Mission and Installation Contracting Center – Fort McPherson
Simplified Customer Service Guide to
Government Purchase Card Procedures
Revised January 8, 2009
Table of Contents
Chapter 1 – The GPC Program 1-1 1-2 1-3 1-4 1-5 1-6 1-7 1-8 1-9 1-10 Purpose References Explanation of definitions Responsibilities Background Authority Policy Applicability GPC Program organization and responsibilities Management of the GPC Program - Mandatory sources - Government Purchase Card - VISA - Single purchase - Backordering - Partial shipment - Separation from Duties as Cardholder/Billing Official - Transfer of Cardholders
Chapter 2 – Establishing and Maintaining a GPC Account 2-1 2-2 Requesting a New GPC Account and Changes to an Account Training 2
2-3 2-4
Account establishment Account Maintenance - Bank contact information Liability of the Government, Cardholders and Billing Official - Unauthorized Use of the GPC - Violation of Use - Cardholder responsibility - Billing Official Responsibility - Account Delinquencies - Late Certification - Repeated Delinquencies and/or - Habitual Late Certification Account Suspension Policy Card Security - Lost or Stolen Card/Account Number
2-5
2-6 2-7
Chapter 3 – Operational Guidance and Procedures 3-1 Make a Purchase - Standards of Conduct - Dispute Procedures o Non-disputable transactions o Disputable transactions o Delayed Disputed transaction - Credit returns - High $ cards Prohibited Purchases and Restrictions Separation of duties Span of Control Tax Exempt Status Property Accountability Merchant Category Code Blocks (MCC) Reconciliation Pay and Confirm 3
3-2 3-3 3-4 3-5 3-6 3-7 3-8 3-9
3-10 3-11 3-12
File Retention Convenience Checks Contingency operations
Chapter 4 – Program Oversight and Reviews 4-1 4-2 4-3 4-4 Monitoring and Surveillance Management Reviews Suspected Waste, Fraud or Abuse Metrics and Reporting Requirements
Appendix A - Definition of Terms
Attachments Atth 1: Purchase Card Certifying Officer Letter Atth 2: DD 577 (Signature Card) Atth 3: Delegation of Authority –Cardholder Atth 4: Cardholder Nomination Request Form Atth 5: Cardholder Statement of Questioned Item (CSQI) Atth 6: Request for Transfer of Billing Official Duties Atth 7: Separation of Cardholder/Billing Official Atth 8: New Billing Official Nomination Form
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Chapter 1 – The GPC program 1-1. Purpose This Standard Operating Procedure will delineate the responsibilities of the Government Purchase Card (GPC), formerly referred to as IMPAC. 1-2. References To find supply and or GPC guidance refer to the following: a. AR 715-XX dated 21 March 2006, the Army GPC regulation b. AR 710-2, Supply Policy Below the Wholesale c. AR 735-5, Policies and Procedures for Property Accountability d. Army Mandatory BPA Memorandum dated 13 September 2004 1-3. Explanation of definitions Definitions are explained in Appendix A. 1-4. Responsibilities Responsibilities are listed in Chapter 1-9. 1-5. Background The General Services Administration (GSA), Federal Supply Service (FSS) awarded Contract (GS-23-F-98002) for Government-wide Commercial Credit Card Services to US Bank System. The contract provides, at the request of Federal ordering agencies, government-wide commercial credit cards and associated services for civilian and military government employees commercial credit card for official government use. For additional information refer to the AR 715-XX, 1-5. 1-6. Authority Refer to AR 715-XX, 1-6 1-7. Policy a. Department of the Army policy is to use the Government-wide Purchase Card for micro-purchases. An Agency/Organization Program Coordinator (A/OPC) appointed by the Mission and Installation Contracting Center – Fort McPherson (MICC CENTER - FT. MCPHERSON) located at Fort McPherson, GA manages the Government-wide Commercial Card Program to ensure that all transactions 5
comply with AR 715-XX, these procedures and any other applicable internal regulations for customers supported by MICC CENTER - FT. MCPHERSON contracting office. b. The GPC is the preferred method to purchase supplies and services up to the micro-purchase threshold, in accordance with Part 13 of the Federal Acquisition Regulation (FAR) and any supplements thereto and as a payment mechanism for orders placed against established contracts or with established sources of supply (see FAR Part 8). The GPC can be used to purchase supplies or services using various methods such as verbal solicitation procedures using fax, phone, email/internet or face to face. c. See Chapter 3-1 for information on High $ Cards. d. For additional information refer to the AR 715-XX chapter 1-7. 1-8. Applicability This guidance applies to all GPC purchases with Army-appropriated funds. Non-Army tenant organizations issued Army GPCs or convenience checks by an Army contracting office are also subject to this regulation. All Billing Officials, Cardholders, A/OPCs (at all levels), Resource Managers, Logisticians, and other stakeholders that participate in the GSA SmartPay Purchase Card Program under the MICC CENTER - FT. MCPHERSONast Level 4 A/OPC are subject to this guidance. The policy established in this document supersedes previous guidance issued by the MICC CENTER - FT. MCPHERSONast Level 4 A/OPC. Explanation of the Army Level hierarchy is provided below at 1-9. 1-9. GPC Program organization and responsibilities a. Level I: The Department of Defense (DoD) Purchase Card Program Management Office (PCPMO) serves as the reporting agency for DoD. b. Level II: The Army responsibility for GPC management is shared by two Level II A/OPCs, one reporting at the DA level to the Deputy Assistant Secretary of the Army (Policy & Procurement) and the DoD PCPMO and the other located at Headquarters-Army Contracting Agency responsible for establishing policies and guidelines, and ensuring effective surveillance within ACA. c. Level III: The Mission and Installation Contracting Center’s A/OPC is located at the Mission and Installation Contracting Command at Ft. Monroe, VA and is responsible for implementing, administering and monitoring MICC’s GPC Program and providing program support to installation A/OPC’s. d. Level IV: The local MICC CENTER - FT. MCPHERSON A/OPC Staff (Agency/Organization Program Coordinator) reports directly to the Level III A/OPC and is responsible for implementing, administering and monitoring the 6
