FOREST SERVICE HANDBOOK SOUTHWESTERN REGION (REGION 3) ALBUQUERQUE, NEW MEXICO

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Id_6309.32_2007-1
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FOREST SERVICE HANDBOOK
SOUTHWESTERN REGION (REGION 3)
ALBUQUERQUE, NEW MEXICO
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
PART 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Interim Directive No.: 6309.32-2007-1
Effective Date: February 7, 2007
Duration: This interim directive expires on 08/07/2008.
Approved: LUCIA M. TURNER
for Regional Forester
Date Approved: February 7, 2007
Posting Instructions: Interim directives are numbered consecutively by Handbook number
and calendar year. Post by document at the end of the chapter. Retain this transmittal as the first
page(s) of this document.
New Document(s):
id_6309.32-2007-1
10 Pages
Superseded Document(s) by
Issuance Number and
Effective Date
id_6309.32-2005-1
9 Pages
Digest:
Extends Interim Directive until current version updated.
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 2 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
4G13.301 Government wide commercial purchase card.
Local Area Program Coordinators shall conduct audits in accordance with the Region 3 Internal
Process Plan.
4G13.301-72 Responsibilities
(a) General responsibilities for the purchase card program:
(1) Individual units are responsible for accomplishing their micro purchasing,
even under circumstances where certain cardholder privileges have been
suspended or revoked.
(2) Cardholders are responsible for reconciling their accounts.
(3) The cardholder’s supervisor is responsible for the cardholder’s proper use of
the card and checks (current check writers) and proper expenditure of funds.
Supervisors shall recommend appropriate personnel action in the event of
purchase card or convenience check abuse.
(b) Regional Policy:
(1) Ensure that the Local Area Program Coordinator (LAPC) function is staffed at
a level and quality at which good performance can be attained.
(2) Provide adequate training and regional-level assistance for LAPC’s.
(3) Involve cardholder supervisors directly in the Purchase Card Program:
(i)
Selecting who will have a card.
(ii)
Monitoring card use and cardholder performance.
(iii)
Keeping informed of Acquisition Management and Fiscal actions
related to cardholder performance.
(4) Keep the Procurement Officials involved in management of the program.
(5) Ensure that Financial Management participates in audits and, where required,
in necessary corrective actions.
(6) Supervisors of cardholders must follow the guidelines identified in Exhibit 131.
(7) To ensure cardholder compliance with regulation and policy, acquisition
personnel will follow the administrative actions listed in Exhibit 13-1.
(c) Administrative Actions:
(1) An analysis of purchase card and check transactions indicate errors involving
statute or regulation, and policy and procedure.
(2) Exhibit 13-1 shows the type of errors typically found in the micro-purchase
program and the administrative actions, which are taken by acquisition personnel
when these errors are discovered. Each situation requires analysis. For example:
(i)
Is this an isolated incident or part of a pattern from this cardholder?
(ii)
Is this occurring with many cardholders suggesting that there is a
weakness in the training?
(iii)
Does this seem to stem from a lack of knowledge?
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 3 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
(iv)
(v)
Does this seem to stem from a lack of care?
Does this seem to be deliberate?
(3) The administrative actions in Exhibit 13-1 apply only to administration of the
cards. More severe administrative actions may be warranted based on the
analysis of the given situation. In addition to these administrative actions, the
employee may also be subject to disciplinary actions, including removal.
(4) Procedurally, once an error is discovered, the LAPC will gather the relevant
information and review it with their respective Procurement Official. The
appropriate administrative action will be taken at the lowest permissible level.
Those that are reserved for the Director, Acquisition Management will be
submitted with a written recommendation for appropriate action. Administrative
actions associated with specific organizational levels are as follows:
(i)
Ratification and cancellation of the card – Director, Acquisition
Management (See FSH 6309.32, 4G01).
(ii)
Reduction of the Single Purchase Limit (SPL) to $1 – Procurement
Official.
(iii)
Letter(s) to cardholder – Procurement Official.
(iv)
E-mail to cardholder – Local Area Program Coordinator.
(5) The tables are divided into two sections. The first table describes those
actions required by law or regulation, and the second table describes actions
required by policy or procedure.
(i)
Cancel card means to revoke the cards and/or checks and close out
the account.
(ii)
Card to $1 means: The single purchase limit is reduced to $1. If
the cardholder were also a check writer, check-writing authority
would also be reduced to $1.
(iii)
Ratification means following the regional procedures for
ratification. It is recognized that paying the bill is not dependent
on the outcome of the ratification process. Rather, the process is
necessary because the purchase (or set of purchases) is actually
outside the cardholder’s authority and thus becomes an
“unauthorized commitment”.
(iv)
Supervisor means the cardholder’s first line supervisor.
(v)
Treat as new application means that the former cardholder must
take the current required training.
(vi)
Split purchase means splitting requirements into several purchases
to avoid the cardholder’s delegated single purchase limit.
(vii) Personal preference means unjustified procuring of a supply or
service from other than a mandatory source or procuring an
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 4 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
(viii)
(ix)
extravagant service or supply where an appropriate one already
exists.
Personal use means use of the card for other than official
government purposes.
Procurement Official means Lead Contracting Officer or Zone
Lead Contracting Officer or RO Lead Contracting Officer.
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 5 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Problem
Split Purchase
Exceed authority
Personal Preference
Personal Use
Mandatory Source
Violation
Exhibit 13 -1
ADMINISTRATIVE ACTIONS
–
Statutory/Regulatory Issues
1st occurrence
Ratification; card to $1 for 60 days.
Reinstatement only on supervisor
request and Procurement Official
Approval. (Statement of Facts and
consideration by Procurement
Official.)
Ratification; card to $1 for 60 days.
Reinstatement only on supervisor
request and Procurement Official
Approval. (Statement of Facts and
consideration by Procurement
Official.)
Letter to employee (cc: supervisor)
explaining error.
Statement of Facts and consideration
by Procurement Official
Letter to employee (cc: supervisor)
explaining error.
Purchase contrary to law
or regulation (See PCMS
Guide and MicroPurchase Guide)
Letter to employee (cc: supervisor)
explaining error.
Use of incorrect funds
(such as, Accounting
Information)
Fiscal to take the lead in seeking
correction. Cardholder’s failure to
make timely corrections may result in
request from Fiscal to Acquisitions to
