2/27/02

 

Office of Facilities, Acquisitions, and Central Services

 

International Merchant Purchase Authorization Card (IMPAC)

On-Line Training Course

 

 


Welcome to the FDA IMPAC program.  This online training tool will teach you how to use the purchase card responsibly.  For specific information on FDA training and restrictions, refer to the IMPAC BankCard Manual and the FDA Staff Manual Guide. After reading this material, you are required to take the FDA IMPAC Quiz.  Students achieving a 70% score on the quiz will have successfully completed the FDA training and certification requirements.  You will receive your certificate electronically.

 

How to Take the Course

Read the course.  At certain points during the course you will see icons that will guide you to specific areas of the FDA IMPAC BankCard Manual and other FDA resource materials that contain information you will need to answer questions on the FDA IMPAC Quiz.  Click on the link and read the designated section of the manual.  After reading the section, click the BACK button of your browser to return to the course.

After reading the course, print the quiz and circle your answers. When you are finished, fax the quiz to the OFACS IMPAC Coordinators on (301) 827-7103.

 

Getting Started

You have been selected to receive a purchase card. The agency/organization program coordinator (A/OPC) for your organization will help you get started. The term agency/organization program coordinator refers to the Director, Division of Contracts and Procurement Management, and the IMPAC Program Staff in the Office of Facilities, Acquisitions and Central Services (OFACS).  The A/OPC will set up your account with the purchase card contractor.

 

Your Purchase Card is Issued to You for Official Government Business Only.

The purchase card can NEVER be used for personal reasons. Your name is imprinted on the card. Only you are authorized to use the card. Do not lend it to anyone. No member of your family, your staff, or your supervisor may use your purchase card. Safeguard your purchase card number as well as the purchase card itself.   To prevent accidentally using the IMPAC for personal use, keep the card in your wallet, but in a separate section from your personal cards.

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If you accidentally use your IMPAC card for a personal purchase before leaving the store, you should return to the store cashier and request that a credit be processed immediately.  Pay for the transaction with a personal credit card or cash.  Notify your Approving Official, A/OPC, and your supervisor by the next business day.

 

If you realize that you used your IMPAC for a personal purchase within a few days after the transaction took place, you should attempt to get the charge credited to a personal credit card.  Notify your Approving Official and your supervisor of the mistake within the next business day.  In the event that the charge cannot be credited, notify the A/OPC, write a check payable to the Food and Drug Administration and submit it to the Office of Financial Management (OFM).

 

Do not attempt to have the charge credited to a personal credit card since it may not be feasible for the credit card company/issuer of the personal card to process the action.  Notify your Approving Official and your supervisor within the next business day.  Notify OFM, write a check payable to FDA, and contact the A/OPC.

 

If you use your IMPAC for a requirement that was for official FDA business, but was not an allowable purchase under IMPAC program guidelines, contact the vendor/contractor and limit the amount of work that will be billed too the purchase card.  This will eliminate or minimize any adverse administrative problems that could arise.  Prepare a requisition for the remainder of the work that is required.  Briefly document your IMPAC records and inform your Approving Official and your supervisor.

 

Become knowledgeable of what are allowable and unallowable purchases under the IMPAC program.

 

Benefits of the Purchase Card to the Government

 

Use of the purchase card benefits the government in many ways. The government saves time, money and resources. The purchase card program provides the government with financial and cash management control over low dollar, value high volume procurements.

The government saves money by making only one payment to the purchase card contractor rather than thousands of payments to individual merchants. The Government improves the use of its resources by freeing up contracting personnel so they are able to focus on activities that require their expertise.

 

Merchants throughout the world accept your purchase card without question because they are familiar with commercial credit cards and they understand how to accept them. As a cardholder, you are going to be able to decide what to purchase, when to buy it, and from whom. You will monitor funds availability yourself. The concept of the purchase card program is "just-in-time." You can get what you need when you need it. Merchants like it too because they are paid quickly for the supplies and services they provide.

 

Benefits of the Purchase Card to YOU

Your personal credit history is not required to use the card. Use of the purchase card will not affect your personal credit history. The most important criterion is a job requirement to make purchases. Any government employee or employee of another entity authorized to use the program who has a responsibility to make purchases and who completes the necessary training is eligible to become a cardholder. There are no civil service grade requirements. Cardholders are either appointed by their A/OPC or nominated by an Approving Official.

 

ROLES

 

The effective operation of the purchase card program is designed around the relationships of seven key players. Each has a critical role in assuring the integrity of the process. The most important player on the purchase card team is the cardholder.

  1. The Cardholder.

The other players are:

  1. Approving Official.
  2. Agency/Organization Program Coordinator.
  3. Agency IMPAC Co-Coordinators.
  4. Designated Billing Office.
  5. Purchase card contractor.
  6. Merchant.

 

Cardholder

Your role as the cardholder is to use the purchase card to buy goods and services for government use.  You hold the primary responsibility for the proper use of the purchase card.

Your responsibilities as a cardholder are to:

 

·        Secure the card.

·        Maintain a purchase log.

·        Use the card only to make informed buys of approved goods and services.

·        Ensure funds availability before purchase.

·        Observe all dollar limits on purchases.

