Government Purchase Card Billing Official Questions (Speedy Completion Necesary)

Atlantic Region Government Purchase Card Program Annual & Local Procedures Training

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

REGIONAL HEALTH CONTRACTING OFFICE-ATLANTIC

Chief: LTC Kathleen Hamilton

Location: GPC SECTION IS LOCATED IN Building 1467 at Fort Belvoir, VA (currently teleworking)

Instructor: Mr. Ted Frank, Agency/Organization Program Coordinator (A/OPC)

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Training Information

Use of the GPC Up to the Micro-Purchase Limit (finishes around 1100)

Use of the GPC as a Method of Payment and for Purchases over the MPT Against Federal Supply Schedule up to $25,000 (finishes around 1230)

Breaks About Every Hour

After Training, Tests will be Sent. 80% Required to Pass

Annual Refresher is Specialized

UNCLASSIFIED//FOUO

Course Elements

Ethics

Fraud, Waste and Abuse Prevention

GPC Program

GPC Roles and Responsibilities

GPC Account Establishment and Maintenance

GPC Guidance and Procedures

GPC Oversight and Review

Insights On-Demand (IOD)

2019 NDAA Section 889

Exam (emailed) Based on Verification of attendance via roll calls * (Do the Roll Call)

*

UNCLASSIFIED//FOUO

The USAHCA GPC program provides cards to activities/departments throughout USA MEDCOM. The GPC Program is intended to streamline procurement of small, non-repetitive requirements support use of the GPC as a method of payment and generally simplify the administrative effort associated with procuring goods and services under the micro-purchase threshold.

Course Overview *

UNCLASSIFIED//FOUO

Special Process

Reasonable Accommodation, Ergonomic Related Purchases

Small Package Delivery/Shipping (FEDEX, UPS, Polar) Must use NGDS Contract

Commander Coins

Automobile Tolls (Not for TDY)

Purchase of Services over $2,500

Food and Water

Court Reporter

Interpretation Services such as Language Line

Giveaway Items

Training and Conference Registration

For these purchases contact your A/OPC for additional information

*

UNCLASSIFIED//FOUO

GPC Program

Statutory Authority Federal Acquisition Regulation (FAR)

FAR 1.603-3, Appointing micro-purchase authority to Government Employees. FAR Part 13.30/DFARS Part 213.301/ AFARS, Part 5113.2, Use of Government- wide commercial purchase card to Simplified Acquisition Procedures. FAR Part 3, Improper business practices & Conflicts of interests.

Treasury Financial Manual, Vol I, Part 4, Ch 4500, Government Purchase Cards DOD Financial Management Regulation (FMR) Vol 10, CH 23, Purchase Card Payments DOD FMR Vol 10, CH 23, Annex 1, Purchase Card Certification Statements Joint Ethics Regulation (JER) 5500-7-R, Standards of Ethical Conduct 10 U.S. Code 2784 - Management of purchase cards Rehabilitation Act (29 U.S.C. 794d), Section 508

UNCLASSIFIED//FOUO

GPC Program References

Department of the Army Government Purchase Card Operating Procedures: 22 JULY 2015 (sourced from AFARS Appendix EE)

DoD Government Charge Card Guidebook 10/1/2017 including 8 April 2020 administrative update

Title 5 Code of Federal Regulations (CFR), part 2635

Health Care Acquisition Activity (HCAA) GPC Operating Procedures: Dated: 27 FEBRUARY 2015

Federal Acquisition Regulation (FAR): https://www.acquisition.gov/content/regulations

Part 8: Required Sources Of Supplies And Services Part 3: Improper Business Practices and Personal Conflicts of Interest Part 13: Simplified Acquisition Procedures

DFARS, Part 213: Small Purchase And Other Simplified Purchase Procedures

AFARS, Part 5113.2, Simplified Acquisition Procedures. GAO Standard for Internal Controls, Green Book Supply Bulletin 8-75-11- Includes Requirements for DMLSS, ECAT etc. OSD SP3 Transition Memoranda

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Key Program Elements

BO Approval prior to purchase (AFARS Appendix EE 1-7 (d) 2 d and SP3 Transition Memo #6)

Third Party Receipt consists of: the date received, along with the signature (or electronic alternative when supported by appropriate internal controls), printed name, telephone number, and office designator or address of the receiving official AFARS Appendix EE 3-11 (c) Requirement to upload documentation in Access on Line (SP3 Transition Memo #6)

GPC Limits - AFARS Appendix EE Appendix A Best Practices 11. (8) Financial Controls - at a minimum every 6 months monitor and assess single and monthly purchase limits; USAHCA OPORD 17-03 Accounts for which the 3-cycle spending average is less than 70% of the average cycle limit shall be reviewed and credit limit reduced to meet the average spending.

Services properly documented as Exempt from Service Contract Labor Standards are authorized up to the MPT ($10,000) (FAR 2.1 Micro-purchase threshold. See also FAR 22) but: Recurring services performed at regular intervals having a demand that can be accurately predicted on an annual basis may be purchased with the GPC if they do not exceed $2,500 ($10,000 if exempt from SCLS) per fiscal year. Recurring services requirements estimated to exceed $2,500 per fiscal year shall be acquired through the servicing contracting office. Non-recurring services involve one-time, unpredictable, or occasional requirements, and may be purchased with the GPC up to $2,500 ($10,000 if exempt from SCLS) whenever a requirement occurs. (AFARS Appendix EE Appendix A)

9 of 196

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Key Program Elements Cont.

Alternate Billing Official - Every USAHCA GPC account is required to have a BO and ABO appointed. Supervisors should nominate a replacement for a BO or A/BO 30 days in advance of the employee leaving. The account should be used for emergency purchases only and credit limit reduced to reflect emergency purchases spending, until the account has both BO/ABO appointed. Level 4 A/OPCs will restore the account to the original credit limit when there is both a BO and ABO appointed. (USAHCA OPORD 17-03 Paragraph 3. c. 5)

File Retention - The approving or certifying official maintains certified billing statements and supporting documents for six years and three months in accordance with National Archives and Records Administration (NARA), General

(AFARS Appendix EE 3-13 and FAR 4.805)

Repetitive Purchases - Indicators of possible fraud waste and abuse - Repetitive buys from the same merchant (AFARS Appendix EE 4-3)

Rotation of Sources Cardholder Duties: Rotating merchants when practicable (AFARS Appendix EE 1-7 e (4))

Requirement to document mission essentiality of purchases - Mandatory: The GPC shall be used only for mission- essential purchases; a) Review transactions to ensure they are legal, proper, correct, and mission essential (DoD Charge Card Guidebook A.1.12 a)

10 of 196

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Ethics and Fraud Prevention

Joint Ethics Regulation DoD 5500.7-R All Soldiers, Army Civilians and employees, regardless of rank or position, shall comply with ethics rules and regulations as established in the Joint Ethics Regulation.

Violation of ethics standards may result in administrative or criminal penalties.

Under the Joint Ethics Regulation, there is an obligation to report suspected ethics violations. This includes reporting by Certifying Officials, Supervisors, and fellow employees of suspected misuse of the GPC.

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Ethics

Office of Government Ethics Standards of Conduct for Executive Branch Employees apply to purchase card and convenience check use.

