GENERAL SERVICES ADMINISTRATION Washington, DC 20405 OAS 4200.1B June 29, 2017 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 General Services Administration (GSA) policy as established by the Office of Administrative Services (OAS), Office of Travel and Charge Card Services. 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, Office of Management and Budget (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. 3. Scope and applicability. This Order contains policy, standards, instructions and procedures governing the management and use of the purchase card and is not meant to preclude the authorized use of other requisition-based ordering tools (e.g. requisitioning with a GSA activity address code (AAC)) when applicable). Management officials may issue supplemental guidance containing instructions and procedures that do not conflict with this Order. The Order applies to GSA employees who perform any function in the purchase card program and to the Office of Inspector General (OIG) to the extent that the OIG determines it is consistent with the OIG’s independent authority under the Inspector General Act and does not conflict with other OIG policies or the OIG mission. Contractors are not permitted to be cardholders. 4. Cancellation. OAS 4200.1A Management and Use of the GSA SmartPay® Purchase Card. 5. Nature of revision. This Order is being revised to reflect the new roles and responsibilities of the Charge Card Coordinators in OAS, and update procedures for effectively managing the purchase card program. The revised Order incorporates the following policies and procedures:
Transcript
GENERAL SERVICES ADMINISTRATION Washington, DC 20405
OAS 4200.1B June 29, 2017
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 General Services Administration (GSA) policy as established by the Office of Administrative Services (OAS), Office of Travel and Charge Card Services.
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, Office of Management and Budget (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. 3. Scope and applicability. This Order contains policy, standards, instructions and procedures governing the management and use of the purchase card and is not meant to preclude the authorized use of other requisition-based ordering tools (e.g. requisitioning with a GSA activity address code (AAC)) when applicable). Management officials may issue supplemental guidance containing instructions and procedures that do not conflict with this Order. The Order applies to GSA employees who perform any function in the purchase card program and to the Office of Inspector General (OIG) to the extent that the OIG determines it is consistent with the OIG’s independent authority under the Inspector General Act and does not conflict with other OIG policies or the OIG mission. Contractors are not permitted to be cardholders.
4. Cancellation. OAS 4200.1A Management and Use of the GSA SmartPay®
Purchase Card.
5. Nature of revision. This Order is being revised to reflect the new roles and responsibilities of the Charge Card Coordinators in OAS, and update procedures for effectively managing the purchase card program. The revised Order incorporates the following policies and procedures:
a. Memorandum on Increase in the Micro-purchase Threshold and Impact on the GSA purchase card, dated September 11, 2015,
b. Memorandum on Update on Compliance with Federal Strategic Sourcing
Initiative - Office Supplies Third Generation, dated February 19, 2015.
6. Signature.
/S/____________________________
CYNTHIA A. METZLER
Chief Administrative Services Officer Office of Administrative Services
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TABLE OF CONTENTS
Section Number Page Number
1. Roles and Responsibilities……………………………..………….. a. Office of Administrative Services…………………………………………
b. Office of the Chief Financial Officer……………………………………... c. Cardholders………………………………………………………………… d. Requesting Officials……………………………………………………….. e. Approving Officials…………………………………………………………. f. Funds Managers……………………………………………………………. g. Billing Office………………………………………………………………… h. Bank Customer Service Representatives………………………………
1 1 3 3 4 5 6 7 7
2. Selection and Approval Process ……………………...…………..
a. Approving Officials…………………………………………………………. b. Cardholders…………………………………………………………………. c. Charge Card Coordinators…………………………………………………
7 7 7 8
3. Delegations of Authority…………………………………...………. a. Authority for Micro-purchases……………………………………………. b. Authority for Other Purchases……………………………………………
8 8 8
4. Training ……………………………………………………………….
8
5. Establishment of New Accounts ………………………………... 6. Account Maintenance………………………………………...…….
7. Cardholder Transfer ………………………………………………….. 8. Name Change………………………………………………………... 9. Cancellation of Cardholder Accounts……………………………... 10. Single and Monthly Payments……………………………………
8 8 8
9 9 9
11. Number of Cards per Cardholder………………………………… 12. Emergency Situations…………………………………………….. 13. Termination of Cardholder Duties……………………………… 14. Termination of Approving Official Duties……………………
9
9
9
9
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15. Issuance of Cards……………………………………………………. 16. Safeguarding of Cards……………………………………………… 17. Lost or Stolen Cards………………………………………….……. 18. Card Renewal………………………………………………..………. 19. Reinstatement………………………………………………….……..
10
10
10 10
10
20. Purchases at or below the Micro-Purchase Threshold..………..10 21. Ways to use the purchase card …………………………………… 11 22. Approval ……………………………………………………………… 11 23. Blanket Authorization……………………………………………… 12 24. Required Sources of Supplies and Services.………………… . 12 25. Section 508 of the Rehabilitation Act …………………………… 12 26. Environmental Quality of Products Procured with Purchase Cards……………………………………………………………..12 27. Competitive Price Quotations ………………………………….… 13 28. Small Business Requirements…………………………………… 13 29. Federal Strategic Sourcing Initiative……………………………....13 30. Purchases subject to Commercial Supplier Agreement Terms..13
31. Purchases above the Micro-Purchase Threshold……………..…13 32. Intra-Governmental Purchase………………………………………..14
33. Prohibited Use of the Purchase Card ……………………………. 14
42. Record Retention…………………………………………………....17 43. Other Purchases…………………………………………………….17
a. Subscription………… ………………………………………………….…17 b. Building Services and Construction…………..……………………….…17 c. Memberships………… …………………………………………………....18 d. Advertisements… …………………………………………………………18 e. Recurring Bill or Payment…… …………………………………………..18 f. Training and Education..…… ……………………………………………18 g. Meals and Beverages……… …………………………………………....19 h. Conferences…………………………… ………………………………....19 i. Local Travel …………………………… ………..………………..……….19 j. Parking ……………………………………… …………………………….19
44. Program Oversight……………………………………………….……19
a. Inactive Cards Report……………………………………………………..19 b. Impending Suspension Report…………………………………………..19 c. Questionable Charges Report...………………………………………….20 d. Employee Separation List………………………………………………...20 e. Log and Reconciliation Report…………………………………………..20 f. Approving Official Span Report…………………………………………..20 g. Reconciliation of Approving Official Report…………………………….20 h. Reconciliation of CHRIS to Cardholders with the Servicing Bank .....20 i. Potential Split Transactions Report...…………………………………….20 j. Lost and Stolen Report...…………………………………………………..20 k. Merchant Category Code…………………………………………………20
45. Disciplinary Actions for Improper Use of the Purchase Card. 21
46. Reimbursements to GSA…………………………………..……… 21
Appendix A. Terms and Definitions………………………..…….…. A-1 Appendix B. Sample Pegasys Log Entries………………..………. B-1 Appendix C. Sources and References……………………………….C-1 Appendix D. Convenience Checks…………………………………... D-1
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Appendix E. List of Internal Controls………..…………………….… E-1 Appendix F. Essential Policy Requirements for the Purchase Cardholder…………………………………………………………..…… F-1 Appendix G. Essential Policy Requirements for the Approving Official……………………………………………………………………... G-1 Appendix H. Essential Policy Requirements for the Charge Card Coordinator........................................................................................ H-1
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MANAGEMENT AND USE OF THE GSA PURCHASE CARD
1. Roles and responsibilities.
a. Office of Administrative Services (OAS) (H).