installations GPC Program to include: establishing policy and guidance; conducting regular training; monitoring GPC usage; maintaining accounts; and, conducting annual BO audits. e. Level V: The Billing Official (1) See page ## f. Level VI: The Cardholder (1) See page ## 1-10. Management of the GPC Program - Mandatory sources a. Before making a decision to use a commercial source, the Cardholder will determine if mandatory sources meet the need. If a mandatory source of supplies can fulfill the need or requirement, they must be used. If mandatory sources are not available the Cardholder must document in writing the basis for decision to use commercial sources (see attached sample ##). The Cardholder will screen the following three sources in order of priority, the sources are: (1) Activity/Installation inventories. (DOD Email is to be utilized whenever possible) www.emall.dla.mil. This includes ITEC-4 and ASCP BPA’s. (2) National Industries for the Blind/Severely Handicapped (NIB/NISH). www.basesupply.com (3) Wholesale supply sources (GSA Advantage). www.gsaadvantaqe.qov b. It is mandated by AR 715-XX 1-9(6)(b), the Army Mandatory BPA Memo of 9/13/2004, and by Part 8 of the Federal Acquisition Regulation (FAR) that before purchasing from a commercial source (especially when purchasing office supplies and like items, i.e.: furniture) that mandatory sources must be checked and considered. This process must be documented in writing. As of 1 Oct 2002, the Army has mandated the use of Army Basic Purchasing Agreements on the DOD E-Mall. You may use other Mandatory Sources of Supply to check for price reasonableness, and may use the other Mandatory Source if one of the following exceptions is met: (1) Purchase is made from local JWOD Self-Service Stores (2) The Mandatory BPA vendor cannot meet the delivery requirements (3) If the Mandatory BPA price for JWOD products is determined to be higher in price than found on the commercial market otherwise called the 7
fair market value for that product, then a comparison with other JWOD sources is required and the least expensive JWOD source shall be used. (4) The product does not meet your specifications or requirements c. When buying furniture, although UNICOR is no longer a Mandatory Source they must be considered on all furniture purchases. If UNICOR is used as your source, then a written determination must be prepared that includes supporting rationale explaining it is the Best Value to the Government. Other mandatory sources, as listed in para 1-10(a), must be checked and documented prior to purchasing from a commercial source. d. There are several ways to obtain assistance when making a purchase from UNICOR or mandatory source (i.e. ordering through the Internet or phone, GSA Schedules with office supply firms, use of DLA corporate contracts, etc). The UNICOR catalog (Federal Prison Industries [FPI] trade name for UNICOR) is available on the Internet at http://www.unicor.gov . The e-mail address for Customer Service is http://custsewcentral.unicor.qov. Customer service phone number is 800-827-3168 or fax 606-254-9692. GSA has established contracts with six office supply firms where Federal customers can purchase mandatory Javits-Wagner-O'Day (JWOD) office products (see paragraph a. above). Cardholders do not have to rotate these GSA vendors but it is recommended you do so whenever possible. e. By-pass of DLA managed inventory-managed items is not authorized. However, when the supply system does not offer the best value in terms of time, cost or quality, the Defense Federal Acquisition Regulation Supplement (DFARS) authorizes organizations to procure supplies from commercial sources. - Government Purchase Card - VISA The GPC VISA that the Cardholder receives has his/her name embossed on it and may be used only by the Cardholder. No other person is authorized to use the card such use constitutes fraud. The card was designed showing the Great Seal of the US and the words "United States of America" imprinted on card face to avoid being mistaken for a personal credit card. - Single purchase A single purchase may be comprised of multiple items. A single purchase total using the card cannot exceed the Cardholders authorized single purchase limit. The maximum single purchase limit that can be authorized for Supplies is $3000, the limit for Services is $2500 and for Construction is $2000. Purchases will be denied if the authorized single limit is exceeded. Payments for purchases are not to be split in order to stay within the single purchase limit. Example: If the item you are purchasing has component parts that exceed the micro-purchase threshold, do not purchase each part separately to stay within the single limit purchase. Do not wait one day and 8
purchase the remaining component part(s) to stay within the single limit purchase limit. Do not have another Cardholder purchase the other component part(s) to stay within the single purchase limit. Purchases that are over the single limit purchase are to be processed through normal supply channel procedures or purchased through the Fort McPherson MICC CENTER - FT. MCPHERSON contracting office. Improperly Splitting a Purchase is a violation of Federal Law and may constitute fraud. (18 U.S.C. 1001). - Backordering Backordering is not permitted and all items purchased must be immediately available. This means available for shipment or pickup on the same or next day. However, as an exception, services such a, engraving, custom printed tee-shirts, hats, etc. should be available for delivery within thirty (30) days. - Partial shipment No partial shipments are permitted. The merchant should deliver all items purchased in a single delivery. Orders should not be placed without this assurance by the merchant. Cardholders are cautioned that when buying off the DoD E-Mall that an order consisting of several items may be delivered by multiple vendors in various shipments. This is not considered a partial shipment or if not received all at once it is not considered a backordered item. However, if a Cardholder receives a notice of a backordered item on the shipping invoice the Cardholder is to cancel the item and reorder. - Separation from duties: Cardholder/Billing Official When the Cardholder departs the organization or will no longer make purchases, the Billing Official is to notify the A/OPC in writing to cancel the Cardholder's account. The Cardholder must destroy the GPC card and turn it into their Billing Official (See Atth ##). When the Billing Official departs or is no longer serve as a Billing Official the Billing Official or the Resource Manager shall notify the A/OPC that the Billing Official’s account needs to be suspended or canceled and should be prepared to name a trained Billing Official. The alternate Billing Official shall assume the Billing Officials duties until a new Billing Official is assigned. - Transfer of Cardholders In order for a Cardholder to move from one Billing Official to another, the current GPC cards must be canceled and new accounts must be requested under the name of the gaining Billing Official, using the standard Cardholder Nomination form (See Atth ##).
