Department of Health and Human Services 

OFFICE OF 

INSPECTOR GENERAL 

JANET REHNQUIST 

Inspector General 

MARCH 2003 

OEI-07-02-00510 

International Merchant Purchase 

Authorization Card Program: 

Review of Calendar Year 

2001 Transactions 
OFFICE OF INSPECTOR GENERAL

http://www.oig.hhs.gov/ 

The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, as amended 

by Public Law 100-504, is to protect the integrity of the Department of Health and Human Services 

(HHS) programs, as well as the health and welfare of beneficiaries served by those programs. This 

statutory mission is carried out through a nationwide network of audits, investigations, and inspections 

conducted by the following operating components: 

Office of Audit Services 

The OIG's Office of Audit Services (OAS) provides all auditing services for HHS, either by conducting 

audits with its own audit resources or by overseeing audit work done by others. Audits examine the 

performance of HHS programs and/or its grantees and contractors in carrying out their respective 

responsibilities and are intended to provide independent assessments of HHS programs and operations in 

order to reduce waste, abuse, and mismanagement and to promote economy and efficiency throughout the 

Department. 

Office of Evaluation and Inspections 

The OIG's Office of Evaluation and Inspections (OEI) conducts short-term management and program 

evaluations (called inspections) that focus on issues of concern to the Department, the Congress, and the 

public. The findings and recommendations contained in the inspections reports generate rapid, accurate, 

and up-to-date information on the efficiency, vulnerability, and effectiveness of departmental programs. 

Office of Investigations 

The OIG's Office of Investigations (OI) conducts criminal, civil, and administrative investigations of 

allegations of wrongdoing in HHS programs or to HHS beneficiaries and of unjust enrichment by 

providers. The investigative efforts of OI lead to criminal convictions, administrative sanctions, or civil 

monetary penalties. The OI also oversees State Medicaid fraud control units which investigate and 

prosecute fraud and patient abuse in the Medicaid program. 

Office of Counsel to the Inspector General 

The Office of Counsel to the Inspector General (OCIG) provides general legal services to OIG, rendering 

advice and opinions on HHS programs and operations and providing all legal support in OIG’s internal 

operations. The OCIG imposes program exclusions and civil monetary penalties on health care providers 

and litigates those actions within the Department. The OCIG also represents OIG in the global settlement 

of cases arising under the Civil False Claims Act, develops and monitors corporate integrity agreements, 

develops model compliance plans, renders advisory opinions on OIG sanctions to the health care 

community, and issues fraud alerts and other industry guidance. 
EXECUTIVE SUMMARY 

PURPOSE 

To determine whether Department of Health and Human Services’ (HHS) employees properly 

used the International Merchant Purchase Authorization Card (IMPAC), and whether 

employees properly followed the HHS guidelines and agency procedures. 

BACKGROUND 

The IMPAC program was introduced to save the government money by avoiding costly 

paperwork and to speed the process of making purchases. In June 2002, HHS had 

8,909 open IMPAC purchase card accounts. Cardholders made 654,322 purchases in 

calendar year (CY) 2001, spending more than $321 million. 

When the IMPAC program came into effect, the HHS issued guidelines for the respective 

agencies to use in developing their individual operating procedures. Core areas within the HHS 

guidelines include card issuance, card limits, training, written procedures, card security, record 

keeping, and acquisition. Agency procedures should be no less restrictive than the HHS 

guidelines. 

The Inspector General for HHS testified on April 30, 2002, before the House Energy and 

Commerce Committee, Subcommittee on Oversight and Investigations. In that testimony, the 

Inspector General noted concerns with the IMPAC program and card usage, and identified 

current and future work on the part of the Office of Inspector General (OIG) designed to 

protect HHS against misuse. 

We selected a stratified random sample of 400 transactions from all transactions that occurred 

during CY 2001. We requested and reviewed agency-specific procedures to identify key 

internal controls, and used these procedures to determine compliance based on documentation 

collected from cardholders and approving officials for the sampled transactions. We received a 

file of all cardholders and approving officials as of June 2002, and analyzed this file to identify 

vulnerabilities related to cards, cardholders, and approving officials. 

FINDINGS 

Although We Did Not Identify Any Transactions That Clearly Indicated Misuse or 

Purchases Converted to Personal Use, 44 Percent of Transactions Did Not Fully 

Comply With Requirements for Using the IMPAC Purchase Card 

Based on our stratified random sample of 400 transactions, we did not identify any that clearly 

indicated misuse on the part of cardholders and approving officials, or purchases 

IMPAC: Review of 2001 Transactions i OEI-07-02-00510 
converted to personal use. However, 166 transactions did not fully comply with the HHS 

guidelines and agency procedures for using the IMPAC purchase card. This number projects 

to 44 percent of all transactions, accounting for $127 million of the $321 million purchased in 

CY 2001. Because some of these transactions contain more than 1 problem, the sum of 

percentages for these 3 types do not total 44 percent. Approximately 38 percent lacked 

documentation of approving official review, 8 percent lacked sufficient purchase 

documentation, and 7 percent did not document the associated object class code. 

Additional Control Weaknesses Increase the Risk of Improprieties 

Although internal agency procedures are in place governing card usage, issues related to the 

cards themselves came to light through an examination of the file of all IMPAC accounts 

“open,” as of June 2002. 

These issues, along with selected examples, include: 

• open accounts that should be closed – 1,390 cards were reported lost or had expired, 

yet these accounts remained open on U.S. Bank’s file; 

• infrequent card usage – 790 of 6,823 accounts had no activity during CY 2001; 

• agencies failing to set reasonable card limits – the HHS had at least $2.4 billion in 

available “credit” during CY 2001, yet made only $321 million in purchases; 

• relationships of cardholders to approving officials – 7 accounts have the cardholder and 

approving official listed as the same person; 

• span of control of approving officials – 19 percent of approving officials have 

responsibility for 5 or more accounts; and 

• approving officials and cardholders not collocated – 17 percent of accounts have 

approving officials with different zip codes in their mailing addresses than the 

corresponding cardholders. 

As these concerns persist, the IMPAC program remains vulnerable to misuse. 