·        Reconcile and document transactions.

·        Use the card ethically.

 

You are the government's legal agency for each purchase made with the purchase card.  You are legally responsible and accountable for each transaction. You must comply with all applicable regulations and procedures of your agency.

 

The purchase card bears the cardholder’s name and may be used only by that individual and only to purchase and/or pay for official government purchases in compliance with the policies and procedures governing the purchase card. 

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The purchase card is strictly for use by the cardholder to which it is assigned.  Under no circumstances is a cardholder to give their card or account number to another individual.  Furthermore, no other individual can sign for/or as the cardholder.  Use of a card or account number by an individual other than the cardholder is considered fraud against the U.S. Government.

 

Approving Official

Let's look at the second key player, the Approving Official. The primary purpose of this position is to assure proper use of the purchase card.  The Approving Official makes sure that your purchases are necessary for accomplishing the mission of your agency.

 

Approving Officials are designated by the Central Control Points and approved by the A/OPC.Approving Officials are not required to supervise the cardholders assigned to them.

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Approving Officials are responsible for reviewing their monthly cardholders’ statements and verifying that all transactions are for necessary government purchases in accordance with the FAR and the FDA IMPAC Bankcard Manual.Although cardholders bear the ultimate responsibility for their cards, Approving Officials have the right and responsibility to question purchase(s) as to validity.In the event that a cardholder is unable to provide an adequate explanation as to circumstances, the Approving Official has the responsibility to pursue further action to resolve the issue and/or request termination of card account(s) and, if appropriate, seek disciplinary action.

 

The Approving Official reviews the monthly bank report, reconciles each of his/her cardholders' monthly statements, and verifies that all transactions are valid government purchases made in accordance with these procedures.The reconciliation must be completed within five (5) working days from receipt of the Statement of Account (SOA).  The Approving Official approves the document by signing and dating the statement at the time of review.

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Unlike cardholders, Approving Officials can delegate their responsibilities only in their official absence from the office.  Consequently, when on leave, official travel, or on detail, the Approving Officials shall issue a memorandum of delegation of authority to an individual within their organization.  (OFACS does not need a copy.)  Individuals that are acting for Approving Officials must be completely familiar with the terms and conditions of the IMPAC program.  Cardholders cannot be named to be acting Approving Officials over their own account.  Acting Approving Officials that have those responsibilities for more than a two-week period must attend a training session conducted by the organization’s OFACS contact (A/OPC).  OFACS need not be notified to change bank records until a PERMANENT replacement is named as the new Approving Official.

 

Agency/Organization Program Coordinator (A/OPC)

The third key player is the Agency/Organization Program Coordinator (A/OPC). The A/OPC generally serves as the focal point for answering questions, task order administration, establishing and maintaining accounts, issuing and destroying cards. Only the A/OPC is authorized to request the contractor to establish new accounts. The A/OPC also serves as the liaison between the Agency/Organization, and the purchase card contractor. The A/OPC oversees the card program(s) for the FDA and establishes guidelines. Changes to authorization controls must be submitted to the contractor by the A/OPC.

The A/OPC will:

 

·        Help you set up your account.

·        Serve as liaison between you and the purchase card contractor.

·        Provide on-going advice.

·        Audit purchase card accounts as required.

·        Keep necessary account information current.

 

Designated Billing Office (DBO)

The fifth player, the Designated Billing Office (DBO), serves as the focal point for receipt of official centrally billed invoices.  The DBO oversees the proper processing of invoices and ensures invoices are paid within the Prompt Payment Act timeframes. Responsibilities typically include the following:

 

·        Reconciling invoices.

·        Providing feedback to the A/OPC on contractor performance.

·        Determining whether to pursue faster payment of official invoices in order to take advantage of the productivity refunds, if in the best interest of the government, and paying on the proper date.

·        Providing timely payment.

·        Providing proper interest penalties for payments that exceed Prompt Pay Act timeframes.

·        Making certain that the FDA task order is adequately funded.

 

The Purchase Card Contractors

The purchase card contractors are important players in this program and are dedicated to high levels of service.  The Department of Health and Human Services has contracted with U.S. Bank (I.M.P.A.C.)

 

The Contractor:

 

·        Pays merchants for purchase card transactions.

·        Establishes cardholder accounts.

·        Issues cards.

·        Prepares the monthly statement for each cardholder.

·        Issues invoice to DBO.

·        Provides 24 hour customer service.

·        Prepares reports that assist your agency in effectively using its funds.

 

The Merchants

The last key player is the merchant who is the source for your supplies or services.

The merchant may be:

 

·        A required source inside or outside the government.

·        Another government agency.

·        A private sector merchant of supplies or services.

A merchant must provide supplies and services at a reasonable price.

 

MAKING PURCHASES

 

The purchase card is given to you, the cardholder, in trust that it will be kept safe. Unauthorized use of the card due to your failure to secure the card may result in disciplinary action.

 

After receipt of the card the following steps should be taken:

 

·        Verify the accuracy of your name and address.

·        Call the toll free number provided by the purchase card contractor to confirm receipt of your card and to activate your account.

·        Sign your card.

·        Review the cardholder guide provided by the purchase card contractor.