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Chapter 2 – Establishing and maintaining a GPC account 2-1. Nomination, selection, and appointment of Cardholders and Billing Officials - Request new account set-up a. Requests for new Cardholder accounts must be in writing on the Cardholder Nomination Request (See Atth ##) and must be approved by the Billing Official and the appropriate Resource Manager (RM). The request is then routed from the RM to the A/OPC. Be sure to include copies of most recent training certificate, DAU training certificate, and two each Delegation of Authority Letter completed and ready for A/OPC signature (See Atth 3). New cards will not be issued if training has not been completed. Upon receipt of your credit card, notify the A/OPC. Additionally, notify the A/OPC if you notice any errors in your mailing address or if your mailing address has changed so that necessary corrections can be made. Requests for new Billing Official or Alternate Billing Official accounts must be in writing on the BO/ABO Nomination Request (See Attth ##) and must be approved by the appropriate RM. The request is then routed from RM to the A/OPC. Be sure to include a copy of Billing Official’s most recent training certificates, DAU training certificate, two each Appointment Letter as Certifying Official (See Atth 1) and four each DD Form 577 Signature Card (See Atth 2) completed and ready for A/OPC signature. b. The DD Form 577s must be signed originals, copies and faxes are not accepted. New accounts will not be processed if the appropriate documentation has not been properly completed and submitted. c. It is recommended by the AR 715-XX 1-9(5) that the Billing Official be in the Cardholder’s supervisory chain. - Changes to GPC cards Changes to GPC cards or accounts must be requested in writing and must be routed thru the Billing Official, and RM to the A/OPC. Be sure to include the dates and copies of training certificates if changing Billing Official's or Alternate Billing Official's. Changes to accounts shall be made only by the A/OPC. Requests for increases or decreases MUST be submitted through the proper chain of command. A written request from the Billing Official through the appropriate RM is required. The RM will then notify the A/OPC by email or in writing as to changes to be made to the Cardholder's or Billing Official’s account. The A/OPC will not make changes based directly on Billing Official or Cardholder requests. . 2-2. Training 10
a. Initial Required Training: Government Purchase Card training is mandatory for all Cardholders, Billing Officials and alternate Billing Officials prior to issuance of a Government Purchase Card or appointment as a billing/ alternate Billing Official. This training will consist of: (1) Completion of the mandatory DAU on-line training course, and (2) A 4-6 hours classroom training session. b. The DAU on-line training class at www.dau.mil should be completed prior to attending the classroom session. c. Register the DAU class thru https://www.atrrs.army.mil/channels/aitas/ prior to trying to register for the class on the DAU site. Training will include all phases of using the GPC to include procurement integrity. The A/OPC will offer training classes on a quarterly basis. A schedule of the training classes will be published yearly, check the MICC CENTER - FT. MCPHERSON GPC website (http://www.forscom.army.mil/aacc). d. Annual Refresher Training is mandatory for all Cardholders, Billing Officials and Alternate Billing Officials. In accordance with AR 715-XX, annual refresher training for all Cardholders and Billing Officials can be accomplished locally by the Level IV A/OPC or via the DAU GPC Refresher training course. Cardholders and Billing Officials who fail to complete annual refresher training shall have their GPC account suspended until training is completed. It is highly recommended that all Cardholders and Billing Officials attend locally provided training at least on a biannual basis. Contact the MICC CENTER - FT. MCPHERSON A/OPC to register for local training (See Appx A for contact info) 2-3. Account establishment a. A GPC will be issued only as mission requirements warrant. Only DoD civilian employees and military personnel may be issued a GPC or be appointed a Billing Official. GPCs shall not be issued to contractor personnel. b. Only those personnel with a continuing need to use the GPC will be appointed Cardholders. Billing Officials will advise the Level IV A/OPC when Cardholders no longer have a continuing need or will transfer to other duties or organizations, retire, or leave Government service. c. The Level IV A/OPC, in coordination with the Resource Manager and Billing Official, will set and maintain each Cardholder’s spending limits. The Resource Management Office will establish the default and alternate lines of accounting for the proper designation of appropriation.