All purchases/transactions must be transacted for official Government business only.

GPC personnel with questions regarding the propriety of a particular purchase should consult their Level 4 A/OPC and agency ethics officer, for guidance and assistance prior to making the purchase.

*

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Ethics 14 Principles of Ethical Conduct

1. Place public service above private gain

2. Financial interests cannot conflict with official duties

3. Do not use non-public information for private gain

4. No gifts from prohibited sources (20/50 Rule)

5. Employees must put forth honest effort in performance of duties

6. No unauthorized promises purporting to bind the government

7. Do not use public office for private gain

8. Act impartially and no preferential treatment

9. Protect and conserve government property and only use it for authorized purposes

10. No outside employment or job hunting that conflicts with Federal job

11. Obligated to disclose waste, fraud, and abuse

12. Satisfy financial obligations in good faith

13. Uphold EEO laws and regulations 14. Avoid appearance of unethical

conduct/violating the law or ethics regulations

Attend local ethics training when offered. When unsure a purchase is authorized, have concern about conflict of interest or other ethics concerns, contact your supporting Ethics attorney or your A/OPC

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Fraud/Waste/Abuse

What is Fraud? - Intentional use of the GPC for other than official Government business may be considered an attempt to commit fraud against the U.S. Government and will result in immediate cancellation of an individual's GPC and further disciplinary and legal actions. What is not fraud? -Merchant error/disputed transactions; Inability to pay (anti-deficiency) Cardholders will be held personally liable to the Government for non-government transactions. Under Title 18 U.S.C. 287, misuse of the purchase card could result in a fine of not more than $10,000 or imprisonment for not more than five years or both. Military members who misuse the purchase card may be subject to court martial under Title 10 U.S.C. 932, UCMJ Art. 132. Depending on the circumstances, other sections of the US Code may apply and may carry additional penalties. Certifying Officials (Billing Officials) are liable for full amount of any erroneous payments resulting from the negligent performance of their duties (i.e., resulting from misuse, abuse, or unauthorized purchases of the GPC).

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Fraud/Waste/Abuse

Statutory Authority Misuse/Abuse of the GPC is subject to criminal and civil actions:

False Claims (18 U.S.C. Section 287) False Statements (18 U.S.C. Section 1001) Major Fraud Act (18 U.S.C. Section 1031) Mail Fraud (18 U.S.C. Section 1341) Wire Fraud (18 U.S.C. Section 1343) Conspiracy to Defraud (18 U.S.C. Section 371) Conflicts of Interest (18 U.S.C. Section 208) Theft, Embezzlement, and Destruction of Public Money UCMJ (10U.S.C. Chapter 47)

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Fraud/Waste/Abuse

Unauthorized Use of GPC

Transactions made by an authorized individual for personal use. Unauthorized transactions made by Vendors Transactions made on compromised accounts

Fraudulent Transactions

Transactions intended for government use, but are not for a purpose permitted by law, regulation, DOD policy or type of funds.

Improper Transactions

Transactions that were authorized, but the items purchased were at an excessive cost or for a questionable government need, or both.

Abusive Transactions

Transactions made by cardholder for which there was not a reasonable and/or documented justification

Questionable Transactions

*See OSD Final Governmentwide Commercial PC Disciplinary Category Definitions Guidance 27 JAN 2020

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Fraud/Waste/Abuse

Military Disciplinary Actions

Removal from Program Counseling Admonishment Reprimand Non-judicial punishment (Article 15) Civil enforcement action Pecuniary liability Criminal prosecution in civilian court

Civilian Disciplinary Actions

Removal form Program Adverse counseling Suspension w/o Pay Termination (Job) Pecuniary liability Personal liability Criminal prosecution in civilian court

Improper GPC Use

At the A/OPC Level Direct Retraining, Suspend , or Terminate

*

There is no dignity

in this!

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Fraud/Waste/Abuse Policy Violation

GPC Personnel Non-Cardholder Merchant

Directly by the Cardholder themselves

Not rotating vendors Splitting False statements Payment of UCs Lack of documents Misuse/Abuse Exceeding delegated authority Not for Official Use By Third Party with CH Consent Incorrect funding type

By third party without knowledge or consent of the cardholder

Never received Lost / stolen Counterfeit Identity theft Email Cyber Attacks Data Phishing Merchant Compromised

Directly by merchant with or without knowledge or consent of the Cardholder

False charges Mischarges Bribes / gratuities Overpricing Kickbacks

DD 1155 (Addendum)

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Fraud/Waste/Abuse

Protecting Against Fraud Keep your government purchase card(s) and your account information secure. Do not leave your card or your account number unsecured. Do not tack your card number up on a wall or leave it out for convenience. Do not transmit through any media (e-mail, Fax, etc.) If you print a report or a file with account information on it, shred it when finished. Sign up for fraud alerts

Cardholder must diligently review his/her account statement to identify purchases which may have been made on their behalves. Never give out your account number/personal data to someone who contacts you without verifying their need to know. Non-Cardholder Fraud. The risk of fraud is higher in these situations:

Card never received/sign Altered or counterfeit card Account takeover

Promptly report unknown charges to US Bank

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016 * UNCLASSIFIED//FOUO

If questionable/unauthorized purchases are discovered during an audit, the reviewer must ask the Certifying Officer (Billing Official) for justification

If there is no justification, the reviewer must notify

The Commander or Director must conduct an investigation in accordance with AR 15-6

The investigation must provide the DOD employee or military member with an opportunity to rebut the presumed liability.

Investigations *

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Reporting Fraud

If you suspect fraud immediately report telephonically (in the following order) to:

The issuing Bank (US Bank) 888-994-6722 A/OPC Approving/billing official Supervisor

Statement of Fraud is mailed to CH to complete and return where necessary (some attempts decline).

Determine When the card was last used Last transaction Other pertinent information

Always cooperate with card-issuing Bank

*

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Summary

Ethics & Fraud Prevention Violating ethical principles or misuse/abuse of the GPC may result in disciplinary or corrective action, including criminal prosecution. Protect yourself from disciplinary action by seeking the advice of your Agency Ethics Official, Resource Manager or the A/OPC (especially when pressured to do something you think is unauthorized). Educate Yourself to Recognize

Card misuse/abuse Fraud

*

*

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures Prohibited Purchases and Purchases Requiring Additional Approval or Special Processes**

Items Purchased for non Government use Purchasing and returning for credit Buy above micro-threshold w/o contract $ Advances/Money Orders/Travel Checks Gift Certificates Lease of land/building more than 30 days Wire Transfers Repair of GSA vehicle Vehicle related expenses** Auto Insurance Vehicle fuel** Fines Wire transfers Training Vouchers before LGN Savings Bonds Foreign currency Tolls** Package Shipping** Services Over $2,500** Training and Conference Registration**

Dating and escort services Court costs Alimony and/or Child support Payment of salaries and wages Airline, bus, or travel Travel-related purchases/Travel advances** Payment of travel claim Explosives, munitions, Firearms, Toxins** Contractor (agents) whom are GI/GE Non-rotation of vendors** Trophies, gifts, awards, plaques** Business Cards (Print Store) Insignia, name plates, and name tapes Video Surveillance Cameras Coins not complying w/ DA Memo 600-70 and

OTSG/MEDCOM 20-077

Items Requiring Placement on the Property Book, Books or Book Sets $100 or more**

Non-Use of Mandatory Sources**

Food**

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program

U.S. General Services Administration (GSA) Smart Pay contract awarded to multiple providers

U.S. Bank The cards are issued to an INDIVIDUAL whose name appears on the card. No one else may authorize charges against a card.