Cardholder and Approving Official Actions Demonstrate a Lack of Understanding 

of Agency Procedures and the Need for Updated and Enhanced Training 

Although the HHS guidelines and agency-specific procedures require training, cardholders’ and 

approving officials’ actions demonstrate a lack of understanding in properly controlling and 

safeguarding cards. Specific examples from our sample of 400 transactions include: 

IMPAC: Review of 2001 Transactions ii OEI-07-02-00510 
• 31 percent of cardholders produced their cards from their personal wallets, despite the 

HHS guidelines, which recommend that cardholders keep cards in locked locations 

when not in use, and 1 cardholder could not find his card; 

• 23 percent of cardholders had not signed their cards, increasing the ease with which 

another person could use the card, if lost or stolen; and 

• 1 office maintained a listing of card numbers in an electronic file so that any cardholder 

in the office could use any other card if he or she reached the 30-day limit on his/her 

card, and 1 cardholder had given the card to another individual, despite the HHS 

guidelines and agency procedures, which specifically prohibit use of a card by anyone 

other than the authorized cardholder. 

CONCLUSION AND RECOMMENDATIONS 

Although we did not identify any transactions that clearly indicated misuse on the part of 

cardholders and approving officials, or purchases converted to personal use, issues related to 

documentation, or the lack thereof, and the failure to follow internal controls did raise concerns. 

Our review of the cardholder file from U.S. Bank raised issues with cards and cardholders, 

such as unused accounts and questionable card limits. Finally, cardholders’ and approving 

officials’ actions demonstrate a lack of understanding of agency procedures and the need for 

updated and enhanced training. 

Therefore, we recommend that the Office of the Assistant Secretary for Administration and 

Management, working through agency program coordinators: 

• Ensure that cardholders, approving officials, and agencies are in full compliance with the 

guidelines established, 

• Develop guidance where none currently exists, and 

• Provide periodic targeted training for current cardholders and approving officials. 

AGENCY COMMENTS 

The draft of this report was reviewed by the Office of the Assistant Secretary for 

Administration and Management (ASAM). In its response, ASAM noted that it received input 

from the General Accounting Office and the Office of Management and Budget (OMB) that 

emphasized findings in our report. The ASAM noted that it will work with OMB to improve 

internal controls highlighted in our report. 

The ASAM did state that the OIG may have drawn an “incorrect inference from the vendor’s 

(US Bank) use of non-standard terminology.” More specifically, the OIG failed to note that 

“open” accounts reported lost or stolen do not create a risk because they have been 

deactivated. Although it is true that we did not identify purchases associated with the cards we 

identified as lost or stolen, we chose to include the information because we had requested a file 

of “open” accounts, expecting to receive only open, active accounts. 

IMPAC: Review of 2001 Transactions iii OEI-07-02-00510 
Instead, we received a file containing large numbers of inactive accounts. We believe this could 

create difficulties in successfully managing the IMPAC program within HHS. Agency program 

coordinators, with whom we spoke, expressed frustration with their attempts to “clean up” their 

cardholder accounts, only to see accounts they attempted to get closed continue to show up on 

“open” account reports. We have revised the report to help clarify this point. The full text of 

ASAM’s comments can be found in Appendix D. 

IMPAC: Review of 2001 Transactions iv OEI-07-02-00510 
TABLE OF CONTENTS 

PAGE

EXECUTIVE SUMMARY ...................................................... i

INTRODUCTION ............................................................. 1

FINDINGS .................................................................. 5

Documentation and Internal Control Problems ................................... 5

Additional Control Weaknesses .............................................. 8

Lack of Understanding of Procedures ......................................... 12

CONCLUSION AND RECOMMENDATIONS ................................... 13

AGENCY COMMENTS ...................................................... 14

APPENDICES

A: Confidence Intervals for Key Estimates ..................................... 15

B: Matrix of Transactions with Problems ....................................... 16

C: Overview of Guidelines and Procedures ..................................... 20

D: Agency Comments .................................................... 26

ACKNOWLEDGMENTS ..................................................... 27
INTRODUCTION 

PURPOSE 

To determine whether Department of Health and Human Services’ (HHS) employees properly 

used the International Merchant Purchase Authorization Card (IMPAC), and whether 

employees properly followed the HHS guidelines and agency procedures. 

BACKGROUND 

The IMPAC program was introduced to save the government money by avoiding costly 

paperwork and to speed the process of making purchases. In June 2002, the HHS had 8,909 

open IMPAC purchase card accounts. Cardholders used the IMPAC purchase cards and 

checks (a feature of the program that allows cardholders to write a check against the IMPAC 

purchase card account when individuals or entities do not accept purchase cards) to make 

654,322 purchases in calendar year (CY) 2001, spending more than $321 million. 

To protect against unauthorized or fraudulent use of purchase cards, the Treasury Financial 

Manual, Vol. 1, Part 4, Section 4525 requires that each agency has its own internal 

procedures for using purchase cards. When the IMPAC program came into effect, the HHS 

issued guidelines for the respective agencies to use in developing their individual operating 

procedures. Core areas within the HHS guidelines included card issuance, card limits, training, 

written procedures, card security, record keeping, and acquisition. Agency procedures should 

be no less restrictive than the HHS guidelines. 

Nine agencies within the HHS have IMPAC program coordinators and have issued procedures 

governing card usage. These agencies are the Agency for Healthcare Research and Quality, 

Centers for Disease Control and Prevention, Centers for Medicare & Medicaid Services, Food 

and Drug Administration, Health Resources and Services Administration, Indian Health 

Service, National Institutes of Health, Program Support Center (PSC), and the Substance 

Abuse and Mental Health Services Administration. Smaller agencies or offices that do not have 

their own program coordinators, such as the Office of Inspector General (OIG), receive their 

cards through the PSC. 

The Inspector General for HHS testified on April 30, 2002, before the House Energy and 

Commerce Committee, Subcommittee on Oversight and Investigations. In that testimony, the 

Inspector General noted concerns with the IMPAC program and card usage, and identified 

current and future work on the part of the OIG designed to protect the HHS against 

unauthorized or questionable activity. As part of the current work, the OIG’s Office of 

Investigations (OI) has received from U.S. Bank (the vendor for the HHS IMPAC purchase 

card program) information for all transactions dating back to 

IMPAC: Review of 2001 Transactions 1 OEI-07-02-00510 
November 1999. The OI electronically reviews the data to identify potentially questionable 

purchases. These purchases are forwarded to the cognizant agency for their review; the 

agencies return the results to OI for appropriate action. 

