compliance reviews - University of Louisville

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Procurement Card Program
www.louisville.edu/procard
Training Outline
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Benefits and Overview
Testing, Training, and Obtaining a ProCard
ProCard Policies and Role Responsibilities
ProCard Suggested Uses and Restrictions
Policy Violations and Card Misuse
Departmental Controls
Compliance Reviews
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BENEFITS AND OVERVIEW
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Program Overview
• ProCard program started in 2000
• Current partnership is with PNC Bank
• 1427 active cards – as of January 1, 2013
– Departmental (477)
– Individual (956)
– Declining Balance (17)
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Benefits of the ProCard Program
• Efficient, timely, and cost-effective method of payment for small dollar
transactions (expenses incurred to process a small dollar purchase can run
as high as the price of the item itself).
• The card may be used for items that are needed immediately.
• Eliminates the need for petty cash reimbursements.
• Vendors will be paid immediately by the credit card company, increasing
vendor good will, and at times generating better discounts.
• The University makes one payment per month to PNC, rather than one per
vendor.
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TESTING, TRAINING, AND
OBTAINING A PROCARD
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Testing and Training
Testing
All cardholders, reconcilers,
reallocators, and approvers of
ProCards must complete the
online Blackboard Test with a
score of 100%.
Training
Classroom Training is required
before an employee can
reallocate transactions in
PeopleSoft.
Approvers should only complete
this training if they would like to
review/approve transactions in
PeopleSoft.
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Process for Obtaining a ProCard
Any cardholder, reconciler, or approver must be an employee of UofL, ULAA, or ULRF.
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Pass the ProCard test on Blackboard - all cardholders, reconcilers, and
approvers.
Attend PeopleSoft training - approvers and reconcilers only.
Complete card application in PeopleSoft.
Print application from University Reports the following business day.
Obtain appropriate departmental signatures.
Forward signed forms to ProCard Office.
Pick-up and activate card(s). (The new card will be ready for pick-up 5-7
business days after proper completion of the application.)
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PROCARD POLICIES AND ROLE
RESPONSIBILITIES
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Basic Policies
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One (1) card per employee except for grants - an individual may have a card tied to each grant.
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The cardholder/responsible party should be the person who uses the card most often.
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The approver of a card must not be a subordinate in the direct reporting line of the cardholder.
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An Employee Usage Agreement must be completed by anyone, other than the cardholder, who makes
purchases on the card.
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A Transaction Summary Log (TSL) must be completed for each billing cycle.
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All cards that have had no activity for twelve (12) continuous months will be canceled.
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A Disputed Items Form must be completed within 60 days if a fraudulent or inappropriate transaction is
discovered on the statement.
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Monthly ProCard documentation must be retained for a period of 3 years (possibly longer if tied to a
grant). This includes: original itemized receipts, TSLs and supporting documentation, PNC statements.
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Transaction Summary and Reconciliation Sheet
University of Louisville Procurement Card
Department:
Card Account #:
Cardholder's Name:
(last 6 digits)
Transaction Summary for Month:
Cardholder's Signature & Date:
Reallocator Signature & Date:
Printed Name (Reallocator)
Approver Signature & Date:
Printed Name (Approver)
Transaction
Date
Vendor
Description/Business Purpose
Received
Reallocated
Total
Purchase Amount
Reconciled
1
$
2
$
3
$
4
$
5
$
6
$
7
$
8
$
9
$
10
$
11
$
12
$
13
$
14
$
15
$
16
$
17
$
18
$
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$
20
$
Reconciliation and approval must be completed and signed by the 15th of the month following receipt of statement.
Ending Balance:
$
Completed reconciliation's and supporting documentation shall be retained in the cardholder's department for at least three (3) years.
Reconciliation and supporting documentation must be made available on demand to the departments of Internal Audit, Purchasing, or
Controller's Office for review if deemed necessary by these departments.
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Cardholder
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Monitor ProCard website on a monthly basis for changes to policies and procedures.
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Keep the card(s) secure at all times – treat the ProCard(s) like your personal credit card.