There are no joint accounts, cash advances or PIN numbers (except chip and pin for security)

Cards may be used to Micro-purchase Simplified acquisition procedures Make payments Procure Commercial/Off the-Shelve Training

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program

The preferred method for payment of goods and services of non-recurring requirements

Micro-Purchase Thresholds $10k (Supplies) $10k (Services Exempted from Service Contract Labor Standards vendor must complete a certification form) $2,500 subject to 41 U.S.C. chapter 67, Service Contract Act (Services) $2,000 subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements. Davis Bacon Act (Construction).

Streamlines the acquisition process, saving both time and expense

Mandatory method of payment for office supplies

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program

What is a Micro-Purchase? (FAR Subparts 2.101 and 13.201(b))

the preferred method to purchase and to pay for micro- purchases (see FAR 2.101

What - The acquisition of supplies and services with an aggregate total that does not exceed the Micro-Purchase Threshold (MPT) defined in FAR 2.101.

Micro-Purchase Threshold means $10k*, except for construction ($2,000), services ($2,500 if not exempt from SCLS) & contingency

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program

MPT Allowance for Construction Construction, alteration, or repair buildings,

structures, or other real property

MPT = $2,000 Altering, remodeling, installation on site of items fabricated off-site; Dredging; Painting and decorating (at time of construction or as an alteration or repair); Manufacturing or furnishing materials, supplies, or equipment on a work site; Transportation of materials to the work site or portions of the building or work between a secondary site. Subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction)

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program *

MPT for Services Under Contract Labor Standards Directly engages the time and effort of a contractor whose primary

purpose is to perform an identifiable task

Services (Nonpersonal) are performed by skilled persons and include job categories subject to the Service Contract Labor Standards (SCLS) (formerly the Service Contract Act). MPT = $2,500

Professional Services (Nonpersonal) are performed by persons who are recognized professionals based on a prolonged course of study.

MPT = FAR 2.101 or current class deviation

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016

GPC Program *

MPT for Labor Standards Services that are exempt from Service Contract Labor Standards IAW the below are authorized for purchase up to $10,000 provided that:

The exemption (and therefore the description of the equipment and services to be provided) is clearly documented in the purchase supporting documentation;

purchase supporting documentation; The required service is not available from a required source other than the

vendor solicited; The required service is not already covered under an existing contract; The service (or services) is/are known to be a type that is recurring (such as for preventive maintenance or calibration) that does not exceed $10,000 for all equipment serviced by an individual vendor annually;

MPT = $10,000 Reference: Class Deviation 2018-O0018 and FAR 22

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016

GPC Program *

Labor Standards Vendor Certification

Description of equipment and service to be provided:

The offeror [ ] does [ ] does not certify that

1. The services under this purchase are offered and sold regularly to non-Governmental customers, and are provided by the offeror (or subcontractor in the case of an exempt subcontract) to the general public in substantial quantities in the course of normal business operations;

2. The services are furnished at prices that are, or are based on, established catalog or market prices. An

maintained by the manufacturer or the offeror, is either published or otherwise available for inspection by customers, and states prices at which sales currently, or were last, made to a significant number of buyers

course of ordinary and usual trade between buyers and sellers free to bargain, which can be substantiated from sources independent of the manufacturer or offeror;

3. Each service employee who will perform the services will spend only a small portion of his or her time (a monthly average of less than 20 percent of the available hours on an annualized basis, or less than 20 percent of available hours during the contract period if the contract period is less than a month) servicing the Government under this purchase;

4. The offeror uses the same compensation (wage and fringe benefits) plan for all service employees performing work under this purchase as the offeror uses for these employees and for equivalent employees servicing commercial customers;

5. Certification by the offeror as to its compliance with respect to this purchase also constitutes its certification as to compliance by its subcontractor if it subcontracts out the exempt services.

Signature Printed Name of Authorized Company Representative Name of Company POC Address POC Telephone

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program MPT Exception for Contingency Operations (only when officially notified such as for COVID 19 Pandemic)

To support contingency ops or facilitate defense against or recovery from nuclear / biological / chemical / radiological attack1

MPT is $20,000* if awarded and performed, or

purchase is made

INSIDE the U.S.

MPT is $3 ,000 if awarded and performed, or purchased is made OUTSIDE the U.S

1DoD Class Deviation 2018-O0013 (9/21/2018) adds: defense against or recovery from cyber attack, international disaster assistance (22 U.S.C. 2292); an emergency, or major disaster (42 U.S.C 5122).

*Does not include construction subject to Wage Rate Requirements (Construction)

*

MUST BE SPECIFICALLY DELEGATED

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC Program

Army Level Hierarchy Structure Effect on Policy

I. Department of Defense

II. Military Agency

III. MACOM or Equivalent

IV. Agency/Organization Program Coordinator

V. Billing Official/Alternate Billing Official

VI. Cardholder

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities Level V - Billing Official (Primary/Alternate)

A.K.A., Certifying Official Recommends GPC $ limits to RMD and A/OPC Provides written approval/disapproval of CH purchases Ensures CH fulfills responsibilities by conducting annual compliance reviews of all CHs Reports questionable transactions (fraud/abuse) to A/OPC or proper authorities Verifies payments to be legal, proper, necessary and correct Reviews and approves CH transactions (only in US Bank) during CH absence per GPC policy Identifies and communicates billing discrepancies to US Bank during CH absence

#Pay attention to duties and responsibilities in DoD, Army and MEDCOM GPC Policies as well as your appointment memo

33 of 196

*

*

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Level V - Billing Official (Primary/Alternate) Notifies A/OPC at least 30 days out to close CH accounts or revoke a Billing Official Notifies A/OPC in writing within 5 days of lost, stolen or compromised GPCs Retains copies of billing statement to include all original supporting documentation, receipts, logs, invoices, delivery tickets, and approvals for 6 years and 3 months after final payment Resolves any questionable purchases with CH Reconciles invoices and timely certifying of managing account within:

3 business days for electronic data interchange EDI AXOL accounts 15 days for manually paid accounts non-EDI (contract)

*

* *

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Level V - Billing Official (Primary/Alternate) Ensures use of correct funding e-order prior to certification Ensures designation of Alternate BO* Performs an annual review of CH files using checklist contain in Appendix D of Operating Procedures Ensures adequate funding exists prior to approving the purchase Notifies A/OPC to terminate, reassign a BO prior to departure (30 days out) Works with US Bank to resolve payment issues

* MA (Managing Accounts) are required to have primary and alternate at all times.

*

* *

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Level VI - Cardholders Use the purchase card "For Official Use Only". Safeguard the card and account number at all times. Maintain proper documentation such as written/pre- approved request, funding availability, purchase log, Justification/Mission Essentiality, and property book procedures as appropriate. Ensure purchase is consistent with policies and procedures for the GPC. Ensure that all BO approvals, are obtained prior to making a purchase. Ensure purchases are within the single purchase, cycle purchase limits and funding is available.