METHODOLOGY 

The OIG’s Office of Evaluation and Inspections (OEI) obtained data from OIG/OI for all HHS 

IMPAC card transactions occurring between November 1999 and April 2002. Using this file, 

we identified all transactions that occurred during CY 2001. There were 654,322 transactions 

that met this criteria. We excluded from the population transactions of $5 or less, due to the 

low risk to the HHS associated with these purchases (8,426 transactions in CY 2001 totaling 

$28,748). We also attempted to exclude all New York-based hotel expenditures (34 

transactions totaling $2.8 million) that were used for continuity of operations following 

September 11, 2001, due to the potential sensitivity related to these transactions and because 

normal restrictions for use of credit cards were temporarily not in effect to accommodate these 

types of transactions. We did not exclude transactions for other types of purchases (e.g., 

security services, communication equipment) that occurred because of operational changes 

after September 11, 2001. From the remaining transactions, we selected a stratified random 

sample of 400. A description of the 5 strata with their population, corresponding dollar 

amounts, and sample size are shown in Table 1 below. 

Table 1: Stratified Sample of Transactions 

Purchase Amount 

Number of 

Transactions 

(CY 2001) 

Dollar Amount of 

Transactions Sample Size 

$25,000 or more 159 $7,873,071 50 

$10,000 to less than 

$25,000 1,163 $18,363,580 50 

$2,500 to less than 

$10,000 10,112 $45,284,615 100 

$500 to less than 

$2,500 151,206 $167,850,785 100 

Greater than $5 to less 

than $500 483,222 $79,361,431 100 

Totals 645,862* $318,733,482 400 

*Total excludes transactions of $5 or less and hotels related to continuity of operations 

post September 11, 2001. 

IMPAC: Review of 2001 Transactions 2 OEI-07-02-00510 
For 375 of the 400 transactions, we met with the cardholder, approving official, and/or acting 

or designated officials.1 We collected from them all documentation supporting the transaction 

that was maintained in the cardholder or approving official’s files. For the remaining 25 

transactions, we requested that documentation be submitted via mail or fax because the 

locations of the cardholders and approving officials were remote, making the costs associated 

with travel to the locations greater than the risk associated with not making on-site visits. 

For each transaction, information that we requested included, but was not limited to, receipts, 

orders, invoices, or packing slips; the object class code associated with the item; proof of 

approving official review and approval; inventory control and transferred/excessed forms (if 

appropriate); and evidence of bids, sole source, or the existence of a master contract for 

purchases exceeding $2,500. Whenever possible and appropriate, we matched equipment 

(e.g., computers, fax machines) against the inventory control forms. We also checked where 

cardholders maintained their cards and whether the cards were signed, the training status of 

cardholders and approving officials, and whether cardholders or approving officials had in their 

possession their agency’s IMPAC procedures. Finally, we had the cardholder, approving 

official, and/or acting or designated officials sign an attestation verifying that the information we 

received was complete and accurate. 

We sought to collect only those documents maintained in the cardholder and approving official 

files, based on agency procedures that require cardholders and approving officials to maintain 

documents to support each individual transaction. Therefore, we did not seek documents at 

off-site locations, although we did allow approving officials and cardholders to fax 

documentation to us for one week following on-site fieldwork. Documents were faxed to us for 

10 percent (37 of 375) of the sampled transactions. Fieldwork was conducted between July 

17 and August 23, 2002. 

We requested and received from the nine aforementioned agencies their current IMPAC 

procedures. We reviewed these procedures to identify key internal controls, and compared 

these procedures against the HHS guidelines and across agencies. We used the identified 

controls as the basis of reviewing the sampled transactions. For each transaction, we made a 

determination of whether documentation was maintained to support the purchase and whether 

there was a failure to comply with internal controls (e.g., no proof of approving official review, 

object class code not maintained). Confidence intervals for key estimates can be found in 

Appendix A of this report. 

We requested from U.S. Bank a listing of all “open” accounts as of June 2002. This file 

contained 8,909 records, with fields identifying the cardholder and address; approving official 

and address; dates issued, returned, and expired (if appropriate); and limits on 

1

Some cardholders and approving officials were not available when we were scheduled to visit their 

location. We made arrangements for someone to act on the cardholder or approving official’s behalf and to provide 

access to and certify the information we required. 

IMPAC: Review of 2001 Transactions 3 OEI-07-02-00510 
card usage, including single-purchase and 30-day limits. We used this file to review various 

aspects related to the cards, and the cardholders and approving officials. We also matched the 

file to our transaction file to determine card usage as well as to determine the cardholder and 

approving official associated with each sampled transaction. 

This inspection was conducted in accordance with the Quality Standards for Inspections 

issued by the President’s Council on Integrity and Efficiency. 

IMPAC: Review of 2001 Transactions 4 OEI-07-02-00510 
FINDINGS 

Based on our stratified random sample of 400 transactions and the documentation we received 

from cardholders and approving officials supporting these transactions, we did not identify any 

transactions that clearly indicated misuse on the part of cardholders and approving officials, or 

purchases converted to personal use. However, we did find significant noncompliance with the 

HHS guidelines and agency procedures regarding (1) approving official review, (2) purchase 

documentation, and (3) object class codes. In addition, our review of the cardholder file from 

U.S. Bank disclosed internal control weaknesses, such as unused accounts and questionable 

card limits, which increase the risk of improprieties. Finally, although guidelines and procedures 

require cardholders and approving officials to receive training, cardholder and approving official 

noncompliance with the HHS guidelines and agency procedures demonstrate a lack of 

understanding of these policies and the need for updated and enhanced training. 

Although We Did Not Identify Any Transactions That Clearly 

Indicated Misuse or Purchases Converted to Personal Use, 44 

Percent of Transactions Did Not Fully Comply With 

Requirements for Using the IMPAC Purchase Card 

One hundred sixty-six of the 400 sampled transactions did not fully comply with requirements 

for using the IMPAC purchase card, as described in the HHS guidelines and agency 

procedures. This number projects to 44 percent of all transactions, accounting for $127 million 

of the $321 million purchased in CY 2001. Three types of problems comprise the 44 percent 

projection, including (1) no evidence of approving official review, (2) lack of purchase 

documentation, and (3) failure to record object class codes. Because some of these 

transactions contain more than 1 problem, the sum of percentages for these 3 types do not total 

44 percent. Table 2 on the following page summarizes these problems, while Appendix B 

provides breakdowns of problem types for each transaction. 

