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OFFICE OF 

INSPECTOR GENERAL 

U.S.DEPARTMENT OF THE INTERIOR 

CARES Act Flash Report 

Lessons Learned for Purchase Card Use 

The DOI received 

$909.7 million 

under the CARES Act to 

respond to impacts from 

COVID 19: 

• $453 million for the Bureau

of Indian Affairs

• $157.4 million for DOI

operations (Office of the

Secretary)*

• $222.7 million for the

Bureau of Indian Education 

$69 million from the DOI

and $153.7 million from

the U.S. Department of

Education

• $55 million for the Office of

Insular Affairs

• $12 million for the Bureau

of Reclamation (BOR) water

resources

• $8.1 million for the BOR

policy and administration

• $1 million for the Office of

Inspector General (OIG)

• $500,000 for the BOR 

Central Utah Project

Completion Act

* The Office of the Secretary

transferred funds to the National Park

Service, U.S. Fish and Wildlife Service,

and Bureau of Land Management.

On March 27, 2020, the President signed into law the Coronavirus 

Aid, Relief, and Economic Security Act (CARES Act). To date, the 

CARES Act has provided the U.S. Department of the Interior (DOI) 

with $909.7 million, which includes direct apportionments totaling 

$756 million and a $153.7 million transfer from the U.S. Department 

of Education. 

DOI programs and bureaus have used Government purchase cards to 

make expenditures, some coded specifically to CARES Act funds and 

some coded as “COVID-19.” As of July 26, 2020, CARES Act 

purchases totaled $3.1 million and COVID-19-related purchases 

totaled $8.5 million (see Figure 1). The COVID-19 amounts are not 

charged to CARES Act funds, and as part of future transaction 

reviews the DOI may make adjustments to properly classify these 

expenditures as use of CARES Act funds. 

Figure 1: Purchase Card Spending as of July 26, 2020 

Bureau CARES Act ($) COVID-19 ($) Total ($) 

BIA 1,201,312 2,356,899 3,558,211 

BLM 376,735 954,783 1,331,518 

BOR 651,119 6,240 657,359 

FWS 99,195 1,093,382 1,192,577 

NPS 810,564 3,631,058 4,441,622 

Other 0 457,231 457,231 

Totals $3,138,925 $8,499,593 $11,638,518 

Abbreviations: BIA = Bureau of Indian Affairs • BLM = Bureau 

of Land Management • BOR = Bureau of Reclamation • FWS =

U.S. Fish and Wildlife Service • NPS = National Park Service 

In May 2018, the Office of the Secretary increased the micropurchase 

threshold from $3,500 to $10,000; however, for response to an 

emergency or major disaster such as COVID-19, the micropurchase 

threshold was increased to $20,000 for purchases made inside the 

United States and $30,000 for purchases made outside the United 

States. These increased thresholds, combined with the fluid nature of 

any disaster or emergency situation, heighten the risk of fraud and 

abuse and necessitate even greater oversight. 

CARES Act Flash Report • No. 2020-FIN-055 • Issued August 25, 2020 1 
 

 

 

 

 

 

Governmentwide Issues 

The U.S. Government 

Accountability Office (GAO) 

has identified insufficient 

documentation as a 

Governmentwide issue. 

Specifically, in a 2017 report, 

the GAO found that 22 percent 

of Governmentwide 

transactions did not have 

complete documentation to 

support the approval process. 

In 2019, the Congressional 

Research Service found the 

following weaknesses in the 

use of Government purchase 

cards: 

• Ineffective transaction

review and approval

processes

• Inconsistent program

monitoring

• No separation of duties

• Inadequate training

• Excessive number of cards

issued and high credit limits

In this report we present lessons learned and risks identified in our 

prior work—both audits and investigations—that the DOI should 

consider as it uses purchase cards to spend CARES Act funds.

1

We have found that the following factors are crucial for successful 

oversight of purchase cards transactions: 

• Ensuring sufficient documentation for purchases

• Timely reviews and approvals of statements or transactions

• Using mandatory sources for purchases

• Training cardholders and approving officials

Ensure Sufficient Documentation 

Our past work has identified instances of cardholders not providing 

sufficient documentation to support purchases. Documentation is 

required by law and DOI policy and is essential in helping to prevent 

or detect potential fraud or misuse, especially for higher risk disaster 

relief or emergency funding. 

In our last three purchase card audits, we found insufficient 

documentation. Specifically, in a 2016 audit, we found that out of the 

355 transactions reviewed across the DOI, 15 (or 4 percent) did not 

have the required supporting documentation. In a March 2019 audit, 

we found that out of the 100 transactions reviewed across the DOI, 

24 (or 24 percent) did not have the required documentation. Based on 

this finding, we projected that 6,312 of the 26,302 high-risk 

transactions were missing the required documentation. 

In a November 2019 audit, we found that out of the 282 purchase card 

transactions we reviewed across the DOI, 53 (or 19 percent), totaling 

$393,095, did not have the required documentation. We are in the 

process of auditing purchases using disaster relief funds and have 

found the same issue. Specifically, we found that out of 1,299 

transactions reviewed at the Bureau of Reclamation, U.S. Fish and 

Wildlife Service (FWS), National Park Service, and U.S. Geological 

Survey (USGS), 53 (or 4 percent) did not have the required 

documentation. While we saw improvement, our 2019 audits 

demonstrate that continued diligence is needed to ensure purchases 

are supported. 

Key Action: Ensure sufficient documentation for transactions, 

including what was purchased, by whom, and for what purpose. 

1 On June 24, 2020, we briefed the DOI Charge Card Program Manager on issues the DOI should consider as it uses purchase cards to spend CARES 

Act funds. 