#Pay attention to duties and responsibilities in DoD, Army and MEDCOM GPC Policies as well as your appointment memo

*

**

*

*

*

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Level VI - Cardholders Verify the establishment of the legitimate government need Comply with required sources

FAR Part 8.002 Required Sources of Supply/Service Utilize mandatory BPAs to purchase office supplies Section 508 of the Rehabilitation Act of 1973 Environmentally Preferable Purchasing (EPP), FAR Part 23

Verify receipt/acceptance of purchased goods or services received Review and reconcile monthly statements Resolve unauthorized, erroneous transactions with merchants Notify the BO of unusual/questionable requests and disputable transactions

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Level VI - Cardholders Inform the merchant that billing cannot occur until the item (s) are shipped and/or delivered. Ensure that the Statement of Account is completed and forwarded to the Billing/Certifying Official, within 1 to 2 business days after cycle end, along with all backup documentation to allow timely certification of the Billing Statement. Notify BO of upcoming personal leave or travel Notify their BO/ABO and A/OPC before they leave and dispose of their card in accordance with local procedures. Ensure adequate funding is available prior to purchase SCCS/DLA

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Level VI - Cardholders

Check with PBO to determine what is durable/highly pilferable and property required to be recorded in the property control system Purchases required to be recorded in the property control system require additional approval from PBO Maintain manual purchase log if electronic log is not accessible (recommended even if it is) CH is a Departmental Accountable Office (DAO) as per DoD FMR, Chapter 33, Volume 5.

i.e. have the card charged

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Other Key Personnel

1. DFAS (Payment Specialists) The Government entity responsible for providing payment to the US Bank Maintain DD Form 577 for BO Notifies A/OPC within one day of rejects Receives and processes manual payment

2. Resource Manager/Budget (Funds Holders) Process New Accounts Initiated by the A/OPC Funds purchases using GFEBS Establishes monthly cycle limits and accounting data Assigns default and alternate LOA Reserves funds (may use bulk commitments) Establishes reallocation lines Monitors certification of accounts in coordination with A/OPC

*

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Roles & Responsibilities

Other Key Entities3. PBO Develops and disseminates property accountability procedures to all personnel entrusted with acquisition Assists the A/OPC to ensure property accountability procedures are followed Records sensitive and pilferable property Requires controlled property to be accounted for Requires control when property is issued at user level (Durable) Provides written additional approval when property is purchased outside of the property management office

4. US Bank GPC Contractor Administers AXOL Card Management Environment Investigates disputes

5. Supervisor Must be knowledgeable of CH and BO requirements and execution of duties, approves PIEE/JAM Nomination/Appointment

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Training Requirements

Re-Occurring Training Requirements

* Unless individual is accepting a new GPC position, in which case, all certificates must be dated within last 12 months of delegation of authority approval by CCO/AOPC.

(The above list does not include all required documentation for either new or existing maintenance of a GPC account.)

Annual Requirement 1. RHCO-A GPC Tng

a.Micro ($10K) b.SAP ($25K)

2. DAU CLM 003 Tng 3. DAU-CLG 0010 Tng

(Refresher) 4. DAU-CLG 006 (BO Only)

Certifying Officer Legislation (COL)Tng

Required Once* 1. US Bank Access

Online WBT Cert 2. DAU-CLM 023

Ability One Cert 3. MasterCard

Insights On Demand (BO)

Initial Training Requirements Should Already Have Been Sent, If not Contact Your Servicing A/OPC

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

DoD PIEE/JAM

JAM is the PIEE module used to initiate, review, approve, store and terminate required delegations of procurement authority and/or appointments

As appropriate, JAM GPC appointments result in issuance of not only GPC Delegation and/or Appointment letters, but also (at a date to be determined):

DD Form 577 Appointment/Termination Record Authorized Signature (commonly referred to as a Certifying Officer appointment)

GPC Program participants are required to register for a PIEE account and request the GPC role(s) appropriate for their program function(s) as directed by your A/OPC

Electronic GPC Delegation of Authority and/or Appointment Letters must be granted for GPC Program participants

Process & Maintain*

*Load training certificates into PIEE

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain

Mission requirements dictate type of GPC. Purchase Card, Payment Card, Training Card, Representational Fund Card

Issued only to DoD civilian and military personnel (not contractors).

GPC receives limited Merchant Category Code (MCC) authorization* The cumulative spending limit of all CH cycle purchases make up the BO monthly cycle limit.

RMD establishes lines of accounting and spending limits in AXOL (Dummy LOA for GFEBS)

44 of 196

*

* These can be adjusted with submission of Merchant Authorization Control Code Access Form and proper justification

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain

There are two main types of $ limits applied to your purchase account:

Single Purchase Limit Cycle Limit (Credit Limit is Mandatory and is Based on Cycle limits)

The single purchase limit is the dollar limit for a requirement The cycle limit represents the total dollar limit for a billing cycle Limits are based initially on anticipated need/funding and adjusted based on historical need/funding These can be found in the Cardholder appointment

45 of 196

**

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain

Delegation of Contracting Authority BOs (Primary/Alternate), and CHs, must be issued written authority IAW AFARS Subpart 5113.2 and the Army Government Purchase Card Operating Procedures. Identifying their limits of

Authority Duties; Responsibilities; Ongoing training; $ limits, and Mandatory compliance with procurement sources.

Authority to Appoint has been Delegated to A/OPCs and is executed using the PIEE Nomination and JAM Appointment Processes

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain

Merchant Category Code issuing bank to categorize the type of business in which the merchant is engaged and the kinds of supplies or services provided.

Merchants bill under various MCCs, AOPCs have no way of knowing what MCC a merchant is registered under.

AOPC Management Controls and Program Oversight

Initial card set-up has a limited set of authorized MCCs.

If additional MCCs are required (usually discovered upon card decline) they can be added either permanently or temporarily based on need and type of code (some are higher risk then others). The request form is signed and submitted by the BO/ABO for the requiring cardholder

Declining a request to add an MCC based on unclear/no justification and description of the transaction

A/OPC will remove codes based on abuse

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain* If you need to add a code

form, contact your A/OPC as the form is required to make any change.

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain

Modification of $ Limits Controlling spending limits, Single Purchase and Cycle, are an important program requirement.

As it is critical in mitigating risk, the A/OPC is responsible for ensuring that aggressive oversight on spending limits occurs.

Reducing cycle limits on cards where the average spend is less than 70% of that cycle limit

Reducing Single Purchase (transaction) Limits not supported by spending patterns or where higher limits have been abused

Cancelling accounts with no activity over 6 months.

Set the single purchase limit to $1 in order to suspend the account in the event of unauthorized activity, delinquent training or other non-compliant issues.

