government online purchasing system like DOD

EMALL, GSA Advantage or VA.Gov.

These systems provide information to help the

CH comply with FAR Part 8 and other

procurement requirements like Strategic

Sourcing, Green Procurement and supporting

Small Business.

57


What steps should a CH consider when getting

ready to make a buy?

58


1. Ensure funding is available.

2. Check the requirement.

Approved by authorized individual

Item description and need date

Not available from the „supply system‟

Strategic sourcing item? Office Supplies,

Incidental Janitorial Supplies, Furniture,

Wireless Services,

3. Use online purchasing system to check

required sources.

4. Make the purchase. 59


How can I find out if I am allowed to buy

something with the GCPC?

60


Check GCPC policy for prohibited items

Check CCPMD website FAQs

Check GCPC Desk Guides

Apply the Necessary Expense Rule

Search GAO „Red Book‟

Seek advice from local experts

Contracting Office

Comptroller

Legal Office

HA makes decision based on advice

Document decision and advice

61


How should I handle iPad Buys?

62


Buying IPADs and similar devices present several risks,

such as property accountability, security and recurring

payments. These purchases will most likely be the

target of any audit.

The Chief of Naval Operations recently released

guidance for purchasing Information Technology (IT)

products, supplies, and services that requires

Command CIO approval of non-weapon or non-C4ISR

system IT related purchases under $500K.

While not Purchase Card policy, CHs need to be aware

of this new IT Procurement Policy when purchase IT

equipment, supplies, and services.

63


What controls are in place for deleting

downloadable apps that are not needed by the

next user?

64


Each Activity should develop its own procedures for use,

tracking, and disposal of these devices.

Procedures should be placed in the Agency‟s IOP.

Devices and Apps should only be purchased if

necessary for mission accomplishment. “Necessary

Expense Rule” applies.

Apps should only be deleted if the mission changes.

The purchase should be centered around the

mission, not the person.

65


What is the policy for purchasing command

coins?

66


Command Coins may be purchased using appropriated funds.

As an AWARD to recognize individual outstanding performance that contributes to a command's efficiency and effectiveness

Should be limited in number, accounted for in a logbook, and NOT personalized with the CO name.

67


Command Coins may be purchased using appropriated funds as RECOGNITION for military recruitment or retention.

Each coin shall be of nominal value (less than $50 per item).

Used to recognize and commemorate their service

Document justification for the basis for the recognition

Can be presented to members of the armed forces and their families, and other individuals recognized as providing support that substantially facilitates their service in the armed forces

68


Command Coins may be purchased using ORF funds.

Mementos to foreign dignitaries or other

prominent citizens NTE $335 (command coin

NTE $50)

Mementos to prominent visiting DoD/DoN

officials NTE $40

69


Why do some EMALL venders require minimum

purchases which sometimes are more than we

need?

70


One of the benefits to using EMALL is strategic

sourcing which allows Navy to negotiate better

pricing. Some vendors have minimum ordering

requirements to help control prices. Small orders

drive up unit costs and without the minimums the

vendor would not be able to provide the items at

the contracted price. Remember these minimums

are order specific not item specific. Office

Supplies are rarely emergent where an order can‟t

be "saved" until more items are required and the

minimum is met. 71


Our providers are very passionate about getting

the community involved in their healthcare.

What is the policy on "give-away" items for

health fairs, patient safety, etc.?

72


Activities frequently want to use gifts to attract attention to

their Activity‟s mission or to specific programs. For

example, gifts are often used as recruiting tools or to

inform individuals about an Activity‟s program.

The general rule is Appropriated funds may not be used for

personal gifts, unless there is specific statutory authority.

Because a necessary expense analysis is case specific, it

is impossible to draw a rational line identifying the gift

items that are acceptable and those that are not. It is

important that anyone confronting a "gift" issue scrutinize

the case law carefully to appreciate distinctions that may

not be apparent at first. This is why we recommend getting

your legal office involved.

73


Instead of paying for something I‟ve yet to

receive, wouldn‟t it be better to simply roll it to

the next billing cycle?

Is there a plan to modify pay & confirm to

alleviate confusion?

74

The GCPC program uses industry charge

card business rules; any change to these

business rules would be cost prohibited.

To avoid having to use Pay & Confirm

procedures a CH can take the following steps:

Buy EARLY in the billing cycle

Ensure items are available for deliver when

ordering

Confirm anticipated receipt date

75



Given the increased emphasis and review on

conferences, are there any additional

requirements for GPC payments for

conferences below the micro purchase level?

76


The recent attention to conferences focuses on

approving the hosting and attendance of

conferences, NOT paying for conferences.

However, a CH should ensure any conference

fee they are asked to pay is approved by the

conference attendee‟s supervisor.

77


Will there be a strategic sourcing initiative

(contract) for IT equipment?

78


The DON Strategic Sourcing Team does not expect a

single IT contract will be awarded.

CNO message 152325Z NOV 11 requires acquisitions of

non-weapon or non-C4ISR system related IT materiel

and support services above $500K to be processed

through SPAWAR.

Non-weapon or non-C4ISR system IT acquisitions below

$500K must be approved per Command CIO procedures.

CHs should not procure any ensure IT requirements

have been approved by their Command CIO.

79


Due to the requirement to maintain all

documentation indefinitely for audit readiness

purposes, can we start scanning documents

over 7 years old and maintain them

electronically in order to save space?