(1) Office of Travel and Charge Card Services (H1C).
(a) Provides leadership in policy, strategic planning, and program management.
(b) Establishes GSA policies, procedures and internal controls for the management and use of the GSA purchase card in compliance with laws and regulations, to include OMB Circular A-123, Appendix B.
(c) Appoints Charge Card Coordinators throughout GSA.
(d) Removes charge card participants from the program who fail to comply with policy.
(e) Approves requests for use of convenience checks.
(2) Charge Card Division (H1CC).
(a) Serves as Agency/Organization Program Coordinator (A/OPC).
(b) Manages and oversees the GSA charge card program. (c) Develops and updates the Charge Card Management Plan. (d) Develops and implements charge card training. (e) Prepares reports for OMB. (f) Develops and implements corrective action plans based on audits. (g) Develops management reports to monitor program effectiveness.
(h) Conducts reviews to ensure program participants comply with GSA purchase card policy and regulations.
(i) Serves as the liaison for audits and reviews.
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(j) Conducts annual risk assessment. (k) Suspends charge card privileges for non-compliance with policy.
(3) Charge Card Coordinators.
(a) Ensure cardholders and approving officials (AOs) comply with GSA purchase card policy and regulations.
(b) Serve as the liaison between GSA and card issuing bank.
(c) Ensure new cardholders and AOs complete mandatory purchase card training.
(d) Ensure GSA Form 3661, Purchase Card Application and Maintenance, is complete and accurate before processing.
(e) Ensure the data on GSA Form 3661 is entered correctly in Pegasys
and the bank’s electronic access system (EAS)
(f) Monitor and ensure AOs resolve questionable purchase card charges in 30 business days. Suspend charging authority of cardholders under AOs who do not comply.
(g) Monitor and ensure AOs review and certify their Pegasys monthly
transactions report within 10 calendar days of receipt from Pegasys.
(h) Monitor and ensure cardholders complete the purchase card mandatory refresher training, when requested. Suspend charging authority of cardholders who do not comply.
(i) Monitor and ensure AOs complete the purchase card mandatory
refresher training, when requested. Suspend charging authority of cardholders under AOs who do not comply.
(j) Monitor and ensure cardholders re-certify their security access in
Pegasys, when requested. Suspend charging authority of cardholders who do not comply.
(k) Monitor and ensure AOs re-certify their security access in Pegasys, when
requested. Suspend charging authority of cardholders under AOs who do not comply.
(l) Monitor and ensure cardholders log and reconcile their purchase card
transactions timely in Pegasys (see par 37). Suspend charging authority of cardholders who do not comply.
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(m) Monitor and ensure cardholders upload their supporting documents in Pegasys (see par 38). Suspend charging authority of cardholders who do not comply.
(n) Upon notification of suspected misuse by the AO, suspend charging
authority of cardholders pending the outcome of an investigation.
(o) Cancel cardholder accounts upon separation from GSA or upon notification that the cardholder no longer requires a purchase card because of a change of organization, position or role.
b. Office of the Chief Financial Officer (OCFO)
(1) Conducts an 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) Develops the requirements for the ADM P 5400.41B Agency Internal Control
Program at https://insite.gsa.gov/portal/content/522626.
(3) Monitors purchase card logging and reconciliation in Pegasys.
(4) Conducts audits on purchase card transactions, as warranted.
(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. Cardholders.
(1) Complete all required training and submit documents before obtaining the purchase card. Application instructions are available on the webpage at https://insite.gsa.gov/portal/content/581386. In addition, cardholders must understand how to log and reconcile purchase card transactions, and upload supporting documentation in Pegasys prior to becoming a cardholder. (See Appendix F)
(2) Use the purchase card only for official business in compliance with
applicable procurement laws, regulations, and GSA policies.
(3) Use the purchase card to procure all authorized purchases and/or pay for authorized goods and services, whenever possible. The cardholder must:
(a) Obtain written authorization (see par 22) from the AO before making any purchase.
(c) Obtain independent verification of receipt and acceptance for all orders of goods over $500 (see par 40).
(d) Log and reconcile purchase card transactions timely (see par 37).
(e) Upload supporting documentation in Pegasys (see par 38).
(f) Not split purchases to circumvent the micro-purchase threshold (see par 33).
(g) Review the bank billing statement to ensure the accuracy of the statement. Resolve errors with vendors and bank, as necessary
(4) Use convenience checks only when approved by the Office of Travel and
Charge Card Services.
(5) Contact the vendor immediately and take corrective action if the purchase card is erroneously used (e.g. a purchase card is used in lieu of the travel or personal card).
(6) Safeguard the card, convenience checks (when applicable), and account number and prevent others from using them.
(7) Report lost/stolen card to the servicing bank by calling their Customer Service number. Also report the loss to the Charge Card Coordinator.
(8) Complete the annual Pegasys recertification process, when requested. Failure to recertify will result in the suspension of the Pegasys account.
(9) Respond timely to requests for documentation to auditors and OAS. Untimely response will result in the suspension of the purchase card account.
(10) Attend the purchase card training provided by the Charge Card Coordinator at least once a year. Failure to attend may result in the suspension of the purchase card.
(11) Respond to monthly questionable transactions on the Questionable Charges Report upon receipt from your Charge Card Coordinator. Failure to respond timely will result in the suspension of your purchase card.
d. Requesting Officials (typically a Division Director/equivalent or higher level official), Heads of Services and Staff Offices (HSSOs), and Regional Commissioners .
(1) Designate employees to be cardholders or AOs based upon the needs of the program office.
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(2) Ensure AOs are in the same Service or Staff Office as the cardholder. This includes re-organization and consolidation activities.
(3) Ensure AOs are the same or higher grade as the cardholder, preferably the cardholder’s 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.
(6) Ensure cardholders and AOs perform their duties in accordance with policies and procedures.
(7) Take appropriate administrative or disciplinary action in accordance with CPO 9751.1, Maintaining Discipline, https://insite.gsa.gov/portal/content/523318, when notified of cardholder misuse and/or abuse.
(8) Cooperate with all reviews or audits of the charge card program.
(9) Notify the Charge Card Coordinator to close the cardholder’s purchase card when the card is no longer needed.
(10) Ensure a replacement AO is identified within five business days when an AO relinquishes their charge card duties or leaves GSA (see par 14) .
e. Approving Officials (AOs).
(1) Ensure the purchase card is used properly for government business: (a) Ensure purchase is necessary and for official use.
(b) Ensure applicable procurement regulations and policies are followed (See Appendix C, Sources and References). When in doubt, consult the Office of General Counsel (OGC).
