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GENERAL SERVICES ADMINISTRATION Washington, DC 20405
OAS 4200.1A January 7, 2015
GSA ORDER
SUBJECT: Management and Use of the GSA SmartPay® Purchase Card
1. Purpose. This order provides guidance on the proper use of the GSA SmartPay® purchase card (purchase card) to comply with laws, regulations, and GSA policy established by the Office of Administrative Services, Travel Policy and Charge Card Program Division. 2. Background. The Government Charge Card Abuse Prevention Act of 2012 (the Charge Card Act), Public Law 112-194, requires all executive branch agencies to establish and maintain safeguards and internal controls for purchase cards and centrally billed accounts. Consistent with the Act, OMB Circular A-123, Appendix B, Improving the Management of Government Charge Card Programs, prescribes policies and procedures to reduce waste, fraud, and error in Government charge card programs. OMB also issued Memorandum 13-21 as a supplemental guidance to OMB Circular A-123 to implement the Charge Card Act. In compliance with OMB A-123, GSA SmartPay® purchase cardholders (cardholders) use the purchase card to procure all authorized purchases, and to pay for all supplies and services, whenever possible. The single purchase limit (transaction limit) for micro-purchase cardholders cannot exceed the micro-purchase threshold, as described in the Order (currently $3,000). The single purchase limit for warranted cardholders (contracting officers) cannot exceed the Simplified Acquisition Threshold (currently $150,000). 3. Scope and applicability. This directive contains standards, instructions and procedures governing the management and use of the purchase card. These policies and procedures apply to GSA employees who perform any function in the purchase card program. Regional and Staff Offices may issue supplemental guidance containing local instructions and procedures that do not conflict with policy herein. 4. Cancellation. CFO 4200.1A Use of the GSA Purchase Card. 5. Nature of revision. This guidance consolidates policy on management and use of the purchase card. This revised Order includes the following updated policies and procedures:
a. Memorandum on Policy Guidance for the GSA Purchase Card and E2 Miscellaneous Reimbursements issued by OAS and OCFO, dated January 3, 2013.
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b. Memorandum on Clarification to Revised Policy on Use of the GSA SmartPay®
Purchase Card for all Micro-Purchases issued by OAS and OCFO, dated March 17, 2014.
6. Signature. /S/___________________________ CYNTHIA A. METZLER Chief Administrative Services Officer Office of Administrative Services
OAS 4200.1A January 7, 2015
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TABLE OF CONTENTS
Section Number Page Number
1. Roles and Responsibilities ………………………………………..…………. a. Office of Administrative Services, Travel Policy and Charge Card Division
b. Office of the Chief Financial Officer, Office of Financial Policy and Operations c. Agency/Organization Program Coordinators d. Regional Charge Card Coordinators e. Cardholders f. Requesting Officials g. Approving Officials h. Funds Managers i. Billing Office j. Bank Customer Service Representatives
1
2. Selection and Approval Process ………………………………...………….. a. Approving Officials
b. Cardholders c. Regional Charge Card Coordinators
8
3. Delegations of Authority ……………………………………………...………. a. Authority for Micro-purchases b. Authority for Other Purchases
8
4. Training …………………………………………………………………………..
8
5. Account Establishment and Maintenance ………………………………… a. New Accounts b. Maintenance Changes
9
6. Card Administration …………………………………………………………… a. Issuance of Cards b. Safeguarding of Cards c. Lost or Stolen Cards d. Card Renewal
11
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7. Requirements for Micro-Purchases ………………………………………… a. Micro-purchase Threshold b. Use of the Purchase Card for Micro-purchases c. Rules for Micro-purchases d. Written Authorizations e. Required Sources of Supplies and Services f. Section 508 of the Rehabilitation Act g. Environmental Quality of Products Procured with Purchase Cards h. Competitive Price Quotations i. Small Business Requirements j. Federal Strategic Sourcing Initiative
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8. Requirements for Purchases above the Micro-Purchase Threshold ….
15
9. Prohibited Use of the Purchase Card ……………………………………….
16
10. Tax Recovery ……………………………………………………………………
17
11. Merchant Authorizations ……………………………………………………... a. Surcharges b. Transactions
18
12. Mandatory Logging of Transactions ………………………………………..
18
13. Mandatory Upload of Supporting Documents …………………………….
19
14. Reconciling Cardholder Statements ………………………………………..
19
15. Disputes ………………………………………………………………………….
19
16. Verification of Receipt and Acceptance ……………………………………
20
17. Property Accountability ……………………………………………………….
20
18. Record Retention ………………………………………………………………
20
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19. Convenience Checks …………………………………………………………. a. Usage b. Prohibitions on use c. Check writing d. Convenience check fees e. Transaction posting f. Reordering checks g. Physical safeguard h. Cancellation i. Reporting
20. Other Purchases ………………………………………………………….. 23
a. Subscription
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b. Building Services and Construction c. Memberships d. Advertisements e. Recurring Charges f. Training Registration g. Meals h. Conferences i. Local Travel
21. Monitoring Purchase Card Usage ………………………………………… a. Inactive Cards b. Impending Suspension Report c. Questionable Charges Report d. Employee Separation List
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22. Disciplinary Actions for Improper Use of the Purchase Card……..……
25
23. Reimbursements to GSA ……………………………………………………. 26
Appendix A. Terms and Definitions ………………………………….……….…
A-1
Appendix B. Sample Pegasys Log Entries ………………………….………… Appendix C. Sources and References ………………………………………….. Appendix D. List of Internal Controls …………………………………………..
B-1 C-1 D-1
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MANAGEMENT AND USE OF THE GSA PURCHASE CARD
1. Roles and Responsibilities.
a. Office of Administrative Services (OAS), Travel Policy and Charge Card Division (H).
(1) Establish GSA policies and procedures and internal controls for the
management and use of the GSA purchase card in compliance with laws and regulations and the Office of Management and Budget (OMB) Circular A-123, Appendix B.
(2) Develop the Charge Card Management Plan. (3) Develop and implement charge card training. (4) Develop management reports to monitor program effectiveness. (5) Prepare the Office of Management and Budget (OMB) reports. (6) Develop and implement corrective action plans based on audits. (7) Revoke charge card privileges for any program participant that fails to adhere
to established policies and procedures. (8) Ensure cancellation of cardholder accounts upon separation from GSA. (9) Approve requests for convenience checks. Reorder convenience checks as
needed.
b. Office of the Chief Financial Officer (OCFO), Office of Financial Policy and Operations (BC).
(1) Conduct annual internal control assessment under OMB Circular
A-123, Appendix A, Internal Control over Financial Reporting. Upon identifying internal control deficiencies, ensure that corrective action plans are developed for remediation of deficiencies.
(2) Develop the requirements for the ADM P 5400.41B Agency Internal Control
Program.
(3) Monitor purchase card logging and reconciliation in Pegasys (GSA’s financial system).
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(4) Conduct audits on purchase card payment transactions. (5) Conducts annual mandatory refresher training on financial accounting codes
in order to accurately capture the proper funding source and the sub-object class code.
c. Agency/Organization Program Coordinator (A/OPC).
(1) Oversee the Purchase Card Program.
(2) Serve as the liaison between GSA and card issuing bank.
(3) Provide administrative support and training to Regional Charge Card Coordinators.
(4) Conduct annual review of Merchant Category Codes and approve changes
to retail blocks or flags for purchase card transactions.
(5) Monitor misuse of the purchase card and actions taken by management in response to charge card violations.
(6) Serve as liaison for audits and reviews of the Purchase Card Program.
(7) Analyze monthly questionable purchase card transactions and prepare
monthly questionable transaction report for Heads of Services and Staff Offices (HSSO), and Regional Commissioners (RC) for review and action.
(8) Prepare monthly Impending Suspension Report for HSSOs and RCs which
identifies Approving Officials (AOs) who have not reviewed and certified their Pegasys monthly transactions report. Suspend the charging authority of cardholders under these AOs until certification has been completed.