IMPAC: Review of 2001 Transactions 5 OEI-07-02-00510 
Table 2: Breakdowns of Transactions with Problems 

Reason 

Number of 

Transactions/ 

Problems 

Percent of 

Universe 

Projected 

Purchase 

Amount 

(Millions) 

No evidence of approving official 

review 125 38% $97 

Insufficient purchase documentation 65 8% $46 

Failure to record object class code 28 7% $22 

Total of transactions which do not 

fully comply with requirements 

218 problems 

across 166 

transactions 

44% $127 

Agency procedures require cardholders and approving officials to maintain documents to 

support purchases and demonstrate compliance with internal controls. We gathered available 

documents (mostly through on-site visits) and reviewed these documents to determine whether 

procedures were followed. An overview of guidelines and procedures for IMPAC transactions 

can be found in Appendix C. 

Approximately 38 percent of transactions had no evidence of approving official 

review 

The HHS guidelines describe the need for approving officials to review accounts prior to 

forwarding information to their respective finance offices for payment. Agency procedures 

provide greater specificity on (1) what approving officials must do – reviewing invoices, 

packing slips, or other appropriate purchase documentation – and (2) how they must do it – 

signing the bottom of card statements or, more recently, using electronic automated systems to 

document review. 

Cardholders or approving officials either did not obtain or maintain evidence of approving 

official review for 125 of the 400 transactions. This number projects to 38 percent of all 

transactions, accounting for $97 million in purchases. Some cardholders claimed approving 

official review had occurred, but we could not find anything to support these claims within the 

cardholder or approving official files, and cardholders and approving officials did not supply 

any additional documentation via fax after completion of our site visits. Cardholders and/or 

approving officials did sign attestations indicating that the information we received at the 

completion of our fieldwork was complete and accurate. 

IMPAC: Review of 2001 Transactions 6 OEI-07-02-00510 
Approximately 8 percent of transactions had insufficient purchase documentation 

The HHS guidelines indicate the need to maintain a paper trail “ . . . that will support all 

purchases and be available to anyone auditing the process.” Agency procedures support this 

guideline by requiring cardholders or approving officials to obtain charge slips, cash register 

receipts, packing slips, or invoices, or to include a statement in the files as to why such 

documentation does not exist and what steps were taken to collect the missing documentation. 

Sixty-five of the 400 transactions had insufficient purchase documentation. This number 

projects to 8 percent of all transactions, accounting for $46 million in purchases. For 51 of 

these transactions, there was no invoice or receipt. For 12 transactions, the invoice amount did 

not equal the transaction amount. For 2 transactions, we could not determine if credits for 

disputed transactions were ever received. 

Due to the seriousness of problems for 30 of the transactions with documentation problems, we 

re-contacted the cardholders and approving officials and requested additional documentation. 

More than half could not or did not supply any additional documentation. Of those that did, 

some still could not fully support the transaction, and one supplied information indicating that the 

purchase was split between two cardholders to circumvent single-purchase limits.2 We have 

referred several transactions for further development and/or investigation. 

Approximately 7 percent of transactions did not have a recorded object class 

code 

The HHS guidelines state that “The individual card holder must write the CAN [Common 

Accounting Number] and object class on the Statement of Account as appropriate, and the 

approving official must also verify this information.” All agency procedures echoed the need to 

document the object class code. 

Cardholders did not maintain the object class code for 28 of the 400 sampled transactions, or 7 

percent when projected to the universe, accounting for $22 million in purchases. The object 

class code is an accounting code, which is used to classify expenditures to maintain budgetary 

control and report expenditures to the Office of Management and Budget. We did not trace 

these transactions to final accounting records to determine whether the transactions were 

properly classified. Our objective was to determine whether the 

2 Agency procedures clearly prohibit cardholders from splitting purchases to avoid purchase limits. We 

purposively selected 16 attempted transactions that would have exceeded the account’s single-purchase limit as 

further evidence of efforts to circumvent limits. We identified all transactions that each of the 16 cardholders made, 

and then, for each cardholder, searched for purchases on the same day or within a few days of the declined 

transaction. Six of the 16 had 2 or 3 purchases that, when added, matched the amount of the declined transaction. 

One cardholder, with a $25,000 single-purchase limit, split a $36,450 transaction into two transactions – $18,225 each 

– after having the original transaction declined. 

IMPAC: Review of 2001 Transactions 7 OEI-07-02-00510 
cardholder documented the object class code as the HHS guidelines and agency procedures 

require. 

Additional Control Weaknesses Increase the Risk of 

Improprieties 

In addition to our work on the sampled transactions, we expanded our review to include 

analyses of accounts listed as open to identify additional vulnerabilities. Because agencies could 

not adequately provide us with a listing of all “open” IMPAC accounts, we requested such a 

listing from U.S. Bank. The file we received contained all the HHS accounts with the status 

listed as “open” as of June 2002. Additional vulnerabilities that could place the HHS at risk of 

misuse include the following: 

• coding 1,390 accounts as open that should be closed, 

• maintaining infrequently used cards, 

• setting extreme 30-day limits, ranging up to $2 million, and 

• having approving officials responsible for an excessive number of accounts and allowing 

circumstances that compromise the independence of approving official review. 

As these concerns persist, the IMPAC program remains vulnerable to questionable, fraudulent, 

and unsupported purchases, and overall misuse. 

Approximately 16 percent of open accounts should be closed 

A review of the file from U.S. Bank revealed that 1,374 cards were reported lost, although the 

account status remained open. An additional 16 accounts had expiration dates that made the 

accounts inactive, yet, again, the status on the accounts remained “open.” 

Although no account activity was associated with any of these 1,390 accounts, they do increase 

the administrative burden associated with managing the IMPAC program. Several of the 

program coordinators throughout the HHS indicated they report to U.S. Bank when accounts 

should be closed. However, the coordinators claim that these accounts frequently remained in 

an “open” status when the coordinators received updated statements of open accounts. They 

were left to make additional contacts to U.S. Bank to attempt to resolve the matter. 

More than one-fifth of cards are being used infrequently 

Using the U.S. Bank file, we identified 6,823 accounts that were “active” throughout 

CY 2001. We arrived at this number by taking the file of “open” accounts from U.S. Bank and

excluding all cards reported lost or with expiration dates prior to 2001, or with dates indicating

accounts opened in 2002.

IMPAC: Review of 2001 Transactions 8 OEI-07-02-00510 
Of the 6,823 accounts active throughout CY 2001, 790 had no transaction activity during the 

entire year. Approximately 22 percent (1,491) of all accounts had fewer than 6 total 

transactions – less than 1 transaction every 2 months – during 2001. Cardholders may be less 

likely to notice that a card is lost or stolen if it is used infrequently. 