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain

GPC Out-Processing Policy 30 days out BO/ABO/CH notify A/OPC

Transferring (PCS, ETS, new job) Retiring

MEDCOM Out-Process Policy CH through A/OPC and RMD BO (Alternate) through unit level

Complete Forms DD Form 577, MEDCOM, RHCO-A

Card destruction Witness by A/OPC, Unit Cdr/1SG, RMD Memo to A/OPC when card is destroyed

Nominate GPC Personnel 30 days prior to departure

Account Suspension

Ask for Latest Forms and Process

DD 577 with Revocation completed (signed by appointing authority)

BO or CH Leaves without Notice to A/OPC

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Establish & Maintain GPC is an Acquisition Instrument

GPC Types GPC funded thru SCCS ($10k/5K & $25K) EDI Enabled

Used to pay for services, supplies, construction. Process is impacted by SCCS

GFEBS PR & Obligation must be completed prior to acquiring GFEBS PR & Obligation creates E-Order in AXOL CH matches purchase to E-Order (No manual matching)

Contract GPC ($25K) Non-EDI Enabled Used to pay contracts executed for CH Agency Process not impacted by SCCS CH cannot process in AXOL BO sends GPC signed paper statement to DFAS for payment

Stock Fund (DLA) GPC ($10k/$5K & $25K) - EDI Enabled These cards are funded thru Defense Working Capital Funds Process not impacted by SCCS CH can manually match purchases in AXOL

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

USAMEDCOM Prioritized Acquisition Strategy (Deviation) DLA Troop Support Medical Prime Vendor (PV)

Single distributor of brand specific medical supplies. CONUS/OCONUS contract coverage includes pharmaceuticals/ medical/surgical supplies and equipment. https://www.medical.dla.mil/Portal/PrimeVendor/PrimeVendorHome.aspx

DLA Troop Support Electronic Commerce/Catalogs Net-centric ordering system providing multiple manufacturer and distribution commercial catalogs at discounted prices. https://dmmonline.dscp.dla.mil/Portal/ECAT/EcatHome.aspx Includes pharma, medical/surgical, laboratory, dental and optical

Contracts DLA and Depot FEDMALL and GSA Global Supply (FAR 8.002 a(1)V) Government Purchase Card (Least Preferred)

References SB 8-75-11, Army Medical Department Supply Information NOV 2018 AR 40-61, Army Medical Logistics Policies, 28 January 2005

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

DOD INSTRUCTION 6430.02 - DEFENSE MEDICAL LOGISTICS PROGRAM

Purchase medical materiel to the extent practicable, using electronic commerce (eCommerce) and other enterprise medical materiel acquisition programs established by the DLA, limiting purchases using government credit cards and other local purchase methods

and

ensure all government purchase card and other local purchases for medical supplies and equipment are recorded

DMLSS system With Line Item Detail Recommend Setting up Ordering via Milstrip when possible

53 of 196

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Acquisition Planning

PR to CH

Legitimate Government

Need

Funds Availability

(SCCS)

Market Research/Price Reasonableness

Required Mandatory

Source

Receive BO Pre- Approval

Purchase

Receipt & Acceptance

Match Approve Certify Document

IOD Case and/or A/OPC

Surveillance

* If available via PV, ECAT, GPC would not be used (exceptions).

SB 8-75-11 3-12 Identifying and Cataloging New Materiel a. Policy is established in AR 40-61, Medical Logistic Policies, to standardize throughout all health care activities within the USAMEDCOM the methodology to catalog medical materiel items. It is applicable to all activities and distribution centers utilizing TEWLS or DMLSS to provide medical supply support. f. Medical Master Catalog (MMC) is used to source records to the prime vendors and ECAT.

(5) A PSR must be submitted for all items purchased with the GPC. A copy of the PSR will be included in the purchase card supporting document files.

Upload Supporting documentation into AXOL Approved Request Itemized Invoice Proof of delivery/3rd Party

Receipt MFR or other Documents That explain/support

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Making a Purchase Activity must perform acquisition planning to identify procurement needs with ample time. Avoid issuing requirements on an urgent basis as this restricts competition. GPC micro-purchases should be distributed impartially and rotated among qualified suppliers. Use of A Purchase Request Form is mandatory but there is no specifically required form Special consideration to support designated Small, Small disadvantaged and GSA schedule vendors. CH may place orders online via internet if authorized by internal agency procedures. CH will safeguard their account numbers and ensure to buy from secure web site.

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Mandatory but may be used. Whatever PR Form is used must have detailed description including quantity and cost or estimate, justification/statement of mission essentiality (not

verification required sources were reviewed and if not used why. Other considerations include PBO review and approval and documentation of 3rd party receipt (The date received, along with the signature, printed name, telephone number, and office designator or address of the receiving official .

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Constitution of an Authorized Transaction Lawful

Meets Legitimate Government Need

Meets Bona Fide Need (Used now or soon)

Meets Minimum Needs (not a Mercedes when a Yugo will suffice)

Conduct Market Research for Sources and to verify a Fair and Reasonable Price (Are you familiar with the requirement?) If unsure, research via

Vendor Catalogues Sales Brochures Historical Pricing Personal Knowledge of Item Comparable Price of Similar Item

Guidance & Procedures*

Are you familiar with the requirement? Is it Mission Essential? Fair and reasonable price? Bonafide Need? Customer may have Information!

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures Required Documentation for a Micro Purchase

Bottom Line Cardholder shall: Verify documented legitimate government need

Provided by requestor and verified by the cardholder Verify Funds Availability AXOL (Order Management) Perform Market Research/Price Reasonableness Comply with mandatory sources

FAR Part 8, AFARS 5108, Required Sources Supply/Service Use Ability One to purchase office supplies Section 508 of the Rehabilitation Act of 1973 Environmentally Preferable Purchasing (EPP), FAR Part 23

Obtain\Document pre-approval/authorization from BO Document Vendor Compliance with 2019 NDAA Section 889 Obtain itemized invoice from vendor Verify receipt and acceptance of goods and services

(coordinate with PBO for items requiring documented control) Document 3rd Party Receipt (not a cardholder or Billing Official)

Optimally rolled up on the PR

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Prior to purchase, CH/BO must check availability of funds by

verifying E-Order within AXOL. (Not Applicable to DWCF)

Order Management Order Maintenance

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Making a Purchase Ask the Vendor:

If they accept the GPC (Mastercard) If the goods or services are immediately available For complete pricing to include shipping/handling, government discounts, Federal Supply Schedule terms For delivery information

Inform the Vendor: Purchases are tax-exempt Must attempt to deliver in a single delivery Must attempt to deliver within the billing cycle Do not invoice until items are shipped or service performed

Rotate Vendors Obtain itemized copy of invoice for all purchases

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Required Sources

AbilityOne is a mandatory source at any $ amount where they can provide the requirement (FAR 8.002)

At requirements above $3,500 UNICOR (Federal Prison Industries) takes precedence except for certain exceptions (see separate UNICOR training) (FAR 8.002)

Small Business (as classified in SAM and listed in GSA Advantage) usage becomes mandatory at requirements $10,000 and above. If possible, compare the schedules of three vendors classified as small business. *Use of Small Business sources at dollar amounts lower than $10,000 is highly encouraged where other sources do not take precedence. (AFARS Appendix EE)

GSA Advantage supports but does not take precedence over UNICOR and Ability the only source that can

be used for requirements over the MPT (three schedule comparison required)

Federal Strategic Sourcing Initiative takes precedence over other non-Ability One, non-UNICOR and non-Small Business Sources.

