Approved by:	The President
History:	Issued	-- March 14, 2002
	Revised	-- March 11, 2020
	Last Reviewed              -- March 11, 2020
Related Policies:	Prohibited Transactions Policy; Grant and Contracts Policy; Procurement Policy; Contract Approval and Signature Authority Policy; Employee Cell Phones for Business Use Policy; Gifts and Donations to External Parties Policy; Gift Card Policy; Conflict of Interest Policy; Corporate Travel Card Policy
Additional References:	Enterprise Spend Platform; Procard Forms and Reference Materials; Procurement Card Application Process Website
Responsible Official:	Senior Director, Strategic Sourcing and Procurement tel. (202) 319-5046

I.  Introduction

 

The University offers a card program is a tool to streamline and simplify the procurement and payment functions for general procurement and business-related travel and entertainment. The card is intended to reduce transaction costs, facilitates timely acquisition, automate data flow for accounting purposes, and offer flexible controls to ensure proper use. 

The Catholic University of America procurement card (also known as the p-card) is issued to individuals through the University, and secured by the Card Issuer in the name of the University and the employee. Using the procurement card is the preferred method to purchase low value, non-capital expense items. Items previously acquired by petty cash, direct pay, or check requests should be targeted for the procurement card. 

The cardholder should purchase from University-approved contract vendors, and whenever possible cardholders should take advantage of the pricing agreements and terms negotiated on the University consortium contracts with the Education & Institutional Cooperative Service (E&I), US Communities, General Services Administration (GSA) and other group purchasing organization.

II. Definitions

1. Authorized Approver- A person designated by a financial manager to review and approve procurement card transactions.
2. Cardholder -The person named on the card and authorized to make purchases using the card.
3. Card Issuer -The banking entity that provides the card. 
4. EnterpriseSpend Platform (ESP) -The software and webpage provided by the Card Issuer used to review, code (allocate transactions to a chartfield) and approve transactions by cardholders and the authorized approver. The software is also used by the plan administrator to oversee and administer the procurement card program, including issuing cards, replacing lost or stolen cards, as well as other administrative functions.
5. Bank Statement -Monthly statement from the Card Issuer identifying card transactions for the month. This statement includes all account activity for any defined cycle period and is available online in ESP.
6. Default Accounting Chartfield -The department and account where all purchases will be charged, unless re-classed by the cardholder or the authorized approver in ESP. Note that the default accounting chartfield will be a non-grant/award funded department for principal investigators, and all charges must be reclassified for proper cost allocation.
7. Financial Manager- The Provost, a Vice President, Dean, Director, Department Head or Business Manager with budget authority.
8. Merchant Category Code (MCC) -The code assigned to each merchant to identify the industry description and type of product or service offering provided.
9. Plan Administrator -The individual at the University responsible for issuing the procurement card and administering other facets of the University's procurement card program. The Director of Procurement Services is be the University's plan administrator.
10. Procurement Card (P-card) - The credit card issued by the University to eligible faculty and staff.
11. Small Dollar Purchases -Purchases which in aggregate cost $2,500 or less per transaction.

III.  Eligibility

 

The P-card is available to active, full-time employees of the University who have completed required training.  Eligible employees may apply for a P-card with the written approval of the Provost or the cognizant Vice President.  Application procedures are available on the Procurement Card Application Process Website: 

 IV. Allowable and Prohibited Transactions

 

The Financial Manager, Cardholder Approver, or Cardholder supervisor may establish additional controls on card use for individuals within their divisions/departments.  Such restrictions should be monitored by the Authorized Approver or Financial Manager

Examples of allowable purchases include:

Office products and supplies
Books and subscriptions
Approved dues/membership organizations
Conference registrations
Events catering
Printing/duplicating/copy services
Travel and business entertainment (see also the Corporate Travel Card Policy)

The P-card is not used for any of the following types of purchases unless authorized by the Plan Administrator or other administrator as identified below.  All instances of pre-approvel should be uploaded with the associate receipt in ESP.

Examples of prohibited types of purchases, and/or those requiring pre-approval prior to purchase, include:

Animals (except for approved laboratory research use)
Appliances
Cell phones (see the University's Employee Cell Phones for Business Use Policy)
Telephone equipment unless pre-approved by Technology Services and the Controller and Assistant Treasurer
Food for non-University purposes
Computers (desktop, laptop, notebook/netbook, or iPad/tablet) unless pre-approved by Technology Services and the Controller and Assistant Treasurer
Cash (includes adding funds to the Cardinal Card)
Gifts or items of sentiment (parties, flowers, decorations etc.) construed as personal unless approved by a department or unit head (see also the Gifts and Donations to External Parties Policy)
Gift cards (see the University's Gift Card Policy)
Donations (see the Gifts and Donations to External Parties Policy)
Purchases which involve signing an agreement, license or contract (see the Contract Approval and Signature Authority Policy)
Purchases delivered to a non-University building address
Radioactive materials (unless pre-approved by the Radiation Safety Officer)
Prescription drugs
Payments to individuals, consultants and employees for services rendered or reimbursement of expenses incurred
Capitalized expenses for construction projects (unless pre-approved by the General Accounting Office)
Capital equipment
Faculty, staff, and student tuition and related payments
Weapons, ammunition, and explosives
Employee relocation expenses
Personal use/purchases
Purchases over $2,500 unless the Cardholder's individual transaction threshold has been increased via approval of the Card Approver and the Plan Administrator
Splitting transactions to avoid the individual transaction limit threshold
Any items listed in the Prohibited Transactions Policy

As previously noted, personal purchases are prohibited on the P-card even if the requester's intent is to reimburse the University.

The Financial Manager or Plan Administrator may identify additional spending limits. Spending limits will be identified on the cardholder application. Increases to the transaction limit amount require approval by the Plan Administrator.

V. Cardholder Responsibilities and University Rights

 

University P-cards are issued based on the primary role of the respective University faculty or staff member (Cardholder). The Procurement Card is not a benefit of employment; it is a tool to be utilized in assisting University employees to carry out their functions. It is assumed that Cardholders, along with their division Vice President, are responsible and accountable for using the Pro-card within the University's guidelines. The University reserves the right to terminate an individual's card privileges at any time, with or without cause. The University retains the rights to any incentives or rewards resulting from the use of the Pr0-card. Bonuses, incentives, or rewards earned through the individual's use of a card may be considered taxable income by the IRS and the fair market value of such a distribution must then be reported as taxable income on the employee's annual tax return. For this reason, the University recommends that Cardholders not participate in any promotional offers.

A. Inadvertent Personal Charges

 

University policy requires inadvertent personal charges made to the card to be settled by the Cardholder within five (5) business days of the return travel date. Payments can be made to the University via the Deposit dropbox within the Controller and Assistant Treasurer’s office and should include the account and organization number where the funds are being deposited, with a brief description of the transaction.

B. University Liability

 

Charges to the P-card are attributable to the University and have no impact on an employee's personal credit. The P-card is only issued to active eligible University employees, and although the card is issued to a specific University executive officer, faculty or staff member, the P-Card is the property of The Catholic University of America. The University is not liable for transactions made by a terminated employee. In the event of employee termination, the Plan Administrator is notified immediately and the P-card account must be checked for any pending transactions. If pending transactions exist, they must be coded (with their attached receipts), and approved by the responsible manager prior to card cancellation. In addition, the University is not liable for fraudulent charges if the card issuer and the University are not notified in a timely manner.

C. Responsibilities

 

1. Cardholder Responsibility

 

Every Cardholder is required to have a valid University email address and to check that email account regularly, because ESP transaction notifications will only be sent to that account. The Cardholder is responsible for reclassifying charges from the default accounting chartfield to the correct chartfield, and to ensure that all receipts are scanned and attached to their transactions in ESP. Cardholders are also responsible for being familiar with the University's procurement and finance policies.  The Cardholder is responsible for documenting the business purpose of each transaction within ESP in accordance with Documentation Requirements identified below.  It is the Cardholder's responsibility to know their available funds and spend within their budgeted limits. P-card purchases that exceed budget will result in suspension of card privileges. During the suspension period, P-card purchases for that employee's work center will be made by the Cardholder's next higher organizational authority. Two suspensions in one fiscal year will result in permanent removal of P-card privileges. Please remember that an individual is committing University funds each time the P-card is used.

While the Cardholder is authorized to make purchases on behalf of the University, good stewardship of University funds still requires due diligence. Consequently, it is University policy to seek the lowest prices within the parameters of quality, delivery and the efficient use of the Cardholder's time. Accordingly, the Cardholder must check as many sources of supply as reasonable to assure best value.

The Cardholder must protect the security of the P-card at all times. If the P-card is lost, stolen, or becomes compromised, the Cardholder must immediately notify the card issuer, the University's Department of Public Safety, the Plan Administrator, and the appropriate Authorized Approver.

 2. Cardholder Supervisor Responsibility

 

The Cardholder's supervisor will identify the Authorized Approver for each Cardholder. The Cardholder's supervisor, whether or not he or she is the Authorized Approver, is ultimately responsible for each Cardholder's use and reporting requirements. The Cardholder's supervisor is also responsible for notifying the Plan Administrator if the Cardholder leaves University employment, is terminated, or transfers to another department or assignment within the University.