Before Using the Purchase Card

You should:

 

·        Determine specific requirements.

·        Determine that funds are available.

 

Market Research

What help can your contracting activity be in market research? Your contracting activity can provide information on required sources of supply, existing contracts, good merchants and many other areas.

 

Market research allows you to make an informed, responsible, reasonable purchase.  Do enough market research to ensure that the government gets a good value for its money in terms of reasonable price and timely/reliable/quality service. The purchase should represent the best buy that meets the government's minimum requirements.

Check with your contracting activity to see if there are existing contracts that offer you a good price, service, and quality. These existing contracts have been negotiated at your agency or by other agencies and can sometimes offer advantages in time and money savings. Check with the merchant to determine if they accept the purchase card.

 

Selecting the Best Value for the Supplies or Services

When making micro purchases, identify the supply or service that best satisfies the requirement, weighing both price factors and non-price factors. You can buy a higher priced item if it represents a better value.

 

State Tax Exemption

On December 10, 1998, the GSA sent a letter to all states and commonwealths requesting their support of the purchase cared program by continuing to extend tax exemption status to the Federal Government credit card purchase. A copy of the letter can be found at http://apps.fss.gsa.gov/services/gsa-smartpay/taxletter/.

 

In virtually all instances, IMPAC purchases are tax exempt except for Arizona, Hawaii, and for conference/meeting space in Washington, D.C.

You may make IMPAC purchases in locations recognized as non-exempt, but you must realize that tax will be part of the cost and to note your IMPAC supporting documentation.

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Talking To Merchants

You should be as specific as possible when talking to merchants.  Ask about:

 

·        Price.

·        Whether the price includes shipping.

·        Time of delivery.

·        Discounts for Government purchases.

·        Merchant's return policies.

When you have all the necessary information, make the purchase.

 

·        A merchant may never charge a fee for using the purchase card.  Report any merchant who asks you to pay a fee to your A/OPC.

·        A merchant may never establish a minimum or maximum transaction amount as a condition for honoring a purchase card.

·        A merchant may never require the cardholder to complete a postcard or similar device that includes the cardholder's account number, card expiration date, signature, or any other card account data in plain view when mailed.

 

What are Point of Sale Discounts?

Certain merchants offer automatic discounts when you use your purchase card to make purchases. These merchants recognize the government purchase card and apply a discount at the time of the sale.

 

Is It Necessary to Distribute Purchases?

Yes.  Part 13.202(a) of the Federal Acquisition Regulations recommends that micro-purchases be equitably distributed among qualified merchants to the extent practical.

 

Placing the Order over the Counter

By using the purchase card, you can step into a store and pick out the items to purchase. Take your items to the sales clerk and identify the purchase as an OFFICIAL GOVERNMENT PURCHASE. It is therefore a totally tax exempt purchase (no federal, state or local taxes).

 

·        The sales clerk should itemize your purchases.

·        Sales taxes should not be charged on your order.

·        You should sign the receipt.

·        Get a copy of the itemized receipt.

·        Upon return to your office with your purchases, place the receipt in a safe place until your monthly invoice statement arrives.

 

Placing the Order by Phone or Fax

When you use the purchase card, you can order right from your desk. Begin by placing your order by telephone or fax by:

 

·        Contacting the merchant and identifying yourself as a government employee who is making a purchase with a government credit card.

·        Indicate that the purchase will be tax exempt.

·        Note the total purchase price after going over the price of individual items.

·        Be careful in giving out your purchase card number.

·        Identify the items to be purchased reaching agreement as to the price of each item (including shipping charges).

·        Note the purchase in your purchase log.

·        Give your name and address for shipping, making sure your name appears on the mailing label and making sure that an itemized shipping document or invoice is included in the shipment.

·        When the item arrives, make sure you have what you ordered, at the price you agreed to pay.

·        If there is any discrepancy, call the merchant immediately.

·        Keep your records until receipt of your monthly invoice statement.

 

Before placing an order on line, familiarize yourself with the on line service's general information for placing orders.  If the procedure for placing orders is acceptable, register your purchase card and the expiration date with the on line service.  To place the order:

 

  1. Identify the merchant you wish to use and bring up the merchant's ordering screen.
  2. Enter the requested data.
  3. Make it clear that you are a government employee.
  4. Use your business address only, and indicate your purchase is tax exempt.
  5. Make sure the merchant will include an itemized shipping document or invoice with the shipment.
  6. Record the purchase in your purchase log.
  7. When the items arrive, make sure you are satisfied with the purchase. If not, notify the merchant immediately.
  8. Keep your records until you receive your monthly invoice statement.

 

Denied Transactions

 

If the purchase card is rejected during the merchant authorization process, the vendor or the cardholder may call the “800” telephone number of U.S. Bank printed on the back of the card for assistance.  Cardholders may or may not receive information by the bank and/or merchant as to why the transaction is being denied.  In the event that information is not provided, the cardholder should contact the A/OPC directly to resolve the situation.

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  Common examples of denied transactions are:

 

1.      Merchant error, such as input of incorrect expiration dates.  In cases where a transaction is denied, cardholders are encouraged to have the merchant verify the account number and expiration date by reading them back as they were submitted.  Consequently, such incidents may be less likely to occur.

