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PCard Best Practices:
Policy Compliance
University Policy 3.12, Procurement Card, identifies a business service center director (also known as an "administrator") as the individual responsible for ensuring that procurement cards (pcards) are used only in full compliance with university policy, and that any violation of policy results in the suspension or revocation of the pcard. The guidelines in the procurement card policy were developed to ensure sound business practices and full compliance with other university policies, as well as various external requirements, such as IRS regulations, federal OMB circulars (particularly A-21), NCAA requirements, etc.
The following "Best Practices" provide a course of action in responding to a policy violation. "Best Practices" also encourage uniform enforcement of the pcard policy within, and between, business service centers.
The following violations of the procurement card policy should result in a minimum 60-day suspension of the pcard:
- Any instance of lending/sharing of a procurement card
- More than two instances of the following "non-compliance" events during any rolling 12-month period - sometimes referred to as the "three strikes rule":
- Prohibited transaction (see Appendix B of policy)
- Splitting a transaction
- Failure to submit adequate documentation, including a clear business purpose
Depending upon the circumstances, certain other violations of the procurement card policy may also warrant a suspension of the card, such as:
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Submitting documentation (or an explanation, as described in the Documentation section of the pcard policy) more than 10 days after the transaction, causing the automatic release of the charge against the default account. Note: Absent any extenuating circumstances, more than three late submissions should result in a suspension of the pcard.
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Submitting written explanations for missing, lost, not received receipts, in lieu of originals, may warrant a suspension if/when the frequency or circumstances do not appear reasonable.
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Exceeding a pcard's transaction limit. Note: Merchants can (and do) force through transactions without verification of a card's limits. Take into consideration the amount of the transaction, and whether or not the cardholder should have been aware that an order would total more than his/her transaction limit.
- Any other use of the pcard that violates this, or other, university policies.
When an individual's use of the pcard warrants a third suspension in any rolling 12-month period, the pcard should be revoked.
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