NASA-Glenn Research Center

Bankcard Program

Audit Procedures

Effective 4/22/96

Web Version Revision February 2013

Bankcard Issuance & Closing of Accounts

The CAPC (Center/Agency Program Coordinator) issues bankcards to individuals whose supervisors submit a written request identifying a justifiable need.

The CAPC will review cardholder activity levels quarterly in order to identify cardholders having little or no purchasing activity over a period of one year. These cardholders will receive an e-mail inquiring whether they still require a bankcard. Individuals who no longer need a bankcard account or cannot adequately justify the retention of the bankcard will have their account closed.

Training

Prospective bankcard users, approving officials and ‘alternate’ bankcard users must complete two training courses prior to obtaining a bankcard and using the P-Card software: “NEACC1035 Bankcard Purchases & Desktop Receiving,” and “NASA GRC-PROC-11 Purchase Card Program.”

The first course provides training on the use of P-Card software, and the second provides guidelines for use of the bankcard, such as such as allowable and prohibited purchases. Both courses are available on the SATERN website.

Training information is updated on a continual basis as changes occur. Cardholders are kept appraised of changes to the Bankcard Program and P-Card software via e-mail. Bankcard information is also available on the Glenn Bankcard web page at: http://www.grc.nasa.gov/WWW/Purchase/bankcard.html. This site contains links to the online Bankcard Program User Manual, source selection guidance, related forms and other information pertinent to the Bankcard Program.

Refresher training is required every three years. This can be accomplished by completing the SATERN course “NASA Purchase GRC-PROC-11 Card Program”.

Cardholder Responsibilities

- Make sure that your purchase is within the guidelines as stated in the Bankcard Program User Manual.

- Do not split requirements to stay below the $3,000 bankcard order threshold.

- Do not place any orders until you have a saved order log.

- Reconcile promptly each month once you receive the notice that transactions are available.

Approving Official Responsibilities

- Only request new cardholder accounts if there is a genuine need for additional cardholders in your organization.

- Advise cardholders to have proof of receipt readily available for your review upon request.

- Approve monthly cardholder transactions by the specified deadline.

Dollar Limits

Single purchase and monthly limits are assigned by the CAPC when the account is set up with the bank. The single purchase limit for all cardholders (other than Contracting Officers) is $3,000. Monthly limits may vary depending on each cardholder’s usage, and can be modified by the CAPC as needed. The single purchase limit cannot be modified. If a purchase exceeding either limit is attempted, the card will decline and the transaction will not be processed.

Reconciling Monthly Transactions

Because delinquency in reconciling monthly transactions impedes timely bankcard payment, the following process has been instituted to encourage compliance with due dates as well as to provide consequences for late reconciliation and approval.

Cardholders:

When transactions are available for reconciliation (typically by the 17th day each month) P-Card alerts cardholders via e-mail that they have transactions to reconcile and the deadline by which reconciliation and approval must be accomplished. In addition, upon logging into the P-Card system, a banner message appears noting the due date for reconciling.

Prior to the deadline for reconciling, the CAPC or Alternate CAPC e-mails cardholders a reminder to reconcile in a timely fashion and to seek assistance if needed.

For a first offense of late reconciliation, cardholders will be issued a warning notice.

The second occurrence (within one year) will result in suspension of bankcard privileges for 30 days.

Any subsequent occurrence (within one year) will result in suspension of the bankcard account for three months.

Approving Officials:

P-Card automatically generates an e-mail to the approving official once the cardholder has completed reconciling. In the event an approving official does not approve transactions by the designated deadline, the following procedures apply:

First occurrence of not approving by the deadline, the approver will be issued a warning notice.

The second occurrence (within one year) will result in suspension of cardholder account(s) (whose transactions weren’t approved by the deadline) for 30 days. A notice of these suspensions will also be sent to the approver’s supervisor.

Any subsequent occurrence (within one year) will result in suspension of cardholder accounts (whose transactions weren’t approved by the deadline) for three months. A notice of these suspensions will also be sent to the approver’s supervisor.

An approving official cannot direct a cardholder to make a purchase that is noncompliant with bankcard policies and procedures, such as (but not limited to): unauthorized commitments, splitting requirements, purchasing restricted items, etc. (refer to the Bankcard Program User Manual for complete information).

If an approver sees a questionable transaction, they must discuss it with the cardholder. If it is determined that the purchase should not have been made, the approver shall instruct the cardholder to make arrangements for return and credit of the purchase. A note shall be added within the comments field in P-Card that the item(s) are being returned and a credit will be issued. However, the transaction must still be ‘approved’ within P-Card while the return/credit issue is resolved offline.