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Complete and sign the Transaction Summary Log (TSL) by the 15th of the following month.
– List information about each purchase (i.e. vendor, amount, and business description).
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Verify all transactions on the PNC monthly statement.
– This is to ensure all transactions are accurate and match the TSL and receipts provided.
– Disputed Charges must be reported to the ProCard Office and PNC immediately.
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Complete the ProCard Receipt Form when no receipt if available.
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Do not photocopy the front and back of the ProCard.
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Cardholder (cont.)
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Do not write the full 16 digit card number or other card security information on any form for
ordering purposes or otherwise.
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Complete the Sign In/Out Log if the card is given to someone else for use. (see checkout card
process)
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Report lost or stolen cards immediately to PNC and then notify the ProCard Department, and DPS
when applicable.
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Verify receipt of goods or services and contacting the vendor to resolve delivery problems,
discrepancies and damage claim.
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Work with the vendor and/or PNC Bank to handle returns, replacements, and disputed
transactions.
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If an item you are attempting to purchase is questionable, review the restricted items and
suggested use list on the website before making the purchase.
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Remember, the Cardholder is
ultimately responsible for all
transactions on the ProCard
account and has the right to
deny access to his/her card at
any time.
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Approver
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Verify that purchases are appropriate for the funding source and are for the benefit of the
university.
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The approver must not be a subordinate in the direct reporting line of the cardholder. Also, the
cardholder cannot be an approver on his/her own card.
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Review all monthly ProCard documentation consisting of the PNC bank statement, TSL, and
original receipts. This review must be completed by the 15th of the month following the billing
cycle and should be clearly documented on the TSL with the approver's signature and the date of
the review.
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Review the ProCard website on a regular basis for changes to policies and procedures.
If an approver chooses to perform the optional online approval of transactions, this process should be completed by
the monthly close-out date. When the approver is also acting as the reconciler, he/she must adhere to the reconciler
responsibilities in addition to the approver responsibilities.
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Reconciler (Reallocator)
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Ensure all charges are allocated to the appropriate speedtype and/or account code in PeopleSoft
by the monthly cut-off date (cut-off dates are listed on the ProCard website). Any charges not
reallocated through PeopleSoft by the cut-off date should be corrected using an IUT.
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Perform a manual reconciliation each month, comparing the TSL, PNC statement, and
receipts. Upon completion of this review, sign and date the TSL. This task must be completed by
the 15th of the month following the end of the billing cycle.
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Review the ProCard website on a regular basis for changes to policies and procedures.
When the reconciler is also acting as the approver, he/she must adhere to the approver’s responsibilities in addition
to the reconciler’s responsibilities.
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CARD CHECK-OUT PROCESS
1. Complete the Employee Usage Agreement (first time only).
2. Complete the Pre-Approval Form.
3. Present Pre-Approval Form to the Cardholder.
4. Sign the Sign-In/Out log showing you are taking the card.
5. Make purchase(s) and obtain itemized receipt(s).
6. Return card and receipt(s), including list of attendees if it was a
business meal, to the Cardholder.
7. Sign the Sign-In/Out log showing you have returned the card.
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PROCARD SUGGESTED USES
AND RESTRICTIONS
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Suggested Uses
•Appliances
•Cell Phones
•Equipment
•Membership Dues
•Art & drafting supplies
•Component items that will comprise
a piece of equipment when
assembled
•Flowers
•Office supplies from
OfficeMax (online orders
only)
•Athletic supplies
•Conferences/Meetings room rental
•Industrial gases
•Postage stamps
•Blueprints
•Copy IT Centers at MITC, Ekstrom,
HSC & School of Business
•Instructional materials and
supplies
•Registration fees
•Bookstore
•Dental Lab Prosthetics
•Lab supplies and chemicals
•Software
•Car rental & gasoline (one-day trips only)
•Employee Appreciation/Recognition;
gifts for employees
•Lunch/Dinner/Event
meetings (business-related
only)
•Travel expenses for nonemployees
•Catering
•Equipment Repair and Rental
•Medical Supplies
•Van rentals
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Restrictions
•Airfare
•Furniture with upholstery or fabric
furnishings, unless it meets fire code
•Parking Permits or fees
•Services subject to Personal
Services Contracts
•Alcoholic Beverages are restricted unless
authorized and documented as a legitimate
entertainment expense as defined in
the ProCard Policy
•Gasoline, unless purchased in
conjunction with a one-day car rental
or group van rental.