(c) Consult OGC before authorizing the purchase of meals and beverages. There are restrictions on such purchases. See General Counsel Memorandum dated July 22, 2005 at https://insite.gsa.gov/graphics/staffoffices/ADMIL-12-01AttachmentA-MealsandRefreshments23.pdf
(2) Authorize all purchase card transactions in writing before purchases are
made by the cardholder (e-mail is acceptable). If the AO is not available, a higher level official in line of authority over the AO may issue written authorizations for purchase card transactions.
(3) Monitor the purchase card activity of assigned cardholders:
(a) Ensure unauthorized or improper transactions by the cardholder are reimbursed to GSA and disciplinary actions are imposed.
(b) Review and certify Pegasys Monthly Credit Card Transactions reports within 10 calendar days of receipt.
(c) Prior to relinquishing AO responsibilities, review and certify all charges for the cardholders for the statement cycle. A higher level official may also certify the Pegasys monthly transactions report in the absence of the AO.
(d) Ensure cardholder disputes are resolved timely.
(e) Notify the Charge Card Coordinator and the OIG upon evidence of unauthorized charges or misuse by the cardholder.
(4) Ensure cardholders respond timely to the questionable charges report. Failure of the cardholder to respond timely will result in the suspension of the cardholder’s purchase card.
(5) Discipline cardholder for improper use of the purchase card in accordance
with GSA Order, CPO 9751.1 Maintaining Discipline, https://insite.gsa.gov/portal/content/523318. Consult the Office of Human Resource Management (OHRM) and Office of General Counsel (OGC) for assistance with any proposed disciplinary action.
(6) Complete all required training and submit documents before becoming an AO. Application instructions are available on the webpage at https://insite.gsa.gov/portal/content/581386
(7) Complete the annual Pegasys recertification process, when requested. Failure to recertify will result in the deactivation of the AO’s Pegasys account and the account of the cardholders under the AO.
(8) Notify the Charge Card Coordinator and/or requesting official when the AO or a cardholder under the AO separates from the office or GSA.
(9) Ensure cardholders respond timely to audit requests for documentation from auditors, OAS, and other management officials.
(10) Request suspension of a cardholder‘s account if a cardholder is expected to be away from the office for more than 20 business days.
(2) Ensure that funding is available for cardholder’s use. (3) Monitor fund levels. (4) Approve GSA Form 3661, Purchase Card Application and Maintenance,
https://www.gsa.gov/portal/forms/download/115150, for changes to purchase card limits, changes to default accounting code, and the establishment of new cardholders. Verify the accuracy of the default accounting code on GSA Form 3661.
g. Billing office. The financial shared service provider processes payments daily for the purchase card program and performs audit of payment transactions.
h. Bank Customer Service Representatives.
(1) Activate accounts.
(2) Provide account information (i.e. balance, availability).
(3) Cancel reported lost or stolen cards and cards assigned to 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 Charge Card Coordinators or other authorized OAS management official.
2. Selection and approval process.
a. Approving Officials (AOs). GSA employees that oversee cardholder accounts are AOs. The requesting 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. Only six cardholders are assigned to an AO for effective oversight, monitoring, reconciliation and review of cardholders’ accounts.
b. Cardholders. GSA employees that are authorized to buy goods/services on behalf of their division/organization. Cardholders are responsible for the proper use of the purchase card. The requesting 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.
c. Charge Card Coordinators. OAS appoints Charge Card Coordinators. All coordinators report directly to OAS and perform charge card duties on a full-time basis. A list of Charge Card Coordinators is available on the following webpage, https://insite.gsa.gov/portal/content/500047.
3. Delegations of Authority. Head of Contracting Activity (HCA) is delegated in GSA Order ADM 5450.171, at https://insite.gsa.gov/portal/content/520721.
a. Authority for micro-purchases. The HCA may authorize Division Directors (or equivalent) or higher level officials to delegate authority to employees to make purchases not to exceed the micro-purchase threshold. Micro-purchase cardholders may be designated on GSA Form 3661.
b. Authority for other purchases. The HCA appoints all contracting officers with authority above the micro-purchase threshold. Contracting officers who are cardholders may be designated on GSA Form 3661 and must hold a Certificate of Appointment (Warrant).
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 and Charge Card Coordinators must complete mandatory purchase card training prior to appointment. All program participants must complete refresher training every three years.
ACCOUNT ESTABLISHMENT AND MAINTENANCE
5. Establishment of new accounts. The requesting official must follow the instructions on the webpage at https://insite.gsa.gov/portal/content/581386, Application & Renewal Procedures, and submit the required documents to the Charge Card Coordinator for processing. 6. Account maintenance. All changes to the cardholders’ purchase card account or AO must be reported on GSA Form 3661 and submitted to the Charge Card Coordinator for processing. An e-mail is acceptable for decrease to purchase limits, change of address or cancellation of accounts. 7. Cardholder transfer. Procurement authority does not transfer. If cardholders are transferring to another organization within GSA, the acquiring office must submit a
request for AO and default code change on GSA Form 3661. In the absence of a GSA Form 3661, the Charge Card Coordinator must suspend the purchase card. 8. Name change. The requesting official must provide documentation supporting the name change in addition to GSA Form 3661. 9. Cancellation of cardholder accounts. The requesting official must initiate action to cancel the purchase card for each cardholder who separates from GSA or no longer needs a card by submitting a GSA Form 3661 or an e-mail to the appropriate Charge Card Coordinator. 10. Single and monthly purchase limits. The single purchase limit (transaction limit) for micro-purchase cardholders cannot exceed the micro-purchase threshold as described in par 20, Micro-purchase threshold. For warranted contracting officers, the single-purchase limit may not exceed the Simplified Acquisition Threshold (currently $150,000). The monthly purchase card limit for a micro-purchase cardholder is $100,000. The monthly purchase card limit for a warranted contracting officer cardholder is $250,000.
11. Number of cards per cardholder. Only one purchase card is issued to each approved 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.
12. 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. 1903), 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.
13. Termination of cardholder duties. Prior to or on the last day of being a cardholder, cardholders must relinquish their purchase cards to the AO or Charge Card Coordinator for destruction. Cardholders must relinquish all records and supporting documents to the AO.
14. Termination of AO duties. Upon termination of their duties, the AO must relinquish all records and supporting documents to the HSSO or requesting official. The purchase card documents are the property of the program office. The HSSO or requesting official must submit a GSA Form 3661 requesting a new AO to the Charge Card Coordinator. The HSSO has five business days to assign a new AO to prevent the suspension of the cardholders’ account under the departing AO.
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CARD ADMINISTRATION
15. Issuance of cards. The bank delivers the card to the cardholder’s office address approximately two weeks after the application is processed. Upon receipt of the card and prior to use, the 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 Charge Card Coordinator to determine the status.
16. 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 other physical safeguard that can only be accessed by the cardholder.
17. Lost or stolen cards. The cardholder may be held accountable for failure to report the loss of a card. 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. If a lost card is found after receiving a replacement card, it shall be destroyed. 18. 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 Charge Card Coordinator. Cardholders must destroy the expired card upon receipt of the renewal card.
19. Reinstatement. Cardholders and/or AOs must retake the required purchase card training for accounts that have been closed, suspended, or terminated for more than 12 months.