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d. In organizations with both appropriated and non-appropriated funds, separate Cardholder accounts must be established to segregate purchases by fund type. 2-4. Account maintenance The MICC CENTER - FT. MCPHERSON GPC team maintains and updates account information as provide by the Billing Official or Resource Management Office. - Contact with US Bank US Bank should be contacted by Cardholders (1-888-994-6722) under the following conditions: a. b. c. d. e. Reporting lost or stolen card Activating a new card Inquiries as to the status of account C.A.R.E. password re-sets C.A.R.E. technical issues
2-5. Liability of the Government, Cardholders and Billing Official - Unauthorized use of the Government Purchase Card Unauthorized uses of the Government Purchase Card are delineated in AR 715-XX. If you have a question regarding whether or not a particular use of your card is authorized consult your A/OPC before proceeding. Among the list of unauthorized uses are: a. Construction (including repairs to real property) - services over $2000. NOTE: Painting is considered a construction service. b. Purchase card will not be used to purchase, rent, or lease any office, quarters or parking spaces, the purchase of meals, or any service for which the government travel card would be appropriate. c. Purchase of award type items for individuals (i.e.: plaques, certificate frames, trophies) or purchases supplemental to these types of items is prohibited. d. The purchase of bottled water without an EPA study declaring the water in the facility not potable. - Violation of use 12
Violation of procedures or improper use of the GPC card may result in the following actions: a. FIRST OFFENSE: Depending on the nature of the offense, the action to be determined by the A/OPC in accordance with AR-715-XX, Section 2-5. b. SECOND OFFENSE: Immediate Suspension and depending on the nature of the offense, the action to be in accordance with AR-715-XX, Section 2-5. Reinstatement must be requested through the Chain of Command and approved by the Resource Management Officer and the A/OPC. c. THIRD OFFENSE: Termination of Account and/or other in accordance with AR715-XX, Section 2-5 and 2-6. - Cardholder responsibility The Cardholder must maintain complete documentation for all transaction made IAW AR 715-XX, Chapter 1, Part 9 and all other regulations and policies as applicable, until all transaction documentation is submitted to the Billing Official after the close of the cycle. The Cardholder’s responsibilities include but are not limited to: a. Maintain complete records of purchases made to include all documentation required by AR 715-XX. b. Submit all originals to the Billing Official within 3 business days after the end of each billing cycle for retention. c. Contact A/OPC immediately if your card is lost or stolen. d. Ensure the safekeeping of your GPC card. e. Ensure that purchases are not "SPLIT" to stay within the micro-purchase threshold. f. Ensure that funds are certified and available before making a purchase. g. Utilize mandatory sources of supply whenever possible. h. Ensure that vendors are rotated whenever possible. i. Ensure that approval is received from your Billing Official before making a purchase. j. Process proper paperwork for all disputed items and following up with merchants after disputed transactions are identified.
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k. Ensure that pricing is fair and reasonable. If you need to go outside of the supply system, maintain a hardcopy of your Army Master Data File (AMDF) for backup documentations to show pricing or unit of issue is more reasonable in the commercial market. l. Notify the BO immediately of any problems you are having (i.e.: accessing ACCESS ONLINE, accessing Transaction Management, not seeing your account information, not receiving a credit card within one month of the request being submitted, or notice any unauthorized charges) m. DO NOT LET ANY OTHER PERSON USE YOUR GPC ACCOUNT. THIS CONSTITUTES FRAUD! - Billing Official Responsibility The Billing Official must maintain complete documentation for all transactions IAW AR 715-XX, Chapter 1, Part 9 and all other regulations and policies as applicable. The Billing Official’s responsibilities include but are not limited to: a. Ensure that you have access to your Cardholder's files. b. Ensure that you have approved your Cardholder's purchases. c. Ensure purchases are not split to stay under the micro-purchase limit. d. Ensure items purchased are not for personal use. e. Ensure that purchases do not exceed the approved spending limit set by the Resource Manager. f. Billing Officials will collect all Cardholder original documentation and retain them for six (6) years and three (3) months. Billing Officials are responsible for ensuring that all purchase transactions have the appropriate documentation IAW AR 715-XX. Any documentation pertaining to dispute actions must be retained until resolved. The Billing Official is responsible for turning over these records to their command for retention upon their departure from that command. g. Billing Officials will be made Certifying Officers and will be pecuniarily liable for purchases made by his/her Cardholders. Billing Officials are liable for any illegal, improper, or incorrect payment due to an inaccurate or misleading certification. h. Verify the transactions meet the legal requirement for authorized purchases. i. Verify the facts presented in the documents for payment are complete and accurate. j. Implement correct dispute procedures when transactions are questioned. 14
k. Create and maintain an Admin File with all support documentation for your Cardholders and your Alternate Billing Official and ensure that all individuals comply with the mandatory training requirements. File should contain Appointment Documentation, Delegation Letters, DAU and Army Training documentation, and a copy of most recent audit report. l. Prepare an internal SOP. m. Ensure that all accounts are certified in C.A.R.E. no later than 5 business days from when the cycle closes each month. n. The Billing Official is responsible for the management of their account, and ensuring that they and all persons (ABO, CH’s) are in full compliance with all regulatory requirements. - Delinquencies The A/OPC will generate a delinquency report on the 20th of each month, for accounts past due. Accounts that are delinquent will be reviewed in accordance with the following: a. If the account is delinquent, the Billing Official will be notified to take corrective action immediately. b. If the account is still on the delinquency report at 60 days, a notice will be sent to the Billing Official and their command, advising immediate corrective action be taken. c. If the account is still delinquent at 90 days, the account will be suspended and a new Billing Official shall be selected - Late certification of monthly statement The A/OPC will generate a late certification report on the 30th of each month. Accounts that have not been certified IAW AR-715-xx will be addressed in the following manner: a. If the account is on the initial report, the Billing Official will receive a Late Certification notice. (1) If the account remains uncertified for 5 business days, after the initial Late Certification notice, a Second Late Certification notice will be sent to the Billing Official and to their command. (2) If the account still remains uncertified an additional 5 business days, after the 2nd Late Certification notice, the account may be subject to 15