(9) Prepare and submit semi-annually report of cardholders who have not used
their purchase card in the preceding twelve months to Regional Charge Card Coordinators for review and action.
(10) Follow up and monitor responses to questionable charges. (11) Notify the Office of Inspector General (OIG) of RCs and HSSOs that do not
provide timely response to their monthly questionable charges reports.
(12) Monitor compliance with Federal Strategic Sourcing Initiative for office supplies (FSSI, OS3).
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d. Regional Charge Card Coordinators.
(1) Ensure cardholders and AOs complete the mandatory purchase card training at GSA On-line University prior to establishment of an account. Cardholders must provide a copy of the training certificate to their Regional Charge Card Coordinator
(2) Ensure cardholders complete Pegasys charge card training course or know
how to use Pegasys prior to establishment of an account. Cardholders must certify Section II of GSA Form 3661, Purchase Card Application and Maintenance.
(3) Coordinate training for cardholders and AOs at least once a year to ensure
compliance with GSA policy.
(4) Ensure cardholders and AOs are set up in Pegasys before processing Form CB001, Citibank Government Purchase Card Set Up Form by logging into Pegasys and searching for the AO or cardholder’s name under System Administration/ Security/ Principal or at http://pegasys.gsa.gov/admin/queries.htm which is updated weekly.
(5) Coordinate applications for setup, maintenance and cancellation of charge card accounts for regional cardholders and AOs.
(6) Maintain all administrative support documents for purchase card accounts.
(7) Monitor resolution of transactions on the Monthly Questionable Charges Report and maintain documentation of resolution.
(8) Ensure replacement of AOs upon knowledge of an AO relinquishing their duties or take action to suspend cardholder accounts under the AO’s authority if replacement is not accomplished in five business days.
(9) Initiate cancellation of cards with the bank.
(10) Ensure AOs review and certify their Pegasys Monthly Charge Card
Transactions report within 10 days of receipt of the Pegasys reports. Regional Charge Card Coordinators should run the AO report in Business Object after the 10 day period and notify the AOs that have failed to certify their reports.
(11) Suspend charging authority of cardholders who do not complete the
mandatory refresher training requirements.
(12) Suspend charging authority of cardholders under AOs who do not complete the mandatory refresher training requirements.
(13) Suspend charging authority of cardholders upon notification of misuse by the AO or supervisors. Charging privileges are suspended pending the outcome of an investigation.
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(14) Ensure each AO is not assigned more than six cardholders. Run a Pegasys
or Citibank query report.
(15) Ensure cardholders do not serve as their own AOs on GSA Form 3661.
(16) Ensure AOs do not appoint themselves as Requesting Officials on GSA Form 3661.
(17) Cancel the accounts of cardholders who separate from GSA.
(18) Ensure all cardholders have an active AO. Update the Citibank database
with the correct AO and provide GSA Form 3661 to OAS to update Pegasys.
(19) Ensure all cardholders and AOs re-certify their security access in Pegasys. Contact the Pegasys helpdesk for the list at [email protected] at the end of the recertification process.
e. Cardholders.
(1) Use the purchase card only for official business in compliance with
applicable procurement laws, regulations, and GSA policies.
(2) Use the purchase card to procure all authorized purchases and/or pay for authorized goods and services, whenever possible.
(3) Use convenience checks when approved by OAS to support national
emergencies or major disasters as declared by the President. (4) Contact the vendor immediately and take corrective action if the purchase
card is erroneously used (e.g., purchase card in lieu of the travel or personal card). (5) Safeguard the card, convenience checks, and account number and prevent
others from using them. (6) Obtain written authorization from the authorizing official before making any
purchase. (7) Ensure the independent receipt and acceptance of goods is documented for
all purchases over $150. (8) Create logs and provide complete description of items purchased as
demonstrated in Appendix B, Sample Pegasys Log Entries. (9) Perform reconciliations of all transactions within 10 days receipt of the bank
statement line in Pegasys.
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(10) Upload supporting documentation in Pegasys for items purchased, such as
the written authorization, receipt or invoice, and discard paper documents after verification of upload.
(11) Resolve disputed transactions with vendors and bank, as necessary. (12) Ensure purchases are tax exempt. (13) Report lost/stolen card to Citibank and the Regional Charge Card
Coordinator as soon as possible. (14) Do not split purchases to circumvent the micro-purchase threshold. (15) Complete the OCFO System Access Request Form for Pegasys and
NEAR to obtain your role and approval in Pegasys before you receive your purchase card.
(16) Understand how to log and reconcile credit card transactions and upload
supporting documentation in Pegasys prior to becoming a cardholder (read the Pegasys Reference Card on Credit Card at http://pegasys.gsa.gov/ref/qrc.htm or read the Pegasys User Guide at http://pegasys.gsa.gov/ref.htm). Take the Pegasys credit card training course when available.
(17) Complete the annual Pegasys recertification process. Failure to complete
the recertification process will result in the suspension of Pegasys account. (18) Respond timely to requests for documentation to auditors. Untimely
response may result in the suspension of your purchase card account.
f. Requesting Officials (typically a Division Director/equivalent or higher level official).
(1) Designate employees to be cardholders or designate AOs based upon the needs of the program office.
(2) Ensure AOs are in the same Service or Staff Office as their cardholders.
This includes re-organization and consolidation activities. (3) Ensure AOs are the same grade or higher than the cardholders, preferably a
supervisor. (4) Ensure subordinates do not serve as AOs for their direct supervisor. (5) Ensure the number of cardholders is kept to the minimum necessary to
support office operations.
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g. Approving Officials (typically a supervisor).1
(1) Ensure the purchase card is used properly.
(2) Authorize all purchase card transactions in writing (e-mail is acceptable) before purchases are made by the cardholder. A higher level official in line of authority over the AO may also issue written authorizations for purchase card transactions.
(3) Ensure that unauthorized or improper transactions by the cardholder are
reimbursed to GSA and disciplinary actions are imposed.
(4) Monitor the purchase card activity of assigned cardholders.
(5) Certify that all transactions meet legitimate Government requirements.
(6) Ensure appropriate supporting documentation, as defined in paragraph 13, is uploaded by conducting a monthly sampling of purchase card transactions.
(7) Ensure that the cardholder’s purchase card transactions are logged and
reconciled within 10 calendar days from receipt of the bank statement line.
(8) Ensure cardholder disputes are resolved timely.
(9) Review and certify Pegasys Monthly Credit Card Transactions reports within 10 days of receipt. The AO should certify the reports even if there are no purchase card charges for the statement cycle. Prior to relinquishing AO responsibilities, the AO must review and certify all charges for their cardholders.
(10) Ensure applicable procurement regulations and policies are followed.(See
Appendix C, Sources and References)
(11) Notify the Regional Charge Card Coordinator, the A/OPC, and the OIG upon evidence of unauthorized charges or purchases for personal use by the cardholder.
(12) Take necessary action on all questionable transactions upon receipt of the
monthly Questionable Charges Report.
(13) Discipline cardholder for improper use of the purchase card in accordance with GSA Order 9751.1 CPO (Revalidated) Maintaining Discipline. Consult your Human Resources Services Division for assistance with any disciplinary action.
(14) Ensure that cardholders under the AO are in the same Service or Staff
Office as the AO.
1 As a non-supervisor, the AO is still responsible to ensure the purchase card is properly used.
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(15) Complete the OCFO System Access Request Form for Pegasys and NEAR
to obtain the role and approval in Pegasys. (16) Complete the annual Pegasys recertification process. Failure to complete
the recertification process will result in the deactivation of Pegasys account. (17) Notify the Regional Charge Card Coordinator, AO or equivalent when
cardholders and/or AOs leave office. (18) Ensure that cardholders respond timely to audit requests for documentation.
h. Funds managers.
(1) Establish card limits.
(2) Ensure that funding is available for cardholder’s use.
(3) Monitor fund levels.
