PART 26

PURCHASE CARDS

# Table of Contents

26.1 PURCHASE CARD (P-CARD) PROGRAM [1](#purchase-card-p-card-program)

26.2 DEFINITIONS [1](#definitions)

26.3 POLICY [2](#policy)

26.4 RESPONSIBILITIES [3](#responsibilities)

26.4.1 Head of the Contracting Activity (HCA)
[3](#head-of-the-contracting-activity-hca)

26.4.2 Supply Chain Services: [4](#supply-chain-services)

26.4.3 Agency/Organizational Program Coordinator (A/OPC) or P-Card
Program Manager
[4](#agencyorganizational-program-coordinator-aopc-or-p-card-program-manager)

26.4.4 Approving Official (AO) [5](#approving-official-ao)

26.4.5 Card Holder (CH) [5](#card-holder-ch)

26.4.6 Supervisors [6](#supervisors)

26.4.7 Finance Office [7](#finance-office)

### 26.1 PURCHASE CARD (P-CARD) PROGRAM

***INFORMATION:***

\(a\) This part prescribes policies and responsibilities of parties for
BPA's Purchase Card (P-Card) Program. The purchase card is a
purchasing/payment tool established to streamline the purchasing process
for standard, off-the-shelf, commercially available items and services.
The program consists of the Agency/Organizational Program Coordinator
(A/OPC), Card Holders (CH), Approving Officials (AO), Convenience Check
writers, administrative or support staff, and supervisors of CHs and
AOs.

\(b\) BPA maintains a contractual relationship with a financial
institution for issuing the purchase cards and servicing these accounts.

\(c\) The authority to use a BPA Purchase Card is delegated from the HCA
to the Card Holder through the application, training, and purchase card
issuance process. A Certificate of Appointment as described in Part 2 of
this Instruction is not required.

### 26.2 DEFINITIONS

"Agency/Organizational Program Coordinator (A/OPC), also known as and
hereafter referred to as the P-Card Program Manager, is the person
responsible for managing the P-Card Program for an organization.

"Approving Official (AO)" is the person who has primary responsibility
for ensuring the Card Holder has used the P-Card in accordance with this
policy and procedures in the P-Card Manual. The AO certifies the CH's
monthly statement and approves the accounting via the agency's financial
system.

"Card Holder (CH)" is a person with authority delegated by the HCA (via
the P-Card Program Manager) to make off-the-shelf purchases of supplies
and services with a Purchase Card (P-Card).

"Convenience Check" is a check (also known as a third-party draft)
written by a Card Holder. It is used in lieu of the purchase card to
complete a transaction with a payee/vendor who cannot or will not accept
or process a P-Card transaction. Convenience checks are used
infrequently at BPA, and only by named personnel approved by the Chief
Certifying Officer in Finance.

"Final Pay Clearance" is the form and process used to ensure that the
employee has returned BPA property prior to their leaving. For the
P-Card Program, this means cancellation of the P-Card and receipt of all
certified statements.

"Non-Emergency Field Purchases" are purchases needed to complete
assigned field projects that would be delayed if the purchase is not
executed immediately.

"P-Card Manual" is the manual issued by Supply Chain Services that
contains operational guidance for all agency personnel who have a role
in P-Card transactions. This manual is prepared by the P-Card Program
Manager.

"P-Card Program Manager" is the same as the A/OPC.

"Personal-Use Items" are items that are solely of benefit to individual
BPA employees. A specific listing of prohibited purchases and vendors
may be found in the P-Card Manual.

"Purchase Card", also known as P-Card, is the credit card issued by a
financial institution to named BPA employees, used to execute certain
BPA purchases as described in 26.3.

### 26.3 POLICY

\(a\) Only standard, off-the-shelf materials and services that are
needed to complete jobs or projects necessary to fulfill BPA's mission
and are within the delegated P-Card authority and official business
shall be made.

