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Federal Acquisition Service
U.S. General Services Administration
What is the GSA SmartPay® 2 Purchase Card Program?
What is the GSA SmartPay® 2 Purchase Card Program?
Elizabeth SkolnikCamesha EverettOffice of Charge Card ManagementGeneral Services Administration
Elizabeth SkolnikCamesha EverettOffice of Charge Card ManagementGeneral Services Administration
June 2009June 2009
Federal Acquisition Service
Value to the Customer
Learn about the GSA SmartPay® purchase charge card program
Learn about relevant legislation and regulations
Understand specific roles and responsibilities
Learn about fraud and misuse of charge cards, indicators, and preventative measures
Learn and share best practices of charge card program management
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Federal Acquisition Service
Agenda GSA SmartPay® Program Overview
Introducing GSA SmartPay® 2
Purchase Charge Card Overview
Legislation, Regulations, and Oversight
Roles and Responsibilities
Purchase Charge Card Misuse/Abuse and Fraud
Best Practices for Managing Your Purchase Charge Card Program
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Federal Acquisition Service
GSA SmartPay® Program Overview
GSA SmartPay®, established in 1998, is the largest government charge card program in the world
The GSA SmartPay® program enables over 350 Federal agencies, organizations, and Native American tribal governments to obtain charge card products and services through Master Contracts that GSA has currently established with three banks: JP Morgan Chase, U.S.Bank, and Citibank.
Agencies issue task orders against these existing Master Contracts to obtain charge card products and services
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Federal Acquisition Service
Evolution of the GSA SmartPay® Program
Epoch 1 Epoch 2 Epoch 3
Dramatic increase inthe number of cards:
• Cardholders empowered to use cards to conduct Government business
• Assisted with workload management/loss of acquisition personnel
Focus shifted toaccountability and compliance:• Improved card utilization
(reduction in number of purchase cards)
• Increased internal controls
Cards evolve as strategicbusiness tool:
• Strategic sourcing: leveraging buying power of the government to achieve savings and best value procurement
• New products and services: greater “business intelligence”
• Enhanced security
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Federal Acquisition Service
Program Stakeholders Agencies/organizations
• Use charge card products and services to support their missions and operations
GSA Office of Charge Card Management (OCCM)
• Provide overall program management and advocacy
Banks (Bank of America, Citibank, JPMorgan Chase, Mellon Bank, and US Bank)
• Provide charge card products and services through GSA Master Contracts
Associations (MasterCard and VISA)
• Partner with the banks to issue GSA SmartPay® charge cards
Office of Management and Budget (OMB)
• Perform oversight of the government-wide charge card program
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Federal Acquisition Service
Business Lines Purchase Cards
• Use to purchase supplies and services in support of agency/organization missions and operations
Travel Cards
• Cover travel and travel-related expenses
• Only GSA SmartPay® 2 cardholders can access the City Pair Program
Fleet Cards
• Use to purchase government vehicle fuel and maintenance services
• Issued to vehicles, rather than individuals
Integrated Cards
• Offers functionality of two or more of the three business lines
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Federal Acquisition Service
Charge Card Benefits
Administrative savings and efficiency;
• In FY08 agencies/organizations reported $1.72 billion in savings, up from $1.67 billion in FY07
Travel cards provide access to the City Pair program
• 72% average discount off comparable commercial fares
Rebates based on dollar volume and payment performance
Electronic transaction data, enabling better reporting and ability to detect waste, abuse, and fraud
Currently working to obtain Point-of-Sale discounts from various vendors and merchants
GSA SmartPay® provides program-wide representation on regulations and issues impacting the program
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Federal Acquisition Service
Tax Exemption Government purchases are tax exempt, although some merchants may still
apply taxes to the purchases
Each state has different policies and procedures around the tax exemption of purchases made with GSA SmartPay® cards
The GSA SmartPay® website provides information on each state’s requirements; often cardholders will need to print a “tax exemption” certificate to give to the merchant
• Visit the GSA SmartPay® website and click on “tax information”
• The Office of Charge Card Management (OCCM) has requested updated information from states for GSA SmartPay® 2; this information is posted to the website
Tax exemption and recovery plans and processes are an important part of managing your charge card program.
For tax questions contact Camesha Everett at [email protected].