(4) Approve GSA Form 3661, Purchase Card Application and Maintenance, for
changes to purchase card limits. (5) Verify the accuracy of the default accounting code on GSA Form 3661.
i. Billing office. The Financial and Payroll Services Division (BCE) within the Office
of Financial Policy and Operations (BC) processes payments daily for the purchase card program.
j. Bank Customer Service Representatives.
(1) Activate accounts.
(2) Provide account information (i.e., balance, availability).
(3) Cancel reported lost or stolen cards and cards for terminated employees. (4) Provide instructions for disputing transactions.
(5) Provide requested copies of cardholder statements. (6) Process orders for convenience checks authorized by OAS.
(7) Increase/decrease card limits as requested by the Regional Charge Card
Coordinator or other authorized management official.
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2. Selection and approval process.
a. Approving Official. GSA employees that oversee cardholder accounts are AOs. The appropriate Division Director/equivalent or higher level official is responsible for designating AOs. Individuals may serve as a cardholder and/or an AO. However, cardholders cannot serve as their own AOs. In addition, employees cannot serve as AOs for their supervisors. Each AO is limited to no more than six cardholders for effective oversight, monitoring, reconciliation and review of cardholders’ accounts.
b. Cardholders. GSA employees authorized to buy goods/services on behalf of their division/organization. They are primarily responsible for the proper use of the purchase card. The appropriate Division Director/equivalent or higher level official is responsible for designating cardholders. Because the card can only be used by the person whose name is on the card, organizations/divisions may choose to appoint additional employees as cardholders to ensure that someone is always available to make purchases. Contractors are not allowed to be cardholders.
c. Regional Charge Card Coordinators. RCs or their designees appoint the Regional Charge Card Coordinator in their regional offices. Every effort should be made to keep cardholder levels to the minimum necessary to support office operations. OAS designates the Regional Charge Card Coordinator for Central Office. The designating official must submit the Regional Charge Card Coordinator’s name, address, office symbol, and telephone number to the A/OPC via e-mail or in writing. 3. Delegations of Authority. Head of Contracting Activity (HCA) is delegated in GSA Order ADM D 5450.168.
a. Authority for micro-purchases. HCA may authorize Division Directors/equivalent or higher level officials to delegate authority to employees to make purchases not to exceed the micro-purchase threshold. The GSA Form 3661 is used to designate micro-purchase cardholders.
b. Authority for other purchases. The HCA appoints all contracting officers with authority above the micro-purchase threshold. The GSA Form 3661 and the Certificate of Appointment (Warrant) are used to appoint contracting officers as cardholders. 4. Training. Cardholders and AOs must complete mandatory purchase card training at GSA Online University prior to establishment of cardholder accounts. Mandatory training covers basic Federal procurement laws and regulations, and GSA policies and procedures for proper card and convenience check usage. Cardholders must also complete the Pegasys charge card training or read the Pegasys User Guide in order to understand how to log and reconcile transactions, as well as upload supporting documentation. In addition, the A/OPC, Regional Charge Card Coordinators, program managers, and billing officials must complete mandatory purchase card training prior to appointment. All program participants must complete refresher training every two years.
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5. Account establishment and maintenance.
a. New accounts.
(1) The requesting official must perform the following steps: (a) Complete Section I (Type of Action); Section II (Cardholder’s
information); Section III (Privileges and Coding), Section IV (Approving Official) and Section VI (Signatures) of GSA Form 3661, Purchase Card Application and Maintenance2. (b) Submit the complete GSA Form 3661 to the appropriate Regional Charge Card Coordinator along with a copy of the purchase card training certificate, and the Citibank Government Purchase Card Setup Form (CB001) for cardholders or Citibank Government Approving Official Setup/Maintenance Form (CB007) for AOs.
(c) Submit a copy of the Certificate of Appointment (Warrant) if the
employee is a contracting officer.
(d) Submit the complete OCFO System Access Request Form for Pegasys and NEAR to the Regional Pegasys Functional Coordinator for processing.
(2) The Regional Charge Card Coordinator verifies that Forms CB001 and 3661
are complete and accurate and processes the CB001 online or by fax. , The 3661 is submitted to the A/OPC to update Pegasys. The Regional Charge Card Coordinator should ensure that the cardholder has an AO, a role, and approval in Pegasys (paragraph 1(d) (4)) before processing Form CB001.3
(3) Single and monthly purchase limits. The single purchase limit (transaction limit) for micro-purchase cardholders cannot exceed the micro-purchase threshold as described in paragraph 7. To establish a cardholder’s single purchase limit over the micro-purchase threshold, the requested official must send a completed GSA Form 3661 and a copy of the Certificate of Appointment (Warrant) to their Regional Charge Card Coordinator indicating the new single-purchase and monthly limits. Depending on the cardholder’s level of purchasing authority, the single-purchase limit may be established not to exceed the Simplified Acquisition Threshold (currently $150,000). Single purchase limits for micro-purchases and the Simplified Acquisition Threshold are subject to change based on the FAR. The monthly purchase card limit for a micro-purchase cardholder is $250,000. The monthly purchase card limit for a warranted contracting officer cardholder is $999,999.
2 The Approving Official should not approve the Form as the Requesting Official.
3 When a cardholder uses the purchase card without a role in Pegasys, the entire batch payment file containing the
cardholder’s purchases from Citibank is aborted, thus causing GSA to delay payment.
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(4) Only one purchase card is issued to each employee, unless an exception is approved by OAS on a case-by-case basis. Requests must be made in writing to the A/OPC with an appropriate business justification. b. Maintenance changes. The requested official must submit the GSA Form 3661, Purchase Application and Maintenance, to the appropriate Regional Charge Card Coordinator for review. Upon review, the Regional Charge Card Coordinator will submit the approved Form to the A/OPC to update Pegasys.
(1) Purchase limit changes.
(a) When increases to single and/or monthly purchase limits are required, complete the following sections on the GSA Form 3661: Section I (Type of Action); Section II (Cardholder’s information); Section III (Privileges and Coding), and Section VI (Signatures). The signature of the Funds Manager is required for all increases to purchase limits. An e-mail is acceptable for decreases to purchase limits.
(b) Purchase limit increases for emergency situations. As determined by the GSA Administrator, in support of a contingency operation or to facilitate defense against or recovery from nuclear, biological, chemical, or radiological attack (41 U.S.C. 428a), the FAR micro-purchase and simplified acquisition thresholds may be raised for procurements of supplies or services by or for GSA in support of emergency operations. The emergency procurement authority to raise the limitations to higher thresholds will be issued in writing by the Senior Procurement Executive or his/her delegates. OAS issues specific procedures for Program offices to follow in using the emergency procurement authority for the purchase card program.
(2) Approving Official change. An AO change is required when the AO relinquishes his/her duties, transfers to another office, or terminates employment with GSA. The program office has 10 business days to designate another AO. The program office must follow instructions for establishing a new AO. To designate an existing AO, the requesting official must complete GSA Form 3661 by selecting the option from the “Approving Official Changes” block in Section I, Type of Action, and submit the complete and signed Form to their Regional Charge Card Coordinator for processing.
(3) Default accounting code changes. The requesting official must submit a GSA Form 3661 for default code changes to the appropriate Regional Charge Card Coordinator. The Funds Manager should approve the GSA Form 3661 confirming the default code changes are valid for purchase card activity. Upon review, the Regional Charge Card Coordinator submits GSA Form 3661 to the A/OPC to update Pegasys.
(4) Cardholder transfer. If cardholders are transferring to another organization within GSA, they may retain their current card; however, the acquiring office must submit a GSA Form 3661 to request an AO and default code change.
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(5) Cancellation of cardholder accounts. To ensure that purchase cardholders who separate from GSA are closed in Pegasys and Citibank in a timely manner, the A/OPC uses the Employee Separation List and verifies weekly that the account names on the list are closed. The following duties may also be implemented:
(a) The requesting official should also initiate action to cancel the purchase card for each cardholder who ceases to be employed by GSA or no longer needs a card by submitting a GSA Form 3661 or an e-mail to the appropriate Regional Charge Card Coordinator.