REQUIREMENTS FOR THE USE OF THE PURCHASE CARD
20. Purchases at or below the micro-purchase threshold.
a. All micro-purchases 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. b. The micro-purchase threshold is defined in FAR 2.101 is $3,500 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,
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(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. 1903).
(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.
21. Ways to use the purchase card. When placing a written or telephone order, cardholders must inform the vendor that the transaction may not be processed until the order is shipped or services are performed. This restriction does not apply to subscriptions which can be paid in advance (see par 43). Cardholders can use their card for micro-purchases in the following ways:
a. Visit local merchants to shop for the items and present the card for payment.
b. Place orders over the internet.
c. Call a vendor, place an order, and provide the purchase card number to pay for the order.
d. 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 and safeguard the information.
22. Approval. A pre-written authorization is required from the AO before a purchase is made. A higher level official may approve the authorization when the AO is not available.
a. Written authorizations are required to determine that supplies or services are needed for official business and approved for purchase. The written documentation must:
(1) Be in the form of an e-mail, memo, note, fax, or other authorized form.
(2) Indicate the requesting person’s name, item description, quantity, estimated cost of the item plus shipping and handling, date of request, accounting code, date the goods or services are needed, and any other ordering limitations. A tolerance level of 10 percent to the estimated cost of the item(s) is acceptable for shipping without additional authorization. Consult your Funds Manager or Budget Analyst for the correct accounting code. For example, a micro-purchase cardholder was approved to purchase goods for $2,500 with shipping and handling costs for $17 totaling $2,517. The
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cardholder learned from the vendor that shipping and handling costs have increased to $25 for a resulting total of $2,525. The cardholder does not need additional authorization to make the purchase because the total cost of the item is increased only by .32% ($2,525-$2,517)/$2,517) which is less than 10%.
b. An AO may not approve a written authorization for a cardholder to purchase
items for their own use. A higher level official must authorize and approve the request.
23. Blanket authorization. An AO may approve a written blanket authorization for supplies or services that are needed. Each individual purchase must not exceed the micro-purchase threshold of the cardholder. Blanket authorizations must not be used for monthly recurring services that exceed the single purchase threshold (see par 43). The authorization must include the AO’s name, signature, and date. The authorization remains in effect until modified or rescinded. 24. Required sources of supplies and services. 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 12. In general, cardholders should order through the Office Supplies Blanket Purchase Agreements when the items needed are not available from a source holding a higher purchase priority. Cardholders must comply with the following guidelines when making micro-purchases:
a. Required sources of supply are used, if applicable.
b. Micro-purchases are distributed among qualified suppliers. c. Price is reasonable, as described in competitive price quotations. d. Purchase is pre-approved. e. Section 508 of the Rehabilitation Act requirements are met. f. Environmentally preferable products and services requirements are met.
25. 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. Cardholders are encouraged to take the training to gain familiarity with EIT products. More information is provided at https://insite.gsa.gov/portal/content/627586. 26. Environmental quality of products procured with purchase cards. Cardholders are required to purchase products with certain environmentally-preferable attributes. They are encouraged to review GSA’s Green Purchasing Plan training titled, “Green Purchasing for the Federal Acquisition Workforce,” to gain familiarity with the products and services. GSA Advantage products and services are available to assist in making
environmentally-preferable and compliant purchases. More information is available at https://sftool.gov/greenprocurement. 27. 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 at or below the micropurchase threshold are not necessary if the price charged for an item is deemed reasonable by the cardholder.
28. 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.
29. Federal Strategic Sourcing Initiative (FSSI). a. The goals of FSSI are to reduce the costs of commonly acquired goods and services within the Federal government, reduce the cost of doing business, and increase the achievement of socio-economic acquisition goals (both at the prime and subcontract level). b. GSA cardholders must use the FSSI for the purchase of office supplies. For common office supplies, employees located at GSA Headquarters and regional offices must check if the desired supplies are available in the OAS-managed service centers located in the building. If an office supply item is not available, employees must contact OAS Workplace Services to place a special order. Additional information on the office supply initiative is located on this webpage: https://www.gsa.gov/portal/content/195439 30. Purchases subject to Commercial Supplier Agreement terms. Many supplies or services are acquired subject to supplier license agreements (commonly referred to as End User License Agreements (EULAs) or Terms of Service (TOS). These are particularly common in information technology acquisitions, but they may apply to any supply or service. Many of these agreements contain clauses that are inconsistent with Federal law. GSA cardholders must review the Commercial Supplier Agreement terms and familiarize themselves with GSA Acquisition Letter MV-15-03, Class Deviation Addressing Commercial Supplier Agreement Terms that Conflict or Are Incompatible with Federal Law, July 31, 2015, and CIO 2160.1F CHGE 2, GSA Information Technology (IT) Standards Profile, March 31, 2017. 31. Purchases above the micro-purchase threshold. Cardholders with contracting authority for purchases over the micro-purchase threshold may not use the purchase
card as a contracting mechanism (see FAR 8.4). Cardholders must comply with FAR 13.301, Government-wide commercial purchase card, all applicable Federal procurement laws and regulations, and GSA policy. The use of the charge card as a payment or ordering mechanism does not change any of those requirements.
32. Intra-Governmental purchase. 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. See GSA Order, CFO P 4253.1B CHGE 1 Accounts Receivable and Debt Collection Policy Manual, at https://insite.gsa.gov/portal/content/531626 for information on the OCFO accounts receivable policy on accepting the purchase card for collection of debt. The preferred method for placing orders within GSA is the interfund process in Pegasys.
33. 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. e. Travel or travel-related expenses, except local travel as defined in GSA travel
policy, OAS 5770.1 Local Travel, https://insite.gsa.gov/portal/content/667422
f. Fleet-related expenses such as fuel, oil, routine maintenance, or repair services. Questions regarding the fleet card use should be addressed to GSA SmartPay® Program Support, at (703) 605-2808, or visit https://www.smartpay.gsa.gov/. Additional information is also available in GSA Order, ADM P 5620.1 GSA Internal Motor Vehicle Management, https://insite.gsa.gov/portal/content/520990
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. Use by someone other than the cardholder. OAS will close the cardholder’s account upon becoming aware that the account number is used by another employee.
k. Convenience checks, except as noted in Appendix D. If a vendor does not accept the purchase card, the cardholder must process a Direct Pay in Pegasys or use another vendor.
l. 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 knowingly violates this policy. Cardholders and AOs 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. m. Membership in any retail trade businesses or commercial activities. For example, a cardholder is not permitted to pay for a membership to obtain free shipping services and receive free video and music streaming.
34. Tax recovery. All GSA SmartPay® Purchase Cards are centrally billed accounts (CBA) and are exempt from state taxes. 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”. Refer to this webpage for more information on tax exemption, https://www.smartpay.gsa.gov/content/state-tax-information.
35. Merchant 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. Go to https://www.smartpay.gsa.gov/content/purchase for additional information.
36. Card decline. If the purchase card is rejected while making a purchase, cardholders shall contact the bank’s customer service or the Charge Card Coordinator for assistance. The bank’s customer service phone number is located on the back of the card.
