Procurement Services Kathy Bordenski Assistant Director Business Development Programs Management Advisory Services MAS Michele Evans Director Alexandra ZourasWieneke Manager Jennifer Thompson Management Analyst ID: 496875
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Procurement Card Training Refresher
Procurement Services:
Regina Spencer,
Assistant Director Business Development Programs
Management Advisory Services (MAS):
Michele Evans, Director
Alexandra Zouras-Wieneke, Manager
Jennifer Thompson, Management Analyst
Elaine Portnoy, Management AnalystSlide2
Training Objectives
Review Requirements and Responsibilities of
Cardholder
Authorized ReviewerVerification ReviewerCurrent Monitoring TrendsMAS reviewsAudit ImplicationsVarious reviews and audits of pcard transactions
2Slide3
Introduction
Procurement Card Program is managed by Comptroller’s Office for State of MD
Procurement law mandates that
all purchases over $5,000 be made through Procurement Services to ensure appropriate purchasing method used Example – competitive bids or sole source justifications obtainedConsult Procurement Services regarding any order expected to exceed $5,000Cards are:
A benefit
To be treated with the same level of scrutiny as a purchase order
Any purchase not permitted by purchase order is not permitted by procurement card
3Slide4
Cardholder
ResponsibilitiesSlide5
Cardholder Responsibilities
Understand and comply with
all
policies and procedures in the User's Guide which include:Card securitySecure the card, card number, expiration date, and security code at all timesDo not share the card/sensitive details
Promptly escalate inappropriate use or a lost or stolen card
Make
only allowable purchases - consult Procurement Services or MAS when uncertain
Reimbursement from Foundation or other source for unallowable purchases not acceptable
Promptly record each transaction (purchase or refund) on
the log
as they occur; include a
clear
description to justify business purpose for each purchase
Maintain a
detailed receipt for each purchase (items purchased, quantities, itemized pricing, shipping charges, sales taxes, fees); ensure total on receipt matches the final purchase total
5Slide6
Cardholder Responsibilities
(Continued)
Document delivery of relevant purchases (packing slips, delivery date column of log, etc.)
Promptly notify Inventory Custodian of non-capital and sensitive equipment purchases to ensure appropriate tagging and recording (e.g., document asset tag numbers on log or purchase documentation) Policy – new policy coming!
Reconcile monthly transaction log to Visa statement
within 7 days
of receiptComplete “Reconciled to Bank Statement” column of log for each transaction
Sign
and
date both log and Visa statement
Promptly hand-off log, statement, and supporting documents to authorized reviewer
Quickly address discrepancies or disputes,
including sales taxes
charged inappropriately; remember to log and monitor the status of expected refunds
Accept no vendor incentives (gift cards, free games or other free items with purchase )
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Cardholder Responsibilities
(Continued)
Maintain records at least 3 years beyond fiscal year-end (may be longer for grant-related purchases)
or until audited by Legislative Auditors whichever is laterEffectively respond to all compliance and/or audit inquiriesPromptly notify Procurement Services of any status changes
Change in role
Change in name/contact details
Change of reviewer(s)Card no longer needed
Separation of employment
Surrender card immediately upon separation of employment or change in role/department
7Slide8
Reviewer
ResponsibilitiesSlide9
Authorized Reviewer Responsibilities
Understand and
monitor cardholder activity for compliance with
all policies and procedures in the User's Guide. Confirm the following for each cardholder:All transactions – including any not posted to Visa statement
– were accurately recorded in the transaction log with
clear
descriptions regarding business purposeVisa statement was effectively reconciled to transaction log
within 7 days
of receipt
Receipts and other relevant documents are included,
and
sufficiently detailed, to demonstrate
every
transaction’s compliance
Cardholder has appropriately:Completed all relevant columns appearing on the transaction logSigned and dated both the log and Visa statement
Sign
and
date both the log
and
Visa statement acknowledging compliance with the above requirements
9Slide10
Authorized Reviewer Responsibilities
(Continued)
Document concerns shared with each cardholder, including follow-up actions that need to be addressed by cardholder
Subsequently confirm that each item has been addressed by the cardholderEscalate issues not addressed through appropriate departmental channel(s) and/or Procurement ServicesForward completed transaction logs, Visa statements, and supporting documents to the verification reviewer, allowing sufficient time for the
verification
review to be completed by first business day of the following month
If cardholder had no card activity for the month, obtain written acknowledgement (e-mail, blank/signed log stating this point, etc.)
10Slide11
Authorized Reviewer Responsibilities
(Continued)
Points to Remember
You are the University’s primary line of defense against non-compliant and potentially fraudulent purchasesAuthorized Reviewer is the only one who assesses the reasonableness of each cardholder transaction to ensure compliance
Joe Evans
requires
that you promptly report the following to him – each month - before his monthly affirmation to the State:Non-compliant cardholder transactions
Scenarios in which
all
cardholder transactions have not been reconciled to the Visa statement
Scenarios in which the authorized reviewer has not approved
all
transactions for the billing cycle
Any gift card purchases
A non-response to Joe Evans’ monthly e-mail by the authorized reviewer certifies that
all
charges for the billing cycle have been reviewed
and
are compliant,
and
reviewers have signed
and
dated the transaction log and Visa statement, as appropriate.