\(b\) Property that is tracked and tagged in accordance with the BPA
Asset Management Instructions (<http://webip1/ebr/contracts/>), items or
material that requires testing or inspection, or those items requiring
blueprints may not be purchased by P-Card.

\(c\) Purchase-Card authority shall be used only by the employee whose
name appears on the card and shall not be re-delegated.

\(d\) Deliberate use of the P-Card for other than authorized purchases
shall result in the revocation of the P-Card and removal of the CH from
participation in the P-Card Program. These activities may be viewed as
committing fraud against the Government and the individual may be
subject to disciplinary action and/or criminal penalty under 18
U.S.C.§287.

\(e\) Personal-use items shall not be purchased with Government funds
except as defined in this instruction (see BPI 6.9), the BPA Manual,
Safety and Health Program Handbook, specific Personnel Letters, etc. See
the P-Card Manual for a complete listing. The Card Holder, and AO if the
purchase action has been certified, may be held personally and
financially responsible for personal-use items purchased outside of this
policy.

\(f\) Card Holders who fail to properly execute their assigned
responsibilities may be held personally liable to BPA for the amount of
any unauthorized purchases, and may be subject to disciplinary action
and/or criminal penalty under 18 U.S.C.§287.

\(g\) Each Card Holder shall have a fully trained and qualified
Approving Official who is not subject to control or supervision in any
way (including as a Team Lead) by the CH.

\(h\) An Approving Official shall not certify a purchase if it cannot be
identified as a legitimate purchase for BPA purposes. When an AO has
certified a Card Holder's transaction, the AO becomes responsible for
those purchases.

\(i\) Approving Officials who fail to properly execute their assigned
responsibilities may be held personally liable to BPA for the amount of
any unauthorized purchases that have been certified, and may be subject
to disciplinary action and/or the criminal penalty under 18 U.S.C.§287.

\(j\) All Card Holders and Approving Officials shall attend the required
first time and refresher training and follow all policies and procedures
in this Instruction and the P-Card Manual.

\(k\) Purchase Card training for all new Card Holders and Approving
Officials, as scheduled by the P-Card Program Manager, shall contain the
following:

1.  CH- and AO-delegated purchasing authority;

2.  CH, AO, and Card Holder's Supervisor responsibilities;

3.  What is considered acceptable documentation for purchases;

4.  How to asses potential risks to BPA associated with the P-Card
    (examples: suspicious e-mails that request detailed personal or
    purchase-card account information, using the wrong card for a
    transaction, add-on charges not agreed to by the purchaser, exempted
    taxes);

5.  Authorized dollar limits for CHs and Merchant Category Code (MCC)
    restrictions;

6.  Prohibited and coordinated purchases;

7.  Prohibition of personal-use items;

8.  Property policy;

9.  Formal "Acknowledgement of Responsibilities";

10. Practice review and reconciliation of a P-Card statement.

\(l\) All Card Holders and Approving Officials shall also attend
refresher training at least every two years as scheduled by the P-Card
Program Manager. Refresher training may cover the topics mentioned in
(k) above and may also include discussion of results of compliance
reviews or audits, real and practice problem scenarios, etc.

### 26.4 RESPONSIBILITIES

#### 26.4.1 Head of the Contracting Activity (HCA) 

The Head of the Contracting Activity (HCA) shall:

\(a\) Delegate authority to the P-Card Program Manager to establish Card
Holder and Approving Official accounts and make appropriate decisions to
effectively manage the P-Card Program;

\(b\) Develop, publish, and maintain BPA Purchase Card Policy as part of
the Bonneville Purchasing Instructions;

\(c\) Review the P-Card Manual to ensure the procedures are consistent
with the policies in this Instruction;

\(d\) Conduct appropriate P-Card Program reviews to ensure effective
management and compliance with current policy and procedures; and

\(e\) Consult with the P-Card Program Manager before implementing new
procurement or property policies that could impact the P-Card Program;
and

\(f\) Review and approve or deny any requests for single purchase limit
one-time increase above \$10,000 and monthly purchase limit requests
above \$50,000, as requested by a Card Holder through the P-Card Program
Manager.