reduce card to $1 for 30 days or
correction, whichever is longer.
Reinstatement only on supervisor
request and Procurement Official
Approval.
Repeat occurrence
Ratification; cancel card;
after 12 months, supervisor
may request another card;
treat as new application. *
Ratification; cancel card;
after 12 months, supervisor
may request another card
and Procurement Official
Approval; treat as new
application. *
Cancel card. *
Cancel card. *
Card to $1 for 60 days.
Reinstatement only on
supervisor request and
Procurement Official
Approval. *
Card to $1 for 60 days.
Reinstatement only on
supervisor request and
Procurement Official
Approval. *
Fiscal to take the lead in
seeking correction.
Cardholder’s failure to
make timely corrections
may result in request from
Fiscal to Acquisitions to
reduce card to $1 for 60
days or correction,
whichever is longer.
Reinstatement only on
supervisor request and
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 6 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Procurement Official
Approval. *
Problem
Failure to reconcile in 30
days
Exhibit 13-1--Continued
ADMINISTRATIVE ACTIONS
–
Policy/Procurement Issues
1st occurrence
E-mail to employee (cc:
supervisor); 15 days to correct.
Failure to correct, card to $1 for 30
days or correction, whichever is
longer. Reinstatement only on
supervisor request and Procurement
Official approval.
Failure to reconcile within
60 days after card after card
reduced to $1.
Incomplete reconciliation
(such as, no/inadequate item
description; no Debt
Collection Act Waiver
citation; no attempt to
change Budget Object
Codes)
Cancel card.
Inadequate or non-existent
documentation
E-mail to employee (cc:
supervisor); 15 days to correct.
Failure to correct, card to $1 for 30
days or correction, whichever is
longer. Reinstatement only on
supervisor request and Procurement
Official approval.
E-mail to employee (cc:
supervisor); 15 days to correct.
Failure to correct, card to $1 for 30
days or correction, whichever is
longer. Reinstatement only on
supervisor request and Procurement
Official approval.
Repeat occurrence
E-mail to employee (cc:
supervisor); 15 days to
correct. Failure to correct,
card to $1 for 60 days or
correction, whichever is
longer. Reinstatement
only on supervisor request
and Procurement Official
approval. *
E-mail to employee (cc:
supervisor); 15 days to
correct. Failure to correct,
card to $1 for 60 days or
correction, whichever is
longer. Reinstatement
only on supervisor request
and Procurement Official
approval. *
E-mail to employee (cc:
supervisor); 15 days to
correct. Failure to correct,
card to $1 for 60 days or
correction, whichever is
longer. Reinstatement
only on supervisor request
and Procurement Official
approval.
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 7 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Exhibit 13-1--Continued
ADMINISTRATIVE ACTIONS
–
Policy/Procurement Issues
Problem
1st occurrence
Purchase w/o necessary
Letter to employee (cc: supervisor)
approvals (such as,
explaining error; 30 days to present
Advisory & Assistance, and proper approval. Failure to obtain
SF182)
approval, card to $1 for 30 days or
until approval obtained, whichever is
longer. Reinstatement only on
supervisor request and Procurement
Official approval.
Incorrect budget object
codes (valid attempt)
Cardholder’s failure to make timely
corrections may result in card
reduced to $1 for 30 days or
correction, whichever is longer.
Reinstatement only on supervisor
request and Procurement Official
approval.
Unauthorized use of card
for travel related expenses
Letter to employee (cc: supervisor)
explaining error.
Other policy violations
Letter to employee (cc: supervisor)
explaining error.
Repeat occurrence
Letter to employee (cc:
supervisor) explaining
error; 30 days to present
proper-approval. Failure
to obtain approval, card to
$1 for 60 days or until
approval obtained,
whichever is longer.
Reinstatement only on
supervisor request and
Procurement Official
approval. *
LAPC to take lead.
Cardholder’s failure to
make timely corrections
may result card reduced to
$1 for 60 days or
correction, whichever is
longer. Reinstatement
only on supervisor request
and Procurement Official
approval. *
Card to $1 for 60 days.
Reinstatement only on
supervisor request and
Procurement Official
approval. *
Card to $1 for 60 days.
Reinstatement only on
supervisor request and
Procurement Official
approval.
* Refer to HR for possible disciplinary action. These problems may result in criminal or
disciplinary action in addition to the Administrative Actions. Reference DPM Chapter 751,
Amendment 230, Guide for Disciplinary Penalties.
http://www.usda.gov/da/employ/apsd/dpm751a502working.pdf
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 8 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Exhibit 13-2
Guideline for Supervisors of Micro-Purchasers
Congress established the concept of micro-purchases (those up to $2,500 for supplies and
services, $2,000 for construction), and stated that the purchase card would be the tool of choice
for making micro-purchases.
(a) Requesting Cards and Checks
To exert proper control and management over the micro-purchase activity, cardholders’ first line
supervisors need to be involved. This guideline will assist supervisors to understand their role in
managing the program.
Following is a list of questions to consider in deciding whether or not you need your employee to
have a purchase card:
Yes
No
Does employee’s work assignment require frequent purchase of supplies or
services—at least once a month on average?
Does employee’s work assignment require providing lodging and meals for
his/her crew on fire assignments?
Is employee located at a work site away from other micro-purchasers?
Does work group have anyone else to handle micro-purchase transactions?
Does your work group need a backup person for micro-purchase
transactions when the principal micro-purchaser is not available?
The authority to do micro-purchasing carries with it the responsibility to reconcile the
transactions at least bi-monthly through the Purchase Card Management System (PCMS):
Yes No
Does the cardholder have reasonable access to PCMS?
Are you willing to give the cardholder the time necessary to reconcile the
account on a regular basis
Are you willing to monitor the cardholder’s micro-purchasing activities to the
extent that you know what is being bought, how much is being spent, and that
the account is being properly reconciled each month?
Do you feel you have an adequate knowledge of general acquisition rules as
they apply to micro-purchasing so that you can monitor your micro-purchasers
and do not inadvertently ask the micro-purchaser to make a transaction which
violates regulation or policy?
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 9 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Exhibit 13-2—Continued
(b) Monitoring your Micropurchaser(s)
Although micro-purchasers are responsible for the actions they take in using the micro-purchase
tools, you as the supervisor are responsible for the actions of your employees. If you are the
fund holder for the money being used, you are also ultimately responsible for the proper
expenditure of those funds. Because of these responsibilities, you may be well served to monitor
your micro-purchaser’s use of the cards and checks. Here are some ways you might do that:


