Procurement Card Violations
Below are the 7 types of procurement card violations and an explanation of what is an appropriate consequence for a specific violation. The department as well as the Purchasing Department has the authority to cancel a card at any time. The SIUE P-Card Auditor will notify the P-Card Administrator of apparent violations that require follow-up and handling.
Consequences of P-Card Violations
1.Personal Purchase(s)
Definition: A personal purchase is anything that is not purchased for use and ownership by the University.
Violation: It is a Cardholder violation to make ANY personal purchases or transactions with the Procurement Card or on any other purchase method. It is against the law to use University funds, obtained from either State, federal or local sources, to purchase items for personal use. Even though the Cardholder may have paid the University back, or intends to pay back the amount of the purchase, it may be considered a fraudulent act.
Consequence: The University must be reimbursed immediately for the amount of the personal purchase. The Card will be canceled. Any violation of this policy will be investigated and could result in termination and/or criminal prosecution. In the event of willful or negligent default of these obligations, the University shall take any recovery action deemed appropriate, that is permitted by law.
2.Cash or Cash Type Transactions
Definition: Cash, cash in addition to purchase, cash in lieu of credit to account, travelers checks, money orders, gambling, ATM transactions, etc.
Violation: A cash or cash type transaction made using the Procurement Card (this includes accepting cash rather than credit for returned items).
Consequence: The University must be reimbursed immediately and the funds deposited directly into the appropriate University account. Card will be canceled and any violation of this policy will be investigated and could result in termination and/or criminal prosecution. In the event of willful or negligent default of these obligations, the University shall take any recovery action deemed appropriate, that is permitted by law.
3. Split Purchases
Definition: Split transactions are defined as single items costing more than $3500.00 which are split between multiple transactions to circumvent the $5,000.00 limit.
Violation: A split purchase as defined above.
Consequence: Card may be revoked and the Cardholder will be required to obtain further training before the card is reinstated. Individual card limits may be increased to meet legitimate departmental needs by obtaining the approval of the Vice Chancellor for Administration.
4. Inappropriate Purchases
Definition: Any purchase that is a violation as set forth in the user's guide, the purchasing policies and procedures of the University, or State of Illinois purchasing laws and regulations. The Procurement Card is to be used for small dollar purchases ONLY. NO other purchases not allowed by the intent and purpose of the Procurement Card Program shall be allowed.
Violation: Purchase of any inappropriate items or services on the Procurement Card.
Consequence: Any violation of this policy may be investigated and could result in termination and/or criminal prosecution. At a minimum, the Cardholder will receive a warning and may be required to obtain additional training on use of the program. Chronic abuse may result in cancellation of the card and will be investigated as a personal purchase.
5. Failure to Provide Supporting Documentation
Definition: Each transaction on the Procurement Card must be represented by an itemized receipt or other acceptable means of documentation that verifies the date of purchase, the vendor or merchant name, each item purchased and the price of each item.
Violation: Lack of supporting documentation for every transaction is a cardholder violation.
Consequence: Any violation of this policy will be investigated and could result in termination and/or criminal prosecution. Human error and patterns of chronic abuse will be considered. At a minimum, the Cardholder will receive a warning and may be required to obtain additional training on use of the program. Chronic abuse may result in cancellation of the card and will be investigated as a personal purchase.
6. Improper Coding of Transactions
Definition: Each transaction entered into the P-Card System must be assigned the proper expenditure/Object code in order to properly account for the expenditure transaction and to charge it to the appropriate budgetary line.
Violation: Failure to assign the correct Object code to a transaction is a departmental card manager violation.
Consequence: Any violation of this policy will be investigated and the P-Card Administrator will notify departmental card manager by e-mail of problem and request a response. Three separate coding incidents will result in a call to the fiscal officer advising him or her of the problem and soliciting assistance in dealing with the problem. Continued problems may result in the suspension of the individual card(s) for a minimum of three months and/or replacement or removal of departmental card manager.
7. Failure to Timely Reconcile or Approve Transactions
Definition: We recommend that transactions be reconciled in the Pcard software by the Departmental Card Manager (DCM) within 10 days of the email notice to reconcile transactions. (This allows up to 5 days for the Cardholder to provide receipts to the DCM.) We also recommend that transactions be approved by the Approver within 5 days of the email notice to approve. Timely reconciling/approving ensures that Pcard transactions are entered into your fiscal officer reports.
In any case, Pcard transactions should be reconciled and approved by department personnel within 30 days of the transaction.
Violation: Failure to reconcile and approve a transaction within 30 days of the transaction will be a violation.
Consequence: The Pcard Administrator will notify the Departmental Card Manager or Approver by e-mail of the problem and request a response. If the problem persists, a final warning will be issued by the Pcard Administrator, after which the Pcard could be suspended for up to three months. The Departmental Card Manager or Approver could be removed or replaced in their Pcard role, depending upon the nature, repetition, and severity of the problem.
