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United States Department of AgricultureOffice of Procurement & Property ManagementCharge Card Service CenterPurchase CardUSDA Purchase Card ProgramPolicy TrainingFY2018– USDA Charge Card Service Center –
AgLearn Disclaimer: Section 508 ComplianceThis Purchase Card Policy Program training course complies with Section 508 of theRehabilitation Act, which requires that federal agencies purchase electronic andinformation technology that is accessible to people with disabilities.Visit Section508.gov for more information.– USDA Charge Card Service Center –2
Policy Training Requirements – New ProgramParticipants All Agency Program Coordinators (APCs), Local Agency Program Coordinators (LAPCs),Approving Officials (AOs) and cardholders must complete USDA Purchase Card ProgramPolicy Training and other program-required trainings. Coordinators and AOs who are also cardholders must take all the required cardholder modules.No module is taken more than once. Regulations require specific training for all new program participants. A list of all required trainings is available on the CCSC website.Note: Links to all required training (including the specific AXOL modules required of AOs) are available on theUSDA Charge Card Service Center (CCSC) website. For more information, hase card.htm– USDA Charge Card Service Center –3
Refresher Training Requirements A list of AgLearn-based training is located atwww.dm.usda.gov/procurement/ccsc/pc training.htm. Procurement Advisory 125 requires purchase card program participants to complete themandatory Refresher Training annually instead of every two years. Cardholders, Approving Officials (AOs), Local Agency Program Coordinators (LAPCs)and Agency Program Coordinators (APCs) must complete the annual refresher trainingby March 31st of each fiscal year, to maintain participation in the USDA Purchase CardProgram. 30 business days after the March 31st deadline, CCSC will suspend cardholders whohave not completed Refresher Training.– USDA Charge Card Service Center –4
Refresher Training Requirements (Cont.) CCSC will provide the agencies’ Head of Contracting Activities Designees (HCADs) andUSDA senior leadership with the list of Coordinators, Approving Officials and cardholderswho are not in compliance with the Refresher Training policy 45 business days afterMarch 31st of each fiscal year. Purchase card program participants who are still not in compliance by June 30th of eachfiscal year will be required to successfully retake all of the initial required purchase cardtraining to continue participating in the purchase card program. All of the initial training required is listed in the Purchase Card Program Guide. All warranted coordinators and cardholders who complete the mandatory refreshertraining will receive one CLP credit towards their training maintenance requirementsbased upon the duration of time spent receiving official training.– USDA Charge Card Service Center –5
Policy Training Topics Introduction Part I: USDA Purchase Card Overview Part II: Responsibilities Part III: Purchase Card & Convenience Check Use Resources– USDA Charge Card Service Center –6
IntroductionWelcome to the USDA Purchase Card Program Policy Training.This training program reinforces participants’ knowledge of purchase card policy andresponsibilities.Interactive quizzesappear throughoutthe training.– USDA Charge Card Service Center –7
Part I: USDA Purchase Card Overview Program Summary Program Structure Policies & Regulations Liability– USDA Charge Card Service Center –8
Program Summary The USDA Purchase Card is part of a government-wide charge card program initiated by theGeneral Services Administration (GSA) under the SmartPay Program. USDA manages its charge card program through the Charge Card Service Center (CCSC),Procurement Systems Division (PSD), Office of Procurement & Property Management(OPPM), Departmental Management (DM). USDA benefits from participating in the purchase card program: Rebates received from U.S. Bank based upon purchase volume Extensive vendor acceptance Reduced individual vendor payments Cost-effective payment processing methods Cardholders benefit from using the purchase card program: Reduction in paperwork Timely shipment of products Purchasing flexibility– USDA Charge Card Service Center –9
Program Summary (Cont.)Use of the purchase card and convenience checks is governed by a number of lawsand regulations. These laws and regulations include the following:Appropriations Laws and Regulations OMB Circular A-123, Appendix B, Improving the Management of Government Charge CardPrograms Departmental Regulation (DR) 5013-6 Procurement Advisories (PA), as applicable to Purchase Cards PA 52A: Convenience Checks PA 89: Use of the Purchase Card and Related Alternative Payment PA 122: Purchase Authority for Single Purchase Limit PA 123: Acquiring Rental Storage Space short and long term with USDA Purchase Card PA 125: USDA Purchase Card Program – Mandatory, Annual Refresher Training Requirements Supplemental individual agency regulations– USDA Charge Card Service Center –10