At the other extreme, 3 percent (179) had more than 500 transactions during the year. The 

highest number of transactions was 2,650, which averages out to more than 7 transactions a 

day for every day of CY 2001. Table 3 below summarizes transactional activity for all 

accounts open throughout CY 2001. 

Table 3: Number of Transactions Associated with 

Accounts Active Throughout CY 2001 

Number of 

Transactions per 

Account During 

CY 2001 

Number of 

Accounts Percent 

0 790 11.6% 

1 194 2.8% 

2-6 627 9.2% 

7-12 555 8.1% 

13-24 901 13.2% 

25-48 1,228 18.0% 

49-100 1,252 18.4% 

101-1,000 1,218 17.8% 

1,001-2,000 52 0.8% 

Greater Than 2,000 6 0.1% 

Total 6,823 100.0% 

Agencies fail to set reasonable card limits 

The HHS guidelines instruct agencies to establish card limits in relation to the bona fide needs of 

the office involved, consistent with sound management and oversight. In addition, limits should 

be as realistic as possible and tied into the office’s budget and operating plan. Limits help 

protect the office or agency against financial loss if the cardholder or another individual uses the 

card improperly. 

In CY 2001, the HHS had at least $2.4 billion in available “credit” to make purchases with the 

IMPAC cards. We computed this figure by multiplying all available 30-day 

IMPAC: Review of 2001 Transactions 9 OEI-07-02-00510 
limits for the 6,823 accounts “open” throughout CY 2001 by 12 months. The extreme 30-day 

limit was $2 million, with two cardholders having this limit. It bears repeating that the HHS 

used cards to make approximately $321 million in purchases in CY 2001, meaning that 

cardholders used less than 14 percent of available limits for purchases. Table 4 on the next 

page summarizes 30-day limits for cards active throughout CY 2001. 

Table 4: Summary of 30-day Limits 

for Accounts Active Throughout CY 2001 

30-day Limit Number of 

Accounts Percent 

$100 to $2,500 819 12.0% 

Greater than $2,500 

to $5,000 1,168 17.1% 

Greater than $5,000 

to $10,000 2,067 30.3% 

Greater than $10,000 

to $25,000 1,719 25.2% 

Greater than $25,000 

to $50,000 491 7.2% 

Greater than $50,000 

to $100,000 321 4.7% 

Greater than 

$100,000 238 3.5% 

Total 6,823 100.0% 

As further evidence that agencies set questionable limits: 

• 54 accounts (0.8 percent) active throughout CY 2001 had single-purchase limits that 

were greater than the 30-day limits;3 

• Cardholders for 133 accounts (1.9 percent) would need to make 50 or more 

purchases a month to reach the 30-day limit, assuming each purchase was the maximum 

allowable single-purchase amount; and 

3

A program coordinator informed us that the agency uses default single-purchase limits and sets 30-day 

limits, based on office needs. This explanation may explain why some single-purchase limits fall below the 30-day 

limit. 

IMPAC: Review of 2001 Transactions 10 OEI-07-02-00510 
• 28 accounts had a single-purchase limit of $1.4 The cardholder for one such account 

attempted to make 66 purchases during the first quarter (January through March) of 

2002, all of which were denied. The limit remained at $1 at the time we received the 

cardholder file in June 2002. 

Specific guidelines and procedures do not address potential vulnerabilities 

related to cardholders and approving officials 

The HHS guidelines and agency procedures do not specifically address many situations related 

to cardholders and approving officials, including who can act as an approving official for whom, 

the span of control for approving officials, and the location of cardholders relative to approving 

officials. Our review of the file of accounts active throughout CY 2001 revealed the following 

situations: 

• 7 accounts list the same individual as cardholder and approving official – since none of 

these accounts were in our sample, we cannot say whether these cardholders are 

actually approving their own transactions; 

• For 29 accounts, cardholders and approving officials have reversed relationships on 

another 29 accounts (i.e., individual A is the cardholder and individual B is the 

approving official on one account, while individual A is the approving official and 

individual B is the cardholder on another account) – the nature of reversed relationships 

on accounts may present an environment for misuse; 

• 378 approving officials have responsibility for 5 or more accounts, while the extreme is 

1 approving official responsible for 72 accounts – we question the extent of transaction 

approvals for approving officials with many accounts to manage; and 

• 1,193 cardholders had mailing addresses in ZIP codes different from the ZIP codes 

listed for the approving official, with the extreme being 2,770 miles between the address 

for the cardholder and the approving official – this situation potentially limits 

communication and sharing of purchase documentation between cardholders and 

approving officials. 

4

A program coordinator informed us that the agency sets single-purchase limits at $1 when cardholders fail 

to properly comply with requirements governing the IMPAC purchase card. This limit effectively prevents the 

cardholders from using the cards until matters have been resolved. 

IMPAC: Review of 2001 Transactions 11 OEI-07-02-00510 
Cardholder and Approving Official Actions Demonstrate a 

Lack of Understanding of Agency Procedures and the Need 

for Updated and Enhanced Training 

According to the IMPAC procedure manuals for all nine agencies, training is required for 

cardholders and approving officials. Seven agencies specifically require completion of training 

before a card is issued. Nonetheless, our findings show cardholders and approving officials 

lack an understanding of IMPAC procedures. 

In addition to previously identified failures to obtain or maintain evidence of approving official 

review, retain sufficient purchase documentation, and/or properly record the object class code, 

we offer the following examples from our random sample of 400 transactions where 

cardholders and approving officials are not properly following procedures: 

• 31 percent of cardholders produced their cards from their personal wallets, despite the 

HHS guidelines, which recommend that cardholders keep cards in locked locations 

when not in use, and 1 cardholder could not find his card; 

• 23 percent of cardholders had not signed their cards, increasing the ease with which 

another person could use the card if lost or stolen; and 

• 1 office maintained a listing of card numbers in an electronic file so that any cardholder 

in the office could use any other card if he or she reached the 30-day limit on his/her 

card, and one cardholder had given the card to another individual, despite the HHS 

guidelines and agency procedures that specifically prohibit use of a card by anyone 

other than the authorized cardholder. 

Potentially compounding this lack of understanding is the fact that procedure manuals for two 

agencies are currently in draft status. During the on-site visits, approving officials and 

cardholders for one of the agencies told us that their agency had never released a final 

procedures manual, while the other agency recently updated procedures to reflect changes in 

transaction review and approval. 