suspension. b. If the account has a subsequent instance of late certification, a notice will be sent to the Billing Official and their command advising them of the Certification requirements per Army Regulation 715-xx and to take corrective action immediately. c. If a 3rd cycle is late being certified, a notice will be sent to the Billing Official and their command advising that the account has been suspended. The command may designate a new Billing Official and/or provide a Plan of Action to ensure that certification is done IAW the Army Regulation. - Repeated delinquencies and/or habitual late certification a. The A/OPC will review accounts that have a history of repeated delinquencies or late certification. The A/OPC will send a notice to these Billing Officials addressing these issues and may require them to attend the next GPC training session. Failure of the Billing Official to take the appropriate corrective actions shall be addressed with the command. b. The Billing Official’s account is subject to suspension during this time and the Billing Official may be replaced. If be replaced, the command shall designate a new Billing Official and provide a Plan of Action to ensure that certification is done IAW the program guidelines. 2-6. Card suspension policy a. In accordance with DoD business practices, when any of the following conditions exist the Servicing Bank will automatically suspend Billing Official accounts. When a Billing Official’s account goes over 60 days past due (90 days after the billing date), that Billing Official’s account, and those of all assigned Cardholders within the account, will be suspended until the delinquent payment posts at the Servicing Bank. b. Only the Army Level II A/OPC may reopen accounts that have been suspended before the cause of the suspension has been corrected. 2-7. Card security Cardholders are responsible for properly using and safeguarding their GPCs. Accordingly, Cardholders should take the appropriate precautions comparable to those taken to secure personal checks, credit cards, or cash. - Lost or stolen card/account number Procedures for lost or stolen cards will be implemented as soon as the loss is discovered. The phone number to call in case of lost/stolen card is listed on the SOA and billing statement (1-888-994-6722). If out of the country and unable to dial toll free numbers, call collect to 701-461-2232. However, 16
depending on the time of the loss within the billing cycle, transactions may still appear on the Cardholder's SOA and the Billing Official's billing statement. US Bank will immediately have a new card (account number) issued to the Cardholder and will request Federal Express shipment of the new card. Upon receipt of your new card, immediately notify your A/OPC of your new account number. The Cardholder must also notify the MICC CENTER - FT. MCPHERSON A/OPC program manager in the event of a lost/stolen card and CID if the card was stolen. Chapter 3 – Operational guidance and procedures 3-1. Making a purchase - Standards of Conduct a. Cardholders and Billing Officials hold a public trust; their conduct must meet the highest ethical standards. All agency employees shall use this card only to purchase items of supply and services within the guidance of the GPC program. Cardholders and Billing Officials acknowledge that making false statements on GPC card records may provide support of removing the employee from Federal service. "Unauthorized use means the use of a credit card by (any) person, (including) the Cardholder, who does not have actual, implied or apparent authority for such use and from which the (Government) received no benefit". b. Cardholders, Billing Officials and Alternate Billing Officials may be held pecuniarily liable for erroneous payment due to negligent performance of duties. Failure to act in accordance with regulations, policies and procedures may be considered negligence. Refer to AR-715-XX, Section 2-5(c-d). c. Consult the Joint Ethics Regulation (DOD 5500.7R) for further information and guidance, or contact your local Ethics Counselor. - Dispute procedures The Cardholder works directly with the vendor to correct any problems with purchase card transactions. If the vendor does not correct the problem in a reasonable manner, usually by the time the Cardholder receives the next SOA, the Cardholder should initiate a formal dispute. The formal dispute process requires the Cardholder to complete Cardholder Statement of Questioned Item (CSQI) form (See Attachment 5) and sends or faxes it to US Bank. The Cardholder also sends a copy of the CSQI to his/her Billing Official along with the appropriate monthly SOA. Cardholders can also dispute on line in C.A.R.E. Instead of selecting 'Approve" select 'Dispute' when doing the monthly certification. C.A.R.E. will bring up an electronic version of the CSQI. Complete the form and print it before submitting. a. The Billing Official monitors the dispute process to see that disputes initiated by the Cardholder are eventually settled and credit is provided to the government when appropriate. If a Cardholder disputes a charge, the original CSQI is sent 17
directly to US Bank and a copy is attached to the SOA when it is forwarded to the Billing Official for review. b. The Billing Official will sign and date the SOA and billing statement. Payment will not be withheld for disputed items. The Billing Official will certify the invoice for payment in full, and any credits for the disputed items will be offset against future billings. The Billing Official also safeguards documentation. - Non-Disputable transactions a. Sales Tax: If the vendor charges a Cardholder sales tax, the Cardholder must pay the sales tax and contact the vendor for a credit. In most cases, the vendor will credit the Cardholder's account for the amount of the sales tax. b. Shipping Charges: Shipping charges must be negotiated as a part of the total price of an item. Any shipping charges that are billed by the vendor that were not negotiated as a part of the total price of the item must be resolved directly with the vendor. Should there be erroneous shipping charges and if the vendor will not credit the account, the additional shipping charges must be paid. Shipping charges are included in the single purchase total. c. The Quality of Service: The quality of a service rendered by a vendor is a subjective judgment. If the expectations of the two parties entering into an agreement cannot be made clear by an oral agreement, then the service should be purchased through a formal contract, setting out clear terms and conditions. - Disputable transactions These are transactions that the Cardholder has not authorized to be charged to his/her account, incorrect dollar amount of transaction charged, etc. A Cardholder under VISA regulations has sixty (60) days from close of the cycle to dispute a transaction. If you go past the 60 days, you have lost your right to dispute the transaction. - Delayed disputed transactions In accordance with the Assistant Secretary of the Army for Research, Development and Acquisition (ASARDA) Letter dated 12 July 1996, Cardholders are to delay dispute on non-received items for a period of forty-five (45) days or the receipt of the next SOA, whichever occurs first. In other words, if a Cardholder orders something on the 16th of the month and his billing cycle closing day is the 19th day of the month, often the item has been billed by the vendor but not yet received by the Cardholder, however the item is in route and a dispute should not take place. - Credit returns All credits for returned merchandise are to be processed as a credit to the 18
Cardholder's GPC account and not as a "credit voucher" for application to future purchases.