37. Mandatory logging and reconciliation of transactions. 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. Instructions on logging and reconciliation are available on this webpage: https://pegasys.gsa.gov/ref/qrc.htm.
a. Cardholders or reconcilers must log purchase card transactions in Pegasys when a purchase is transacted with the vendor using the credit card logging feature for training (CT) or for all other purchases (CL). The description of the log must clearly communicate what is being procured and/or paid for by the 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. See Appendix B for a sample of log entries in Pegasys. b. Cardholders or reconcilers must manually reconcile the log within 10 calendar days from receipt of the bank statement line if the logged transaction did not reconcile automatically. Manual reconciliation prevents duplicate obligations which encumber budgetary resources, add invalid detail to management reports, and increase the risk of audit findings.
38. 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. Upon verification by the cardholders that the documents have been successfully uploaded in Pegasys, the paper documents may be discarded. Instructions on How to Attach a Document are on the webpage at: http://pegasys.gsa.gov/ref/qrc.htm. Support documents include:
(1) Order form or pre-written authorization must be uploaded when the log is created in Pegasys. (see par. 22).
(2) Invoice or receipt must be uploaded within five business days of receiving the goods from the vendor.
(3) Independent verification of receipt and acceptance of goods over $500 must
be uploaded within five business days of receiving the goods from the vendor. (see par. 40).
b. Cardholders must upload a blanket authorization in Pegasys for all purchases
made under the blanket when the log is created in Pegasys (see par 23).
39. Disputes.
a. The cardholder must review the bank billing statement monthly to ensure the accuracy of the statement. If there are errors or inconsistencies, the cardholder must start the dispute process no later than 60 calendar days after the date of the bill that reflects the incorrect charge or problem. Information on disputing a transaction is addressed on the back of the bank billing statement under Account Inquiries, and on the
b. In instances, where a cardholder fails to dispute and/or resolve an improper charge in a timely manner, 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. 40. Verification of receipt and acceptance. Purchases of goods over $500 must be documented by someone other than the cardholder to ensure goods are received and fulfill the quantity and quality requirements of the order. As confirmation of receipt, the individual other than the cardholder must record on the sales invoice, packing slip, bill of lading, or other shipping or receiving document the following information: name (typed or legibly written), date items are received, and signature. The individual receiving the goods may also send an e-mail to the cardholder stating item was received. Cardholder must upload the verification document to the log in Pegasys for audit and tracking purposes. 41. Property accountability. Purchase cardholders and AOs must adhere to GSA’s personal property policy contained in GSA Order, ADM 7800.12 Management of the U.S. General Services Administration’s (GSA) Internal Personal Property, https://insite.gsa.gov/portal/content/523574. 42. Record retention. All purchase card documents must be maintained electronically. The retention period for finance to maintain financial records/payment is six years and three months. 43. 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 use the purchase card for building services and alterations in accordance with ADM 5450.45 Delegation of Authority to the Heads of All Federal Agencies that Occupy Space in Facilities Under the Custody and Control of the General Services Administration, at https://insite.gsa.gov/portal/content/665290
c. Memberships. 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. Cardholders are prohibited in purchasing memberships in any retail trade businesses or commercial activities. The organizational membership must not be in the name of an individual employee or employees. The organization's membership may authorize any designated employee to attend functions as GSA’s representative. When in doubt, purchase cardholders must consult OGC before using the purchase card. See HRM P 9410.1 GSA Workforce Learning and Development Policy, https://insite.gsa.gov/portal/content/643602, chapter 10, for membership in professional associations, and OAD P 5410.1 GSA Administrative Manual, https://insite.gsa.gov/portal/content/520238, for GSA membership in societies, associations, councils, or organizations when such membership is obtained as a result of the payment of a fee. 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 bill/payment. A micro-purchase cardholder may pay for a monthly recurring payment when the total payments for one year (or the period of the contract or agreement) do not exceed the cardholder’s single transaction limit. Warranted contracting officers must comply with the FAR.
(1) An example of an acceptable recurring payment:
Single Transaction Limit: $3,500
Monthly Recurring bill for telephone services: $200 X 12 months = $2,400
Total annual payments of $2,400 do not exceed single transaction limit of $3,500
(2) An example of an unacceptable recurring payment:
Single Transaction Limit: $3,500
Monthly Recurring bill for telephone services: $300 X 12 months = $3,600
Total annual payments of $3,600 exceed the single transaction limit of $3,500
f. Training and education. Once a training request is approved, a cardholder may provide the purchase card account number to the training vendor by phone or on a registration form. The cardholder must log the training with a CT and attach the training approval and/or training related documents in Pegasys. Purchases for two or more individuals are considered separate and distinct transactions. Training provided by a contractor is not subject to the Service Contract Act (FAR 22.1003-3). For example:
A micro-purchase cardholder with a single transaction limit of $3,500 has been authorized to purchase training for two employees. The cardholder can register each employee up to $3,500.
A micro-purchase cardholder with a single transaction limit of $3,500 has been authorized to hire a contractor to provide training to a group of employees. This service is not subject to the Service Contract Act (FAR 22.1003-3), and is not limited to the $2,500. The micro-purchase cardholder can pay for the service up to the single limit of $3,500. If the cost of the service exceeds $3,500, the purchase must be handled by a contracting officer.
g. Meals and beverages. Cardholders must consult OGC before using the 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 GSA Order, OAS 5770.1 Local Travel, https://insite.gsa.gov/portal/content/667422 j. Parking. The purchase card may be used to pay for commercially available parking spaces for Government Owned and GSA Leased vehicles. Payment for monthly parking spaces is a recurring service; therefore the 12-month payment is limited to the single transaction limit of the cardholder. Additional information is available at ADM P 5620.1 GSA Internal Motor Vehicle Management, https://insite.gsa.gov/portal/content/520990.
PROGRAM OVERSIGHT
44. Purchase card program reviews are required by GSA’s Internal Control Program. All management officials must fully cooperate with all reviews or audits of the purchase card program.
a. Inactive cards report. This report is run semi-annually to determine the status of purchase card accounts that have been inactive in the preceding 12 months. Inactive purchase cards are closed upon follow up with program office.
b. Impending suspension report. This report includes the names of AOs who have not reviewed and certified their cardholders' Pegasys monthly transactions reports in a
timely manner. The charging privileges of cardholders under these AOs are suspended until the AOs provide evidence of certification.
