Id_6309.32_2007-1 Page 1 of 10 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 New Document(s): id_6309.32-2007-1 10 Pages Superseded Document(s) by Issuance Number and Effective Date id_6309.32-2005-1 9 Pages Digest: Extends Interim Directive until current version updated.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.