- High $ cards High $ Cards are only authorized to be used when purchasing against an existing Government contract or open market purchases not exceeding the micro-purchase threshold. The use of the High $ Card is not authorized for open market purchases. All payments for purchases exceeding the micro-purchase threshold are required to be against contracted actions. Submittal of the GPC Purchase Record (R) form to the A/OPC is required for all purchases exceeding the micro-purchase threshold. 3-2. Prohibited purchases and restrictions on GPC use
Purchases made with vendors outside of the United States is prohibited unless in theater. For additional information regarding prohibited items and restriction and a listing of prohibited items refer to AR 715-XX, 3-2 and Appendix C. - Billing cycle purchase limit The spending limit is imposed on a Cardholder's cumulative purchases in a given billing cycle. A purchase limit may be assigned in increments of $100 up to $100,000. This limit may be adjusted, as agencies deem appropriate and shall be established for each Cardholder account. The monthly Cardholder limit is a general budgetary limit assigned by the Billing Official and the appropriate Resource Manager. The Billing Official must coordinate this limit with the program manager that handles his/her particular activity. - Billing cycle office limit This monthly limit is a combined total of all of the Billing Official's Cardholders billing cycle limits x 3. Any office limit may be assigned increments of $100 up to $100,000. The office limit is primarily used for general budgetary control purposes and may be adjusted up or down at any time. Example: If the Billing Official has five Cardholders, two with the billing cycle limit of $5000 and three with the billing cycle of $6000, the approving, the Billing Officials billing cycle office limit is $84,000. 3-3. Separation of duties
The proper separation of duties creates a situation that should preclude errors and attempts at fraud or improper usage of the GPC. Key duties, such as making purchases (Cardholder), authorizing payments (Billing Official), certifying funding (Resource Managers), and reviewing and auditing transactions (Level IV A/OPCs and Property Book Officers) shall be assigned to different individuals in order to minimize the risk of loss to the Government to the greatest extent possible. 3-4. Span of control 19
Billing Official may have no more than a total of seven (7) cardholder accounts assigned to them regardless of how many managing accounts the Billing Official has assigned to them. 3-5. Tax exempt status
When purchasing items by phone or over the counter, the Cardholder should inform the merchant that the purchase is for Official US Government purposes and therefore is not subject to state or local sales tax. 3-6. Property accountability
All activities should follow guidelines set by their supporting property book officer to include accountability procedures, safeguards, etc. All accountable property must be documented and traceable thru a chain of custody. For GPC purchases, an item is considered accountable if it is assigned a manufacturer’s serial number. Activities must follow normal supply channel guidelines. The property book officer and supply personnel will be the qualified resource for determining if items have to be entered into the property book. After purchase, Cardholders must ensure the accountable item is placed on a hand receipt and place a copy of the hand receipt with the transaction documentation. The Billing Official’s are responsible for ensuring that Cardholder files are properly documented to reflect the processing of accountable property on the organization hand receipt. 3-7. MCC blocks and overrides
Refer to AR 715-XX, 3-7 3-8. Reconciliation
- Purchase card account reconciliation 1. Billing cycle a. The billing cycle closing date will be the 19th day of the month. All accounts will be available on-line through Access Online at https://access.usbank.com for up to 6 months. b. Cardholders have 3 business days from the close of the cycle to approve their transactions and approve their statement, and forward all documentation to the Billing Official. c. Billing Officials have 5 business days from when the cycle closes to go on-line, final approve and certify their statement in Access.