 

2.      Cardholders going over their single purchase limits, monthly limits, and closed account numbers.  These causes vary from cardholder and merchant errors to fraud.

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Price Difference between Quotes and Invoices

Sometimes you will encounter problems in reconciling your invoice. Price differences between quotes and the invoice occur most often because the price billed includes shipping or handling or a tax charge. That's why it is important for you to ask the right questions when making your purchase. Price difference between quotes and statement amounts cannot be disputed with the purchase card contractor. You must contact the merchant and ask for a credit. The charge must be paid as it stands on your monthly invoice.

 

Dollar Limits on the Purchase Card

There are generally two types of dollar limits applied to your purchase card:

 

·        Single purchase limit

·        Monthly purchase limit

 

Single purchase limits and monthly purchase limits are established when your account is set up.  They are based on your Delegation of Authority and the budgetary limits of your office.

 

The single purchase limit is the dollar limit for an individual purchase card transaction.  For micro-purchases, the single purchase limit may be set up to $2,500. The monthly limit represents the cumulative dollar limit for your purchases in one month. It may be set to any dollar amount equal to or greater than the single purchase limit.

 

Verify both of your limits with your Approving Official or A/OPC.  Other restrictions such as number of transactions and merchant category codes may apply.

 

The A/OPC and Co-Coordinators in OFACS are the only individuals authorized to contact U.S. Bank to request purchase limit increases, to add new cardholders, change cardholder information, and other changes to FDA IMPAC accounts.

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Exceeding Your Dollar Limit

Prior to processing your purchase, the merchant will check to see if it exceeds any of your dollar limits. All attempted transactions, which exceed your single or monthly limit, will be automatically declined at the point of sale. It is your responsibility to know the level of your limits before you purchase. Do not rely on the authorization system to do this for you. Contact your A/OPC immediately if your card is declined.

 

What You Can Buy With the Purchase Card

The purchase card is a valuable tool but not a blank check. Therefore, before you use the purchase card, you need to know the limits on its use and manage your purchases against those limits. You can buy any commercially available goods or service not prohibited by either federal or agency-specific procurement regulations. If a purchase appears questionable to you, consult your A/OPC or contracting office.

 

There are a number of purchases that are STRICTLY PROHIBITED. The purchase card may not be used for long-term rental or lease of land or buildings, travel or travel-related expenses (excluding conference rooms, meeting spaces, and local transportation services (e.g., metro farecards, subway tokens, etc.), and cash advances.  These items are NEVER to be purchased using the purchase card.

 

Unauthorized Purchases

 

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The purchase card bears the cardholder’s name and may be used only by that individual and only to purchase and/or pay for official government purchases in compliance with the policies and procedures governing the purchase card.  The following goods and services may not be purchased with the IMPAC card even if they are for FDA official business:

 

1.      Hotel lodging, meals, drinks, or transportation tickets, which instead shall be purchased with the government travel card.

2.      Telephone calls, except cell phone airtime.

3.      Sensitive information technology equipment, including computers, unless the cardholder meets the requirements in FDA Staff Manual Guide 3240.1¾Agency-wide Policy for Information Technology Purchases.  

4.      Rental or lease of land or buildings.

5.      Repair or service of leased vehicles when the lease provides for servicing and repairs.

6.      Items from commercial sources when the statutory sources listed in FAR Part 8 will meet the requirement.

7.      Gift certificates under the FDA’s Reward and Recognition Program greater than $100 per person, per award.

8.      Any item intended for personal convenience or consumption.

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9.      Travel-related expenses such as transportation tickets (e.g., airline, bus, or train), ground transportation, vehicle rental, meals and lodging.  Metro fare cards that are used for local transportation are allowable with the IMPAC. Hence, expenses incurred during official travel and/or covered by the government travel card are not to be charged to the IMPAC.Also, do not use the IMPAC under any circumstances to hold reservations for lodging.

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10.  Any purchases connected with the GSA Fleet Management program (i.e., car wash, gasoline, repairs).There is a separate card provided to appropriate FDA personnel for this program.  Also unallowable are maintenance and/or repair of GSA-leased vehicles; i.e., "motor pool" vehicles provided through GSA.

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Determine whether the supplies or services are available from a priority source of supply.If the requirements are not available from one of these sources in a timely manner, a note should be made in the log.The cardholder may proceed to obtain the item from an open market source. 

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For example, let's say your office needs to ship some equipment to one of the FDA district offices and FEDEX (FDA’s priority source for overnight courier services) will not ship due to the nature of the equipment.If UPS can accommodate your needs and there is no in-house mechanism to handle preparation and shipment of this equipment, you may charge the shipping and handling costs to the IMPAC punchcard.

 

Required Sources for Supplies and Services

Use of the purchase card should be consistent with established guidelines for required sources of supply and applicable acquisition procedures, such as those applicable to micro purchases or to acquisitions below the simplified acquisition threshold. Procurements paid for with the card are subject to the acquisition rules established in the Federal Acquisition Regulations (FAR) and FDA policies and procedures.

 

Cardholders may not simply go to the nearest Office Depot, for example, to purchase goods with the purchase card.  There are certain requirements that must be followed before selecting a company from which to buy a product or service. 