Note: In the event that an approver is not available to approve monthly transactions (i.e., travel, S/L etc.) the APC or Alternate may go in to perform an "electronic approval" so as not to delay completion of the monthly file. The APC or Alternate will then send a copy of the transactions via e-mail to the approving official, who must then review the transactions and respond back with their official approval.

Failure of an approver to respond (within 30 days of receipt of email) will result in suspension of the cardholder accounts (whose transactions have not been officially approved) for 30 days.

New Supervisors or Cardholder Change in Organization:

If the cardholder has moved to another organization, and their new supervisor does not yet have access to P-Card, the former supervisor may approve the cardholder’s transactions for one month. If the new supervisor does not complete the necessary training and NAMS request to obtain P-Card access, the cardholder account will be suspended until such time when their new supervisor can approve their transactions. The same applies in the event a new supervisor is assigned to the cardholder’s organization.

Additional Warning Notices and Suspensions

In addition to late reconciliation and/or approving monthly transactions, a warning notice will be issued (with a copy sent to the cardholder’s supervisor) if:

A requirement is divided into two or more order logs in an attempt to avoid exceeding the single purchase limit.

It is determined that a shipment is received on an unfunded procurement (i.e., no order log was created prior to placing the order). This is also referred to as an ‘unauthorized commitment.’

A sensitive or restricted item is procured with no supporting justification; specifically, lacking a note in the comments field that references a verbal/written approval obtained from the CAPC or Alternate, and/or the appropriate functional area. Based on the findings of the weekly audit, information will be provided to the CAPC noting cardholders who purchased inappropriate items and other relevant information pertaining to the purchase.

It is determined that the cardholder authorized another individual to use his/her bankcard.

The cardholder fails to retain purchase receipts for three years, as required by the Records Retention Schedule.

It is determined that a cardholder has used another organization’s funding without prior approval.

Any other action or purchase that is deemed to be noncompliant with Bankcard Program policies or procedures.

Subsequent violations of the bankcard procedures described above shall result in suspension of cardholder accounts as described above for late reconciliation of cardholder accounts. Suspected instances of fraudulent purchases made by the cardholder or purchases of items/services for personal use will be referred to the Office of Inspector General.

Note: Approving officials found to have approved purchases of noncompliant items or services shall receive a warning notice, with a copy sent to their supervisor. Subsequent approvals of noncompliant items or services shall result in suspension of cardholder accounts as described above for late approvals of cardholder purchases. In addition, instances where it appears approvals were made for fraudulent purchases or items/services for personal use will be referred to the Office of Inspector General.

Cardholders who wish to appeal a warning notice may do so by submitting a written

request to the CAPC within 10 days.

Cardholders and approvers may also request a meeting for reconsideration of suspended accounts. A representative from another functional area may also be present at this meeting, depending on the nature of the infraction. This meeting provides the cardholder and/or approving official the opportunity to present any additional information relative to reinstatement of bankcard privileges.

The CAPC will issue a final decision within five workdays after the meeting, which will be based on information provided by the cardholder, approving official and representatives(s) in attendance at the meeting.

Prior to lifting the suspension, the cardholder will be required to attend 1-on-1 refresher training with the CAPC or Alternate CAPC, or complete the SATERN course entitled “NASA Purchase Card Program.”

Revocation and Reinstatement Policy

In cases where a cardholder demonstrates continued inability or unwillingness to adhere to Bankcard Program policies and guidelines, the CAPC reserves the right to revoke the bankcard. Prior to revocation, the cardholder will be permitted to present his or her case as mentioned in Section 5. above.

A cardholder whose bankcard privileges have been revoked may request consideration for reinstatement no earlier than 3 months after termination of the bankcard account. The request shall be made to the CAPC, who will schedule a meeting with (at a minimum) the cardholder and the supervisor/approving official. Other functional representatives may be invited to this meeting when the infractions relate to specific requirements of other functional organizations.

If it is determined to be in NASA’s best interest to reinstate the user’s bankcard privileges, the cardholder will be required to attend a 1-on-1 bankcard refresher session with the CAPC or Alternate, or complete the SATERN course entitled “NASA Purchase Card Program.” This training must be completed prior to reactivation of the bankcard account.

This Audit Plan will be reviewed and updated as necessary to incorporate procedural and regulatory changes as they occur.