(b) Upon notification of a cardholder’s account cancellation, the Regional Charge Card Coordinator processes the cancellation in the bank’s Electronic Access System (EAS) or submits documentation to the bank for processing. In addition, the Regional Charge Card Coordinator must submit a copy of the GSA Form 3661 or an e-mail to the A/OPC to request closure of the account in Pegasys. Regional Charge Card Coordinators must cancel accounts promptly in EAS, but no later than 15 days of the notice of employee’s relief of cardholder duties.
(c) Prior to or on the last day of being a cardholder, cardholders must
relinquish their purchase cards to the AO or Regional Charge Card Coordinator for destruction by shredding. Cardholders must relinquish all records and supporting documents to the AO. Purchase card documents are the property of the program office.
(6) Change of Address. The requesting official may submit a GSA Form 3661 or
an e-mail to the appropriate Regional Charge Card Coordinator.
(7) Name change. The requesting official should complete GSA Form 3661 to include Sections I (Type of Action), Section II (Cardholder), and Section VI (Signatures). The requesting official must submit to the appropriate Regional Charge Card Coordinator along with documentation supporting the name change. 6. Card administration.
a. Issuance of cards. The bank delivers the card to the cardholder’s office address approximately two weeks after the application is processed. Regional Charge Card Coordinators must ensure that new cardholders have the role and approval, and an active AO in Pegasys before processing the Form CB001, Citibank Government Purchase Card Set Up Form. Upon receipt of card and prior to use, cardholder must activate the card by calling the bank’s customer service number. The bank may ask for the last four digits of the cardholder’s social security number for verification purposes. If the card is not received within two weeks after submission of an application, the cardholder or AO should contact their appropriate Regional Charge Card Coordinator to determine the status.
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b. Safeguarding cards. The cardholder is the only individual who can use the card and account number. When the card is not in use, it must be locked away in a safe or another physical safeguard that can only be accessed by the cardholder.
c. Lost or stolen cards. If a card is lost or stolen, the cardholder must contact the bank as soon as possible. The bank will send a replacement for any lost or stolen card.
d. Card renewal. Cards are automatically renewed without any action by the cardholders. If cardholders do not receive their renewal card within two weeks of the expiration date, they must contact their Regional Charge Card Coordinator. Cardholders must destroy the expired card upon receipt of the renewal card.
PURCHASE CARD USE
7. Requirements for micro-purchases.
a. Micro-purchase threshold. Currently, the micro-purchase threshold means $3,000 as defined in FAR 2.101, except for:
(1) Acquisitions of construction subject to the Davis-Bacon Act, $2,000;
(2) Acquisitions of services subject to the Service Contract Act, $2,500; and
(3) Acquisitions of supplies or services that, as determined by the Administrator, are to be used to support a contingency operation or to facilitate defense against or recovery from nuclear, biological, chemical, or radiological attack, as described in FAR 13.201 (g)(1), except for construction subject to the Davis-Bacon Act (41 U.S.C. 428a).
(a) $15,000 in the case of any contract to be awarded and performed, or
purchase to be made, inside the United States; and (b) $30,000 in the case of any contract to be awarded and performed, or
purchase to be made, outside the United States.
b. Use of the purchase card for micro-purchases. All micro-purchases, as defined in FAR 2.101, must be placed on the purchase card unless the merchant does not accept the purchase card. In instances where the merchant does not accept the purchase card, the cardholder must use the Direct Payment method in Pegasys or consider another merchant. Cardholders can use their card for micro-purchases in various ways:
(1) Visit local merchants to shop for the items and present the card for payment. (2) Place orders over the internet. (3) Call a vendor, place an order, and provide the purchase card number to pay
for the order.
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(4) Complete an order form from a vendor's catalog, a subscription form, or a
training registration form. Cardholders should include their account number on the form.
(5) Inform the vendor that the transaction may not be processed until the order is
shipped or services are performed when placing a written or telephone order. This does not apply to subscriptions which can be paid in advance as noted in the Order.
c. Rules for micro-purchases. Cardholders must ensure that the:
(1) Purchase is necessary and for official use. (2) Funds are available to pay for the purchase. (3) Required sources of supply are used, if applicable. (4) Micro-purchases are distributed among qualified suppliers. (5) Price is reasonable, as described in competitive price quotations.
d. Written authorizations. A pre-authorization is needed for each purchase.
(1) Cardholders should receive a written authorization before they make a purchase. Written authorizations are required to determine that supplies or services are required for official business and approved for purchase. The written documentation must:
(a) Be in the form of an e-mail, memo, note, fax, or other authorized form;
(b) Indicate the requesting person’s name, item description, quantity,
estimated amount, date of request, accounting code, date the goods or services are needed, and any other ordering limitations. Consult your Funds Manager or Budget Analyst for the correct accounting code.
(c) Indicate approval by an authorized official, AO or supervisor, or higher level authority.
(2) The authorized official may issue a written blanket authorization for supplies routinely needed or services rendered on a monthly basis; however purchase limitations on the cardholder should be imposed.
An example of a blanket authorization: “John Doe has authority to purchase office supplies not to exceed $200 per month for the Office of Superior Services. This authorization is in effect until modified or rescinded”. Include
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the AO’s Name/Signature/Date. This authorization should be filed electronically by the cardholder for audit purposes.
(3) An AO or supervisor may not approve a written authorization for a cardholder
to purchase items for their own use. A higher level official should authorize and approve the request.
e. Required sources of supplies and services. The FAR 8.002 lists the required sources for supplies and services. Many of these mandatory sources accept the purchase card. Prior to procurement from other vendors, the cardholder must determine whether the items or services are available from required sources. Cardholders must consider the listed sources in the sequence shown in FAR 8.002 before purchasing on the open market. Market research shall be conducted, as required, when purchasing pursuant to FAR 8 and FAR 10. Office supplies for GSA’s internal use must be purchased from Office Supplies Blanket Purchase Agreements (OS BPAs) as required by GSA. In general, cardholders should order through the Federal Supply Schedule when the items needed are not available from a source holding a higher purchase priority.
f. Section 508 of the Rehabilitation Act. Section 508 generally requires procurement of electronic and information technology (EIT) that takes into account the needs of all end users including people with disabilities. EIT, as defined in FAR 2.101, has the same meaning as “information technology”, except EIT also includes any equipment or interconnected system or subsystem of equipment that is used in the creation, conversion, or duplication of data or information. Purchase cardholders are encouraged to take the on-line training at GSA On-line University to gain familiarity with EIT products. The EIT includes, but is not limited to:
(1) Telecommunication products, such as telephones. (2) Information kiosks and transaction machines. (3) Worldwide websites. (4) Multimedia. (5) Office equipment, such as copiers, fax machines, computers,
monitors, printers, software and computer peripheral equipment. More information is provided at https://insite.gsa.gov/portal/content/627586 g. Environmental quality of products procured with purchase cards. GSA is committed to provide world class products and services that minimize harm to the environment, safety, and health. GSA purchase cardholders are required to purchase products with certain environmentally-preferable attributes in accordance with GSA’s Green Purchasing Plan (GPP). Purchase cardholders may also review the GPP training titled
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“Green Purchasing for the Federal Acquisition Workforce” on GSA’s On-line University. GSA provides solutions that help cardholders meet their environmental goals:
(1) Prior to making a purchase, refer to GSA’s Green Procurement Compilation (www.sftool.gov/greenprocurement) to determine applicable environmental purchasing requirements.