For Supplies

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Other Required Sources

DLA Print Services Printing (FAR 8.003) CHESS-Computer/Hardware/Software (AFARS Appendix EE) HERALDRY Guidons/Positional Flags/BN Flags (AR 840-10) Federal Supply Schedules (recommended under the MPT, required for over the MPT)

See SB 8-75-11 Prime Vendor ECAT Commercial sources in the open market last option after others exhausted (when authorized)

www.ability one.gov https://www.fedmall.mil/ www.heraldry.army.mil www.chess.army.mil www.unicor.gov www.gsaadvantage.gov www.dla.mil/HQ/InformationOperations/DocumentServices/

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Office Supplies

63 of 196

(DoD EMALL has been replaced by FedMall [https://www.fedmall.mil/index.html] but the requirements in policy are the same)

1. Generally the guidance is to give the highest priority to AbilityOne base supply stores) or purchases directly from AbilityOne (not AbilityOne distributors).

2. FedMall FSSI BPAs are a higher priority than AbilityOne distributors and higher than GSA Global Supply due to the language in AFARS Appendix EE.

3. GSA Global Supply is also a higher priority than AbilityOne distributors.

Mr. Rafael Garraton / [email protected] / 703-806-4546 20 JUN 2019Slide 64 of 196UNCLASSIFIED//FOUO

Guidance & Procedures

Training and Education Card CHs may use dedicated training GPC to pay for Commercial/Off the-Shelf training and education up to $25,000 for an individual or planned series of the same training event, activity or course material.

Cards must be dedicated for this purpose and SPL can be set at $25k May be used to purchase items in support of PURCHASED training (books, tests, etc.)

Supporting Documents Standard From (SF) 182 must be completed for training up to $25k for Civilian Personnel DA From 3838 must be completed for Uniformed Personnel Form MUST be fully completed and include both immediate supervisor or senior management and training officer approval

Training costs exceeding $25k or below $25K but not off the shelf are to be submitted thru local contracting office CH must ensure price is fair and reasonable by comparing to other commercial off the-shelve vendors

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Regulated Purchases Green procurement is the purchase of environmentally preferable products and services (see FAR 23.202, 23.403, and 23.703) The Army Green Procurement Policy Memorandum, dated 22 Nov 06, established the Army Green Procurement Program (GPP) policy that

procurement requirements to facilitate attainment of the DOD goal of 100% compliance with mandatory Federal

-1)

Covered in Environmentally Preferable Purchase training Easy to ID Compliant Vendors in GSA Advantage and GSA Global Supply

65 of 196

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

From a GPC perspective ask yourself these 3 questions: Is it mission requirement? Do you have money (the right kind, year, amount in AXOL a.k.a., Purpose, Time, and Amount)? Is it within your GPC threshold?

Adherence to the many Government rules and regulations of a particular purchase must be verified by the CH/BO before a purchase is executed. The requestor may provide the information, but it must be verified by the CH/BO!

The requestor should provide the CH with the justification (legitimate Government need), excerpt form any applicable regulation and approvals to spend correct funding on a requirement. The GPC Office or GPC personnel can either fix requirements packages that are incomplete, or reject them back to the customer per their internal policy

66 of 196

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Special Approval Transactions

Conferences Also referred as meeting, retreat, conventions, expositions, symposiums, seminars, workshops or exhibitions. Per 5 CFR 410.404, applies to training activities which are considered conferences. In particular if taking place in a hotel or conference center. Require review and approval by both senior leadership and legal counsel. Organizations shall not finalize or commit to vendors or hotels until approval from appropriate authority. Entertainment-related expenses are expressly prohibited. Food and refreshments must be approved by legal counsel. Competition and marketing plan required.

67 of 196

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Unauthorized use of GPC Do not procure/obtain/extend or renew a contract for system equipment, or service for covered telecom equipment or services as a substantial/essential component of any system

Hardware/Software, or services from Kaspersky Lab Telecom equipment produced by Huawei Technologies Co. or ZTE Corp., or any of their subsidiaries or affiliates Video surveillance/communications produced by (subsidiary/affiliates):

Hytera Communications Corp. Hangzhou Hikvision Digital Technology Company Dahua Technology Company

Purchase for Contractors Items/Services Already on Other Contracts Checkout Fees Gambling, Betting, Gaming, Lotteries, etc.

68 of 196

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Unauthorized use of GPC Taxes Bail, Bonds Construction Above $2,000 Services Above $2,500 Applicable to Service Contract Act Personal Services, Salaries, or Wages Facility Rental for Non-Mission Event Safety-of-Flight Major Telecommunications System(s) Travel Related Expenses Vehicle Related Expenses Charitable/Social Organizational Memberships Recurring/Repeat Purchases

CH must work with supporting Contracting Cell/Office

69 of 196

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Unauthorized use of GPC Entertainment Expenses

Party Supplies, Serving Material, Food/Meals/Drinks*

Items/Services for Personal Benefits Aircraft Fuel/Oil Unmanned Aircraft Systems Preferred Use Memberships

Amazon, Wholesale Clubs

Not rotating of vendors

70 of 196

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Third Party Payment Processors

Third Party Payment Processors (such as PayPal) are non- bank entities that provide payment processing services to

merchants

AFARS Appendix EE CH should make every attempt to choose another merchant with

whom to procure the goods and/or services. If found necessary to procure using a third party payment merchant, the BO must ensure

adequate supporting documentation showing that there was a detailed review of the purchase and that the use of the third party

payment merchant was unavoidable.

71 of 196

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Statutory Violations

FAR Strictly Prohibited Transactions Items or services that cannot be purchased with appropriated funds. Purchases by individuals other than the authorized CH (UC) Violations to the Mandatory Source requirements. Purchases above/Recurring above MPT not against a contract Split Purchases

Splitting requirements into smaller parts to avoid formal contracting procedures, competition requirements, or to keep spending limitations under the micro-purchase threshold is prohibited.

72 of 196

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Split Purchases Defined (AFARS Appendix EE, Appendix C) 1. A single CH making multiple purchases from the same merchant on the same day,

the total of which exceeds the single purchase limit and the total requirement was known at the time of the first purchase.

2. A single CH purchasing the same/similar item(s) from multiple merchants on the same day, the total of which exceeds the single purchase limit and the total was known at the time of the first purchase.

3. A single CH making multiple purchases of similar items from the same or multiple merchants over a period of time when the total requirement was known at time of the first purchase and the value exceeds the single purchase limit.

4. Multiple CHs under the same supervision or BO purchasing the same/similar item(s) the same day or in a compressed timeframe when the total requirement is known at a given time and exceeds the single purchase limit.

5. Requirements exceeding the micro-purchase threshold. (i.e. yearly requirement where the monthly recurring services are less than the micro-purchase threshold but the known yearly total exceed the micro-purchase threshold.)