Program Summary (Cont.)Appropriations Laws and Regulations (cont.) The established rule is that the expenditure of public funds is proper only when authorizedby Congress, not that public funds may be expended unless prohibited by Congress.(U.S. v. MacCollom, 426 U.S. 317, 321 (1976)) Federal funds are made available for obligation and expenditure by means of appropriateacts. Appropriations may be used only for their intended purposes.– USDA Charge Card Service Center –11
Program StructureThe overall structure of USDA’s Charge Card Program is depicted below.Note: Your agency may have additional coordinators between the local and agency levels. GSA SmartPay Office Charge Card Service Center (CCSC) Agency Program Coordinator (APC) Local Agency Program Coordinator (LAPC) Supervisor/Approving Official (AO) Cardholder– USDA Charge Card Service Center –12
Program Structure (Cont.)USDA Purchase Card Roles Charge Card Service Center (CCSC) – Purchase CardsThe CCSC is responsible for the management, monitoring, and oversight of the purchase card program,including providing APCs with training and guidance; and developing procedures, literature and materials forUSDA’s purchase card program. Agency Program Coordinator (APC)The APC coordinates the agency’s support, operations and oversight, and is also responsible for the overallmanagement of the purchase card program within the respective agency. Local Agency Program Coordinator (LAPC)The LAPC is responsible for the day-to-day operation of the purchase card program at the LAPC’s respectivesite. The LAPC works directly with cardholders and AOs, as well as with the bank representative and theAPC. All documentation related to the establishment of cardholders and AOs will be processed through theLAPC. Approving Official (AO)The AO is the cardholder’s supervisor-of-record (or approved designated alternate AO) or someone of at leastequal grade/level as the cardholder in a position to determine the viability of the cardholder’s purchase. AO’sresponsibilities include preventing cardholder’s account suspension by Final Approving cardholders’transactions within 30 days of appearing in the AO’s “Manager’s Approval Queue” in Access Online.– USDA Charge Card Service Center –13
Program Structure (Cont.)USDA Purchase Card Roles (cont.) CardholderThe cardholder is the person responsible for all purchases made with the purchase card or conveniencechecks issued to him or her. The cardholder must ensure all purchases comply with the Federal AcquisitionRegulation (FAR), department and agency regulations. The cardholder must approve his or her transactionsat least once a month using documentation retained from each purchase and ensure the AO has thenecessary documentation to final approve all transactions. U.S. BankU.S. Bank is USDA’s purchase card provider. U.S. Bank’s Access Online is a web-based electronic accesstool designed to be the system source for purchase card program management and related data.– USDA Charge Card Service Center –14
Policies & Regulation Refer to the policies and regulations below: DR 5013-6: Use of the Purchase Card and Related Alternative Payment Methods (November2012) Procurement Advisory (PA) PA 52A: Convenience Checks PA 89: Use of the Purchase Card and Related Alternative Payment PA 122: Purchase Authority for Single Purchase Limit PA 123: Acquiring Rental Storage Space short and long term with USDA Purchase Card PA 125: USDA Purchase Card Program – Mandatory, Annual Refresher TrainingRequirements Office of Management and Budget (OMB) Circular A-123, Management’s Responsibility forInternal Controls, Appendix B Improving the Management of Government Charge Cards (January2009) Federal Acquisition Regulation (FAR) [https://www.acquisition.gov/browsefar]– USDA Charge Card Service Center –15
Policies & Regulation (Cont.) The purchase card program requires initial training for new Purchase Cardholders,Approving Officials, and Coordinators. Coordinators must ensure the completion of the initial training by new cardholders and ApprovalOfficials. APCs must ensure the completion of the initial training by new coordinators. Upon CCSC’s request, coordinators must provide proof of training for agency’s programparticipants. Purchase cards used to reduce procurement and related payment paperwork byeliminating the number and dollar amounts of imprest funds; reducing purchase ordertransactions for supplies and services, including construction; and reducing administrativeprocessing costs and lead times. Under no circumstances is the purchase card to be used for personal purchases. The purchase card is the primary method for making phone, internet and over-the-counterpurchases of 150,000 or less (simplified acquisition threshold).– USDA Charge Card Service Center –16