(2) GSA Advantage has thousands of products and services available to assist
in making environmentally-preferable and compliant purchases.
h. Competitive price quotations. For purchases at or below the micro-purchase threshold, the cost of obtaining price quotes may outweigh any savings that might be realized. Therefore, quotes are only required if the cardholder knows or suspects that a price is not reasonable. For example, if the cardholder has never purchased an item and has no comparable pricing information, or if an item is priced much higher than previously purchased, the cardholder should get several price quotes before making the purchase. Competitive price quotations are not necessary if the price charged for an item is reasonable.
i. Small business requirements. Micro-purchases are exempt from the small business reservation requirements of the Small Business Act and from the Buy American Act; however, cardholders are encouraged to give full consideration to women-owned, veteran-owned, service-disabled veteran-owned, Historically Underutilized Business Zone (HUBZone), and disadvantaged small business concerns when it is practical to do so.
j. Federal Strategic Sourcing Initiative. Federal Strategic Sourcing Initiatives (FSSI) solutions address commonly acquired goods and services within the Federal government. FSSI goals are to reduce the costs of acquired goods and services; reduce the cost of doing business; improve performance; increase the achievement of socio-economic acquisition goals (both at the prime and subcontract level); evaluate the total life cycle management cost; and improve vendor access to business opportunities. Information on the office supply initiative is located on this website: http://www.gsa.gov/portal/content/195439. GSA cardholders must use the Federal Strategic Sourcing Initiative for Office Supplies Third Generation (FSSI OS3) for the purchase of office supplies. Employees located at 1800 F Street, Washington, DC, must use the central office supply service centers available in each wing of the building. 8. Requirements for purchases above the micro-purchase threshold.
a. Cardholders with contracting authority for purchases over the micro-purchase threshold are encouraged to use the purchase card to:
(1) Place a task or delivery order (if authorized in the basic contract, basic ordering agreement, or blanket purchase agreement); or
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(2) Make payments on contracts of any value when the contractor agrees to accept payment by the card and the contractor’s System for Award Management debt flag indicator is not present. When used for contract payments, the cardholder’s single transaction and 30-day limits continue to apply and the contract should include FAR clause 52.232-36, Payment by Third Party. See FAR 13.301 for additional information.
b. Cardholders must comply with all applicable Federal procurement laws, regulations, and GSA policy. Use of the charge card to procure and/or pay for purchases does not change any of those requirements. When a task or delivery order is placed for supplies and services, the underlying contract or agreement should contain the required terms and conditions that are included in FAR 52.212-4, 52.212-5, and 52.213-44. Cardholders must provide these requirements to the vendor and include a statement indicating that acceptance of the order by the vendor constitutes compliance with terms and conditions. These may be provided to the vendor via fax, email or regular mail.
c. Funds certification is required from the funds manager. d. The preferred method for intra-governmental purchases is the Intra-governmental
Payment and Collection (IPAC) System. An intra-governmental card transaction is defined as a sale of goods or services, or collection of other obligation by one Government agency from another using a Government issued card. Each Service or Staff Office is solely responsible for all interchange and processing fees and charges for intra-governmental transactions. Individual transactions for credit card collections should be no more than $49,999.99. Individual transactions greater than $49,999.99 may not be split into two or more transactions over one or multiple days. Per Treasury Financial Management Announcement No. A-2014-04, the individual payment transaction will be lowered to $24,999.99 effective June 1, 2015.
e. The preferred method for placing orders within GSA is the interfund process.
9. Prohibited use of the purchase card. The following actions and/or services are not permitted on the purchase card:
a. Long-term rental or lease of land or buildings. Long-term is defined as any rental or lease that is intended for more than a temporary basis, not to exceed one year.
b. Cash advances.
c. Unauthorized purchases.
d. Personal purchases or purchases for personal use.
4 Effective June 21, 2013, there is a FAR interim rule that inclusion of an open-ended indemnification
clause in an End User License Agreement (EULA), Terms of Service (TOS), or other agreement is not binding unless expressly authorized by law. FAR Case 2013-005
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e. Travel or travel-related expenses, except local travel as defined in GSA travel policy.
f. Fleet-related expenses such as fuel, oil, routine maintenance or repair services. Questions regarding fleet card use should be addressed to the GSA SmartPay® Program Support, at (703) 605-2808, or visit http://smartpay.gsa.gov. Additional information is available in ADM P 5620.1 GSA Internal Motor Vehicle Management. g. Advance payments. Generally, advance payments for supplies or services are prohibited by 31 U.S.C. § 3324; however, advance payments are allowable for subscriptions to publications or training, when required. h. Use the purchase card for personal identification purposes.
i. Someone other than the cardholder. OAS will close the cardholder’s account upon becoming aware that the account number is used by another employee. j. Split transactions. A split transaction is the division of a purchase into two or more transactions to stay within authorized single transaction limit. Micro-purchase cardholders and warranted contracting officers are strictly prohibited from splitting purchases to circumvent their purchase card limits. OAS will revoke the charge card privileges of any cardholder who violates this policy. Cardholders and their approving officials who participate in split transactions will also be subject to disciplinary action in accordance with GSA Order, CPO 9751.1 Maintaining Discipline. An example of a split transaction is as follows:
A micro-purchase cardholder receives an authorization to purchase audio visual equipment costing $4,000. The cardholder makes a payment of $2,000 on one day and $2,000 on a following day. The $4,000 exceeds the micro-purchase limit of the cardholder.
Purchases for individual training classes or registration fees for conferences should be considered as discrete transactions. For example, if a cardholder is paying for a training class for two individual employees and each requires registration, treat each training class as two separate purchases. 10. Tax recovery. All GSA SmartPay® Purchase Cards are centrally billed accounts (CBA) and are exempt from State and local taxes. However, some states require tax exemption forms for Purchase Card CBAs to accompany any transaction. GSA Smart Bulletin No. 20 Tax exemption forms can be downloaded from this website: State Tax Information. In instances where cardholders are erroneously charged the sales tax, they are required to contact the merchant for an adjustment of charges. If necessary, cardholders may provide merchants with GSA’s tax exemption number of “44-0553234” for purchase card transactions.
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11. Merchant authorizations.
a. Surcharges. Merchants are allowed to add a fee to the cost of a purchase when a customer uses a charge card. The fee is called a surcharge. Merchants should notify the cardholders if there is a surcharge before making a purchase. If the merchant is imposing a surcharge, the cardholder should consider another merchant. Some states limit or do not allow surcharges. Read GSA Smart Bulletin No.17 for additional information.
b. Transactions. The merchant requests authorizations for purchase card transactions from the issuing bank. The authorization process automatically checks the cardholder’s account limits, including the single-purchase limit, monthly limit, merchant category code profile and any other limits that are established for the account. If the transaction is within the cardholder’s account limits, it will be authorized. If the authorization is denied, the electronic authorization process does not inform the merchant why the transaction is declined. To determine the reason: (1) Verify that the merchant used the correct account number, expiration date, and transaction amount. (2) Verify that the transaction amount does not exceed the cardholder’s single purchase limit. (3) Verify that the sum of all transactions charged to the card, billed or unbilled, does not exceed the monthly limit.
(4) Contact the bank at the number shown on the charge card if the transaction information is correct and the amount is within the account limits. Provide the transaction date, the amount, and the merchant name. The bank may not be able to identify the transaction immediately, but the information should be available by the next business day. 12. Mandatory logging of transactions.
a. Cardholders or reconcilers must log all purchase card transactions in Pegasys using the credit card logging feature CT (training) or CL (all other) type document. Logging ensures that goods and services are charged to the appropriate accounting classification and are obligated in the proper accounting period. It also provides a matching record with the bank billing record during the reconciliation process. Logs should be created prior to receiving the e-mail notification so the bank statement line would automatically reconcile to the logs. See Appendix B for a sample of log entries in Pegasys.
b. All logs must contain a complete description of the purchase card transaction(s). The description must clearly communicate what is being procured and/or paid for by the
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cardholder. Log description such as "none" or one that merely repeats the name of the provider (e.g., ABC company, etc.,) or financial information is unacceptable.
c. All logs must contain the most appropriate financial accounting codes to accurately capture the proper funding source, as well as the sub-object class code. Cardholders must ensure the written authorization includes the financial accounting code before making a purchase.
