Most PCard approvals and control features occur after the purchase has taken place. Examples of after-the-purchase controls include:

• Support Documents for each PCard transaction. Transactions reported on the monthly account activity report provide very little information about purchases. The name of the vendor is listed, however there is little information regarding the items purchased. Support documents such as itemized receipts provide detailed information about the purchase, including what was bought, the number of items that were purchased, and the total amount charged.
• Reconciling PCard Account Activity Reports. Reconciling itemized receipts to transactions reported on monthly account activity reports allows the Cardholder to make sure that all purchases have been reported, that any credits have been received, and provides the opportunity to resolve any discrepancies.
• Administrative Review. Approving managers indicate approval of purchases by reviewing and approving transactions in the USB system. It is the supervisor’s responsibility to address Cardholders about questionable transactions and ensure all supporting documentation is attached to monthly packet.
• US Bank Controls. Certain merchant codes are blocked so that PCard transactions are automatically declined. US Bank provides access to all transaction data generated by Cardholders to the PCard Administrators. PCard Administrators review transactions and declined transaction reports on a regular basis for unusual or irregular transactions.

A. US Bank Access Online

Access Online is the database of record for all PCard transactions. Access to Access Online is password-restricted to ensure safekeeping of information. Cardholder and Approving Manager hierarchies are maintained in Access Online to ensure proper segregation of the review and approval process. The ability to post fund information to transactions is maintained and monitored in Access Online.

Access Online, USB’s web-based program provides cardholders and AMs a convenient method of querying information and transaction detail for purchasing activity on each PCard, allocating transactions to one or more funds, and accessing monthly account activity report on the first working day of each new month. Transactions generally appear in Access Online within 24 hours after processing by the bank.

B. Monthly Remittance Packet

Each month after the cardholder and AM review and approve transactions in Access Online, a remittance packet must be prepared and forwarded to the PCA for review and audit within the designated time requirements as outlined in section 11., “PCard Monthly Processing Deadlines.” The packets are relied upon to ensure complete transaction information is retained and must include”

• Monthly electronic Cardholder Account Activity Report
• Itemized receipts and documentation supporting each transaction

Packets containing the Cardholder Account Activity Report and associated receipts should be scanned and delivered to the PCA via e-mail. The AM is responsible for maintaining original receipts and providing access on demand as requested for periodic audits for the current fiscal year plus 90 days. The SDSURF fiscal year runs July 1st through June 30th.

C. Internal Controls and Accountability

To ensure the continued success of the PCard program, audits of a cardholder’s remittance packet will occur. The primary purpose of the audits is to ensure that the correct information is being captured and retained; that the PCard is being used for allowable transactions; and that program policies and procedures are in place and being followed.

Audits will be performed and will include:

• Review of statements to ensure itemized receipts support transaction
• Review of transactions for appropriateness and allowability
• Review of transactions for proper justification regarding the nature of the purchase.
• For documentation received electronically, verification that receipts and supporting document images are of sufficient quality to be readable.

D. Suspension and Revocation of Card

The following controls have been put in place to help manage the risks associated with dispersed purchasing authority via a larger system of PCards, with higher limits, and increased purchasing authority.

Immediate Revocation

Pcards will be immediately terminated and cardholder privileges immediately revoked under the following circumstances:

• Cardholder allowing other individuals to use his/her PCard
• Personal use of the PCard (using card for personal purchases/non-business related expenses)
• Fraudulent Use of PCard

Decreased Spending Limits

Any cards that have activity that is not allocated and approved in Access Online as of the monthly deadline will automatically have their spending limit adjusted to $0. The limit will be restored when the transactions have been allocated and approved and the monthly remittance packet has been received by the PCA. Approving managers are encouraged to communicate with the PCA when there are issues that will prevent final approval of the transactions before the deadline to prevent the spending limit from being dropped to $0.

Schedule of Progressive Corrective Actions

The following corrective actions may be used depending on the level of violation. Human error and extraordinary circumstances may be taken into consideration when investigating any violation of policy.

1st Incident - Approving manager and cardholder will be provided with a warning and a resolution date. If not resolved by this date SDSURF may charge expenses to the PI/PD’s discretionary funds and the card(s) limits may be set to $0 until resolved.

2nd Incident - Approving manager and cardholder will be provided with a warning and a resolution date. If not resolved by this date SDSURF may charge expenses to the PI/PD’s discretionary funds and the card(s) may be temporarily suspended until resolved. Card limits and spending privileges may be reviewed and adjusted to a more conservative spending limits and profiles.

3rd Incident - If the 3rd incident occurs within 12 months of the 2nd incident and warning, the PCard may be revoked for a period of three to twelve months. Any outstanding expenses may be charged to discretionary fund(s). Cardholder and approving manager may be required to attend training again. In the case of deficit spending, the PI/PD may be required to provide a discretionary fund, or if they do not have one, may be required to obtain Dean sponsorship.

Immediate Revocation - Cards may be immediately revoked for:

• Allowing other individuals to use one’s PCard
• Using the PCard for personal purchases/non-business related expenses
• Fraudulent use of the PCard

If the cardholder or AM anticipates any circumstance, which may result in transactions not being reviewed and approved by the monthly deadline or the monthly packet(s) not being submitted by the published deadlines it is the responsibility of the cardholder and/or AM to contact the PCA IN ADVANCE to request an exception.

NOTE: While contacting the PCA does not guarantee an exception, reasonable requests will be given due consideration.

The PCA has the authority to investigate and to determine whether a violation of procurement policy has occurred, and in consultation with the Payment Services Manager, to take actions as a result of such determinations. SDSURF will consider the facts and circumstances of each incident, and will take action as deemed appropriate, and as permitted by applicable law and/or SDSURF policy.

E. Validation and Reconciliation of Transactions

The cardholder and AM are responsible for reconciliation, record keeping, and validation of expenditures for all PCard transactions. Periodic statements listing all PCard transactions are available via the web based Access Online. Cardholders, AMs, and AAs will be trained regarding the use of Access Online prior to receiving a card. Please contact the PCA if assistance is required.

F. Office of Record

PCA is the responsible “office of record” for all PCard activity.