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Priority Procurement Sources

 

Determine whether the supplies or services are available from a priority source of supply. Part 8 of the Federal Acquisition Regulation sets forth statutory requirements to acquire supplies and services from priority sources when available and meeting your needs (considering urgency and delivery time).  Micro purchases are not exempt from this requirement.  Other sources should be considered for use only after the priority sources have been considered for fulfilling requirements.

 

The following information is provided to assist you in locating sources that can supply required supplies and services:

 

·        Committee for Purchase from People Who are Blind or Severely Disabled.  (website: WWW.JWOD.GOV or call (703) 603-7740).

·        National Industries for the Blind (website: WWW.NIB.ORG or call (800) 433-2304).

·        NISH (website: WWW.NISH.ORG or call (703) 560-6800).

·        Under the Javits-Wagner-O'Day (JWOD) Program, each purchase of a SKILCRAFT or other JWOD/NIB/NISH product or service helps to generate employment and training opportunities for individuals who are blind or have other severe disabilities.

·        GSA Stock Program on GSA Advantage (website: WWW.FSS.GSA.GOV or call (800) 525-8027 or fax (800) 856-7057).

·        GSA Federal Supply Schedules (website: http://www.fss.gsa.gov/schedules/ or call (800) FSS-0070).

·        Federal Prison Industries, Inc. (website: WWW.UNICOR.GOV or call (800) 827-3168).

·        Excess supplies from other agencies (GSA's website: http://www.fss.gsa.gov/property/ or call (703) 305-7240)

 

With a connection to the World Wide Web, you can quickly browse through the GSA online shopping mall for thousands of commercial products and services including JWOD/NIB/NISH and UNICOR products.

 

GSA Advantage is designed to link GSA schedule products, stock items, catalog descriptions, current pricing and delivery information in a single location to make ordering easier for you.  To place an order, you can use your purchase card. The address for GSA Advantage is WWW.FSS.GSA.GOV.

 

For any questions regarding GSA's Products and Services, call the National Customer Service Center (NCSC) at 1-800-488-3111 or DSN 465-1416.

 

Small Business

The government’s policy is to provide maximum practicable opportunities in its acquisitions to small business.

 

What Is "Splitting the Requirement"?

It might seem logical for you to divide the purchase into parts so each purchase would be below the single purchase limit. It is NEVER permissible to intentionally divide purchases into parts just to get under your limits, this is called "splitting the requirement."  For example, let us say you have a requirement for office furniture.  The total requirement is $4,000.  Your single purchase limit is $2,500.  In order to be able to handle this requirement via IMPAC, you may not split the transaction into two charges – one for $2,200.00 for a part of the requirement and $1,800 for the remainder.

 

Consequently, when you have a defined need all the parts of that need are considered one purchase.  It pays to analyze the situation and do the right thing.

 

Ensure Availability of Funds

You must establish the amount of your available funds BEFORE making any purchases with the purchase card. Some agencies require cardholders to verify the amount of their available funds before each purchase.

 

You must track purchases during the month to ensure that there are sufficient funds available to make all required purchases.  Cardholders must use a log system to record purchases and the dollar amounts committed. Then they know at a glance the amount of their unobligated funds or certified fund availability.

 

Government officials may only spend money from “available appropriations” and determining if an appropriation is available for a particular purpose is an important aspect of the procurement process.While usually straightforward, these decisions often involve applying informed judgment.There are two general sets of circumstances in which questions about these constraints on procurement authority most often arise.The first is what fiscal years’ appropriation is properly chargeable for a particular procurement.  The second is whether any appropriation is available for a particular item or service.  Since few of us are experts in this body of law, it is important to consult with others, e.g., your immediate supervisor and OFM whenever there is doubt that a particular item or service is properly chargeable to appropriated funds.  At the beginning of each fiscal year, funding is often uncertain; therefore, it is essential that cardholders check with the Administrative Officer to assure that funds are available before making any purchases.

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Deliveries on supplies/equipment can take place in the next fiscal year, as long as the need for them arose in the current fiscal year.  This concept is known as a bona fide need rule.  Obligations may not be incurred out of current funds for services/supplies that are needed in the next fiscal year.  The “rule of thumb” is that if “you had it now, you would use it now.”  For example, training that begins in September and continues into December may be charged to this year’s appropriation, since the service begins in the current year.  However, the same training, if it were to begin in October may only be charged to the next year’s appropriation (depending of the registration deadline).

 

Planning

Decide which items are best handled with the purchase card, and decide when to actually buy. When you plan, you can combine requirements in order to qualify for volume discounts. Or, you can make small-scale purchases to avoid wasteful stockpiling. Your planning ensures that you are able to accomplish your mission by purchasing the higher priority items before lower priority items.

 

Order Documents

Keep all necessary information on each purchase card transaction. You must have information on:

·        The item purchased (including a description, unit number and quantity)

·        The amount of the purchase

·        The name of the merchant

·        The date you received the item purchased

 

Just remember to keep your receipts!

 

Annotate any receipts that are too general in the product description area so that it is very clear what you purchased. Failure to retain records can result in excess administrative burden when you attempt to reconcile your monthly invoice statement.  You are responsible for keeping all documentation on your purchases.