13. Mandatory upload of supporting documents.
a. Cardholders must upload documents in Pegasys to support purchases made on the purchase card for audit and tracking purposes. Support documents include:
(1) Order form or pre-written authorization. (2) Invoice or receipt. (3) Independent receipt and acceptance of goods and services when
applicable.
b. Upon verification by the cardholder that the documents have been successfully uploaded in Pegasys, the paper documents can be discarded. AOs are responsible for ensuring that supporting documentation is uploaded by conducting a monthly sampling of purchase card transactions. 14. Reconciling cardholder statements. If a logged transaction does not automatically reconcile with the bank statement line, cardholders or reconcilers must manually reconcile the charge within 10 calendar days from receipt of the bank statement line. If the cardholder and reconciler are not available to complete the reconciliation process within the timeframe (i.e., due to leave, temporary duty travel, etc.), they must perform the reconciliation within five working days after their return. Manual reconciliation prevents duplicate obligations which encumber budgetary resources, add invalid detail to management reports, and increase the risk of audit findings. Information on charge card reconciliation is available on this website: http://pegasys.gsa.gov/ref/qrc.htm. 15. Disputes.
a. Reasons for disputing a transaction may vary from dissatisfaction with the goods or services provided, to non-recognition of the reported merchant or charge (fraud related). In all cases, the first course of action is for the cardholder to contact the vendor and attempt to resolve the dispute directly. If attempts to resolve the dispute with the merchant are not successful, or if attempts to contact the merchant are not possible, then the cardholder should initiate the dispute process with the bank as soon as possible but no later than 60 days of receipt of the charge. Cardholders should contact the bank’s customer service on the back of their card. The bank will normally instruct the cardholder to complete and submit a dispute form which can be found online
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at Cardholder Dispute Form or obtained from the RC. The Government Transaction Dispute Office Guide may be accessed at Citibank Cardholder Dispute Guide.
b. In cases where a cardholder fails to timely dispute and/or resolve an improper
charge, the cardholder, consistent with OMB Circular A-123, Appendix B, Improving the Management of Government Charge Card Programs, shall reimburse GSA for the cost of that transaction. 16. Verification of receipt and acceptance. Purchases over $150 must be documented by someone other than the cardholder to ensure that goods are received and fulfill the quantity and quality requirements of the order. As confirmation of receipt, the individual other than the cardholder should record on the sales invoice, packing slip, bill of lading, or other shipping or receiving document the following criteria: typed or legibly written name, date items are received, and signature, or the individual receiving the goods may also send an e-mail to the cardholder stating item was received. Cardholder should upload the verification document to the log in Pegasys for audit and tracking purposes. 17. Property accountability. Property accountability controls are necessary including those items obtained with a purchase card. Purchase cardholders must adhere to all property accountability policies to include security, inventory management, and recording in the property tracking system. GSA’s personal property policy is contained in the Office of Governmentwide Policy, ADM 7800.12, Management of the U.S. General Services Administration’s (GSA) Internal Personal Property. Accountable property purchases made “over the counter” or directly from a vendor increases the risk that the accountable or pilferable property may not be reported to property managers for inclusion in the property tracking system. 18. Record retention.
a. The retention period for cardholders to maintain purchase card transactions such as pre-authorization, receipts, invoices, etc., is three years. This period starts upon the final payment date of the goods and services. However, these documents should be attached to the Pegasys documents and discarded after the cardholders review and are satisfied that the documents are properly uploaded. The retention period for finance to maintain financial records/payment is six years and three months.
b. Regional Charge Card Coordinators must maintain all administrative support documents to include, but not limited to: GSA Forms 3661 or other documentation for maintenance changes, copies of warrants, training certifications, etc. These documents may be destroyed three years after cancellation of a cardholder or an AO account.
c. The requesting official is responsible to ensure all purchase card documents are maintained for reconciliation, reviewing, and auditing purposes.
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19. Convenience checks. a. Usage. The use of convenience checks is prohibited except as noted in paragraph b below. If a vendor does not accept the purchase card, the cardholder must process a Direct Pay in Pegasys (see Pegasys Purchasing user guide, Direct Pay, Section 3.2.3 for processing instructions) or use another vendor. Citibank will not honor or process any convenience check dated after November 18, 2014, unless an exception applies as outlined in paragraph b below. Convenience checks written after November 18,, 2014, will be referred to OAS for follow-up with the cardholder.
b. Exceptions. Exceptions to the policy prohibiting the use of convenience checks may be granted on a case-by-case basis by the Chief Administrative Services Officer; however, the request must be related to emergency preparedness. While a purchase cardholder may be authorized an exception and may order convenience checks, convenience checks can only be used to support a major disaster or emergency declared by the President. Requests for convenience checks must be made in writing and submitted by the HSSO to the Chief Administrative Services Officer for consideration.
c. Restrictions. Convenience checks must not be written for:
(1) Merchants who accept the purchase card.
(2) Payments to other Government agencies.
(3) Employee reimbursements. (4) Salary payments, cash awards, or any transaction processed through the
payroll system.
d. Check writing. Cardholders authorized to use convenience checks must include the following elements for a properly written convenience check:
(1) Date. Spell out the date (i.e. October 30, 2008). Do not pre-date or postdate a check.
(2) Name of the payee. Cardholders must never write checks to “cash” or
“self”. (3) Amount. Write the exact amount of the purchase in numbers and words in
the spaces provided. (4) Sequence. Checks must be written in sequential order. (5) Signature. Checks must be signed.
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e. Convenience check fees. Cardholders must log all convenience check fees in Pegasys. The fees are equal to a percentage of the face value plus $1 per check. These fees will appear on a cardholder’s statement. In addition, there is a $10.00 fee for returned checks.
Figure 1. Convenience Check Fees
Face Value of Check Effective Time Period
2.1% 11/30/2011 – 11/29/2015
2.15% 11/30/2015 – 11/29/2017
2.2% 11/30/2017 – 11/29/2018
Example: In FY15, a convenience check written in the amount of $50,000 costs an additional $1,051 in fees (2.1% of the face value of the check plus $1).
f. Transaction posting. Checks must be logged in Pegasys. Checks are posted to the cardholder’s account in the cycle in which the checks clear rather than when they are written. Since there isn’t an electronic authorization process for checks, cardholders must ensure that the total of card transactions and any cleared or uncleared checks do not exceed their monthly purchase limit. Otherwise, checks could be returned for insufficient funds.
g. Reordering checks. Cardholders authorized to use convenience checks must contact the A/OPC via e-mail to reorder convenience checks. Upon approval, the cardholder should provide OAS the last check number available and the last six digits of their card number. OAS will contact the bank’s customer service number to reorder the checks. Checks should be reordered well in advance to allow time for the checks to be printed and shipped. The bank delivers them approximately 2 to 3 weeks after the request.
h. Physical safeguard. Cardholders authorized to use convenience checks must keep them locked in a safe or under physical safeguard where only the cardholder has access. If a check is lost or stolen, the cardholder must contact the bank immediately. The bank sends replacement checks for any that are lost or stolen.
i. Cancellation. Upon separation from the agency or when checks are no longer needed, AOs must ensure that unused checks are properly accounted for and destroyed by shredding. AOs must verify the last check number that was used by the cardholder. The last check number used will assist in monitoring any unauthorized check use.
j. Reporting. OAS will monitor all convenience check use across GSA to ensure
compliance with policy.