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 transactions. OAS then follows up with cardholders and AOs for review and action.
d. Employee separation list. This list is used to close purchase card accounts in Pegasys and the bank’s EAS on a weekly basis. If an AO’s name is on the list, the program office has five business days to designate a new AO to prevent the suspension of the cardholder’s purchase card account with the servicing bank. As an additional control, a monthly separation list from the Comprehensive Human Resources Integrated System (CHRIS) is also used to verify closing.
e. Log and Reconciliation report. This report is run weekly to verify that purchase card transactions identified as “No Log” are logged and reconciled in a timely manner. OAS also receives a monthly report from the OCFO to identify and follow up on “No Log” purchase card transactions.
f. Approving official span report. This report is run semi-annually to ensure each AO is limited to six cardholders. If a discrepancy exists, the program office is responsible to designate a new AO in a timely manner to prevent the suspension of the cardholders’ purchase card account under the AO.
g. Reconciliation of approving official report. This report is run annually to ensure the AOs are reported correctly in Pegasys and the servicing bank. If a discrepancy exists, the Charge Card Coordinators follow up with the cardholder and AO to establish the correct AO.
h. Reconciliation of CHRIS to cardholders with the servicing bank. This report is run annually to ensure all accounts of cardholders who terminated employment with GSA are closed.
i. Potential split transactions report. This report is run annually to monitor potential split transactions and follow up with management officials to determine if policy and/or contracting violation have occurred. In the event of a violation, OAS advises management to take corrective action in accordance to GSA Order, CPO 9751.1 Maintaining Discipline. j. Lost and stolen card report. This report is run annually to identify cardholders who report their purchase card lost or stolen during the period. The report is used to monitor potential fraud and abuse of the purchase card. OAS may revoke a cardholder’s purchase card and refer the cardholder to the OIG, as warranted.
k. Merchant Category Code (MCC). A review is conducted annually to verify new
OAS 4200.1B
21
MCCs from the servicing bank and their usage. A review of MCCs is also conducted every two years to assess the frequency and use of MCCs and to approve changes to retail blocks or flags for purchase card transactions.
DISCIPLINARY ACTIONS FOR IMPROPER USE OF THE PURCHASE CARD
45. Disciplinary actions.
a. Cardholders are subject to disciplinary action for improper use of the purchase card in accordance with GSA Order, CPO 9751.1, Maintaining Discipline. Upon notification of suspected misuse by the AO, the Charge Card Coordinator must suspend purchase card privileges of the cardholder pending the outcome of an investigation.
b. AOs must contact their servicing OHRM to determine if disciplinary action is warranted, and if so, the appropriate penalty. They must also notify the Charge Card Coordinator, the A/OPC, and the OIG concerning any fraud, misuse or abuse of the charge card.
c. When a cardholder makes an unauthorized or improper purchase, the cardholder, in accordance with GSA policy, shall:
(1) Reimburse GSA for the cost of the purchase; and
(2) Be subject to disciplinary action.
d. 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.
e. Supervisors must consult OHRM on all disciplinary matters. 46. Reimbursements to GSA.
a. Cardholders must provide refund payment and a copy of the purchase card statement reflecting the overpayment to the AO for submission to GSA Finance. In case of a credit, the AO must provide the accounting code of the original transaction to apply the credit.
b. The cardholder must follow up with the AO to ensure payment is remitted.
c. All payments must be made payable to GSA and mailed to the following address at:
USDA-OCFO Financial Operations and Disbursement Branch
Attn: Travel and Purchase Card Section
OAS 4200.1B
22
2300 Main St - 2SE
Kansas City, MO 64108
d. Reimbursement must be made by check or money order payable to the General Services Administration, or a charge authorization for the employee's personal credit card using Form GSA3602B, Credit Card Collection Claims and Debts-Region 6, at https://www.gsa.gov/portal/forms/download/115042. e. See CFO P 4253.1B CHGE 1 Accounts Receivable and Debt Collection Policy Manual, https://insite.gsa.gov/portal/content/531626, OCFO accounts receivable policy on repayment of debt owed to GSA.
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.
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 employee authorized to use 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 GSA SmartPay® program. These contracts, collectively referred to as the "Master Contract," are administered by the GSA.
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.
OAS 4200.1B
A-2
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.
Charge Card Coordinator: The individual appointed by OAS to manage the purchase card program at the regional level.
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.
OAS 4200.1B
B-1
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.
Good Entries/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.
OAS 4200.1B
B-2
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 GSA 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.
OAS 4200.1B
C-1
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, https://insite.gsa.gov/portal/content/521182, 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.
(3) General Services Administration Acquisition Manual (GSAM), https://www.acquisition.gov/?q=browsegsam, 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 Property, https://insite.gsa.gov/portal/content/523574, establishes policy and procedures for the management of GSA internal personal property.
(5) General Counsel Memorandum dated July 22, 2005, https://insite.gsa.gov/graphics/staffoffices/ADMIL-12-01AttachmentA-MealsandRefreshments23.pdf, Use of Agency Funds for Meals and Refreshments. (6) OAD P 5410.1 CHGE 91 GSA Administrative Manual, https://insite.gsa.gov/portal/content/520238
(7) CFO P 4253.1B CHGE 1 Accounts Receivable and Debt Collection Policy
a. The GSA SmartPay® website, https://SmartPay®.gsa.gov, is an information source of publications for the purchase card. The website is updated on a regular basis.
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 GSA Charge Card Coordinators is available at https://insite.gsa.gov/portal/content/500047.
d. GSA Form 3661, Purchase Card Application and Maintenance., https://www.gsa.gov/portal/forms/download/115150
a. Exceptions. The use of convenience checks may be granted on a case-by-case basis by the Chief Administrative Services Officer (CASO) ; 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 (CASO) for consideration. b. 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. c. 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.
d. 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 the 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
2.15% 11/30/2015 – 11/29/2017
2.2% 11/30/2017 – 11/29/2018
OAS 4200.1B
D-2
Example: In FY16, a convenience check written in the amount of $50,000 costs an additional $1,076 in fees (2.15% of the face value of the check plus $1).
e. Transaction posting. Checks must be logged into 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.
f. Reordering checks. Cardholders authorized to use convenience checks must contact the A/OPC via e-mail to reorder convenience checks. Upon approval, the cardholder will provide OAS the last check number available and the last six digits of their card number. OAS will contact the bank 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.
g. 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.
h. 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.
i. Reporting. OAS will monitor all convenience check use across GSA to ensure compliance with policy.
OAS 4200.1B
E-1
Appendix E. 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 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.
l. Discipline employees for card misuse in accordance with the FAR and GSA’s policy on maintaining discipline.
m. Regular monitoring of cardholders that fail to log and reconcile within 10 calendar days of the bank statement line and provide hands-on training on logging, reconciling, and uploading of documents.
n. Removal of program participants (i.e. cardholders, AOs) who fail to adhere to policies and procedures.
OAS 4200.1B
F-1
Appendix F. Essential Policy Requirements for the Purchase Cardholder
Tasks and Activities
Method
Before Applying for the GSA Purchase Card
o Before you apply for the GSA purchase card, read the Pegasys User Guide to understand how to log, reconcile, and upload documents in Pegasys at http://pegasys.gsa.gov/ref.htm or take the Pegasys training course, when available at https://pegasys.gsa.gov/train.htm
Applying for the Purchase Card
o Complete the Purchase Card Training at GSA On-Line University, the Purchase Card Application and Maintenance Form (GSA 3661), and the Pegasys User ID Form OCFO System Access Request Form for Pegasys and NEAR. Submit the purchase card training certificate and the completed forms to your Charge Card Coordinator for processing. Instructions are also on the webpage at https://insite.gsa.gov/portal/content/581386.