IMPAC: Review of 2001 Transactions 12 OEI-07-02-00510 
CONCLUSION AND 

RECOMMENDATIONS 

The IMPAC card purchase program was intended to save the government money by reducing 

the burden of completing excessive paperwork and to expedite the process of making 

purchases. We did not identify any transactions that, based on the documentation we were 

able to obtain, clearly indicated misuse on the part of cardholders and approving officials, or 

purchases converted to personal use. In addition, where controls exist, they appear to provide 

protection against abuse, if properly followed. Yet 44 percent of transactions had no evidence 

of approving official review, insufficient purchase documentation, and/or no recorded object 

class code. We recognize that, for efficient operation of the IMPAC program, some situations 

(e.g., lack of approving official and cardholder collocation) may be necessary. However, 

control weaknesses, such as unreasonable limits and a lack of specific controls, increase the 

risk of improprieties. Finally, although guidelines and procedures require cardholders and 

approving officials to receive training, questionable cardholder and approving official actions 

demonstrate a lack of understanding of agency procedures and the need for updated and 

enhanced training. 

As the IMPAC purchase card program continues to evolve, internal controls and procedures 

may fail to provide adequate protection against misuse. Therefore, we recommend that the 

Office of the Assistant Secretary for Administration and Management, working through agency 

program coordinators: 

• As soon as possible, ensure that agencies are in full compliance with the established 

guidelines, including the following areas: (1) maintaining documents to support all 

transactions, (2) closing unnecessary accounts, (3) establishing appropriate card limits, 

(4) issuing final procedure manuals, and (5) maintaining physical security of the card. 

• Develop guidance specifically targeting: (1) location of cardholders and approving 

officials, (2) role of approving officials and cardholders and the implications of those 

roles being interchangeable, and (3) breadth of approving official span of control. 

• Provide periodic targeted training for cardholders and approving officials with particular 

emphasis given to: (1) maintenance of supporting documentation, 

(2) responsibilities of approving officials, (3) agency-specific card limits, and 

(4) card security and designated authorized users. 

IMPAC: Review of 2001 Transactions 13 OEI-07-02-00510 
AGENCY COMMENTS 

The draft of this report was reviewed by the Office of the Assistant Secretary for 

Administration and Management (ASAM). In its response, ASAM noted that it received input 

from the General Accounting Office and the Office of Management and Budget (OMB) that 

emphasized findings in our report. The ASAM noted that it will work with OMB to improve 

internal controls highlighted in our report. 

The ASAM did state that the OIG may have drawn an “incorrect inference from the vendor’s 

(US Bank) use of non-standard terminology.” More specifically, the OIG failed to note that 

“open” accounts reported lost or stolen do not create a risk because they have been 

deactivated. Although it is true that we did not identify purchases associated with the cards we 

identified as lost or stolen, we chose to include the information because we had requested a file 

of open accounts expecting to receive only open, active accounts. Instead we received a file 

containing large numbers of inactive accounts. We believe this could create difficulties in 

successfully managing the IMPAC program within HHS. Agency program coordinators, with 

whom we spoke, expressed frustration with their attempts to “clean up” their cardholder 

accounts, only to see accounts they attempted to get closed continue to show up on “open” 

account reports. We have revised the report to help clarify this point. The full text of ASAM’s 

comments can be found in Appendix D. 

IMPAC: Review of 2001 Transactions 14 OEI-07-02-00510 
APPENDIX A 

Confidence Intervals for Key Estimates 

We calculated confidence intervals for five key estimates. The estimates are given at 90 

percent confidence level. 

Key Estimate 

Point 

Estimate– 

Percent 

Confidence 

Interval– 

Percent 

Point 

Estimate– 

Dollar Amount 

Confidence 

Interval– 

Dollar Amount 

Transactions which do 

not fully comply with 

requirements 

43.503% +/-6.439% $126,655,676 +/-$19,770,302 

Transactions which lack 

evidence of approving 

official review 

38.435% +/-6.347% $97,266,068 +/-$17,646,406 

Transactions which have 

insufficient purchase 

documentation 

8.111% +/-3.231% $45,918,740 +/-$13,239,430 

Transactions which lack a 

recorded object class 

code 

6.543% +/-3.267% $21,762,200 +/-$9,796,178 

IMPAC: Review of 2001 Transactions 15 OEI-07-02-00510 
APPENDIX B 

Matrix of Transactions with Problems

One hundred sixty-six of 400 sampled transactions have one or more problems, as indicated in 

the table below. 