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20. Other purchases.
a. Subscriptions. Cardholders must place subscription orders in the name of an organization or a position title (i.e., Building Manager or Director, XXX Division) rather than in the name of an employee. Cardholders must keep the renewal notice or a statement that reflects the beginning and ending date of the service. b. Building services and construction. Public Buildings Service (PBS) cardholders with micro-purchase authority may use the purchase card to pay for open market purchases of building services not to exceed $2,500 and construction not to exceed $2,000. Contracting officers in PBS with authority to contract for building services and alterations may use the card to pay for such purchases up to their single purchase limit. Cardholders must comply with all laws and procurement regulations governing such purchases. Cardholders from other organizations may not use the purchase card for building services and alterations.
c. Memberships. In accordance with 5 U.S.C. § 5946, GSA may not use agency funds to pay for individual membership fees of GSA employees to join non-Federal entities, e.g., societies or associations. This prohibition does not apply if an appropriation is expressly available for that purpose, or if the fee is authorized under the Government Employee Training Act. Cardholders may purchase organizational memberships in the name of GSA if the membership will provide a benefit to GSA and further authorized activities of the agency. The organization's membership may authorize any designated employee to attend functions as GSA’s representative.
d. Advertisements. Cardholders must obtain a copy of the advertisement or an affidavit of publication from the publisher, radio or television station or the advertising agency and keep this proof of advertising for reconciliation and payment purposes. e. Recurring charges. A cardholder may procure and/or pay for monthly recurring charges when the total payments for one year (or the period of the contract or agreement) do not exceed the cardholder’s single transaction limit. When warranted contracting officers issue a purchase order, they may process recurring payments for the total amount of the contract period.
An example of an acceptable recurring service for telephone bills:
Single Transaction Limit - $3,000
Monthly Recurring Services - $200 X 12 months = $2,400
Total annual payments of $2,400 do not exceed single transaction limit of $3,000
An example of an unacceptable recurring service for telephone bills:
Single Transaction Limit - $3,000
Monthly Recurring Services - $300 X 12 months = $3,600
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Total annual payments of $3,600 exceed the single transaction limit of $3,000
f. Training registration. Once a training request is approved, cardholders may provide their purchase card account number to the training vendor by phone or on a registration form. Cardholder must log the training with a CT and attach the training approval and/or training related documents. Purchases for two or more individuals are considered separate and distinct transactions.
g. Meals. Purchase cardholders should consult their Regional General Counsel before using their purchase card to purchase meals or refreshments in any situation.
h. Conferences. The purchase card is used for payment of conference registration fees (tuition), and meeting rooms. Micro-purchase cardholders may process purchase card payments for multiple individuals. For example, a micro-purchase cardholder may pay registration fees for each individual up to their single transaction limit, not to exceed the monthly cycle limit.
i. Local travel. The purchase card may be used for local travel expenses as defined in the GSA Travel Policy.
PROGRAM OVERSIGHT
21. Monitoring purchase card usage. Purchase card program reviews are required by GSA’s Internal Control Program. All management officials must fully cooperate with all internal and external reviews or audits of the purchase card program.
a. Inactive cards. Accounts that are no longer needed should be closed. Semi-annually, the A/OPC creates a report which lists all accounts with no activity in the preceding 12 months. The requesting official should close any accounts on the list that are no longer needed by submitting a GSA Form 3661 or an e-mail to the Regional Charge Card Coordinator. The Regional Charge Card Coordinator will close the account in EAS and submit the request to the A/OPC for closure in Pegasys.
b. Impending suspension report. This report includes the names of AOs who have not reviewed and certified their cardholders' monthly transactions reports. The A/OPC notifies the HSSOs and RCs of the AOs who did not certify their reports and suspends charging privileges of cardholders under these AOs. The suspension remains in effect until the AOs certify their reports. In addition, the AOs cannot be assigned any new cardholders while in suspended status.
c. Questionable charges report. This report lists all transactions that are questionable and require further review. Every month, OAS uses data mining techniques to identify questionable purchase card transaction charges. The Regional Charge Card Coordinators must coordinate with the program offices to obtain detailed and precise explanations of the questionable charges within 30 days of receipt of the
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report. Non-responses or unsatisfactory responses to questionable charges are referred to the OIG as appropriate. This report is sent monthly to HSSOs, RCs.
d. Employee separation list. This list includes the names of employees who terminate employment with GSA. OAS uses this list to close purchase card accounts in Pegasys and Citibank on a weekly basis. If an AO’s name is on the list, the A/OPC will notify the Regional Charge Card Coordinator to provide a new AO in five business days to prevent the cancellation of the cardholder’s purchase card account. As an additional control, the A/OPC will use a monthly separation list from the Comprehensive Human Resources Integrated System (CHRIS) to verify closing.
DISCIPLINARY ACTIONS FOR IMPROPER USE OF THE PURCHASE CARD 22. Disciplinary actions.
a. Cardholders are subject to disciplinary action for improper use of the purchase
card in accordance with the GSA Order, CPO 9751.1, Maintaining Discipline. b. Supervisors/AOs must contact their servicing Human Resources Division to determine if disciplinary action is warranted, and if so, the appropriate penalty. They must notify the Regional Charge Card Coordinator, the A/OPC, and the OIG concerning any fraud, misuse or abuse of the charge card.
c. The misuse or improper use of the card can lead to penalties ranging from salary offset to removal, depending on the facts or circumstances. If misuse is suspected, the Regional Charge Card Coordinator should suspend purchase card privileges of the cardholder pending the outcome of an investigation.
d. When a cardholder makes an unauthorized or improper purchase, the cardholder, in accordance with OMB Circular A-123, Appendix B , Improving the Management of Government Charge Card Programs, shall:
(1) Reimburse GSA for the cost of the purchase; and
(2) Be subject to disciplinary action.
e. When a GSA official directs a cardholder to make a purchase that is subsequently determined to be improper, that official shall reimburse GSA and is subject to disciplinary action.
f. Supervisors should consult the servicing human resources office on all disciplinary matters.
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23. Reimbursements to GSA.
a. Cardholders should not send reimbursements directly to the bank. Refund payments should be provided to the AO. The AO will send payments to the Region 6, Financial Operations and Disbursements Branch. In case of a credit, the AO should provide the accounting code of the original transaction for Finance to apply the credit. A copy of the purchase card statement reflecting the overpayment must be attached with the refund payment.
b. The cardholder should follow up with the AO to ensure payment is remitted.
c. All payments must be mailed to the following address:
GSA—6BCEB, Attn: Purchase Card Section, Room 1011, 1500 East Bannister Road, Kansas City, MO 64131
d. Reimbursement must be made by cash, check or money order payable to the
General Services Administration, or a charge authorization for the employee's personal MasterCard, Visa, or Discover credit card using Form GSA3602B, Credit Card Collection Claims and Debts-Region 6.
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Appendix A. Terms and Definitions
Abuse: Use of a Government charge card to buy authorized items, but at terms (i.e. price, quantity) that are excessive, is for a questionable need or both. For example, purchase of a day planner for $300, rather than one costing $45; year-end or bulk purchases of computer and electronic equipment for a questionable need.
Account deactivation: A method to temporarily block the cardholder's ability to make transactions on the account without canceling the account altogether. While the account is deactivated, any transaction that the cardholder attempts to make will be declined at the point of sale. The agency can deactivate and reactivate an account through the charge card vendor's Electronic Access System (EAS) or by calling the charge card vendor. Agency/Organization Program Coordinator (A/OPC): This individual serves as the focal point for answering management, task order administration, establishing and maintaining accounts, and issuance and destruction of cards. The A/OPC oversees the card program(s) for his or her agency/organization and establishes guidelines. The A/OPC helps set up accounts; serves as liaison between the cardholder and the purchase card contractor; provides on-going advice; audits purchase card accounts as required; and keeps necessary account information current.
Approving Official (AO): This individual (typically a supervisor) ensures that the purchase card is used properly. The AO also authorizes cardholder purchases (for official use only), ensures that the statements are reconciled and properly recorded.
Cardholder: The legal agent using the purchase card to buy goods and services in support of official Government business. The cardholder holds the primary responsibility for the proper use of the card and has the authority to perform all reconciliation actions in the Pegasys Reconciliation Notebook.
Cardholder statement: A statement, listing all transactions during the billing period, which is sent to each cardholder.