Policies & Regulation (Cont.) Use of the purchase card by a cardholder is subject to a single purchase limit and amonthly purchase limit. The single purchase limit is a dollar amount on the procurement authority delegated to thecardholder. A “single purchase” is the total of those items purchased at one time from a particular vendor. The monthly purchase limit is the maximum total dollar amount a cardholder is authorized toprocure each month. The monthly purchase limit applies to the monthly total of all purchase card and convenience checktransactions.– USDA Charge Card Service Center –17
Policies & Regulation (Cont.)Micro-Purchases FAR 2.101 and the DR 5013-6 stipulate the purchasing authority for micro-purchases and thepurchase card for non-warranted cardholders. The maximum amount for purchase card micro-purchases is 3,500 for supplies, 2,500 for services(and for convenience checks) and 2,000 for construction. Splitting purchases merely to stay within the single purchase limit is a violation of the law. Micro-purchases are exempt from some requirements that apply to larger governmentpurchases (see FAR 13.2 and 13.3). Micro-purchases are not subject to small business set-aside rules; although cardholders areencouraged to use small businesses where practical. Micro-purchases are exempt from the Buy American Act. Micro-purchases do not require competitive quotes if the contracting officer (CO) considers the price tobe reasonable, but cardholders must compare prices enough to know that the cardholder’s price isreasonable. To the most practical extent, the purchases must be distributed equitably among qualified suppliers. Purchases above the micro-purchase threshold require cardholders to follow the requirementsprescribed for Simplified Acquisitions (see FAR 13.3), as well as USDA-specific guidance includingDR 5013-6.– USDA Charge Card Service Center –18
Policies & Regulation (Cont.)Authorization Cardholder must obtain proper authorization or a requisition from their AO or anotherauthorized person within cardholder’s program area prior to making any and all purchaseswith the purchase card or convenience check. This requirement is mandatory for allpurchases. The requisition and authorization may be in the form of a written request, email or IntegratedAcquisition System (IAS) procurement requisition from an authorized official. Authorized officials will bedetermined according to individual agency procedures. An authorized person may give a blanket authorization for routine purchases as long as authorizationis in writing, which includes an email.Important Notes About Convenience Checks Not all agencies have convenience checks; not all transactions require convenience checks. Agencies authorized to use convenience checks should use the checks only as a last resort,per GSA’s mandate for the reduction of convenience check usage. Contact the agency APC for further information regarding convenience check authorization. USDA continues to look for ways to reduce the total number of convenience checks.– USDA Charge Card Service Center –19
Policies & Regulation (Cont.)Merchants Cardholders must purchase only from merchants who accept the purchase card. If amerchant does not accept the purchase card, other purchasing alternatives should beinvestigated. If no other options exist, convenience checks may be used only when awaiver applies. Cardholders should follow their agency’s policy regarding convenience checks.Required Sources of Supply Even though some restrictions do not apply to micro-purchases, cardholders are requiredto follow the required sources of supply set forth in Part 8 of the Federal AcquisitionRegulation (FAR). Other sources should be considered for use only after the priority sources, as defined onthe next pages, have been considered for fulfilling requirements.– USDA Charge Card Service Center –20
Policies & Regulation (Cont.)Priority Sources for Supplies Active Inventory (On-Hand Stock/Cupboard Stock) Excess Personal Property Federal Prison Industries (FPI) Procurement List of Products Available Through the Committee for Purchase From PeopleWho Are Blind or Severely Disabled (AbilityOne) Wholesale Supply Sources (GSA, Defense Logistics Agency, VA) Mandatory Federal Supply Schedules (FSS) Federal Strategic Sourcing Initiatives (FSSI) Blanket Purchase Agreements (BPAs) Optional Use FSS Commercial Sources– USDA Charge Card Service Center –21
Policies & Regulation (Cont.)Priority Sources for Services Procurement List of Services Available from the Committee for Purchase From People WhoAre Blind or Severely Disabled (AbilityOne ) Mandatory FSS Optional Use FSS Federal Prison Industries (FPI) Open-Market Commercial SourcesNote: The Government Printing Office (GPO) is the mandatory source for commercial printing.– USDA Charge Card Service Center –22