#### 26.4.2 Supply Chain Services:

The Supply Chain Services organization shall designate the P-Card
Program Manager, whose duties and responsibilities shall include
management of the P-Card Program.

#### 26.4.3 Agency/Organizational Program Coordinator (A/OPC) or P-Card Program Manager

The Agency/Organizational Program Coordinator (A/OPC), also known as the
P-Card Program Manager, shall:

\(a\) Develop and publish procedures in the P-Card Manual, and implement
the P-Card Program in accordance with the following policies and
procedures:

(1) Bonneville Purchasing Instructions (BPI);

(2) Asset Management Instructions (AMI);

(3) The award instrument with the financial institution (BPI 26.1(b));

(4) OMB Circular A-123, Appendix B; and

(5) Other relevant internal policies issued by the Finance, Human
    Capital and Safety Offices;

\(b\) Educate Card Holders and Approving Officials in lost card
procedures;

\(c\) Conduct P-Card training for all new Card Holders and Approving
Officials and refresher training every two years for all CHs and AOs in
accordance with this policy;

\(d\) Determine suitability of Card Holders and Approving Officials;

\(e\) Provide advice and guidance to Supervisors, Card Holders,
Approving Officials, data entry persons, and vendors;

\(f\) Review P-Card statements to ensure policies and operational
procedures are being followed, using data mining tools in addition to
hard copy review;

\(g\) Take appropriate action when policies have not been followed,
including immediate cancellation of the card and reporting possible
fraud to the HCA, Financial Management and Internal Audit;

\(h\) Communicate all issues, including resolutions, audit results, and
new policies to affected Card Holders, Approving Officials, and
Supervisors;

\(i\) Report Card Holder problems that have not been reconciled to CH's
Supervisor and CH's Approving Official;

\(j\) Maintain Card Holder profiles and Official Files on site for all
certified P-Card Statements for six and one quarter years;

\(k\) Generate all required or requested DOE, BPA Finance, HCA, Supply
Chain, Supervisor and Approving Official reports;

\(l\) Review and approve all Card Holder requests for one-time single
purchase limit increase up to \$10,000, and forward higher requests to
the HCA. Review and approve all Card Holder requests for monthly
purchase limit increases up to \$50,000, and forward higher requests to
the HCA. Oversee execution of all increased authorities for one-time and
monthly limit increases and rescission of same when the transaction(s)
are completed;

\(m\) Report to the HCA violations of Card Holder or Approving Official
authorities and responsibilities, when the P-Card Program Manager has
directed the CH or AO to make a refund payment to BPA or take other
action to resolve an erroneous or improper purchase;

\(n\) Initiate and ensure completion of the Card Holder and Approving
Official "Acknowledgement of Responsibilities" form, maintaining copies
for the duration of the CH's or AO's term of service; and

\(o\) Attend all training required to achieve Level II Certification, as
defined in BPI Appendix 2-A, Appointment as a BPA Contracting Officer.
The P-Card Program Manager shall also complete a minimum of 40 hours of
relevant purchasing or purchase card training per year.

#### 26.4.4 Approving Official (AO)

All Approving Officials shall:

\(a\) Follow all policies and procedures in the "Acknowledgement of
Responsibilities," P-Card Manual, Bonneville Purchasing Instructions,
BPA Manual, and Asset Management Instructions and ensure their Card
Holders do the same;

\(b\) Sign and date the AO "Acknowledgement of Responsibilities"
received during training, and submit to the P-Card Program Manager;

\(c\) Review statements to ensure all purchases are official and
necessary, incidental to the proper execution of BPA's programs and
mission, and to check for signs of re-delegation;

\(d\) Attend initial P-Card Training before becoming an AO and required
refresher training;

\(e\) Understand their responsibility to not certify purchases that
cannot be identified or determined to be proper; and

\(f\) Assist the Supervisor in determining appropriate purchase limits
for Card Holders.