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d. Payment card statements are certified using manual procedures. e. The billing statement, which can be printed from Access, reflects the account status of all the Cardholders assigned to the Billing Official. The Billing Official must mark the bank statement with the date and time it was received, sign it, and retain it with the Billing Official files. f. For accounts requiring manual payments, a copy of the signed Billing Statement shall be forwarded to the appropriate paying office. 2. Access Online Access Online replaced the Customer Automation Reporting Environment (C.A.R.E.) and is the on-line system that will be utilized for approval, certification, and transaction log maintenance of all NON-PAYMENT GPC accounts. (If you have a payment account, this Chapter is not applicable to those accounts.) At any given time, the current cycle, as well as the previous five, will be available for viewing. Billing Officials are responsible for verifying all purchase documentation prior to certifying. 3. Receipt of Statement of Account (SOA) Cardholders will print out a copy of their transactions each month off Access Online as well as a copy of their account(s) approval page(s). Description of items purchased on each transaction will have been entered in the Cardholder's credit card log. Disputed charges will be addressed separately. The Cardholder signs the statement, attaches all receipts and other supporting documentation to include copies of hand receipts have been issued as required, and forwards the package to the Billing Official. - Payment Card Account Reconciliation 1. Contract Payment Card Accounts a. Cardholder will forward original Statement of Account (SOA) signed by Cardholder to Billing Official with supporting documentation. b. Billing Officials will maintain the original (date stamped), certified billing statement in their records. Billing Officials are responsible for ensuring that all information for payment is forwarded to DFAS by the 5th business day after the close of the billing cycle. c. Billing Officials are responsible for ensuring that their account is paid and up-todate, this includes working with their Resource Manager and DFAS to resolve any payment discrepancies or errors. d. Billing Officials will submit their completed and accurate statements to the 21
A/OPC by the 5th business day after the close of the billing cycle, and the A/OPC will forward the statement to DFAS via fax (877-575-3332). NOTE: Failure to ensure that payment is made in a timely manner results in lost rebate monies and can result in the government being charged interest penalties. 2. Billing Officials should be aware that if your Cardholder is on leave, TDY, etc., it is your responsibility to complete the Cardholder's SOA and approvals in Access Online (if applicable.) 3-9. Pay and confirm Refer to AR 715-XX, 3-9 3-10. File retention IAW the AR-715-XX, all original (not copies) purchase documentation will be retained for six (6) years and three (3) months after final payment. Documentation for disputed transactions that extend beyond normal retention period must be maintained until discrepancy is settled. 3-11. Convenience checks Refer to local MICC CENTER - FT. MCPHERSON Convenience Check Instruction 3-12. Contingency operations Refer to AR 715-XX, 3-12 Chapter 4 – Program oversight and reviews 4-1. Monitoring and Surveillance
The MICC CENTER - FT. MCPHERSON GPC team monitors all transaction activity, and may periodically require Billing Officials to provide documentation for review to support purchase activity. Additionally, a number of other activities, such as DoDIG; AAA; CID; OMB; etc, have visibility to monitor purchase activity. 4-2. Management Reviews - Audit requirements In addition to the mandatory DOC annual inspections, commanders and managers are responsible for ensuring that adequate management controls are in place and working to provide reasonable assurance that resources are protected from fraud, waste and abuse. The A/OPC will routinely monitor the program to identify potential unauthorized use, misuse or abuse. The A/OPC may request supporting documentation and a 22
written explanation for questionable transactions. If there is evidence of unauthorized use, misuse or abuse, or if there is a failure to comply with the A/OPC's request, the account may be suspended.
- Audits a. Ensure that all files contain a clear audit trail. Credit card files are subject to audit by Internal Review, Army Audit Agency, and the A/OPC. Army policy requires auditing all Billing Officials GPC records each fiscal year. In accordance with that policy, Billing Officials will be notified no less than 15 days in advance of the scheduled audit. If the Billing Official cannot comply with the scheduled audit date they are responsible for scheduling an alternate audit date with the A/OPC. Rescheduled audits should be within 60 days of the original scheduled audit date. b. Audit Reports will be sent to the Billing Official and their command. Billing Officials failing their audit should submit a Plan of Action, signed by the command, addressing their deficiencies within 30 days of the audit report to the DOC A/OPC for coordination and forwarding to the appropriate authority. Failure to comply with this requirement can result in suspension. Billing Officials failing multiple inspections will have their accounts suspended.
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Appendices Appendix A Definition of Terms Agency Organization Program Coordinator (A/OPC) Agency Organization Program Coordinator (A/OPC): Serves as the focal point for the coordination of the applications, issuance, maintenance, destruction of GPC cards, establishment of reports, and all administrative training. This individual also serves as the liaison between the DOC, US Bank, and the GSA Contracting Officer. He/she oversees the GPC program and establishes guidelines, policy and procedures. US Bank will only accept changes to the GPC card from you’re A/OPC. The MICC CENTER - FT. MCPHERSON GPC team consists of the following personnel: Sharon Carson - Supervisor 404-464-4106 sharon.carson@forscom.army.mil Sharon Porter - A/OPC 404-464-4111 sharon.porter@conus.army.mil Patricia Seibert - Asst. A/OPC 404-464-4107 patricia.seibert@conus.army.mil Ray Jackson - Asst. A/OPC 404-464-1452 ray.jackson3@conus.army.mil MICC CENTER - FT. MCPHERSON GPC Web Site
http://www.forscom.army.mil/aacc/GOVERNMENT%20PURCHASE%20CARD/GPC.htm
Alternate Billing Official The alternate Billing Official is responsible for performing the duties of the Billing Official to include certifying the billing statement for payment in the absence of the Billing Official. The alternate Billing Official normally will be the Billing Official's supervisor. Billing Official The duties of a Billing Official include the responsibilities of a purchase card certifying officer. This individual should be in the Cardholders' chain of command, a supervisor and/or a grade higher in rank than the Cardholder, and should meet the following requirements: (a) knowledge of appropriations or funds and accounting classifications; and (b) knowledge of obligation and payment submission process. A Billing Official may have the responsibility of one or more government purchase Cardholders but is limited to no more than seven (7) total Cardholder accounts IAW AR 715-XX. The government uses the Billing Official concept in the commercial credit card program for the monitoring of credit card purchases, internal control purposes, and certifying, the official invoice for payment.