3. Authorized Approver Responsibility

 

The Authorized Approver is responsible for reviewing and electronically authorizing or rejecting each charge made by the Cardholder in ESP within the required timeframe. The Authorized Approver should be familiar with this Procurement Card Policy and the procedures herein, have a valid University email address, and check that email account regularly because ESP transaction notifications only will be sent to that account.

A Cardholder may not approve their own card charges. In addition, an employee cannot approve the card charges of an individual to whom he or she reports to either directly or indirectly.

4. Documentation Requirements

 

Original receipts must be scanned and attached in the ESP system. The original or true copy receipts must be retained by the department per the Record Retention Policy.  Each transaction should include a valid business purpose.  The "Business Purpose" must provide a specific justification for the purchase. The justification must include at minimum:

• Who attended or received the benefit from the expenditure;
• What purpose the expenditure served, why the expense was necessary, or how it furthered the University's goals; and
• When and where the expense took place.

D. Sales Tax on Purchases

 

The Catholic University of America is exempt from sales tax in the District of Columbia, Maryland, and Virginia in addition to other states.  Call Procurement and Payment Services for further information. It is the Cardholder's responsibility to ensure that sales tax is not charged to the University. The tax-exempt numbers for each jurisdiction are located on the front of the P-card.

If sales tax is inadvertently charged to a P-card, the Cardholder is required to dispute the charge, contact the merchant and have the tax removed. If the merchant is uncooperative, a dispute can be initiated in the ESP system before the end of the monthly cycle.

E. Purchases with Terms and Conditions

 

Procurement cardholders are responsible for reading and understanding any terms or conditions that accompany a procurement card purchase. Questions regarding any terms or conditions should be directed to Card Administrator before proceeding with the purchase.

VI. Procurement Card Cycle Deadlines

 

After making a charge, the Cardholder has ten (10) days from the posting date, but not later than the end of the month in which the statement closes, to make any transaction chartfield changes (such as account, fund, org, program, sub-class). The Authorized Approver is able to view and approve the transaction at the same time as the Cardholder; however, any changes to the chartfield by the Cardholder will require re-approval. Therefore, the Cardholder should communicate with the Authorized Approver and establish a regular approval timeline.

If the Cardholder does not want to change the transaction, the Cardholder should go into ESP and "save" the transaction, indicating that it is ready for approval by the manager. The best practice is to submit transactions for approval on a weekly basis.

Any transactions not viewed after ten (10) days but not later than the end of the month in which the statement closes, will be automatically uploaded into Cardinal Financials under the default chartfield. Changes can be made to the transactions in the ESP system only until the time that the transactions are uploaded. If a department has a legitimate reason for requesting a change after the upload occurs General Accounting (or Grant Accounting) will process the change. However, a late reclassification request should be rare and if it occurs several times, Cardholder privileges may be revoked.  If more than three (3) late change requests are received by the same Cardholder over a twelve month period, Cardholder privileges may be suspended. Because the receipts and approvals will be electronically viewable by the Plan Administrator, the Cardholder does not need to send his or her monthly statement to the Procurement Services. However, Cardholders need to maintain their original receipts and monthly statements per the Record Retention Policy after the transaction, for audit back-up documentation purposes.

VII. Returning the Procurement Card

 

Upon separation, termination or retirement, P-cards must be surrendered to the Plan Administrator.

VIII. Code of Ethics

 

Cardholders must refrain from any actions which could be construed to conflict with the best interest of the University or to prejudice the University's reputation or mission. Cardholders are expected to be free of conflicts of interest or relationships which are, or potentially could be, detrimental to the best interests of The Catholic University of America and its mission, and must comply with the University's Conflict of Interest Policy.

IX. Consequences Resulting from Violations of Policy

 

Violations of rules governing use of the P-card can be classified as minor or major. The action taken is dependent upon the nature and severity of the violation. Consequences may include additional training, cancellation of Cardholder privileges, or disciplinary action up to and including termination of employment. The Vice President for Finance and Treasurer, in consultation with the Provost and other Vice Presidents, has the ultimate authority in determining the appropriate action based upon the violation or the frequency of the violations. The Vice President for Finance and Treasurer will involve the Office of Human Resources in all disciplinary decisions.  Violations include the following:

• Allowing someone other than Cardholder to use the P-card without authorization
• Failure to maintain receipts properly
• Not reclassifying charges in ESP to the correct chartfield on a timely basis
• Splitting transactions to avoid the single purchase item limit
• Exceeding budget once warned that the available budget is gone
• Making personal charges using the P-card
• A repeated pattern of inappropriate charges or transferring P-card purchases to sponsored programs.

The circumstances of the violations will determine the appropriate action. The intentional use of the P-card to make a personal purchase will result in termination of P-card privileges and may result in additional University disciplinary action.