Sample 

Number 

No evidence of 

approving 

official review 

Insufficient 

purchase 

documentation 

Lack of 

recorded object 

class code 

6 x 

7 x 

8 x 

9 x 

10 x 

15 x 

16 x 

17 x 

18 x 

21 x 

22 x 

27 x 

32 x x 

34 x 

35 x x 

39 x 

40 x 

41 x 

42 x

44 x

52 x

53 x

54 x

55 x

71 x

72 x

73 x x x

75 x

82 x x

93 x x x

96 x

97 x

98 x

102 x

104 x x

105 x x x 

IMPAC: Review of 2001 Transactions 16 OEI-07-02-00510 
Sample 

Number 

No evidence of 

approving 

official review 

Insufficient 

purchase 

documentation 

Lack of 

recorded object 

class code 

106 x 

108 x 

112 x 

114 x x 

116 x 

117 x 

118 x x x 

119 x 

123 x 

135 x 

140 x 

141 x 

143 x 

144 x 

145 x x x 

150 x 

151 x 

153 x 

155 x x x 

156 x x 

159 x x

165 x

167 x

168 x

170 x

172 x

175 x x

179 x x

180 x

181 x

184 x

186 x x x

187 x x

188 x

189 x

190 x x

191 x x

192 x

193 x

194 x

195 x x

196 x x

197 x x 

198 x 

IMPAC: Review of 2001 Transactions 17 OEI-07-02-00510 
Sample 

Number 

No evidence of 

approving 

official review 

Insufficient 

purchase 

documentation 

Lack of 

recorded object 

class code 

199 x 

201 x x 

202 x x 

203 x x 

204 x x 

206 x 

207 x 

208 x 

210 x 

211 x 

215 x x 

217 x 

218 x 

222 x 

224 x 

225 x x 

226 x 

227 x 

228 x 

229 x 

230 x

231 x

232 x

233 x

234 x

235 x x

240 x

241 x

245 x

248 x

252 x x

253 x x

255 x

256 x x x

261 x

263 x

264 x

265 x

266 x

267 x x

268 x

269 x

270 x 

271 x 

IMPAC: Review of 2001 Transactions 18 OEI-07-02-00510 
Sample 

Number 

No evidence of 

approving 

official review 

Insufficient 

purchase 

documentation 

Lack of 

recorded object 

class code 

277 x 

278 x 

281 x 

282 x x 

284 x x 

285 x x 

288 x 

289 x 

290 x 

291 x 

292 x x x 

293 x x 

294 x x x 

295 x x 

296 x x 

300 x x 

308 x 

313 x 

322 x 

325 x 

327 x

329 x

330 x

331 x

338 x

339 x

347 x

350 x

351 x

357 x

368 x

370 x

374 x

375 x

379 x

380 x

381 x

382 x

384 x

393 x

395 x

397 x

Totals * 125 65 28 

* 166 transactions 

IMPAC: Review of 2001 Transactions 19 OEI-07-02-00510 
APPENDIX C 

Overview of Guidelines and Procedures

The following is an overview of guidelines and procedures governing IMPAC card usage, 

corresponding to areas reviewed in the body of the report. For each section, we provide the 

HHS guideline, if appropriate, and offer examples drawn from one or more of the agency 

procedures to illustrate how agencies have implemented or added to the HHS guideline or how 

agencies have addressed the need for a given internal control. We did make some minor 

revisions to the guidelines and procedures presented below to aid in readability and flow, 

although we did preserve the emphasis that the HHS or agencies added. 

Overall, from the HHS: 

These guidelines apply to all components of the HHS. Each operating component must 

develop written internal operating procedures regarding the use of cards. These procedures 

should detail the internal controls and processing steps that the operating component will follow 

in implementing this program. 

Approving Official Review: 

From the HHS: 

After verification by the cardholders and approving official, the Statements of Account are sent 

to the serving finance office. 

From the agencies: 

The cardholder must register their transactions during the billing cycle in the automated 

Managing/Accounting Credit Card System (MACCS), ensuring that the object class code and 

Common Accounting Number (CAN) for the purchases are included in the data. The 

transaction is forwarded to the approving officials for his/her approval. When the approving 

official approves the transaction, the process status changes from “Registered” to “Approved”. 

The cardholder must document certain information on the statement of account and attach all 

supporting documentation, such as charge slips, packing slips, and purchase log, and forward 

the signed statement to the approving official. After signing the statement of account, approving 

officials will return a signed copy along with back-up documentation to the cardholder to be 

maintained as part of their monthly purchase file. 

IMPAC: Review of 2001 Transactions 20 OEI-07-02-00510 
Approving officials monitor the proper use of the purchase card by cardholders assigned to 

them. Approving officials are responsible for reviewing their monthly cardholders’ statements 

and verifying that all transactions are for necessary government purchases in accordance with 

regulations and agency manuals. Approving officials shall: 

• Ensure that established limits are not exceeded; 

• Ensure that cardholders receive training; 

• Receive, review, and reconcile the bank’s monthly billing statement against the 

cardholders’ statements of account, ensuring that receipts and documentation are in 

order; 

• Certify the monthly bill statement for payment processing; 

• File and maintain the cardholders’ original statements of account, receipts, and charge 

slips, along with copies of the monthly billing statements for 6 years and 3 months. 

Purchase Documentation: 

From the HHS: 

A paper trail must be maintained that will support all purchases and be available to anyone 

auditing this process. At a minimum, this paper trail must include an identification of the items 

bought, who requested the items, date of purchase, amount of purchase, vendor, and funds 

charged. 

It is the responsibility of each individual card holder to keep copies of each charge slip and to 

quickly reconcile each monthly statement and forward the information on to the approving 

official. 

From the agencies: 

All charge slips and other documentation (including cash register receipts, packing slips, 

“Cardholder’s Statement of Questioned Items” forms – if necessary) should be retained in a 

permanent file and will be required for submission to the Administrative Office when the 

cardholder accounts are audited. If no documentation is available, the cardholder should 

indicate the word “lost” under the date of purchase on the purchase log and attach a written 

explanation. Check to see if duplicate copies can be obtained from the merchant. 

Attach all documentation (e.g., charge slips, packing slips, and any Cardholder’s Statement of 

Questioned Item – CSQI – forms) to the log, sign and date the log, and retain in the 

cardholder’s file. 

Any time a purchase is made, whether it is done over the counter or by telephone, a monthly 

cumulative purchase log must be annotated and retained in the purchase file. Each cardholder 

must set up a purchase file for all proof of purchase documents associated with purchase card 

orders. 

IMPAC: Review of 2001 Transactions 21 OEI-07-02-00510 
Recording of Object Class Code: 

From the HHS: 

The individual card holder must write the CAN and object class on the Statement of Account 

as appropriate, and the approving official must also verify this information. 

From the agencies: 

The cardholder must register their transactions/purchases during the billing cycle in the MACCS 

automated system, ensuring that the object class code and CAN number for the purchases are 

included in the data. The transaction is forwarded to the approving officials for his/her 

approval. 

Accounting needs the cardholders to list on the monthly statement the 4 digit object class code 

for each item purchased. This information is needed to report to the Office of Management and 

Budget on how the HHS appropriations are spent. 

Closing Accounts: 

From the HHS: 

Since the cards are issued to individual employees, they must be destroyed when the 

cardholder leaves the organization. The contracting officer who delegated authority and 

distributed the cards has the primary responsibility for recovering the cards from terminating 

employees and for following instructions for card termination issued by the contractor (U.S. 

Bank). 

From an agency: 

If cards need to be canceled, the cardholder must turn the card in to the approving official, who 

must notify the administrative officer and return the purchase card (cut in half). 

Card Activity: 

From the HHS: 

The HHS guidelines do not specifically reference this issue, although recent scrutiny of the 

purchase card program has brought attention to the number of “open” accounts across 

government. 

IMPAC: Review of 2001 Transactions 22 OEI-07-02-00510 
Card Limits: 

From the HHS: 

For those cardholders who have not previously exercised procurement authority, the dollar 

limits for card use should be set in relation to the bona fide purchasing needs of the office 

involved, consistent with sound management and oversight. These limits should be set as 

realistically as possible and the monthly purchase limit . . . should be tied into the budget and 

operating plan. 