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Federal Acquisition Service
Introducing GSA SmartPay® 2 On November 30, 2008 agencies/organizations transitioned to the new
GSA SmartPay® 2 charge card and began processing transactions through one of the GSA SmartPay® 2 banks:
• Citibank
• JPMorgan Chase
• US Bank
All major customers, with the exception of DHS travel and purchase, transitioned successfully to GSA SmartPay® 2 on or before November 30, 2008; DHS travel and purchase will transition on February 28, 2009 (DHS fleet has already transitioned)
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Federal Acquisition Service
GSA SmartPay® 2 Enhanced Products and Services Contactless cards – faster transactions, the card does not leave
the hand of the cardholder
Pre-paid (stored value) cards – capability to load and reload cards with specific dollar values; cards can be issued with required value on short notice
Cardless accounts – provides established vendor-specific charge accounts without physical cards
Convenience checks – improved ability to issue and reconcile checks online such as:
• Electronic transaction records that must include merchant name
• Online imaging of cleared checks
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Federal Acquisition Service
GSA SmartPay® 2 – New Products and Services Continued
Increased security requirements – increased emphasis on security of both personally identifiable information (PII) and procurement data to minimize risk to individual cardholders and to agencies
• Detailed minimum security standards including FISMA and Payment Card Industry (PCI) security standards
• GSA has conducted bank security system reviews and determined that bank Electronic Access Systems (EAS) are Certified and Accredited (C&A), and are Section 508 compliant
Increased data requirements – more focus on Level 3 data, which provides better insight into the program for agencies/organizations and GSA SmartPay®
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Federal Acquisition Service
GSA SmartPay® 2 – New Products and Services Continued
Improved Program Technology • Increased capability of bank EAS systems to provide flexibility in reporting
and account management, including the ability to:o Generate ad hoc reportso Change category block templates (e.g., MCC blocking)o Dispute transactions electronicallyo Enable A/OPCs to turn cards “on” and “off”
• Data mining tools provided by associations – such as MasterCard’s Expert Monitoring System (EMS) and VISA’s Intellilink – offer additional insight into card program data and trends
• Transaction monitoring to detect misuse, fraud, waste, and abuse (e.g., email alert service)
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Federal Acquisition Service
GSA SmartPay® 2 Purchase Card
Purchase
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Federal Acquisition Service
Purchase Charge Card Overview The purchase card program provides cards to federal employees to make
official government purchases for supplies, goods, and services under the micropurchase threshold of $3,000
• The purchase charge card is both a procurement and payment mechanism for micropurchases
• For purchases above the micropurchase threshold, the purchase card may be used as an ordering and payment mechanism, not a contracting mechanism
The following items may not be purchased with the purchase card, as per the GSA SmartPay® 2 Master Contracts:
• Long-term rental or leasing of land or buildings
• Travel or travel-related expenses
• Cash advances
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Federal Acquisition Service
Purchase Charge Card Overview (continued)
All purchase card accounts are Centrally Billed Accounts (CBA), and the liability for transactions made by authorized cardholders is borne by the government
Use of the card by a person other than the cardholder, who does not have actual, implied, or apparent authority for such use, is not the liability of the government
If the card is used by an authorized cardholder to make an unauthorized purchase, the government is liable for payment and the agency/organization is responsible for taking appropriate action against the cardholder
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Federal Acquisition Service
Purchase Charge Card Program Performance FY08 In FY 2008 purchase charge cards:
• Generated over $19.8 billion in spend up from $18.7 in FY07
• Processed 25.4 million transactions
• Were utilized by 276,000 cardholders
Annual spend volume has almost doubled since FY98 (approximately $10 billion to $19.8 billion in FY08)
The government saves on processing costs and generates revenue through volume refunds:
• Productivity refunds: based on the timeliness and/or frequency of payments to the bank (faster payments = higher refunds)
• Sales refunds: based on the dollar or spend volume during a specified time period
• Corrective refunds: payments made to the agency/organization to correct improper or erroneous payments on an invoice
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Federal Acquisition Service
Convenience Checks Convenience Checks provide increased flexibility to acquire
supplies and services, when the purchase card is not accepted
These transactions are similar to purchase card transactions in that they are listed as line items in the monthly statement and invoice
A/OPCs are responsible for the implementation of the appropriate internal controls and oversight of convenience check activity
There is no authorization process for convenience checks; agencies/organizations may have a dollar limit printed on the check, but there is no automated process to pre-approve the amount of the purchase
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Federal Acquisition Service
Relevant Statutes and Legislation American Recovery and Reinvestment Act of 2009:
• Enacted in February 2009; the bill includes a section on the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). The bill delays the withholding of tax on government contractors until December 31, 2011. This is a one-year delay from the original date.
P.L. 109-222 Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA):• Section 511 mandates a three percent tax withholding on all payments made to government
contractors.
