Procurement Card Policy
|History:||Issued||-- March 14, 2002|
|Revised||-- August 31, 2012|
Prohibited Transactions Policy; Grant and Contracts Policy; Procurement Policy; Contract Approval and Signature Authority Policy; Employee Cell Phones for Business Use Policy; Gift Card Policy; Conflict of Interest Policy (Finance); Corporate Travel Card Policy
|Additional References:||Enterprise Spend Platform; Procard Forms and Reference Materials|
|Responsible Official:||Senior Director, Strategic Sourcing and Procurement tel. (202) 319-5046|
The procurement card program is a tool to streamline and simplify the Purchasing and Accounts Payable functions. The procurement card reduces transaction costs, facilitates timely acquisition, automates data flow for accounting purposes and offers flexible controls to ensure proper use.
The Catholic University of America procurement card (also known as procard) is issued to individuals through the University, and secured by SunTrust Bank in the name of the University and the employee. Using the procurement card is the preferred method to purchase low value, non-capital expense items. Items previously acquired by petty cash, direct pay, or check requests should be targeted for the procurement card.
The cardholder should purchase from University-approved contract vendors, and whenever possible cardholders should take advantage of the pricing agreements and terms negotiated on the University consortium contracts with the Education & Institutional Cooperative Service (E&I), US Communities, General Services Administration (GSA) and other group purchasing organizations.
A. Authorized Approver - A person designated by a financial manager to review and approve procurement card transactions.
B. Cardholder - The person named on the card and authorized to make purchases using the card.
C. Card Issuer - The banking entity that provides the card. in the case of the University, the entity is SunTrust bank.
D. Enterprise Spend Platform (ESP) - The software and webpage provided by SunTrust Bank used to review, code (allocate transactions to a chartfield) and approve transactions by cardholders and the authorized approver. The software is also used by the plan administrator to oversee and administer teh procurement card program, including issuing cards, replacing lost or stolen cards, as well as other administrative functions.
E. Bank Statement - Monthly statement from SunTrust Bank indentifying card transactions for the month. This statement includes all account activity for any defined cycle period and is available online in ESP.
F. Default Accounting Chartfield - The department and account where all purchases will be charged, unless re-classed by the cardholder or the authorized approver in ESP. Note that the default accounting chartfield will be a non-grant/award funded department for principal investigators, and all charges must be reclassified for proper cost allocation.
G. Financial Manager - The Provost, a Vice President, Dean, Director, Department Head or Business Manager with budget authority.
H. Merchant Category Code (MCC) - The code assigned to each merchant to identify the industry description and type of product or service offering provided.
I. Plan Administrator - The individual at the University responsible for issuing the procurement card and administering other facets of the University's procurement card program. The Director of Procurement Services is be the University's plan administrator.
J. Procurement Card (Procard) - The VISA credit card issued by the University to eligible faculty and staff.
K. Small Dollar Purchases - Purchases which in aggregate cost $2,500 or less.
A. Guidelines for Procurement Card Use
The Provost, Vice Presidents, Associate Vice Presidents, Deans, Chairs and Directors may establish additional controls on card use for individuals within their departments. Such restrictions should be monitored by the authorized approver or financial manager.
Examples of allowable purchases include:
Office products and supplies Books and subscriptions Approved dues/membership organizations Conference registrations Events catering Printing/duplicating/copy services
The procurement card is not used for any of the following types of purchases unless authorized by the plan administrator.
Examples of prohibited types of purchases:
Animals (except for approved laboratory research use) Appliances Cell phones (see the University's Employee Cell Phones for Business Use Policy) Telephone equipment Food for personal consumption Computers (desktop, laptop, notebook/netbook, or iPad/tablet) Cash (includes adding funds to the Cardinal Card) Gifts or items of sentiment (parties, flowers, decorations etc.) construed as personal Gift cards (see the University's Gift Card Policy) Donations Purchases which involve signing an agreement, license or contract (see the University's Contract Approval and Signature Authority Policy) Purchases delivered to a non-University building address Chemical/hazmat materials Prescription drugs Alcoholic beverages (other than at an approved University event, function or dinner) Payments to individuals, consultants and employees Capitalized expenses for construction projects (unless pre-approved by the General Accounting Office) Capital equipment University to University payments Weapons and ammunition Employee relocation expenses Personal use/purchases Purchases over $2,500 Splitting transactions to avoid the $2,500 threshold Travel and business entertainment expenses (use the Corporate Travel Card for such expenses per the University's Corporate Travel Card Policy)
As previously noted, personal purchases are prohibited on the procurement card even if the requester's intent is to reimburse the University.
