Special controls on procurement cards that are necessary
to make the procedure work
There are two types of special control on procurement cards that
can make the procedure work, they are
1- Preventive conrols
- Background checks: All cardholders should undergo a background
check. Giving an employee a p-card is tantamount to providing the
cardholder access to one of the organization's most liquid assets:
cash.
- Dollar limits: An individual's p-card should have a reasonable
monetary limit based on both daily and monthly use. Some
organizations set limits at a standard level for all cardholders or
for employees with similar jobs. By tailoring the limits to each
cardholder, the total dollars at risk can be reduced. If a special
situation arises in which a dollar limit is too low and a higher
dollar amount is required, the p-card limit can be increased for
the specific transaction and then returned to the original
level.
- Merchant Classification Codes: MCC should be used to prohibit
transactions at various establishments, such as cash advances,
liquor stores, big box stores and movie theaters. This can be
somewhat of an issue, especially when the p-card is used at a big
box store where non-business-related items can be interspersed with
legitimate items.
- Probation: If an employee is placed on probation for a
performance issue, place the p-card on hold status until the person
is off probation.
- Education: Educate all p-card holders, administrators and
supervisors on their card-related roles and responsibilities on an
annual basis. This training should include a clear definition of
roles, timing, type of documentation required, approvals and
specific consequences if not performed in a timely manner. At the
conclusion of the education, all p-card holders must sign an
updated cardholder acceptance form that reiterates the appropriate
uses of a p-card.
2- Detective controls
- Reconciliation review: Perform reviews of transactions,
explanations and receipts in a timely manner. The receipts should
be reviewed with a specific focus on each receipt's date and time,
items purchased and the reasonableness of the expenses.
- Placing p-card on hold status: If the reconciliation is not
completed by the due date or there are missing receipts, place the
p-card on hold status (not allowed to make purchases) until the
reconciliation has been completed, reviewed and approved by the
appropriate supervisor. The approver should send an email
requesting the card be reactivated only after all processes are
completed. Track the number of times a person is late or has an
incomplete reconciliation (missing receipts).
- Three-strike rule: If a person repeatedly abuses the p-card
(for example, routine tardiness in reconciliation or charging
personal items), cancel the p-card and do not allow the person to
get it reinstated.
- Monthly reports: The overall p-card administrator should
generate a monthly report and forward it to the appropriate
manager. The report should include spending trends, potential split
transactions and dollars by merchant. This will provide additional
oversight regarding appropriate use.
- Strong policy: The policy should state clearly what the p-card
can and cannot be used to purchase. The policy also should identify
the disciplinary action for accidental misuse versus intentional
misuse.
- Anonymous tip line: As outlined in the ACFE's 2010 Report to
the Nations, most frauds are discovered as the result of a tip. A
tip line allows employees to report suspected p-card misuse.