 

Acceptance Procedures

Acceptance is verifying that the supply or service actually does meet the minimum requirements of the Government and that the bill should be paid in full. You must report equipment that you ordered and accepted to your Property Officer for inventory management purposes.

 

Acceptance (i.e., signing for receipt of delivery or pick-up of a shipment) of purchases may be performed by individuals other than the cardholder.  However, the cardholder is to sign and date all receipts (e.g., packing slips) once the shipment is in his/her possession.  In cases where shipments go to a requestor other that the cardholder, the requestor must forward receipts to the cardholder in a timely manner to ensure prompt reconciliation of statements of account and proper recordkeeping of back-up documentation.

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Receipts to purchases made in person do not have to be signed and dated by the cardholder.  However, packing slips, resulting from telephone, facsimile, mail and Internet orders must be signed and dated by the cardholder to ensure receipt of items, even if another individual previously signed/dated to accept receipt.

 

Order Cancellation

If you need to cancel an order, immediately contact the merchant. When the merchant accepts the purchase card as payment, he/she must comply with VISA regulations.  This allows you to cancel before the item has been shipped. If the merchant has already processed the transaction, a credit should be issued. If the merchant has not processed the transaction, simply cancel the order. Special order items may include a restocking charge.

 

Returning A Purchase

You may return the purchase to the merchant for a variety of reasons within 60 days after the date on your invoice where the item appears as a charge. By accepting the purchase card as payment, merchants also accept this requirement of the contract between the government and the purchase card contractor. If the item is damaged in shipment, is not what you ordered, or if you are dissatisfied in any way, return the purchase to the merchant and request either a replacement item or a credit to your account.

 

Obtaining Redress for Unsatisfactory Supplies or Services

By accepting the purchase card as payment, merchants agree to refund or replace any defective items. The first step in obtaining redress is to work with the merchant on a resolution. This is usually a refund or replacement of the defective item. If the merchant refuses to issue a credit voucher, you must fill out the required dispute form and send the original to the purchase card contractor. Completing the dispute form is the formal procedure to dispute the purchase.

 

If the merchant refuses to replace, correct, or issue credit for any deficiencies or price discrepancies, the purchase will be considered to be in DISPUTE.  Any corrections should be reflected on the next month's statement.  If the adjustment does not occur, the "Cardholder Statement of Questioned Item" form MUST be completed and sent to the bank.  (Mailing the form is preferable.)

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The bank MUST RECEIVE the form within sixty (60) days from the day that the dispute became apparent.  This is generally considered by the bank to be the statement date in which the disputed transaction appeared.  The bank WILL NOT accept a dispute in which they were not notified within the sixty-day timeframe.  In addition to the copy the cardholder sends to the bank, another copy shall to be submitted to the Approving Official along with the Statement of Account.  A copy should be retained by the cardholder for his/her own records.

 

If the dispute is over (60) days old, neither the bank will address the issue nor can the A/OPC officially impose any action to resolve the situation.

 

Obtaining Copies of Your Sale Drafts

When there is a face to face transaction, obtain a copy of your sales draft (purchase card charge receipts) when you make the purchase. However, sometimes you need a copy of a sales draft to verify an item on your monthly invoice. If you need a copy(s) of sales draft to verify an item on your monthly invoice submit the required form to your purchase card contractor. The purchase card contractor will send you a copy of the sales slip.

 

Recognizing Fraud

Fraud is any felonious act of corruption or attempt to cheat the government or corrupt the government's agents. Fraud may be committed either by government employees or by merchants. There are two responsibilities each cardholder has relative to fraud: You must be alert to the indicator of fraud and report suspected fraud immediately.

 

Indicators of potential fraud by government employees include:

 

·        Splitting requirements to get under the micro-purchase threshold.

·        Making false statements about what was purchased or how the purchase card was used.

·        Using the purchase card for prohibited purchases.

 

Indicators of merchant fraud include:

 

·        False charges/transactions

·        Mischarging

·        Bribes and gratuities

·        Kickbacks

 

Reporting Fraud

You must report all indicators of fraud. Identify the responsible official(s) and report them through the proper channels. You can make reports to any of the following as appropriate:

 

·        Your Approving Official

·        Your A/OPC.

·        Paying/Finance Officer

·        Office of the Inspector General (call the hotline)

·        *Office of Special Investigations, (FDA Insert FDA info.)

 

Unapproved Purchase

What happens if you make a purchase that your Approving Official does not approve?

If the item(s) cannot be returned, the government must pay for the purchase and recoup the amount of the purchase from YOU! That is why it is important to fully understand what CAN and CANNOT be purchased with your purchase card.

 

Reconciling A Credit for A Purchase in A Prior Billing Cycle

Occasionally, your invoice will show a credit for a transaction that took place in a prior billing period. An example would be credit for a returned item. When you get a credit several months after the original purchase, reconcile back to the original invoice and note that the credit was received.

 

Convenience Checks

In cases where your credit card is not accepted, the FDA may permit the use of convenience checks. If the FDA determines a need for convenience checks, your purchase card contractor will provide a supply of checks to designated cardholders drawn on the cardholder's purchase card account. The checks will be processed as they are presented for payment. Convenience checks are multi-copied (one copy for the cardholder's records, the original for the merchant).