Data mining: An automated process used to scan data bases to detect patterns, trends and/or anomalies for use in risk management or other areas of analysis.
GSA SmartPay®: The Federal Government's charge card program as of the issuance of this guidance. This program provides Federal Government cardholders a means to pay for commercial goods and services, travel and travel-related expenses, and vehicle fleet expenses. Charge cards are issued through contracts with those charge card vendors who are a part of the SmartPay® program. These contracts, collectively referred to as the "Master Contract," are administered by the General Services Administration.
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Improper purchase: An improper purchase is any purchase that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements. Incorrect amounts include overcharges and undercharges.
Incorrect purchases: Mistakes that are the result of an unintentional error during the purchase process. For example, when a purchase cardholder is asked to buy one filing cabinet, but purchases three cabinets.
Merchant: The source for the agencies’ supplies or services. The merchant may be a required source inside or outside the Government, another Government agency, or a private sector merchant of supplies or services.
Misuse: Use of a Government charge card for other than official Government purpose(s) for which it is intended.
Purchase card: A centrally billed, Government charge card used to pay for goods and services in support of official Government business.
Reconciler: A person who has the authority to perform all reconciliation actions in the Pegasys Reconciliation Notebook for assigned cardholders. Regional Charge Card Coordinator: The individual appointed in writing by the HSSO or RC to manage the purchase card program at the regional level. The Regional Coordinators are responsible to the HSSO or RC for the management of the purchase card program and are under the oversight of the Charge Card Program Division, H1BB. Split transaction: The division of a purchase into two or more transactions to stay within authorized single transaction limit.
Unauthorized purchases: Intentional purchases that are outside the cardholder’s purchasing authority.
Warranted contracting officer: A Government employee with the authority to enter into, administer, and/or terminate contracts and make related determinations and findings. Warranted refers to the extent of the authority delegated to them, normally described by the dollar amount of the authority.
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Appendix B. Sample Pegasys Log Entries
Poor Entries/DON’T Use
Log Entry Explanation
Verizon Repeating a vendor name is not appropriate. Indicate what service is being provided, for whom and the full address and location.
Product 145 Description lacks specificity, plain language and has no meaning to the average person
None.
Never enter "none" as a description for a log, always enter a detailed description.
N/A
Never enter "N/A" in the description log. Always enter a detailed description.
Award The word "award" does not explain the purchase. Describe what kind of award was purchased, who received it and why it was presented.
Signage for front door Lacks the full address and location for the signage
Safety shoes Lacks who received the shoes and the purpose of the purchase.
55" TV Lacks the full address and location of the TV and the reason it was purchased.
iPad accessories Lacks who received the accessories and the purpose of the purchase.
Vehicle adapter plug and fuses
Lacks which vehicle and the purpose of the purchase.
Event rental Lacks the event name, purpose of the event and description of what is being rented.
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Good Entries/DO Use
Log Entry Explanation
Acquisition 101 training for John Doe 9/21/12 - 9/22/12
Indicates what training is being provided, including the employee name and dates.
Plaque award for Jane Smith for retirement on 12/31/2011
Indicates the type of award given, as well as the reason for the award and the recipient.
Safety shoes for Mark Doe to be used on construction grounds as a safety business measure
Indicates whom the safety shoes were purchased for and the justification.
55 inch TV for meetings in RC’s office in region 8, Room 242, W 6th Ave & Kipling St, Lakewood, CO
Indicates what was purchased, the purpose, for whom and the full address and location.
Product Code 145; scraper blades for cleaning in Rm. 1218 at 7th & D Streets SW, Washington, DC
Indicates what was purchased, the purpose, and the full address.
Plaque for installation at the Buffalo Courthouse, 1275 New York Avenue Buffalo, NY
Indicates what was purchased, the purpose and the full, address.
Space rental at the Marriott, 2122 Castle Blvd, Oakland, CA for the SmartPay® conference on 8/12/12 - 8/16/12
Indicates what was purchased, dates of service, purpose and the full address.
Event rental - PA System and Podiums for American Heritage Week at 1800 F St, Washington DC (Lobby) on 4/20/12
Indicates what was purchased, dates of service, purpose and full address.
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Appendix C. Sources and References
1. Regulations, policies, and procedures governing the purchase card
a. Federal Acquisition Regulation (FAR) contains Federal policy on using the purchase card for purchases and payments.
b. Public Law 112-194, Government Charge Card Abuse Prevention Act of 2012
(Charge Card Act) requires all executive branch agencies to establish and maintain safeguards and internal controls for purchase cards and centrally billed accounts.
c. OMB Circular A-123, Appendix B, Improving the Management of Government Charge Card Programs, prescribes policies and procedures to agencies regarding how to maintain internal controls that reduce the risk of fraud, waste, and error in Government charge card programs
d. OMB memorandum 13-21 prescribes additional guidance governing the
implementation of the Charge Card Act by executive agencies to include required safeguards and internal controls, reports of purchase card violations, and Inspector General risk assessment and audits.
e. Treasury Financial Manual (TFM), Volume 1, prescribes procedures, including
program controls and invoice payment that apply to all departments and agencies that use the Government purchase card.
f. GSA policies and procedures. (1) GSA Order, CFO P 4252.1B, Account Payable Policy Manual, provides guidelines for processing vouchers, invoices, and other documents to make prompt and proper payments, incur obligations, and to assist in administering appropriations and revolving funds. (2) GSA Order, CPO 9751.1, Maintaining Discipline, provides policy on managing discipline. (3) General Services Administration Acquisition Manual (GSAM) contains policy on use of the purchase card to make purchases and payments. (4) GSA Order, ADM 7800.12, Management of the U.S. General Services Administration’s (GSA) Internal Personal, establishes policy and procedures for the management of GSA internal personal property. 2. Other references.
a. The GSA SmartPay® website is an information source of publications for the purchase card https://smartpay.gsa.gov. The website is updated on a regular basis.
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b. Pegasys Credit Card User Guide provides the concepts, functions, and
instructions for the Pegasys Credit Card subsystem. The guide can be found on the GSA website at http://pegasys.gsa.gov.
c. Listing of the Central Office Agency/Organization Program Coordinator (A/OPC)
and Regional Charge Card Coordinators (Regional Coordinators) for the GSA purchase card program is available at Purchase Card Coordinators.
d. GSA Form 3661, Purchase Card Application and Maintenance. e. Bank dispute forms can be found on the following website: Cardholder Dispute
Form.
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Appendix D. List of Internal Controls a. Retail blocks or flags are placed on questionable/high risk Merchant Category Codes for management review. b. Data mining of monthly purchase card transactions to identify questionable charges for management review. c. Delivery of monthly file to OIG for all purchase card transactions. d. Review and certification of monthly reports by AOs to monitor cardholder’s activity and ensure that purchases were authorized. e. Suspension of cardholder’s spending authority when AOs fail to review and certify their monthly transactions. The suspension will remain in effect until the AOs certify the reports. f. Cancellation of spending authority for cardholders without an active AO until a replacement AO is assigned. g. Separation of duties to ensure key functions for the same transaction is not performed by the same individual. These key functions include: authorizing purchases and payments, making purchases, certifying funds, reviewing and auditing. Proper separation of duties minimizes GSA’s risk of misuse, fraud, and abuse.
h. Review of Payroll Separation List to ensure separating employees accounts are closed. i. Monitor convenience check usage to ensure compliance with the new policy. j. Periodic review of recurring charges for micro-purchase cardholders to ensure that single purchase limits are not exceeded. k. Review of inactive accounts (no charges in preceding 12 months) for closure. m. Discipline employees for card misuse in accordance with the FAR and GSA’s policy on maintaining discipline. n. Regular monitoring of cardholders that fail to log and reconcile within 10 days of the bank statement line and provide hands-on training on logging, reconciling, and uploading of documents. o. Removal of program participants, i.e. cardholders, AOs, and Regional Coordinators, that fail to adhere to policies and procedures.