LiabilityCardholder Liability Intentional use of the purchase card or convenience checks by a cardholder for other thanofficial government business will be considered an attempt to commit fraud against the U.S.government and will result in immediate cancellation of the employee’s purchase cardand/or convenience checks. The cardholder may be subject to administrative and/or disciplinary action under applicableU.S. Department of Agriculture Personnel Manual and government-wide administrativeprocedures, up to and including suspension and/or removal. An employee (cardholder and/or AO) will be personally liable to the government for theamount of any unauthorized transaction and may be subject to a fine of not more than 10,000 or imprisonment for not more than 5 years, or both, under 18 U.S.C. 287. Where a cardholder fails to resolve and/or dispute (if necessary) an erroneous charge in atimely manner, the cardholder, consistent with agency policy, shall reimburse thegovernment for the cost of that transaction. When a cardholder makes an improper purchase, the cardholder, in accordance withagency policy, shall (a) reimburse the government for the cost of the purchase and (b) besubject to disciplinary action.– USDA Charge Card Service Center –23
Liability (Cont.)AO Liability In accordance with agency policy, if an official directs a cardholder to make an erroneouspurchase of items or services that are determined to be improper, the official must Reimburse the government Be subject to disciplinary action– USDA Charge Card Service Center –24
Part II: Responsibilities Cardholder’s Responsibilities Program Management Coordinator’s Responsibilities Local Agency Program Coordinator Reporting & Communications Program Management Policy Oversight & Maintenance Communications & Reporting/Data Calls Approving Official’sResponsibilities Agency Program Coordinator Program Management Program Management Card Issuance & Maintenance Communications Oversight & Monitoring Communications Reporting/Data Calls & Policy Program Support Resources– USDA Charge Card Service Center –25
Cardholder’s Responsibilities: ProgramManagement Program Management Purchasing commercial goods and services using the card only if the necessarygoods and services are not required from the federal list of mandatory sources. Maintaining purchase cards and convenience checks in a secure matter andpreventing unauthorized charges against the account. Prohibiting anyone from using your purchase card or convenience checks. Maintaining adequate documentation of all purchase cards and convenience checktransactions including the following: Includes documentation of funds availability, receipts, packing lists and invoices Maintain the supporting documentation for six years from the Access Online posting date Ensuring entry of proper accounting codes and budget object classification codes; forconvenience checks, Taxpayer identification Numbers (TINs) or EmployerIdentification Numbers (EINs) and applicable waiver code, as appropriate. Includes ensuring the correct entry and proper formatting of appropriate merchant addressesin Access Online.– USDA Charge Card Service Center –26
Cardholder’s Responsibilities: ProgramManagement (Cont.) Approving purchase card and convenience check transactions using Access Online(AXOL) on a monthly basis. Changing Access Online password as required. Calling the bank’s customer service representative and the LAPC immediately toreport lost or stolen card and checks. Notifying the bank of any billing discrepancies (e.g., disputes) posted on the accountby disputing the transaction in Access Online and following the bank’s guidelines fortransaction disputes. Completing the Card/Checks Destruction Form and forwarding to AO for signature.– USDA Charge Card Service Center –27
Cardholder’s Responsibilities: Reporting &Communications Reporting Responding promptly to requests—including data, documentation and transactionapprovals—from AO, LAPC or APC. Ensuring the entry of procurement property into USDA’s accountable propertysystem. Communications Notifying the LAPC of any name, telephone, address, email or other accountchanges, (i.e., change in supervisor or division/agency/department changes).– USDA Charge Card Service Center –28
Cardholder’s Responsibilities: Policy Policy Completing required purchase card training, including mandatory annual refreshertraining. Ensuring that all purchases comply with the Federal Acquisition Regulation (FAR),as well as with USDA and agency regulations. Obtaining proper authorization prior to purchasing goods/services. Completing purchases where funds are available and within authorized spendinglimits. Ensuring the disposal of at any dangerously radioactive and other acquiredhazardous materials in accordance with applicable regulations. Refer to the Agriculture Property Management Regulations, Chapter 102, FederalManagement Regulation, Subchapter B, Personal Property PART 102-34, Motor VehicleManagement.– USDA Charge Card Service Center –29