73 of 196

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Account Suspensions When a program is at risk, or procedures are not being followed, GPC cards shall be suspended by:

US Bank AOPC (Level2/Level 3/Level 4)

Billing Official/RMD/Budget may request to suspend CH account. The top reasons for GPC suspension:

Violations of policy or procedures Failure to complete and maintain training requirements Payment Delinquency Certification Delinquency Failure to complete IOD purchase reviews Failure to maintain both a primary and alternate BO

74 of 196

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Program Administrative Requirements A record of each purchase must be kept to perform a reconciliation of purchases against the statement provided by the Bank. It is mandatory to upload purchase supporting documentation in the bank system

To support financial audits (paper trail) the current billing official must personally retain purchase documents for six years and three months.

Required documents include Purchase request; justification and eOrder verification Managing and Cardholder Account statements Quotes, Disputes, Funding verification Original receipts (invoices) Signed Proof of Delivery/3rd Party Receipt and Acceptance Additional Documentation to Support Legality

75 of 196

*

UNCLASSIFIED//FOUO

Purchase Process

Key Steps

Separation of Duties applies

Requiring Activity

Establish Funding & Legitimate

Government Need

Cardholder

Order Placement

Make Purchase

Receive Goods or Services

Pay Vendor

Pay U.S. Bank

Documentation

File Retention

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Security Lock in secure location AR 190 51, PG 17 USAHCA GPC Operating

Procedures, PG 11 Do not take home Only CH can commit the Government Use secure internet sites Card number

Not on Invoice Not Stored by Vendor Not in e-mail Not in Fax

Suspension US Bank Policy

60 Days Past Due BO/ABO CH

180 Days Past Due Entire Level IV

Army Policy 55 Days IOD cases not reviewed

77 of 196

*

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO 78 of 196

Unless an exempt category, prior to making a purchase, the cardholder must document vendor compliance by having the vendor complete the form, pull the compliance from System for Award

about covered telecommunications equipment or services, the cardholder may make the purchase.

the vendor employee making the representation to ensure they are authorized. Note that many vendors will want to send through their legal advisor before completing.

This form gets uploaded into AXOL along with the other required supporting documentation

2019 NDAA Section 889 Requirement

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

889 Categories for AXOL Log Entry

79 of 196

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO 80 of 196

Go to AXOL Transaction Management/Transaction List and Select the blue hyperlink such as date or status. Select

the applicable entry.

An entry is required for every purchase.

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Lost/Stolen/Mutilated GPC

CH notifies in order of priority) US Bank customer service (1-888-994-6722) Assigned A/OPC Billing Official/Alternate Billing Official Supervisor

BO provides written report to A/OPC Within 5 Business Days Detail the circumstances of loss/stolen/compromised

81 of 196

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Pre-Approval Requirements Every purchase must be pre-approved by either BO/ABO CHs may be asked to acquire items that seem questionable, or may have the appearance of being inappropriate.

Always consult with Legal, RM, Level 4 (A/OPC)

82 of 196

Exercise Due Diligence, but if unsure, contact us!

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Span of Control

Billing (Alternate) Official to Cardholder Ratio 1:7 (workload)

Exceptions Approved thru AOPC to MEDCOM Level 3

83 of 196

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Tax Exemption Purchase Card transactions are exempt from tax in most states and U.S. territories. Tax exemption forms are needed for:

Florida Georgia Louisiana

Michigan Minnesota Rhode Island

South Dakota Tennessee Texas

Utah West Virginia Wisconsin

Wyoming

Visit https://smartpay.gsa.gov /content/state-tax- information for more information

Surcharges May be assessed by a retailor and added to the cost of a purchase Several states do not allow or limit use of surcharges:

Surcharges should be disclosed in advance and itemized on the receipt

*Contact your A/OPC when you need assistance with avoiding tax or determining whether a fee is authorized or not

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Tax Exempt Status CONUS purchases CH informs merchant purchase is Official U.S. Government purposes GPC is embossed US Tax Exempt The billing method determines the tax status

Centrally Billed = Bill paid directly by Government Tax Exempt can be determined by card account numbers.

Some local jurisdictions require a tax exempt number found in State Tax Letters

https://smartpay.gsa.gov/content/state-tax-information

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Property Accountability

All personnel entrusted with acquisition of Government property are responsible for proper custody, safekeeping, and accountability (AR 710-2 & AR 735-5) CH provides purchase receipt to PBO within 5 days after receipt Local PBOs must ensure CH are trained on installation specific property accountability procedures A/OPCs will suspend GPC accounts which are repeat non compliance on property accountability procedures Books and book sets valued over $100 must be maintained in the medical library or be placed on the property book

*

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

What is Accountable Property?

Items acquired with the GPC with a unit cost of $5,000 or greater are considered accountable property (in accordance with the provisions of DoDI 5000.64) Includes pilferable property, as defined in the cited DoDI, regardless of unit acquisition cost Ensure ALL accountable property is independently received and accepted by separate DoD officials and that these items are properly recorded in DoD property book systems

Local and HQ Policies Take Precedence if more strict. Document PBO Review and Approval

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Independent Receipt and Acceptance CH ensures receipt and acceptance of goods and services, and accountable property is performed and confirmed by someone other than CH Receipt and acceptance includes receiving official s

Date received Signature (Hand or electronic) Printed name Telephone number Address/office designator

BO must verify existence of receipt and acceptance documentation during reconciliation CH notify PBO of all pilferable, sensitive, or high value property obtained with GPC

Not a BO, Not any CH

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Convenience Checks JUST SAY NO

Provided through US Bank Purchases under $5,000 (micro-purchase)

Must be audited quarterly by a disinterested third party of the BO/ABO choosing GPC has precedence over convenience check For domestic purchases in US dollars Shall be exchanged for credit not cash Must be treated as GPC Disputes are to be handled between CH and merchant

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Convenience Checks

1099 Tax Reporting Process Available at https://dfas4dod.dfas.mil/systems/1099 Submit 1099 to DFAS for each check used Report services, rent, and medical payments Must be entered throughout the year Print 1099 entry for file

Prohibited Purchases Salaries/wages Travel advances or claims Contractor agents who are employed with Government Payment of contracts Repetitive purchases (BPA)

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Acquisition Planning

PR to CH

Legitimate Government

Need

Funds Availability

(SCCS)

Market Research/Best

Value *

Required Mandatory

Source

Receive BO Pre-Approval

Purchase

Receipt & Acceptance

Match Approve Certify

IOD case/or A/OPC

Surveillance

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

After the Purchase The merchant transmits information about the CH and the purchase to US Bank for processing. US Bank receives this information and posts the transactions to the CH account. Once a transaction posts CHs can begin to match purchases. Matching is dependent upon the funding type.

GFEBS SCCS (EDI enabled) Stock Fund (DWCF) Contract GPC (non-EDI enabled)

A paper statement is generated one day after the end of the cycle for non-EDI accounts (accounts not certified electronically via AXOL).

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Creating an order in US Bank Access Online

CH approves pending charges by matching to E-Order

E-Order is loaded into AXOL by GFEBS (Prior to purchase)

Stock Fund CH (anyone?) At a minimum include

Order date Merchant name Order Number Amount of transaction Receiving information Description of item or service

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

CH must match below E- Order to current cycle

purchases. Deviations must be approved by your

supporting RM

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Cardholder Reconciliation

At end of billing cycle, the cardholder reconciles all information contained on the Cardholder's Statement of Account (SOA).

Within 1-2 days after cycle ends. Verify the accuracy of each purchase against the purchase log.