#### 26.4.5 Card Holder (CH)

All Card Holders shall:

\(a\) Ensure that purchases are official and necessary to the proper
execution of BPA's programs and mission, and that all policies in the CH
"Acknowledgement of Responsibilities," P--Card Manual, and relevant
portions of the Bonneville Purchasing Instructions, BPA Manual, Asset
Management Instructions; and other relevant policies such as Personnel
Letters, Safety and Health Handbook, etc., are followed;

\(b\) Sign and date the CH "Acknowledgement of Responsibilities"
received during training, and submit to the P-Card Program Manager;

\(c\) Dispute original charges if an agreed-upon credit does not appear
on the next statement;

\(d\) Immediately notify the financial institution and P-Card Program
Manager if fraudulent charges appear on their statements;

\(e\) Promptly reconcile monthly statements, dispute unrecognized or
inaccurate purchases or other incorrect charges, enter accounting
information into the current purchasing data system, and forward to the
Approving Official in accordance with procedure;

\(f\) Have reasonable assurance that funds are available prior to making
purchases;

\(g\) Never purchase anything that solely benefits an individual
employee such as personal clothing or footwear, eye glasses, sleeping
rooms, medical services, entertainment, food (except as authorized by
the agency recognition program), alcohol, tobacco products, etc.;

\(h\) Obtain the "best buy" for BPA, asking for Government or Best
Customer discounts. When determining which vendor to choose, a CH must
consider the total cost of merchandise such as quality, timeliness
versus urgency of delivery, quantity, ease of service, warrantees,
support and maintenance, standardization, shipping costs, CH's time,
etc.;

\(i\) Attend initial P-Card Training prior to receipt of a P-Card, and
prescribed refresher training at least every two years, regardless of
when initial training is received;

\(j\) Inform merchants that they cannot charge the P-Card number until
the order is complete and the merchandise has been shipped; and

\(k\) Never split purchases or allow vendors to split orders to fit
within the cardholder's single purchase limit.

#### 26.4.6 Supervisors

Supervisors of Approving Officials and P-Card Holders shall:

\(a\) Request CHs and AOs via the P-Card application memo in the P-Card
Manual;

\(b\) Consult with AO to ensure purchase limits requested are
appropriate for the employee's occupation or organizational business
needs;

\(c\) Ensure the requested AO is within the same major organization, is
not under the control or supervision of the CH, and is in a position to
question purchases as necessary;

\(d\) Review P-Card policies and procedures, especially as they relate
to prohibited personal-use items and communicate the expectations that
both CHs and AOs will follow them;

\(e\) Support the AO in carrying out the certification function; and

\(f\) In coordination with the P-Card Program Manager, take the
following action for improper purchases as necessary:

1)  Request immediate cancellation of CH account (if not already
    canceled);

2)  Designate new AO if appropriate;

3)  Require CH to return merchandise for credit as appropriate;

4)  Require CH to pay for improper purchases personally;

5)  Other appropriate disciplinary action of the CH and/or AO as
    appropriate.

#### 26.4.7 Finance Office

The Finance Office shall:

\(a\) Review and reconcile the monthly invoice from the financial
institution with the total amount of purchase transactions;

\(b\) Report to the P-Card Program Manager any anomalies or problems
discovered during review and reconciliation;

\(c\) Ensure payments to the financial institution are made in
accordance with applicable policy and the award instrument;

\(d\) Ensure that all rebates offered by the financial institution are
calculated correctly;

\(e\) Approve or disapprove applications for convenience checks and
review quarterly convenience check report; and

\(f\) Determine appropriateness to purchase personal-use items (in
coordination with subject matter experts) and maintain a listing of
approved personal-use items.