Require the micro-purchaser to get your approval before making any transaction, or
before making transactions above a certain dollar level.
Ask the micro-purchaser to provide you a copy of a CARDHOLDER REPORT on a
regular basis (monthly, for example). This report can also be obtained from LAPC.
This report contains the following kinds of information:
o Merchant Name
o Purchase Date
o Amount
o Accounting Code(s)
o Item description (if the micro-purchaser has inserted the information)
o Whether or not the transaction has been approved
This information will tell you where purchases are being made, what is being purchased, to what
fund code (job code) it is being charged, and whether or not the cardholder is doing a timely and
complete job of reconciling the account.


If for some reason you prefer that your cardholder not be aware of your
monitoring activities, you can request a similar report from the Local Agency
Program Coordinator (LAPC) — the acquisition official responsible for the
Purchase Card program on your unit.
You may request a report from the LAPC, which shows how much money, was
charged for card transactions to a particular job code for a given period of time.
The report also shows who made the transactions.
(c) Working with Acquisition Personnel
Success in managing the micro-purchasing program will be greatly enhanced by close
cooperation between you and the Acquisition personnel servicing your unit. Some things you
should expect from Acquisition (in addition to the reports mentioned earlier):

Both initial and refresher training for your micro-purchasers. Cardholders shall
complete FS 6300-53 for training.
R3 INTERIM DIRECTIVE 6309.32.2007-1
EFFECTIVE DATE: 02/07/2007
DURATION: This interim directive expires on 08/07/2008.
ID_6309.32_2007-1
Page 10 of 10
FSH 6309.32 – FEDERAL ACQUISITION REGULATION
CHAPTER 4G13 – SIMPLIFIED ACQUISITION PROCEDURES
Exhibit 13-2—Continued




Appropriate advice on the legitimacy of transactions about which you have
questions.
Receive (or be shown where to get) appropriate acquisition training for yourself if
you feel it is needed.
Receive guidance in understanding the administrative actions to be taken if one of
your micro-purchasers commits an infraction of one of the rules.
Receive copies of e-mails and/or hard copies of letters directed to your micropurchasers.
In the case of a serious infraction, you can expect to receive a recommendation that you consider
disciplinary action.
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