•Payments to Individuals
(1099)
•Shipment of hazardous
materials
•Cardinal Card Deposits - Cardinal Cash or
Meal Plans
•Gift Cards
•Personal Use
•Smart Parc cards for
employees/students/staff
•Contributions/Donations
•Holiday Decorations
•Phone Cards
•Student Payments
•Controlled Substances/Narcotics
•Insurance
•Printing
•Temporary Help
•Debit cards (i.e., VISA cash cards)
•Legal Services
•Products available through
University Stockroom
•Faculty, Staff and Student Travel
•Movement of Household Goods
•Purchases requiring a
contract
•Firearms/Ammunition
•Office supplies, except from
OfficeMax, the university's
contracted vendor.
•Radioactive Material
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Business Meals/Alcohol Purchases
• Business meal documentation must contain the following
(some of these items will be provided on the itemized receipt):
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name of establishment, city and state;
name and title of attendees;
exact amount and date of expense;
specific business topic discussed; and
specific time of business discussion (before, during or after the event).
• If alcohol is purchased, the cardholder must obtain prior written
approval from the department head (or next highest supervisor if
department head is in attendance).
– Alcohol must also be an allowable expense on the selected funding source.
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Travel Policy
• The ProCard cannot be used for faculty,
staff, or employee travel.
• The ProCard can be used for nonemployee travel for authorized university
purposes, such as recruitment.
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Questions about appropriate use?
If you are in doubt as to whether a purchase
is permitted on the ProCard, contact the
ProCard Office first for confirmation.
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POLICY VIOLATIONS & CARD
MISUSE
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ProCard Misuse & Consequences
A ProCard may be suspended/revoked for the following reasons:
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Failure to adhere to ProCard policies and procedures.
Failure to safeguard the ProCard from unauthorized use.
Use of ProCard for non-University or personal purchases.
Failure to keep all necessary documentation on ProCard transactions.
Possible actions against the cardholder and those performing roles
associated with the card include:
• Surrender ProCard, privileges revoked.
• Disciplinary action, up to and including criminal prosecution and
termination of employment.
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Procurement Card Violations
• Any policy violations or suspected fraud should be
reported immediately to the Assistant Director for Card
Services, Robin Stewart (852-8255).
• Depending on the severity of the violation(s), Audit
Services may be notified, in accordance with the Fiscal
Misconduct Policy. The ProCard Office will contact Public
Safety and Human Resources, in addition to Audit
Services, if deemed necessary.
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DEPARTMENTAL CONTROLS
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Effective Departmental Controls
• UBMs should randomly select a card for a spot audit within their
department each month.
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Ensure the completion of the monthly TSL.
Verify signatures by cardholders, reconcilers, and approvers.
Check all receipts and verify the business purpose of each transaction.
Match the receipts to the PNC statement and the statement to University Reports.
• An Audit Checklist was created to facilitate the departmental review
process.
• When using a shared departmental card, complete a pre-approval
form prior to release of the card.
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PROCARD AUDIT CHECKLIST
Guidelines for conducting internal reviews of ProCards
Date: __________________________________ Card # (last 6 digits): ____________________________ Audit Period: ____________________________
Cardholder: ___________________________________ Reallocator: __________________________________ Approver:_____________________________
TRANSACTION SUMMARY LOG (TSL) & BANK STATEMENT:
□ Verify TSL is present for each billing cycle and includes a detailed description and dollar amount for each item purchased.
□ Verify TSL is signed and dated by the cardholder, reallocator, and approver (as designated in PeopleSoft) by the 15 th of the month
following the end of the billing cycle.