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The Billing Official is responsible for, reviewing his/her Cardholder's monthly statements and verifying that all transactions made were for necessary government purchases and that the Cardholder had prior approval and are in accordance with Federal Acquisition Regulations, this SOP and local agency policies. Other duties may be delegated as agencies/organizations see fit. The Billing Official provides a critical checkpoint by reviewing the Cardholder's transactions to ensure that transactions are necessary and for official government purposes only. The Billing Official is also responsible for ensuring that proper property book procedures have been followed and that hand receipts have been obtained where required. The Billing Official is responsible to ensure that all personnel (alternates BO's and Cardholders) affiliated with their management account(s) are in full compliance with all mandatory training requirements. Automated Data Processing Equipment (ADPE) As defined in Public law 99-500 (40 U.S.C. 759 (a) (2), any equipment or interconnected system or subsystem of equipment that is used in the automatic acquisition, storage, manipulation, management, movement, control, display, switching, interchange, transmission, or reception, of data or information. Cardholder A Cardholder is any individual designated by an agency/organization to be issued a card. The card bears the individual's name and can be used only by that individual to pay for official purchases in compliance with their agency/organization internal procedures, the MICC CENTER - FT. MCPHERSON guidelines, and AR 715-XX. Cardholder Statement of Questioned Item Form (CSQI) The CSQI Form is completed by the Cardholder if he/she recognizes a discrepancy on his/her monthly SOA. A separate form must be completed for each discrepancy (see Encl 5). Certification Certification is the act of attesting to the legality, propriety and correctness of a document for payment as provided for in 31 U.S.C. 3528. Construction Construction, alternation, or repair (including dredging, excavating, and painting) of buildings, structures or other real property by contractors/commercial vendors.
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Credit Card Log The Transaction Log in Access Online required to be used by the Cardholder to record all purchase transactions and details. Delegation of Authority Document issued by the DOC appointing the Cardholder as a procurement official. This delegation specifies the authority being delegated and any limitations on the authority (see Atth 3). Delinquencies An outstanding past due balance that the Government owes to the credit card issuing bank. These past due balances typically occur for one of the following reasons: Late Certification, Faulty Accounting Line information in ACCESS ONLINE, Faulty Accounting Line information provided for manual payment, or monies deobligated after a contract has been issued. GPC Card Review/Checklist Checklist will be used by the DOC when the A/OPC visits an activity to review GPC card files (once annually). Micro-Purchase An acquisition of which the aggregate amount of which does not exceed $3000 for supplies, $2500 for services and $2000 for construction. Micro-purchase limits are set and regulated by Congress thru the Federal Acquisition Regulation (FAR). Official Invoice A document requesting payment be made to the government purchase card contractor. The official invoice (billing statement) covers one Billing Official and one or more Cardholders per billing period. The official invoice is certified for payment by the purchase card Certifying Officer/Billing Official. Open Market Purchase Any purchase being made that is not being placed against an existing, active government contract such as: GSA , Blanket Purchase Agreements (BPA), or Indefinite Delivery-Indefinite Quantity (ID/IQ) contract. Pecuniary Liable Individuals may be pecuniarily liable for incorrect payment as a result of an incorrect or 26
misleading certification. In simple language, this means that an individual may be responsible personally for the amount of loss. Purchase Card Certifying Officer A DOD military member or civilian employee of the Department of Army appointed in writing to certify the official invoice for payment. Both the Billing Official and the Alternate Billing Official will be the designated purchase card certifying officer by issuance of a letter of appointment by the Chief of the Directorate of Contracting or a delegated representative and completion of a signature card (DD Form 577) (see Attachments 1 & 2). The Billing Official is responsible for any illegal, improper, or incorrect payment as a result of inaccurate or misleading certification. The Billing Official certification functions include: a. Verify transactions meet legal requirements for authorized purchases b. Verify that adequate documentation is available for individual transactions c. Take appropriate action to prevent two or more payments for the same transaction d. Implement correct dispute procedures when transactions are disputed e. Issue certification statement to the payment office Receipt of Government Credit Card Receipt letter informs the Cardholder when his/her GPC card was ordered, how to activate the card, etc. Request for New Accounts Memorandum used by supervisors to request issuance of a GPC credit card to an individual. Should an individual require more than one GPC card, a request must be filled out for each card to be issued (see Encl 4). On occasion and with good reason, a waiver may be granted by the Chief of Contracting and must be attached in writing to the request to establish an account. Requirement A requirement constitutes the cumulative requests of similar or like items that exist at the time the order is being placed. Breaking items out on separate work orders does not change the request into a separate requirement. Splitting requirements to circumvent the micro-purchase threshold is fraud.
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Service A contract that engages the time and effort of a contractor whose primary purpose is to perform an identifiable task rather than to furnish an end item of supply. Examples include: maintenance, repairs, housekeeping, subscriptions, consulting services, rentals and operations of equipment. Statement of Account (SOA) The Statement of Account is a monthly listing of all items purchased by the Cardholder and billed by the merchant. Supercard High $ cards which can be used to make purchases against existing Government Contracts (BPA’s, GSA, etc….) which exceed the micro-purchase threshold, up to their authorized Single Purchase Limit. Under no circumstances are orders to be split so as not to exceed the authorized Single Purchase Limit, these actions must go through the contracting office. Supply An item or commodity, that when purchased is owned by the buyer. Does not include real property, such as buildings or land.
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