 

Your convenience checks are sequentially pre-numbered with the following standard pre-printed information:

 

·        United States Government.

·        Name of Agency/Organization.

·        For Official Use Only.

·        U.S. Government Tax Exempt.

·        Maximum Dollar amount (optional).

 

CARD ADMINISTRATION

 

Requesting a Higher Dollar Limit

After you use your purchase card for a time, you may decide that a review of your single purchase limit and monthly purchase limit may be wise. A permanent higher limit on your purchase card may be obtained. Submit a request to your Approving Official or A/OPC. Temporary increases may also be granted. Contact your Approving Official or A/OPC BEFORE using the purchase card for any purchase that exceeds your limit. The A/OPC will submit the request for a higher dollar limit on your purchase card to the purchase card contractor. Neither permanent, nor temporary single, and monthly purchase card dollar limits can be higher than your Delegation of Authority.

 

Reviewing your cardholder statement

Make sure that you receive your cardholder statement. You will not receive a statement unless you had account activity during the month. Identify and annotate any errors and work with the merchants and the contractor on a resolution. The statement is mailed directly to your business address.  You must review and reconcile your statement within the timeframes required by your agency (usually 3 to 5 days).  This is one of your primary jobs as a cardholder. Reconciling your statement includes certifying receipt, annotating accounting codes, documenting disputed items, and any other documentation required by your agency before forwarding your statement to your Approving Official or the appropriate Payment/Finance office for payment.

 

Approving Officials are responsible for reviewing the monthly bank report (Report RO90, IMPAC Detail Invoice and Approving Official Summary), reconciling each of his/her cardholders' monthly statements, and verifying that all transactions are valid Government purchases made in accordance with these procedures.  The reconciliation must be completed within five (5) working days from receipt of Statement of Account (SOA).  The Approving Official approves the document by signing and dating the statement at the time of review.

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If the cardholder will be absent from his/her office for more than 4 days after the SOA is received, all original documentation must be forwarded to the Approving Official who will note the absence and process the SOA.Approving Official needs to review the statement of account and supporting documents, briefly note on statement that cardholder is on leave (or briefly describe the situation, otherwise), sign and date as Approving Official, and forward the appropriate paperwork to the Central Control Point.  Upon the cardholder's return, he/she must log and review each purchase/credit.

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Stolen or Lost Purchase Card Procedures

Report a stolen or lost purchase card to your A/OPC immediately and the purchase card contractor. The purchase card contractor will mail a new card to you within two business days from the time the theft or loss was reported to the company. The purchase card contractor assigns a new number to the replacement card.

 

FDA is not liable for any unauthorized use of the IMPAC, however, the cardholder may be held negligent and administratively accountable to FDA if the loss is not reported timely.  As soon as the cardholder realizes a card is lost or stolen, he/she must call the bank.  The hotline is open 24 hours/day, 365 days/year.  Immediately notify my Approving Official and the A/OPC of its disappearance and the known circumstances of the loss and what actions you have taken.

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Renewing the Purchase Card

The purchase card is issued for a defined period and will expire.

 

·        You do not need to initiate any action to get your card renewed.

·        You will receive your new card before your old card expires.

·        If you do not receive your new card, contact your A/OPC.

·        Destroy expired cards; they need not be returned.

 

Cardholder Accounting Code Change

When you receive your purchase card, your A/OPC may assign you an accounting code(s). An accounting code is the internal number that identifies your purchases for accounting purposes. It is important for you to know what to do if you change offices and your accounting code is no longer valid.

If you are transferred to a different office with a different Approving Official, notify your A/OPC who will take the proper steps to change or assign new information.

 

Cardholder Name Change or Business Address Change

Changes in information occur from time to time. You need to take a few steps to keep your profile up-to-date. Report the current information, the new information, and the date of the change to your A/OPC in writing. Your A/OPC will complete the appropriate form and submit the changes to the purchase card contractor.

 

Account Suspension/Cancellation

Accounts may be suspended and/or cancelled by purchase card contractors due to non-payment. If your account is suspended or cancelled due to failure of the agency to make payment, you will be unable to use the card. If you are advised by the merchant or purchase card contractor that your account has been suspended or cancelled, contact your A/OPC immediately. The purchase card contractor is required to notify your A/OPC when accounts are suspended or cancelled.

 

Canceling the Purchase Card

Procedures have been set up to handle cancellation of your purchase card account. The purchase card must be canceled or transferred to your new office when you change jobs or canceled when you leave the employment of the Government. It must also be canceled when you are no longer required to purchase items in support of your mission. To cancel or transfer your card, notify the A/OPC. Your A/OPC will notify the purchase card contractor to cancel or transfer your account.

 

Several administrative actions are required when a card is cancelled due to departure/reassignment of a cardholder.  Approximately the last day of work, the cardholder must cut the bankcard into several pieces and dispose of them.  Do not send the bankcard to the A/OPC.  The Approving Official and departing cardholder must review the card account before the employee leaves the organization.  Outstanding charges at the time of departure need to be reported to the Central Control Point.  Until any outstanding charges are paid, cancellation should generally not be requested to the A/OPC.  