□ Verify bank statement is present for each month reviewed (including no activity months).
REALLOCATION:
□ Ensure speedtype/account code reallocations were performed in PeopleSoft by the monthly cut-off date. Transactions that were not
reallocated by this date should be moved to the appropriate speedtype/account code with an IUT.
RECEIPTS/INVOICES:
□ Verify an original itemized receipt or invoice is present for all purchases.
□ Ensure all business entertainment expenses include a list of attendees and business purpose (who, what, where, when, and why).
□ If an original itemized receipt or invoice is missing and all measures to obtain a copy have been exhausted, ensure the ProCard
Receipt Form was completed and signed by the cardholder’s supervisor.
□ Confirm Kentucky sales tax has not been applied to purchases. If sales tax was charged and not refunded, there must be
documentation of the steps taken to credit the sales tax.
POLICY:
□ Verify all transactions are for business purposes only. Questionable items should be investigated using the Restrictions &
Suggested Uses lists. (The ProCard cannot be used for employee or student travel.)
□ Ensure the Asset Inventory Form was completed for items valued at $1000.00 or greater.
□ Infrequent, tangible gifts for employees must not exceed $99.99 each and cannot be used as payment for services rendered. Gift
cards cannot be purchased using a ProCard. (See De Minimis Gift Policy for a further explanation.)
□ Verify office supplies have been purchased either from the University Stockroom or our contract vendor (currently STAPLES;
must be on-line purchases). If items were purchased at the Staples store or through another vendor, a letter of approval from
Purchasing must accompany the receipt.
□ Look for split transactions: two or more purchases from same vendor on the same date used to circumvent the spending limit
approved for the card.
□ Verify the Disputed Items Form was completed for transactions deemed unauthorized/suspicious/unknown by the cardholder.
□ Verify that the approver for the card is not in the direct reporting line of the cardholder.
□ Confirm all policies have been followed. Document any policy exceptions to the ProCard Office. Include exception documentation
with the transaction summary log.
CARD SECURITY:
□ Verify the card is stored in a secure location, either locked in an office or on the person.
□ Ensure the Sign-In/Out Log is completed if the card is checked out to other employees.
□ If someone other than the cardholder uses the card, ensure an Employee Usage Agreement was completed and is on file in the
ProCard Office.
Any fraudulent/personal charges or policy violations found during this review should be reported immediately to the
ProCard Auditor, Tanisha Hackett, at 852-8214.
Reviewer’s Name: _________________________________________________________ Date: _____________________________________
Reviewer’s Signature______________________________________________________
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COMPLIANCE REVIEWS
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Compliance Review Procedures
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ProCard activity is analyzed and monitored by the ProCard Office.
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The following types of compliance reviews are performed to review ProCard accounts:
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Departmental
Individual cardholder or card
Monthly spot-check review of transactions (IR spreadsheet)
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Notification of compliance review.
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Compliance reviews will be conducted in the cardholder’s office, assuming there is
adequate space.
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The results of the compliance review are detailed in a report sent to the cardholder (or
UBM when conducting a departmental audit), with a copy to the department head,
Independent Reviewer, and VP/Dean.
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Common Violations
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List of attendees is not included for business meals.
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Food receipts are not itemized.
– Sodexo locations on-campus will give itemized receipts if asked.
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A clear business purpose is not stated on the TSL.
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The TSL is not signed and/or dated by the cardholder, approver, and
reconciler by 15th of the month.
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Receipts are missing.
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ProCard Staff
•Robin Stewart, Assistant Director
852-8255 robin.stewart@louisville.edu
•Tanisha Hackett, Compliance Analyst
852-8214 trhack02@louisville.edu
•Jennifer Knight, Compliance Analyst
852-5280 jlknig02@louisville.edu
•Alma Brandon, Administrative Assistant
852-4433 ambran02@louisville.edu
•Charlotte Numann, Administrative Assistant
852-8218 cdnuma01@louisville.edu
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Questions?
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Don’t forget to visit the ProCard Website!
http://louisville.edu/procard
http://louisville.edu/procard
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