Approving Official’s ResponsibilitiesAO is the individual with oversight and approval responsibility for PurchaseCard activity of cardholders under his or her purview, per USDA policy. The AO is typically the cardholder’s supervisor-of-record (Sor). Other individuals may be appointed as a cardholder’s Alternate AO, providing the personmeets the criteria. Must be the same or higher grade than assigned purchase cardholder.Must be in the same program or location—regional, area or office—as the cardholder.Must satisfy mandatory AO training requirements.Is the preference of USDA policy for the Sor to serve as cardholder’s AO. Two AOs cannot have oversight of and approval for the same cardholder, per USDA policy. The Sor requests the appointment of an Alternate AO by sending the LAPC the following: Completed Appointment Nomination Request Form Written justification explaining the change The appointment is granted or not granted based on the LAPC’s review and the APC’sdecision.Note: The appointment of an Alternate AO does not absolve the supervisor-of-record of the responsibility overthe cardholder’s job performance and purchase card transaction activity.– USDA Charge Card Service Center –30
Approving Official’s Responsibilities: ProgramManagement Program Management Ensuring the purchase card/convenience checks are destroyed before the AO’scardholder leaves the department, transfers to another agency or is on extended leave;this includes completing and submitting the completed Card/Check Destruction Form tothe AO’s LAPC. Ensuring the AO’s cardholder(s) approve their transactions on a monthly basis and prior toa cardholder’s departure from the department, transfer to another agency or extendedleave. Ensuring the AO’s cardholders maintain adequate documents—requisition, receipts orsupporting documentation—for each purchase for the retention period of six years fromthe purchase date. Ensuring the AO and AO’s cardholders complete all required training, including refreshertraining. Ensuring the AO’s cardholder completes the fraud and dispute process.– USDA Charge Card Service Center –31
Approving Official’s Responsibilities: CardIssuance and Maintenance Card Issuance and Maintenance Determining the necessity and appropriateness of each issued purchase card and whounder AO’s authority should receive convenience checks with an issued purchase card. Ensuring the purchase card authority and, if appropriate, convenience check authority isnot conferred upon employees whose position may give rise to a conflict of interest. Ensuring cardholder’s completion of the initial complement of purchase card trainingbefore submitting the purchase card application to the AO’s LAPC. Preventing the suspension of a cardholder’s account. Confirming the entry and the approval of adequate comments for all approvedtransactions.– USDA Charge Card Service Center –32
Approving Official’s Responsibilities: CardIssuance and Maintenance (Cont.) Remembering the following potentially problematic areas when Final Approvingtransactions: Commercial Printing Construction Meetings & Conferences RefreshmentsNote: All card accounts assigned to an AO who fails to final approve the selected transactions within atotal of 60 days will be deactivated, absent extenuating circumstances. These deactivated accounts maybe reactivated after all transactions are final approved. Persistent failure to timely and accurately finalapprove transactions shall constitute grounds for management to revoke purchase card and/or alternativepayment method privileges of all cardholders assigned to the AO and may subject the AO to possibledisciplinary action.– USDA Charge Card Service Center –33
Approving Official’s Responsibilities:CommunicationsCommunications Informing cardholders of program updates, including refresher training deadlines and cardsuspensions. Notifying the AO’s LAPC when changes in the AO’s organization affects purchase cardmanagement.– USDA Charge Card Service Center –34
Coordinator’s Responsibilities An Agency Program Coordinator (APC) is designated in each USDA agency,departmental office or mission area to provide program support, operations and oversightwithin the organization through the CCSC leadership. A Local Agency Program Coordinator (LAPC) may be designated in each USDAagency, departmental office or mission area to assist the APC in coordinating theprogram support, operations and oversight within the specific agency, departmental officeor mission area.– USDA Charge Card Service Center –35
LAPC’s Responsibilities: Program Management Program Management Responsible for the day-to-day operations of the purchase card program at the LAPCs’respective sites. Work directly with the cardholder, APC and the U.S. Bank contact person. Ensure the accurate processing of all documentation for establishing a cardholder. Establish and maintain the purchase card program within the LAPC’s designated location. Provide additional guidance to Approving Officials and cardholders when needed. Establish and update cardholder information. Instruct cardholders to immediately notify the U.S. Bank’s customer servicerepresentative of a lost or stolen purchase card, or convenience check. Instruct cardholders to immediately notify the U.S. Bank of any discrepancies orunauthorized charges within 90 days of the transaction date. Ensure and track AOs’ and cardholders’ completion of mandatory training, includingannual refresher training and new cardholder training.– USDA Charge Card Service Center –36