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Verification Reviewer Responsibilities
Receive monthly emails from Procurement Services showing cardholder activity for the most recent billing cycle
By the
first business day of the month following the cardholder’s reconciliation, confirm that:All relevant cardholders and authorized reviewers have signed and dated both their transaction logs and Visa statements timely
The authorized reviewer signing is the reviewer on record with Procurement Services
Note: the cardholder’s reconciliation is to be completed within 7 days of receipt
of the Visa statement
Sign
and
date the transaction logs, acknowledging the above points
Promptly escalate instances of cardholder and/or authorized reviewer non-compliance to Procurement Services
12Slide13
Compliance TrendsSlide14
Compliance Monitoring Trends
What is currently happening
…
Missing and incomplete transaction logs (completed log example)Transactions not logged as they occur/inadequate reconciliation to VISA statement
Inappropriate charges not identified by cardholder
or
authorized reviewer Compromised card
Duplicate vendor payments
Personal purchases
Incomplete and delayed reviews and/or verifications
Incorrect reviewer of record
Non-capital and sensitive equipment purchases not recorded on department’s inventory register or inventory register not maintained by department at all
14Slide15
Compliance Monitoring Trends
(Continued)
Documentation concerns
Clear business purpose Item descriptions, quantities, and prices on vendor documentation Vendor documentation present for all purchases (put back if removed for copies) Evidence that goods were received (packing slip, email, date on log)Logging and monitoring of returns/expected refunds
Documented explanations for
all
off-campus shipmentsSales tax paid and recovery not pursued Security of card and sensitive card details
Maintained on filed documentation or in a safe with unrestricted access
15Slide16
Compliance Monitoring Trends
(Continued)
Vendor incentives
Ex., gift cards, coupon vouchers, food items, tote bags/gift items Travel costs (taxi, parking, limo, lodging, etc.)Furniture purchases without MCE waiversUnauthorized food and accessory purchases Revised Policy effective 2/1/2014: New Food Policy
Fellows and residents are not
students!Gifts and awards Foundation expenses paid using state-issued VISA and subsequently reimbursed
16Slide17
Compliance Monitoring Trends
(Continued)
Split purchases
– what, why and how!Purchases exceeding $4,999 and split into multiple transactions to circumvent the thresholds Problem arises when Daily Purchases with same vendor exceed $4,999 (Example)What did you know and When did you know it? At the time of purchase/order
, if you know the order will exceed $4,999 -
do not use
the pcard and contact procurement services for further assistanceAt the time of purchase/order, the amount does not exceed $4,999 – pcard used to place order. Later that same day, another order was requested/placed with the same vendor and the combined orders exceeded $4,999….you must:
Document the
time/date
of each request and order placement to show the orders were requested and made independent of the one another
Requests should be from separate individuals and/or for separate projects
Payment of multiple invoices from same vendor on same day exceed $4,999
Document invoices are for separate orders made on separate days – order date important
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Reviews and Audits
General Accounting Division, Comptroller of Maryland
Sends list of questionable transactions monthly
GAD Questionable VendorsLevel 3 Data examplesOffice of Legislative Audits Recently completed a Statewide Audit of the Procurement Card ProgramOLA State CPC Audit Report 2014
University System of Maryland
Routinely sends lists of questionable transactions based on level 3 descriptions
Management Advisory Services
Performs routine pcard reviews of Departments
Reviews questionable transactions
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Contacts
Procurement Services:
Regina Spencer,
Asst Director Business Development Programs (410) 706-8304; rspencer@umaryland.eduWebsite: www.umaryland.edu/procurement/Management Advisory Services (MAS): Michele Evans, Director
(410) 706-5584; mevans@umaryland.edu
Alexandra Zouras-Wieneke, Manager
(410) 706-6848; azouras@umaryland.edu
Jennifer Thompson, Management Analyst
(410) 706-5996; jthompson01@umaryland.edu
Website: www.umaryland.edu/mas
/
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Helpful Links
Procurement Card website for general pcard information:
http://www.umaryland.edu/procurement/corporate-purchasing-card
/Procurement Card User’s Guide: http://www.umaryland.edu/media/umb/af/procurement/UserGuide.pdfPcard Program Forms (for changes to cardholder acct, reviewers, etc): http://www.umaryland.edu/procurement/forms/Financial Services Policies/Procedures:
http://www.umaryland.edu/financialservices/policies-and-procedures
/
Non Capital Equipment (including sensitive) Policy: http://www.umaryland.edu/media/umb/af/fs/policies/Non-CapitalEquipment.pdf
Food and Business Meals Expense Policy:
http://
www.umaryland.edu/media/umb/af/fs/policies/FoodBusinessMealsExpense.pdf
Office of Legislative Audits - Statewide Purchasing Card Audit 2014:
http://
www.ola.state.md.us/Reports/Performance/CPC14.pdf
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