• Given commercial charge card payment model, concerned withholding cannot be accomplished in a sensible manner.
• GSA/OCCM is participating in OMB/OFFM Section 511 working group.
FAR Case 2006-026 Government-wide Commercial Purchase Card Restriction for Treasury Offset Program Debts:
• The Office of Charge Card Management provided comments to the FAR Secretariat – comment period closed February 29, 2008.
• Proposed rule would prohibit use of purchase card as a payment tool under contracts held by vendors with a Federal debt until such time as the debt is resolved. In the meantime, contract payments would be processed using a method subject to levy.
S. 789 Credit Card Abuse Prevention Act of 2007:• OCCM has provided multiple sets of comments to OMB and Hill staff.
• Latest draft of legislation is an improvement.
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Federal Acquisition Service
Public Laws and Regulations for Purchase Cards
Office of Management and Budget (OMB) Circular A-123, Appendix B:
• Establishes standard minimum requirements and best practices for improving the management of government charge card programs
• For more information, visit: http://www.whitehouse.gov/omb/circulars/a123/a123_appendix_b.pdf
Federal Acquisition Regulations (FAR): http://www.acquisition.gov/far/
Agency/organization-specific policies and established procedures
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Federal Acquisition Service
Responsibilities of the A/OPC Agency/Organization Program Coordinators (A/OPCs) are primarily
responsible for overseeing the agency’s/organization’s purchase charge card program in support of its mission and operations
A/OPCs work with the Office of Charge Card Management (OCCM), GSA SmartPay® banks, cardholders, and agency/organization management
A/OPC responsibilities are outlined in the GSA SmartPay® Master Contract and will vary among agencies/organizations
“Level 1” A/OPCs are the highest ranking A/OPC within the agency/organization and the primary agency/organization point of contact with OCCM
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Federal Acquisition Service
Responsibilities of the A/OPC (continued) A/OPC responsibilities may include tasks such as:
• Promoting appropriate use of purchase charge card by cardholders
• Ensuring cardholders receive appropriate training
• Monitoring account activity and managing delinquencies
• Taking appropriate action regarding charge card fraud, misuse or abuse
• Working with the bank to ensure agency and cardholder needs are met
• Resolving any technical and operational problems between the bank and the cardholder as necessary
• Managing agency/organization post-transition challenges or issues with the new GSA SmartPay® 2
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Federal Acquisition Service
Responsibilities of Cardholders
Use of the charge card appropriately, in accordance with agency/organization policy, laws, and governmental regulations
Keep up to date with required training, including refresher training
Look out for communications from A/OPCs and take appropriate action
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Federal Acquisition Service
Responsibilities of Approving Officials (AO)
Approving Officials are responsible for:
• Ensuring that all purchases made by the cardholder are appropriate and charges are accurate
• Resolve all questionable purchases with the cardholder
• Certifying the monthly invoice resulting from the purchases of the cardholders within his/her account structure
• Verifying receipt of the purchase
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Federal Acquisition Service
What is Purchase Card Misuse/Abuse and Fraud?
The use of a purchase card for anything other than official federal government goods and services is considered to be misuse/abuse of the card, and depending on the facts, may involve fraud
Common examples of misuse/abuse include:
• Personal use or unauthorized purchases
• Use for or by someone other than the cardholder
• Purchases from an unauthorized merchant
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Federal Acquisition Service
Non-Cardholder Fraud
Non-cardholder fraud involves use of the card or cardholder data by an unauthorized person
High-risk situations for non-cardholder fraud include:
• The card was never received
• The card was lost
• The card was stolen
• Altered or counterfeit cards
• Account takeover
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Federal Acquisition Service
Possible Indicators of Misuse/Abuse or Fraud
Merchant Category Code (MCC) appears to be outside the cardholder’s general area of responsibility
The account has been closed due to fraud and a new card has been reissued
The cardholder frequently disputes transactions
The cardholder has had multiple authorizations declined
The cardholder makes transactions on non-work days
The cardholder consistently hits his/her monthly limit
The merchant address appears to be a home address
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Federal Acquisition Service
Possible Indicators of Misuse/Abuse or Fraud (continued)
The cardholder has several transactions with the same merchant within a short period of time (e.g., 48 hours), and the transactions total more than $3,000 (micropurchase threshold)
The cardholder is unable to provide proof of purchases such as receipts
The cardholder has multiple transactions of even dollar limits (e.g., $20, $100)
The cardholder repeatedly does business with the same merchants (minimal rotation of sources)
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Federal Acquisition Service
Addressing Misuse/Abuse and Fraud