The financial manager or plan administrator may identify additional spending limits. Spending limits will be identified on the cardholder application. Increases to the transaction limit amount require approval by the plan administrator.
Note: A University procurement card is not a benefit of employment. The University reserves the right to terminate individual prourement card privileges at any time, with or without cause.
At times, University purchases may result in cash or cash-like incentives. The cash and/or incentives are the property of the University and may not be used for personal gain. Examples of such incentives include, but are not limited to: rebates, gift cards, two-for-one purchases and spend rewards. The University recommends that cardholders not participate in these promotional offers. It is the responsibility of the cardholder's department to be assured that any monetary or cash incentive reward received as a result of University purchase becomes the property of the University. Contact Procurement Services if further clarification is needed.
Should any personal charges be unintentionally charged on the procurement card, the user will immediately notify their supervisor; the supervisor will review the transaction and attach a signed statement of acknowledgement. The cardholder will then make payment to the University cashier window, and the payment must include the appropriate documentation crediting the accounts where these funds were expended. A copy of the deposit receipt must be attached to the cardholder's monthly statement covering this transaction.
B. University Liability
Charges to the procurement card are a University liability and have no impact on an employee's personal credit. Although the card is issued to a specific University faculty or staff member, the card is the property of The Catholic University of America, and is only issued to active, eligible full-time employees of the University. The University is not liable for transactions made by a terminated employee. To avoid potential charges after employee termination, the terminated employee's supervisor must notify the plan administrator immediately when an employee holidng a procurement card is terminated so that the card may be cancelled.
The University is not liable for fraudulent charges if SunTrust Bank is notified in a timely manner.
C. Cardholder Responsibility
Every cardholder is required to have a valid University email address and to check that email account regularly, because ESP transaction notifications will only be sent to that account. The cardholder is responsible for reclassifying charges from the default accounting chartfield to the correct chartfield, and to ensure that all receipts are scanned and attached to their transactions in ESP. It is the cardholder's responsibility to know their available funds and spend within their budgeted limits. Procurement card purchases that exceed budget will result in suspension of procurement card privileges. During the suspension period, procurement card purchases for that employee's work center will be made by the cardholder's next higher organizational authority. Two suspensions in one fiscal year will result in permanent removal of procurement card privileges. Please remember that you are committing University funds each time you use the procurement.
While the cardholder is authorized to make purchases on behalf of the University, good stewardship of University funds still requires due diligence. Consequently, it is University policy to seek the lowest prices within the parameters of quality, delivery and the efficient use of the cardholder's time. Accordingly, the cardholder must check as many sources of supply as reasonable to assure best value.
The cardholder must protect the security of the procurement card at all times. If the procurement card is lost, stolen, or becomes compromised, the cardholder must immediately notify SunTrust Bank, the University's Department of Public Safety, the plan administrator and the appropriate authorized approver.
D. Cardholder Supervisor Responsibility
The cardholder's supervisor will identify the authorized approver for each cardholder. The cardholder's supervisor, whether or not he or she is the authorized approver, is ultimately responsible for each cardholder's use and reporting requirements. The cardholder's supervisor is also responsible for notifying the plan administrator if the cardholder is terminated or transfers to another department or assignment within the University.
E. Authorized Approver Responsibility
The authorized approver is responsible for reviewing and electronically authorizing or rejecting each charge made by the cardholder in ESP within the required timeframe. The authorized approver should be familiar with the Procurement Card Policy and procedures, have a valid University email address, and check that email account regularly, because ESP transaction notifications will only be sent to that account.