Before Making a Purchase
o Before you make a purchase, obtain approval from the Approving Official (AO):
Receive an e-mail from the requester with the following data:
Name of person who wants the goods. Item description. Estimated amount or price. Accounting code. Date when goods and/or services are needed
After you verify that the e-mail contains this information Forward the e-mail to your AO for approval. Inform your AO that a response is required.
o If the item is being shipped directly to the requester or the end-user and it’s more than $500, reply to the requester to send you an e-mail when the items have been received and are acceptable.
Making a Purchase
o Upon approval from AO, you can make the purchase as follows:
In person at the store
On-line
On the telephone
If actual cost exceeds the amount approved by the AO by 10 percent or less, make the purchase. If not, e-mail the AO and obtain approval for the actual cost.
After Making a Purchase
o Create a log in Pegasys. Instructions for creating a credit card log are at
o Load the written authorization (the AO’s approval e-mail). o Upon receipt of Pegasys e-mail notification that your purchase
cleared the bank:
Log into Pegasys and verify that the log was automatically reconciled with the bank statement line.
If the log was not automatically reconciled, you have 10 calendar days to do a manual reconciliation using the instructions, Reconcile a Bank Statement Line to a Credit Card Log at https://pegasys.gsa.gov/docs/ref/qrc/6.5/CCReconcileCCLogQRC.pdf.
Receipt of Items purchased
o If the price is correct and the shipment meets the quality and quantity requirements, load the receipt or invoice to the Pegasys log using the instructions at https://pegasys.gsa.gov/ref/qrc.htm, How to Attach a Document. If not, dispute the charges by following the instructions on the webpage, https://insite.gsa.gov/portal/content/500048 ,GSA Purchase Card - Citibank Dispute Procedures.
If the total transaction cost is more than $500, let someone else verify the quantity and quality requirements of the order. The person will print on the sales invoice or packing slip, their name, date the items were received, and sign. Upload the signed document to the Pegasys log.
o If the item was shipped directly to the requester or end-user,
follow up with an e-mail to confirm that the item was received and met the quantity and quality requirements of the order. Upload the e-mail confirmation to the Pegasys log.
Supporting Documentation
o Upload the following documents to the Pegasys log.
Written authorization - upload when the log is created in Pegasys.
Receipt/invoice - upload within five business days of receiving the goods or services from the vendor.
Independent verification receipt and acceptance of goods over $500 - upload within five business days of receiving the goods from the vendor.
Log and o You must log all charge card transactions in Pegasys and
Reconciliation reconcile the logs to the bank statement line within 10 calendar days of notification from Pegasys.
o Failure to log and reconcile your purchase card transactions in a timely manner may result in suspension of your charge card privileges. Credit transactions are not logged. Reconcile the credit transactions to the accounting code of the original transaction.
Questionable transactions report
o Review and complete the questionable charges spreadsheet upon receipt from your Charge Card Coordinator.
o Failure to respond timely will result in the suspension of your purchase card.
Taxes o All charges on the purchase card are exempt from local and state taxes. However, some states require tax exemption form to process a transaction.
o You can download tax exemption form from this website, State Tax Information, when needed.
If taxes are included in the cost of a transaction, call the vendor to request removal of the taxes. If you do not succeed with the vendor, call the bank to dispute the charges. Go to this website for more detailed information, https://insite.gsa.gov/portal/content/500048, GSA Purchase Card - Citibank Dispute Procedures.
Direct Payment o All micro-purchases must be placed on the purchase card. If the vendor does not accept the purchase card, use the Direct Payment method in Pegasys, https://pegasys.gsa.gov/ref/qrc.htm, Creating Direct Payments, or use another vendor.
Payment for Recurring Services
o Contracting officers with warranted purchase card should use the card as a payment vehicle for contracts, whenever possible.
o For micro-purchase cardholders, if total annual payments exceed your single transaction limit, Stop. Contact a contracting officer.
An example of an acceptable payment for recurring services for telephone bills:
Single Transaction Limit - $3,500
Monthly Recurring Payment - $200
Total annual payments of $2,400 ($200 X 12 months) do not exceed single transaction limit of $3,500
An example of an unacceptable payment for recurring services for telephone bills:
Single Transaction Limit - $3,500
Monthly Recurring Payment - $300
Total annual payments of $3,600 ($300 X 12) exceed the single transaction limit of $3,500
****Contact a contracting officer to process the telephone payments.
Split Transactions
o Do not split transactions. It is a violation of procurement laws and regulations. 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.
o OAS will revoke the charge card privileges of any cardholder who splits transactions. Cardholders and their AO who participate in split transactions will also be subject to disciplinary action in accordance with GSA Order, CPO 9751.1 Maintaining Discipline.
Payment for Training
o A cardholder can pay for training class for two or more individual employees by:
Creating a CT in Pegasys, https://pegasys.gsa.gov/ref/qrc.htm.
Creating a Credit Card Training Log.
Completing the Employee tab for each individual. (Note: There is no need to create a separate log for each individual.)
o Training provided by a contractor is not subject to the Service Contract Act (FAR22.1003-3). The micro-purchase cardholder can pay for the service up to the single limit of $3,500. If the cost of the service exceeds $3,500, the cardholder should consult with a contracting officer.
Office Supplies o You must use FSSI OS3 for the purchase of office supplies, OS3 Category List. Under Quick Search, select OS3 on the drop down
list and click “GO”. This website details the type of supplies you can purchase in OS3.
o All 24 FSSI OS3 contractors are now uploaded in GSA Advantage for ordering. To order office supplies, cardholders can click on the Office Supplies and Equipment FSSI link on the left side of the page.
Monthly Bank Billing Statement
o Verify your monthly billing statement to make sure you have made all the charges on the purchase card. Contact the bank within 60 calendar days for unauthorized charges that appear on the statement. After 60 days, you may be responsible to reimburse GSA for the unauthorized charges.
Pegasys Recertification
o You must recertify in Pegasys, when requested. Your purchase card may be suspended if you do not recertify in a timely manner.
Misuse of the Purchase Card
o If you are suspected of misusing the purchase card, your purchase card privileges will be suspended pending the outcome of an investigation.
o If you make an unauthorized or improper purchase on the purchase card:
You are liable to the government for the cost of the purchase, and
Appendix G. Essential Policy Requirements for the Approving Official (AO)
Tasks and Activities Method
Cardholder’s request to make a purchase
o Cardholders must have a written authorization for all purchases on the card.
o Review written authorization received via e-mail from the cardholder to include :
Name of person who wants the goods or services
Item description Estimated amount or price Accounting code Date goods and/or services are needed
o Submit an e-mail to the cardholder to approve the
purchase.
Authorization o Ensure applicable procurement regulations and policies are followed (See Appendix C, Sources and References
in the purchase card policy). o When in doubt, consult your respective Office of General
Counsel at https://insite.gsa.gov/portal/content/502445
Questionable Charges Ensure cardholders respond timely to the monthly questionable charges spreadsheet upon receipt from the Charge Card Coordinator. Failure of cardholders to respond timely will result in the suspension of their purchase card.