80


NAVSUPINST 4200.99B allows for scanning

and electronic storage of supporting

documentation if procedures are in place to

ensure the scanned image is an accurate

representation of the original document and

the storage system is centrally managed with

a backup system.

Scanning and electronic storage procedures

that meet the above requirements should be

documented in the Activity IOP. 81


DoD EMALL surcharge. Does the surcharge

ONLY apply to office supplies?

82


No – The surcharge applies to ALL DLA stock numbered

items not just office supplies or EMALL.

The surcharge reimburses the Stock Fund for expenses

in managing the item and is a long established process

for funds management in the supply system.

There is NO surcharge when shopping in the Navy

Contracts corridor.

83


If CH‟s go outside the Navy Contracts

corridors, will they be required to justify the

use of other corridors regardless if what is

being purchased is an office supply or not?

84


No justification is needed to use “All DOD

EMALL” for office supplies not found in the

Navy Contracts corridor.

Navy policy for acquisition of office supplies is

to use the base supply stores (ServMarts) or

vendors in the Navy Contracts Corridor of

EMALL.

If using EMALL, only if the office supply product

cannot be located from the Navy Contracts

Corridor should the search be expanded to “ALL

DOD EMALL”. 85


If an office supply item is not found within the

Navy Contracts corridor, will CH‟s be required

to use a local ServMart first (to avoid the

surcharge) prior to using any of the other

corridors?

86


DON Office Supply Policy does not prioritize

between EMALL and SERVMART, both are

authorized sources of supply for office

supplies. Shopping in the Navy Contracts

Corridor will avoid any surcharge.

Only if the office supply product cannot be

located from the Navy Contracts Corridor

should the search be expanded to “ALL DOD

EMALL”.

87


Who has the waiver authority for the furniture

procurement policy?

This is a big impact on cost and time

consuming to an OCONUS command.

88


Exceptions to this policy must be made on a

case by case basis at a level no lower than the

Chief of the Contracting Office.

The furniture BPAs achieve an initial discount

and reduce use of redundant vehicles. These

BPAs were competitively awarded against

Federal Supply Schedules and to the Federal

Prison Industries as part of Spiral II of the Navy's

Strategic Sourcing Initiative for Furniture.

89


I am not clear on the prioritized order of

purchases between GSA and open market to

card holders under 3K.

Please clarify.

90


GSA provides access to supplies and

services from two online systems

1. GSA Global Supply provides online shopping for GSA

Stock Program and Special Order Items. This is a

working capital program and fees are added to orders.

This falls into the category of Wholesale Supply

Sources.

2. GSA Advantage provides online shopping for items

available from GSA Multiple Award Contractors. Fees

are included in the schedule price of the contracts.

This falls into the category of Optional FSS.

91

Answer (Continued) Using the GCPC

NAVSUPINST 4200.99B authorizes use of

commercial sources if:

the item is not available from Government online

systems, or

is not available to meet the required need date, or

can be acquired at a lower cost - REQUIRES AO

pre-approval.

EXCEPTION: Items on the AbilityOne

Procurement List MUST be purchased if

available in time to meet requirement,

REGARDLESS of cost.

92


What is the possibility of increasing the

micro purchase level from $3,000?

93


Increasing the micro purchase threshold is

currently being discussed at the highest levels

of the Department of Defense.

The DOD Comptroller suggested an increase,

but the Director of Procurement and Acquisition

Policy was concerned this might lead to

additional misuse, so a study was done to

determine the impact of raising the micro

purchase threshold.

DON CCPMD will keep HL3 A/OPC informed of

the status of the study. 94


What is the definition of a split buy? Be

specific .

95


Split Purchases are simply the “intentional” breakdown

of a single requirement into separate purchases merely

to get around the micro-purchase threshold.

Split Requirements are the “intentional” breakdown of

a single requirement into separate purchase requests to

get around the micro-purchase threshold.

The "requirement" is the description of what is needed

and when it is needed.

96

Question GCPC Program Oversight

Can there be an enterprise consolidated report

built that can be generated at the enterprise

level for consolidation of the information for

the Semi Annual Review?

97

Answer GCPC Program Oversight

Many improvements have been made to the semi

annual reporting process since it was introduced

in 2003.

The majority of the information required for the

semi annual review is contained in the PAT CO

Management Report.

However, there are some internal controls/

weakness that are not reviewed within PAT, like

findings from audits, that have to manually be

reported. 98


What‟s considered a weakness in the Semi

Annual Review?

99

Weaknesses in the Semi Annual Review

include anything that indicates a lack of

internal controls, policy compliance,

absence of oversight, or anything that

indicates the GCPCs are being used for

other than their intended purpose.

100



Why are the Level 5 A/OPC and the AO/CO not

notified by email when transaction(s) are added

by a higher level A/OPC in PAT?

101


Whenever a transaction is added in PAT, the system

sends an email to the AO.

PAT uses the email address in CCMS of the AO that

performed the last review.

APCs can use the „Manage Contracts‟ function of

CCMS to change an erroneous AO email address.

PAT will be changed to provide email notification to the

HL5 APC whenever a higher level APC adds a

transaction.

102

Question

Are there any other questions someone

would like to ask?

Raise your hand and someone will give

you a microphone.

103