F. Documentation Requirements
Original receipts must be scanned and attached in the ESP system. The original hardcopy receipts must be retained by the department for eighteen (18) months. Faxes and email notices from cardholders are not acceptable proof of payment; however they may be used to explain unusual situations. If the procurement card is used for an event the business purpose of the event must be documented as well as the names of the event attendees; refer to the Corporate Travel Card Policy for documentation guidance.
G. Sales Tax on Purchases
The Catholic University of America is exempt from sales tax in the District of Columbia, Maryland and Virginia. It is the cardholder's responsibility to ensure that sales tax is not charged to the University. The tax-exempt numbers for each jurisdiction are located on the front of the procurement card.
If sales tax is inadvertently charged to a procurement card, the cardholder is required to dispute the charge, contact the merchant and have the tax removed. If the merchant is uncooperative, a dispute can be initiated in the SunTrust ESP system before the end of the month cycle.
H. Purchases with Terms and Conditions
Procurement cardholders are responsible for reading and understanding any terms or conditions that accompany a procurement card purchase. Questions regarding any terms or conditions should be directed to Procurement Services before proceeding with the purchase.
IV. Procurement Card Cycle Deadlines
After making a charge, the cardholder has ten (10) days from the posting date to make any transaction chartfield changes (such as account, fund, org, program, sub-class). The authorized approver is able to view and approve the transaction at the same time as the cardholder; however, any changes to the chartfield by the cardholder will require re-approval. Therefore, the cardholder should communicate with the authorized approver and establish a regular approval timeline.
If the cardholder does not want to change the transaction, the cardholder should go into ESP and "save" the transaction, indicating that it is ready for approval by the manager. The best practice is to submit transactions for approval on a weekly basis.
Any transactions not viewed after ten (10) days will be automatically uploaded into Cardinal Financials under the default chartfield. Changes can be made to the transactions in the ESP system only until the time that the transactions are uploaded. If a department has a legitimate reason for requesting a change after the upload occurs General Accounting (or Grant Accounting) will process the change. However, a late reclassification request should be rare and if it occurs several times, cardholder privileges may be revoked.
Because the receipts and approvals will be electronically viewable by the plan administrator, the cardholder does not need to send his or her monthly statement to the Procurement Services. However, cardholders need to maintain their original receipts and monthly statements for eighteen (18) months after the transaction, for audit back-up documentation purposes.
V. Returning the Procurement Card
Upon separation, termination or retirement, procurement cards must be surrendered to the plan administrator.
VI. Code of Ethics
University cardholders should refrain from any actions which could be construed to conflict with the best interest of the University or to prejudice the University's reputation. Procurement cardholders are expected to be free of conflicts of interest or relationships which are, or potentially could be, detrimental to the best interest of The Catholic University of America, and must comply with the University's Conflict of Interest Policy.
VII. Consequences Resulting from Violations of Policy
Violations of rules governing use of the procurement card can be classified as minor or major. The action taken is dependent upon the nature and severity of the violation. Consequences may include additional training, cancellation of cardholder privileges, or disciplinary action up to and including termination of employment. The Vice President for Finance and Treasurer, in consultation with the Provost and other Vice Presidents, has the ultimate authority in determining the appropriate action based upon the violation or the frequency of the violations. The Vice President for Finance and Treasurer will involve the Office of Human Resources in all disciplinary decisions.
Minor violations include:
- Allowing someone other than cardholder to use the procurement card
- Failure to maintain receipts properly
- Not reclassifying charges in ESP to the correct chartfield on a timely basis
- Splitting transactions to avoid the $2,500 single purchase item limit
- Exceeding budget once warned that the available budget is gone
A cardholder will receive two warnings for minor violations. A third violation will result in loss of procurement card privileges.
A major violation indicates a willful intent to disregard rules. Examples would include:
- Making personal charges using the procurement card
- A repeated pattern of inappropriate charges or transferring procurement card purchases to sponsored programs.
The circumstances of the violations will determine the appropriate action. The intentional use of the procurement card to make a personal purchase will result in termination of procurement card privileges and may result in additional University disciplinary action.