A/OPCs have the responsibility to report any suspected or actual fraud to the appropriate authorities within the government
If fraud is suspected of a cardholder, merchant, or other third party, A/OPCs may file a complaint with the agency’s Inspector General for investigation
Many agencies/organizations provide a fraud hotline number for reporting misuse/abuse and fraud
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Federal Acquisition Service
Consequences of Misuse/Abuse and Fraud
Reprimand
Counseling
Cancellation of card
Notation in employee performance evaluation
Suspension of employment
Termination of employment
Criminal prosecution
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Federal Acquisition Service
General Charge Card Program Management Best Practices
Engage management at the highest levels
Train A/OPCs and cardholders
Review credit limits and lower as appropriate
Use the bank’s Electronic Access System (EAS), data mining tools, and/or agency/organization technology to run reports for reviewing questionable transactions and monitor charge card spending
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Federal Acquisition Service
Provide the GSA SmartPay® card-sized booklet, “Helpful Hints for Purchase Card Use”, with each cardholder application
Publish frequently asked questions (FAQs) related to the purchase card on your agency’s/organization’s website
Create a monthly newsletter to reinforce agency/organization charge card policies and procedures
Eliminate manually performing data analysis by developing ad hoc reports that can be generated as needed
Perform an annual review of all issued cards to determine if each cardholder meets the criteria for continued participation in the federal government purchase charge card program
General Charge Card Program Management Best Practices (continued)
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Federal Acquisition Service
Best Practices for Convenience Checks
The number of convenience check accounts and the number of checks on hand should be limited to reduce risk
Checks should be secured at all times
Before a check is issued, every reasonable effort should be made to use the purchase card
Cardholders should record the date, check number, payee and amount of each check in their files
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Federal Acquisition Service
Best Practices for Preventing Misuse/Abuse and Fraud
Set reasonable spend limits
Restrict use through MCC Blocks
Deactivate cards as appropriate
Review cardholder activity through reports generated from bank Electronic Access Systems
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Federal Acquisition Service
Set Reasonable Spend Limits Monthly credit limits should correspond to historical spend
patterns and the requirements of the job
Limits may be raised easily to accommodate special circumstances
Higher credit limits increase risk of fraud and misuse/abuse
Restrict Use Through MCC Blocks
Block certain merchant category codes (MCC) to prevent unauthorized use
Remember: MCC blocks are NOT foolproof! Work with merchants/contractors to correct inaccurate MCCs
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Federal Acquisition Service
Deactivation Deactivate purchase charge cards when not in frequent use by
cardholders
A/OPCs may quickly deactivate/reactivate cards electronically or through the bank’s customer service
If a card is deactivated, authorizations will be declined at the point of sale
• Notify cardholder of deactivation, and communicate procedures to re-activate (e.g., who to call, when to call)
• Be wary of automatic billing (e.g. magazine subscriptions) and forced transactions (e.g. vendor manually charges card)
Close purchase charge card accounts for employees/cardholders who leave the agency
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Federal Acquisition Service
Cardholder Activity Review
Segregate questionable transactions
Look for patterns of suspicious behavior
Decline transactions could indicate misuse
Review questionable transactions through Exception Reports
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Federal Acquisition Service
Training Best Practices
Provide a comprehensive face-to-face cardholder training as orientation for new cardholders
Address standards of conduct/ethics and clearly state consequences for misuse
Discuss agency/organization policy
Ensure cardholders and A/OPCs fulfill the required refresher training requirements at a minimum every three years, or more frequently as per agency/organization policy
Ensure that training is easily accessible
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Federal Acquisition Service
Training Resources Purchase-specific GSA SmartPay® online training:
Cardholders: Charting the Course (http://fss.gsa.gov/webtraining/trainingdocs/smartpaytraining/index.cfm)
A/OPCs: (http://apps.fss.gsa.gov/webtraining/trainingdocs/aopctraining/index.cfm)
Agency/organization-provided training
Bank-provided training
GSA SmartPay® Annual Training Conference
Materials (available online, and hard copies may be ordered by visiting http://apps.fss.gsa.gov/cmls):
Blueprint for Success: A Guide for Purchase Card Oversight
Mini card-sized brochure – “Helpful Hints for Purchase Card Use”
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Federal Acquisition Service
Questions?
Elizabeth Skolnik
(703) 605-5736
Camesha Everett
(703) 605-2799
You will find a wealth of contract and program information, training, publications, the GSA SmartPay® 2 Master Contract, and points of contact at our website: www.gsa.gov/gsasmartpay
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