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Item Billed Not Received

If you have been billed for an item that has not yet been delivered, you should contact the merchant to determine if the item has been shipped. Try to solve the problem at the merchant level by arranging for receipt of the item or by requesting a credit for the item.

Item Billed Has Been Returned But Not Credited

If you have returned the merchandise to the merchant, but have not received a credit on your invoice, there is a simple solution. You should submit the dispute form. Check the appropriate block and send the original of the dispute form to the purchase card contractor.

 

Item Received but Not Billed

 

Cardholders shall contact merchants that have not billed in a timely manner after all goods/services were received (i.e., within one billing cycle).  While it is standard business practice for merchants to bill upon shipment, there may be occasions when a merchant apparently has not billed.  Do not allow this situation to remain unresolved beyond two billing cycles.  Otherwise, charges could be attempted months later possibly when either funds are no longer available for the fiscal year in which the transaction occurred  (although payment would still have to be made).  Another scenario might be that the card account may have been cancelled by the time a much later charge is attempted to be processed.

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Multiple Billing

If you have confirmed a double billing you should submit the dispute form, check the appropriate block, and send the original of the dispute form to the purchase card contractor.

 

Item Billed but Not Ordered

If you have been billed for an item that you never ordered, submit the dispute form and check the appropriate block. Send the original of the dispute form to the purchase card contractor.

 

Cardholders must use the "Cardholder Statement of Questioned Item" form if an unrecognized or unauthorized charge appears on their statement.  An unrecognized charge(s) CAN be an indication that the card account has been compromised in some manner.For two or more unrecognized charges, or if a cardholder thinks that an unrecognized charge may be fraudulent, immediately contact US Bank and the A/OPC.

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If you see more than one unrecognized charge on my statement of account, notify your Approving Official and then immediately call the bank and the A/OPC to report the situation.

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Statutes That Govern Use of the Purchase Card

The purchase card has a solid grounding in key statutes and regulations.  Although many micropurchases are low in dollar amount, taken together, small micropurchases account for billions of dollars in contracting and are a critical part of the Government's acquisition process. For further information see Government Purchase Cards, which prescribes procedures that apply to all departments and agencies that use the Government purchase card HTTP://WWW.FMS.TREAS.GOV/TFM/V1P4C450.TXT

Purchases of supplies and services are covered by Federal Acquisition Regulations (FAR), purchase of property is covered by Federal Property Management Regulations (FPMR), and the Federal Acquisition Streamlining Act of 1994 (FASA) provides an additional basis for a more simplified approach to purchasing.

 

Use of the purchase card for other than official Government business is considered fraud against the U.S. Government and may result in disciplinary action under applicable administrative procedures.  Depending upon the nature of the violation, such penalties can range from verbal admonishment to termination of employment, in addition to restitution.  In addition to administrative action, criminal penalties are prescribed for card theft and illegal use; e.g., intentional personal purchases NOT for Government purposes.  Along with law enforcement organizations in the Federal Government, U.S. Bank can and will prosecute fully of the law.

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ETHICAL CONDUCT

 


Standards of Ethical Conduct

An employee shall not, directly or indirectly, solicit or accept a gift from a prohibited source because of the employee's official position. A gift is considered to be anything of monetary value such as: gratuities, favors, discounts, entertainment, hospitality, loans, forgiveness of a loan, services, training, transportation, travel, meals, and lodging.

 

What does it mean to accept a gift directly or indirectly? Directly is straightforward - You accept the gift. Indirectly means that someone gives a gift, with your knowledge and acquiescence, to someone else, possibly your spouse or child, a sibling or other dependent relative because of that person's relationship to you. A gift could also be indirectly given to any other "person" including any charitable organization at your recommendation or designation.

 

The definition of gifts is broad, but the gift rules specifically exclude certain things from being treated as gifts.  The gift exclusions are:

 

1.      Modest items of food and refreshments, such as soft drinks, coffee and donuts, offered other than as part of a meal.

2.      Greeting cards and items with little intrinsic value, such as plaques, certificates, and trophies, which are intended solely for presentation.

3.      Loans from banks and other financial institutions on terms generally available to the public.

4.      Opportunities and benefits, including favorable rates and commercial discounts, available to the public or to a class consisting of all Government employees or all uniformed military personnel, whether or not restricted on the basis of geographic considerations.

5.      Rewards and prizes given to competitors in contests or events, including random drawings, open to the public unless the employee's entry into the contest or even is required as part of his official duties.

6.      Pensions and other benefits resulting from continued participation in an employee welfare and benefits plan maintained by a former employer.

7.      Anything that is paid for by the Government or secured by the Government under Government contract.

8.      Any gift accepted by the Government under specific statutory authority, including:

 

·        Travel, subsistence, and related expenses accepted by an agency under the authority of 31 U.S.C. 1353 in connection with an employee's attendance at a meeting or similar function relating to his official duties which takes place away from his duty station.  The agency's acceptance must be in accordance with the implementing regulations at 41 CFR Part 304-1 and

 

·        Other gifts provided in-kind that have been accepted by an agency under its agency gift acceptance statute.