If the card was misused, notify the Charge Card Coordinator, the A/OPC, and the Office of the Inspector General (OIG). Also contact the Office of Human Resource Management (OHRM) for assistance with proposed disciplinary action.
Purchase Card Training o Complete the mandatory refresher training every three years when requested.
Verification of Monthly Pegasys Transactions Report
o Review and certify the charges on the monthly Pegasys transactions report within 10 calendar days of receipt.
Verify that you had approved the charges from your e-mails.
If the card was misused, notify the Charge Card Coordinator, the A/OPC, and the Office of the Inspector General (OIG). Also contact OHRM for assistance with proposed disciplinary action.
o The cardholder’s statement cycle is the 26th of every
month. Certify the report even if you relinquish your duties after the 26th. You are responsible for reviewing and certifying the charges while you were the AO.
o OAS suspends the cardholders’ purchase card if you do
not certify the Pegasys monthly transactions report timely.
Oversight of Designated Cardholders
o AO must be in the same Service or Staff Office as the cardholders. For example, if you are a FAS employee, your cardholders should be in FAS.
o Notify the Charge Card Coordinator if it comes to your attention that a cardholder is leaving office or relinquishing his/her duties or you are doing the same.
o Follow up with cardholders to ensure they respond timely to audit requests for supporting documentation. OAS suspends the purchase card of cardholders who do not respond timely to audit requests.
Disputes o Follow up with the cardholder for any vendor disputes or fraudulent charges on the card. The dispute process is detailed at https://insite.gsa.gov/portal/content/500048, GSA Purchase Card - Citibank Dispute Procedures
Pegasys Recertification o Recertify your access to Pegasys within the designated timeframe.
o If you do not recertify your access in Pegasys in a timely manner:
You will not receive notification of the monthly Pegasys transactions report for certification causing OAS to suspend the cardholders’ accounts.
Appendix H. Essential Policy Requirements for the Charge Card Coordinator
Tasks and Activities Method
Request for a Purchase Card
o Ensure the cardholder complete the required training and submit the required documents as specified on the website at https://insite.gsa.gov/portal/content/581386.
o When setting up cardholder in Citibank, ensure the
following fields are completed:
Cardholder’s GSA e-mail address.
Discretionary Field 2 for the unique id number.
SS# is not needed. Use 0000.
o When setting up cardholder in Pegasys, ensure the Credit Card Type and the Approval Group Code reflect the Office Symbol on GSA Form 3661 of the cardholder, except for staff offices. Staff offices have Credit Card Type: GSA; Approval Group Code begins with “100….”
Request for a new Approving Official (AO)
o Ensure the AO complete the required training and submit the required documents as specified on the website at https://insite.gsa.gov/portal/content/581386.
o Ensure the AO uses GSA e-mail address and business phone number on Form CB007.
o Submit CB007 to Citibank for recording
GSA Form 3661 o Verify that all sections are completed based on the need of the program office in Section I.
o Verify that the cardholder did not sign the form as the AO. o Verify that the AO did not sign the form as the Requesting
Director. o Verify that the Funds Manager signs the form for addition
or changes to Section III, Privileges and Coding. o Process the form in Pegasys and Citibank.
Request to replace an AO
o Verify that the option for AO changes is selected in Section I of GSA Form 3661 and the form is completed properly.
o Verify that the proposed AO is in Pegasys.
If the AO is not in Pegasys, contact the program office to establish a new AO. Follow instructions at
If the AO is in Pegasys, verify that the AO does not exceed the six cardholder limit.
o Update Citibank and Pegasys.
Questionable Charges o Coordinators have 30 business days to review the spreadsheet. Verify the charges in Pegasys, and ensure AOs respond to the charges correctly.
o Upon receipt of the questionable charges, in a google spreadsheet, do the following:
Verify in Pegasys that the transactions are logged and you are able to determine what was purchased. Complete the spreadsheet.
For the charges you could not identify in Pegasys, give the AOs 10 business days to complete the spreadsheet. Let the AOs know that the purchase cards of the cardholders will be suspended after 10 business days if you do not receive the completed spreadsheet.
After the 10 business days, review the spreadsheet to ensure the AOs respond to the questionable charges. If incomplete, suspend the cardholders’ purchase card with the bank and annotate on the spreadsheet.
If there are charges that need to be resolved, follow up with the cardholders/AO to ensure they are resolved, and maintain documentation.
Log and Reconciliation Report
o Run the report in Business Objects weekly and remind the cardholders to log and reconcile their transactions according to OAS policy.
o Every month, the office of the OCFO sends a report to OAS of all cardholders’ transactions. The A/OPC reviews the data to identify Regions that exceed the 10 percent OMB score card. If you receive a report from the A/OPC for your Region:
Follow up with the cardholders, cc the AO, to log and reconcile the transactions in 10 business days.
timely manner, suspend the purchase cards in Citibank.
Supporting Documentation
o Maintain training certificates for new cardholders, GSA Form 3661, Citibank Forms, warrants, and other pertinent documentation electronically in your folder on the shared drive.
o At the end of 30 calendar days, run Pegasys report for Attachments in Business Objects. Conduct a monthly sampling of 40 transactions from the attachment tab. Verify that the 40 transactions have the required supporting documents as addressed in the policy. If incomplete, follow up with the cardholders/AO.
If you do not receive the required documents in 10 business days, suspend the purchase card of the cardholder in Citibank.
Training o During the months of January – August, set aside a time frame to conduct training for the cardholders and AOs regarding compliance with the purchase card policy. Maintain attendance record for audit tracking.
Cancellation of Purchase Card in Citibank
o When you are notified that a cardholder is leaving GSA’s employment or no longer needs the purchase card.
o When you are notified that an AO is leaving GSA’s employment or relinquishing his/her duties. Make sure GSA Form 3661 is completed to replace the former AO.
If the AO is not replaced in five business days, suspend the cardholder’s purchase card under the AO in Citibank until the program office designates an AO.
o When a cardholder does not complete the mandatory refresher training requirements as requested by OAS.
o When an AO does not complete the mandatory refresher training requirements as requested by OAS.
o Upon notification from the cardholder’s supervisor or AO
that the cardholder misused the purchase card. Suspend the purchase card pending the outcome of an
OAS 4200.1B
H-4
Tasks and Activities Method
investigation.
Approving Official Verification Report
o Run the AO verification report in Business Objects after 10 calendar days to ensure the AOs have certified their monthly Pegasys transactions report.
o Inform the AOs that their cardholders’ purchase card privileges will be suspended if they do not certify.
Pegasys Recertification o Follow up with the cardholders and AOs to ensure they recertify within the time allotted by Pegasys.
Inform the cardholders that their purchase card will be suspended if they don’t comply.
Inform the AOs that failure to recertify prevents them from receiving the monthly Pegasys transactions report for certification, thereby causing OAS to suspend the cardholders’ accounts.
Upon expiration of the time allotted by Pegasys, suspend the purchase cards of the cardholders under AOs who do not recertify. Also suspend the purchase cards of the cardholders who do not certify.