From the agencies: 

An email is sent to request that a card be issued to the named cardholder (with the appropriate 

approving official’s name, title, and organization), which indicates the monthly and singlepurchase limits desired. The standard single-purchase dollar limit is $2,500. 

Each purchase card is subject to a single-purchase limit, a billing cycle limit, and a billing cycle 

office limit. Neither cardholders nor merchants are allowed to exceed single-purchase limit or 

split the purchase in order to accommodate the purchase card limit. 

When a card is presented for purchase, and the merchant slides it through the electronic 

verification machine (or telephonically requests approval), the limits are compared against the 

proposed purchase and the transaction will not be approved if either limit is exceeded. 

Cardholder and Approving Official Relationships: 

From the HHS: 

The HHS guidelines do not specifically reference this issue. 

Approving Official Span of Control: 

From the HHS: 

The HHS guidelines do not specifically reference this issue, although an official with 

responsibility for the purchase card program noted that it is “assumed” a supervisor will be the 

approving official for any employees whom he or she supervises, with the result that an 

approving official would not have a larger span of control than a typical supervisor. 

From an agency: 

The recommended ratio of cardholders to approving official is 5 to 1. Under certain rare and 

extenuating circumstances, up to 10 cardholders per approving official may be 

IMPAC: Review of 2001 Transactions 23 OEI-07-02-00510 
allowed. The monthly transaction volume of the cardholder will be taken into consideration. 

Location of Approving Official and Cardholder: 

From the HHS: 

The HHS guidelines do not specifically reference this issue. 

Training: 

From the HHS: 

All cardholders who have not previously held a warrant for procurement authority must be 

provided training by the issuing agency, preferably before the card is issued, but in any case 

within 6 months of issuance. The training must cover, as a minimum, the following topics: 

• Required sources of supply, including Federal Prison Industries, blind and handicapped 

workshops, mandatory General Services Administration schedules and printing 

services. 

• Applicable requirements of the Federal Acquisition Regulation Section 13, including 

small business set asides, thresholds for competition, price reasonableness, and rotation 

of sources. 

• Allowable and non-allowable purchases, as determined by statute, regulation, and 

Comptroller General decision. 

• Requirements for payment of monthly statements, such as: identifying each item 

purchased, indicating object class and fiscal data for each item, and noting credits not 

shown. 

Approving officials should make sure all prospective cardholders fully understand all policies 

and procedures regarding card usage and have signed a statement to this effect before they 

receive a card. 

From the agencies: 

Prospective cardholders and approving officials must attend a training course or review the

U.S. Bank Purchasing Program videotape and complete certifications (as required) prior to

their account set up forms being submitted to U.S. Bank. The cardholder and approving official

will sign a statement that he/she has been fully trained and understands all policies and

procedures regarding the card usage prior to receiving a card.

IMPAC: Review of 2001 Transactions 24 OEI-07-02-00510 
All purchase card users must receive their cards and their authorization to use them from an 

agency contracting officer, via a letter of limited procurement authority. Training is also 

required. 

Safeguarding Cards: 

From the HHS: 

The card is for official use only! The cardholder is responsible for the security of the card and 

can be personally liable for its misuse. Cardholders should take precautions to prevent others 

from gaining access to their cards and should not give out their card number, since this could 

lead to misuse and personal liability. It is recommended that cardholders keep their cards 

locked up when not in use. 

From the agencies: 

The cardholder is the only person authorized to use his/her purchase card, is responsible for the 

security of the purchase card, should not give anyone their card number, and can be personally 

liable for its misuse. It is recommended that the card be kept in a locked cabinet when not in 

use. 

Use of IMPAC by a cardholder for a personal purchase and/or a purchase of supplies or 

services which the cardholder had no authority to make, and/or use of the card by a person 

other than the cardholder, is unauthorized. 

No member of the cardholder’s staff, the cardholder’s supervisor, or anyone else may use the 

card. 

Splitting Purchases: 

From the HHS: 

The HHS guidelines do not specifically reference this issue, although all agency procedures 

address split purchases. 

From the agencies: 

The cardholder cannot split orders to stay within the dollar limitations. 

The temptation may arise to break up a $2,800 acquisition into one $2,500 purchase and one 

$300 purchase, so that the purchase card may be used. This proposed action would be wrong 

and not in the best interest of the government. 

IMPAC: Review of 2001 Transactions 25 OEI-07-02-00510 

ACKNOWLEDGMENTS 

This report was prepared under the direction of Brian T. Pattison, Regional Inspector General for 

Evaluation and Inspections in the Kansas City Regional Office. Other principal Office of Evaluation 

and Inspections staff who contributed include: 

Tricia Fields, Project Leader Elise Stein, Director, 

Mike Craig, Program Analyst Public Health and Human Services Branch 

Linda L. Hall, Program Specialist 

Barbara R. Tedesco, Mathematical Statistician 

We would like to acknowledge the following OIG staff for their assistance in this project: 

Michael P. Barrett, OEI, Region VII

Erin Bliss, OEI, Region V

Diana S. Clark, OEI, Region VII

A. Blaine Collins, OEI, Region VI

Jason Coopey, OI, Region III

Carnitta DeVaughn, OEI, Headquarters

Tanaz Dutia, OEI, Region III

Linda A. Frisch, OEI, Headquarters

Paul A. Gottlober, OEI, Region IX

Michael Grasso, OI, Region VII

Erin Guay, OEI, Region V

Norman Han, OEI, Region I

Steven Hanson, OI, Region VII

Michael Henry, OEI, Region IX

Scott Horning, OEI, Headquarters

Stephanie Lattin, OEI, Headquarters

Kevin Lawrence, OEI, Region IV

Alan S. Levine, OEI, Headquarters

William C. Moran, OEI, Region V

Genevieve Nowolinski, OEI, Headquarters

Elander J. Phillips, OEI, Region VII

Joan Richardson, OEI, Headquarters

Brian P. Ritchie, OEI, Headquarters

Bambi Straw, OEI, Headquarters

Dennis J. Tharp, OEI, Region VII

Joe Townsel, OEI, Region IV

Lisa Vasquez, OEI, Headquarters

Brian T. Whitley, OEI, Region VII

Steven Zerebecki, OEI, Region IX

Thomas Zimmermann, OEI, Region II

For information or copies of this report, please contact

the Office of Inspector General’s

Public Affairs office at (202) 619-1343.

Reports are also available on the World Wide Web at our home page address:

http://www.oig.hhs.gov/ 

IMPAC: Review of 2001 Transactions 27 OEI-07-02-00510