LAPC’s Responsibilities: Oversight & Maintenance Oversight & Maintenance Monitor cardholder transactions—purchase card and, if applicable, convenience checks—using electronic management applications and tools. Conduct statistical sampling reviews. Ensure proper use of required sources of supply. Query quarterly final approval transaction reports by completing the LAPC Quarterly ReviewChecklist.– USDA Charge Card Service Center –37
LAPC’s Responsibilities: Oversight & Maintenance(Cont.) Ensure timely maintenance of cardholder accounts. Approve cardholder’s transactions on an emergency basis or if the cardholder hasseparated from the agency. Approve trailing transactions after a cardholder’s account is closed. Final approve transactions when the Approving Official (AO) has separated from theagency. Perform card cancellations, including the collection of a completed Card/CheckDestruction Form, due to employee terminations, transfers or extended leaves. Where applicable, serves as the Coordinator in Access Online for Purchase CardAccount requests. Completes CCSC-provided training on card request process. Reviews card requests for accuracy; before entering, rejects card requests with errors. Using AXOL, enters error-free card requests; submits to Final Approver for approval. Corrects rejected requests via AXOL. Checks card status in AXOL. Emails Final Approver with Purchase Card Request Package (e.g., request form,warrants).– USDA Charge Card Service Center –38
LAPC’s Responsibilities: Communications &Reporting/Data Calls Communications Provide training (e.g., in-person, webinar, materials) to both AOs and cardholders onthe proper use and maintenance of the purchase card. Inform AOs and cardholders regarding issues, such as outstanding training andsuspended cards. Distribute program literature and materials to cardholders. Attend CCSC-offered meetings and trainings to learn new program changes and toupdate knowledge of program policies, processes and procedures. Reporting/Data Calls Report fraud, waste and abuse in accordance with agency procedures.– USDA Charge Card Service Center –39
APC’s Responsibilities: Program Management Program Management Appoint Assistant, Deputy or Regional APC. Appoint LAPC. Provide guidance to LAPCs or additional training when needed. Ensure and track completion of all mandatory training, including Annual RefresherTraining, for agency’s purchase card community. Determine and recommend appropriate Merchant Category Classification (MCC)code ranges for card use. Depending upon agency, serve as either Coordinator or Final Approver in AccessOnline for purchase card account requests. Maintain documentation and retention procedures.– USDA Charge Card Service Center –40
APC’s Responsibilities: Oversight & Monitoring Oversight & Monitoring Conduct agency-wide oversight of the purchase card program, including proper use ofrequired sources of supplies and services, and when applicable, using U.S. Bank’sAccess Online. Ensure timely maintenance of managing accounts. In the absence of a LAPC, cancel purchase cards immediately upon employee’s termination Confirm the immediate cancellation of purchase card accounts and completion of Card/CheckDestruction Form upon employee’s termination or extended leave. Audit program compliance and file retention. Notify the LAPCs of non-compliance issues.Assist LAPCs in enforcing non-compliance measures. Ensure timely maintenance of User IDs. Confirm the timely cancellation of removal of User IDs when closing a cardholder’s account. Confirm the access assigning only to those individuals needing access to purchase card data. Confirm the assigning of individuals with the appropriate level of access. The level of accessshould not exceed the required level for individuals to perform their duties.– USDA Charge Card Service Center –41
APC’s Responsibilities: Oversight & Monitoring(Cont.) Where applicable, serves as Coordinator in Access Online for Purchase Card Accountrequests. Completes CCSC-provided training on card request process. Reviews card requests for accuracy; before entering, rejects card requests with errors. Using AXOL, enters error-free card requests; submits to Final Approver for approval. Corrects rejected requests
USDA manages its charge card program through the Charge Card Service Center (CCSC), Procurement Systems Division (PSD), Office of Procurement & Property Management (OPPM), Departmental Management (DM). USDA benefits from participating in the purchase card program: Rebates received from U.S. Bank based upon purchase volume