Disputes purchases not made by cardholder. Provides a complete description of each item listed on the SOA. Ensures availability of appropriate funding identification (reallocate as needed). Approve/reconcile transactions via Access Online/Paper. Forwards documentation to BO for certification.

E-order selection, statement approval, CH Absence, verification/documentation

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Always question tax charges on your purchase card especially on

invoices. Also look for prompt payment discounts and ensure

they are applied when earned (i.e. 15 days 1% 30 days net)

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Managing Account Certification Process, CH Absence verification/documentation

The Billing Official Review each transaction to ensure all supporting documentation is present. Final approve CH statement. Within 3 days after cycle end MUST certify for payment. BO must maintain all supporting documentation for each billing cycle.

For accounts manually certified, the BO ensures that the billing statement signed and forwarded to the Accounting Office in accordance with local procedures for payment. Failure to do so may delay payment, generating interest penalties to the Card- Issuing Bank.

*

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

IDOC errors

Goal- No manual Payments!! BOs/ABOs are to match correctly

Once the certified statement processes into GFEBS and post to the correct GFEBS PO, errors exceptions will be identified by the GFEBS

GFEBS PO. These IDOC errors will require the PO processor to correct or create a manual payment packet for RM to process in GFEBS. It is the requirement of each BO/ABO to gather the required information that caused the IDOC and coordinate with their RM to correct the IDOC, which is cited on the AXOL IDOC Error Report sent from MEDCOM HQ each Monday and Thursday, to pay US BANK timely. These IDOC corrections are to be corrected within 5 days from the date initially cited on the AXOL IDOC ERROR REPORT. Not acting promptly on a IDOC error will cause interest payments to US Bank, loss of rebates, and loss of purchasing power .

* (Not Applicable to DWCF Accounts)

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Confirm and Pay - Payment Model

Cycle closes (19th) and a billing statement is generated. BO must establish a system to flag/track

Allows US Bank to be paid

Items that have been shipped but not received. Transactions reconciled and approved to pay will have receipt verified NLT 45 days after original invoice.

*

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Disputes

Valid Disputes Unrecognized/Unauthorized

Unauthorized requires account to be closed Duplicate Charge Merchandise returned Merchandise/Services not

received Cancelled Incorrect Amount Paid by Other Means Defective Merchandise Quality of Service

Invalid Disputes

Sales Tax Shipping and Handling Exchange Rates Convenience Checks Credits/Re-bills Government Service Rebates Different Fiscal year

Unofficial/Unauthorized cardholder purchases, cardholder abuse

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Disputes Continued

101 of 196

DISPUTE PROCEDURE Attempt to resolve all disputes with the vendor first

Approve action in AXOL Cardholders order match Approving officials certify Document file with discrepancy

After all attempts to resolve (but NLT 90 days from Transaction Date) YOU MUST DISPUTE TO PROTECT THE GOVERNMENTS RIGHTS, if you have not received full credit or the item or service as required!

Dispute in AXOL During the cycle in which the charge appears. Order creation and order matching will still be required

Dispute via hard copy Cardholder Statement of Questioned Item (CSQI) fax (with confirmation phone call) within 90 days of the transaction date of the subject charge (Army policy is within 60 days, but 90 days is allowed by US Bank). After 90 days you lose the right to dispute IAW the current contract w/US Bank.

* Failure to resolve and/or timely dispute an erroneous charge may result in the requirement for the CH, consistent with agency policy, to reimburse the Army!

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Dispute During Open Cycle

102 of 196

Dispute by selecting a blue hyperlink for the transaction in

UNCLASSIFIED//FOUO UNCLASSIFIED//FOUO

Disputes

103 of 196

Paper Cardholder Statement of Questioned Item (CSQI) Use this

to dispute when you cannot dispute because the cycle has

closed and been certified.

Can be faxed in to the bank

Stateside: 701-461-3463

Ensure you document in your files the dispute and the outcome.

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Billing Official Statement (Statement of Account) Sample

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Cardholder Statement Sample

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Transfers, Retirement etc. Notify Us So we Can Send Relief from Responsibility Requirements

Cardholders: Attempt to limit purchases within 90 days of your

DEROS, PCS, ETS, or Retirement Turn- BO or CH can notify A/OPC of date to suspend the

card, will terminate at the end of the next billing cycle

Billing/Certifying Officials: Send replacement to training and initiate account transfer 90 Days Prior to DEROS, PCS, or ETS or Change of Duty Assignment To finalize account transfer, appointment must be revoked

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Preventative Measures

Program Evaluations Reports (C.7.3.1)

Internal Policies

Compliance Convenience Check Spend Reviews Procurement / Purchase Management Reviews Records Retention Training

Account Activity Declined Transactions Disputes Fraud Analytics Lost / Stolen / Invalid Cards Unusual Spending Activity Ad Hoc

Authorization Controls Card Limits Delegation of Authority Merchant Code Blocks Random Record Checks Separation of Duties Regular Recurring Refresher Training

See OMB Circular A-123 Appendix B and OMB Memo M- 13-21

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Performed by various methods (electronic/manual) Responsibility of multiple functional areas including A/OPC, Billing

Official, Organization RM, IG, IRAC. A/OPC performs on-going oversight by review of Access Online Transaction Logs, other U.S. Bank reports and Insights on Demand (IOD) DoD conducts Department-wide data-mining and review of transactions on an ongoing basis. IRAC performs data-mining to identify possible abusive transactions and test management controls. DoD IG as well as other audit agencies conduct periodic reviews/audits.

If any official in the process suspects fraud or misuse, it is their responsibility to report that suspicion to the appropriate authorities.

Program Oversight

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Insights on Demand: Data mining fraud & misuse identification and on-demand insights.

Artificial Intelligence and Machine Learning Every transaction analyzed. Across the entire organization. With full context of past behavior. DoD IG/IRAC as well as other audit agencies conduct periodic reviews/audits Full Transparency.

User Role BO/ABO. Reviews 100% Flagged Cases within 10 days of date detected A/OPC Level 4

Cycle based

Insights on Demand

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

: BO pre-approvals missing, not signed/dated

Unclear Legitimate Government need/Justification

Mandatory Source violation

Receipt & Acceptance not Documented or Not Documented Correctly

Split Purchases

Unauthorized Transactions

Failure to adhere to regulations and policy constitutes negligence

Review Findings: *

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Guidance & Procedures

Account Suspensions

Accounts will be suspended due to:

Failing to have 1 Billing Official, 1 Alt Billing Official

Failing to have training up to date

Failing to certify within 3 business days

Past Due (transfer of payment to US Bank after Certification

Failure to respond to A/OPC requests

Failure to complete Insights on Demand Data Mining

A/OPC findings of questionable purchases

Failure to correct procedures after notification

(This list is not all-inclusive)

*

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

GPC POCs

Theodore Frank, , A/OPC Office: 703-806-4543

US Bank 1-888-994-6722 (Customer Service) 1-800-523-9078 (Fraud Prevention)

Rank Action Officer / e-mail / phone number Slide 5 of x 08 January 2016UNCLASSIFIED//FOUO

Questions

Our highly skilled and intelligent personnel are eagerly waiting to serve you....