CARES Act Flash Report • No. 2020-FIN-055 • Issued August 25, 2020 2 
 

 

 

 

 

 

 

’

Purchase Card Misuse 

and Abuse 

Intentional use of a Government 

purchase card for other than 

official business is misuse, and 

may be fraud. Examples of 

misuse include purchases that: 

• Exceed the cardholder s limit

• Are not authorized by the

agency

• Are made without available

funds

• Are for personal use

• Do not comply with agency

policies

Purchase Card Fraud 

Fraud is intentional deception 

for personal or monetary gain. 

Indicators of purchase card 

fraud include: 

• Receipts that have been

altered or are illegible

• Unauthorized weekend

purchases

• Lack of proper approvals and

periodic reviews of purchases

and inventory records

• Numerous missing invoices,

receipts, and purchase

justifications

• Purchases at, or slightly

below, the micropurchase

threshold

Conduct Timely Reviews and Approvals of 

Statements or Transactions 

When supervisors conduct timely reviews, they can identify 

potentially questionable transactions soon after they are made. Such 

early identification can stop further questionable transactions and 

keep more funds from being misused. In past work we have found that 

reviews and approvals of statements or transactions were not done in a 

timely manner or at all. 

In a 2016 audit, we found that out of the 267 purchase card statements 

we reviewed across DOI bureaus, 36 (or 13.5 percent) were not 

reconciled within 30 days of the statement date by the cardholders, 

and 67 statements (25.1 percent) were also not reconciled by the 

approving officials within the required 30 days. 

In a 2019 investigation, we found that a USGS approving official was 

able to prevent an employee from making additional fraudulent 

charges by reviewing transactions in real time. This real-time review 

identified that the employee had charged more than $14,000 for 

personal items and services. The employee subsequently resigned 

after being confronted by supervisors and the approving official. 

In a 2018 investigation, we found that an FWS cardholder made 

unauthorized purchases of supplies between 2013 and 2017 totaling 

$6,000 and used them for work that was outside the scope of her 

assigned duties and unauthorized by her supervisors. The only reason 

this was discovered was that in 2016 a new supervisor conducted 

timely reviews and asked repeatedly for the purchase card statements 

from the employee, who acknowledged she had fallen behind in 

providing the statements to her supervisor. 

In a 2019 audit, we noted that because of a change in vendors, after 

November 2018, DOI cardholders and approving officials no longer had 

access to an online system to review and approve transactions and could 

not review transactions until the paper statement was issued. Prior to the 

change, transactions were often reviewed earlier than the required 30 

days after the statement date, via the bank’s online system. 

Key Action: Establish real-time monitoring for Government charge 

card transactions and make monitoring available to all levels of 

reviewers to help identify fraud, waste, and abuse in a timely manner. 

Use Mandatory Sources for Purchases 

We contributed to a 2018 Council of the Inspectors General on 

Integrity and Efficiency (CIGIE) report examining risks associated 

with U.S. Government purchase card transactions, which found 

deficiencies in purchases made using nonmandatory sources. Out of 

CARES Act Flash Report • No. 2020-FIN-055 • Issued August 25, 2020 3 
 

 

 

 

 

 

the 1,255 transactions sampled, 14 Offices of Inspector General 

(OIGs) identified 531 potential transactions in which cardholders may 

not have procured supplies or services through mandatory sources 

when they were available and instead acquired supplies or services 

from nonmandatory (i.e., unauthorized) third-party merchants. 

Together the OIGs found 250 transactions that did not follow policies 

to use mandatory sources (or 19.9 percent of the total 1,255 

transactions). We found that in 65 of the 100 DOI transactions we 

reviewed, cardholders used third-party vendors such as Amazon or 

PayPal and did not document whether they explored required Federal 

supply sources, such as the U.S. General Services Administration 

(GSA), before making the purchases. The GSA considers online 

transactions that are made using third-party vendors, such as Amazon 

or PayPal, to be high-risk transactions. 

Detecting Fraud 

Cardholders should review card 

statements to: 

• Look for transactions they do

not recall making

• Check for unknown vendors

• Identify account withdrawals

they do not remember

making

Preventative Measures 

The DOI and its bureaus can 

take the following preventative 

measures to reduce fraud, 

waste, and abuse related to use 

of purchase cards: 

• Set credit limits

• Block specific merchant

category codes

• Define the

agency/organization program

coordinator for each bureau

• Train staff on roles and

responsibilities

• Deactivate cards not in use

• Review transactions

• Limit the number of personnel

who can make purchases

Key Action: Cardholders should acquire supplies and services from 

required sources whenever possible. When purchasing from a thirdparty vendor, the cardholder should make sure the vendor is well 

known or the agency has a positive purchase history with the vendor. 

Train Cardholders and Approving Officials 

We have learned from our prior work that training could help 

cardholders and approving officials detect and prevent purchase card 

misuse. Annual training helps ensure that cardholders and managers 

understand their roles and responsibilities and stay informed of any 

changes or updates to the purchase card program. 

During the 2019 investigation mentioned above, first-line supervisors 

and approving officials told us that they did not have the training to 

identify fraud schemes and abuse indicators and were not aware of all 

the resources available to them. While the USGS was able to prevent 

its former employee from making additional charges through the use 

of budgeting software, it could have identified the problem up to 

21 days earlier (when the initial purchase card misuse occurred) 

if reviewers had received training on fraud indicators and available 

resources. 

In a 2019 audit, we found that 232 out of 267 cardholders DOI-wide 

had not documented completion of the annual training in the DOI 

tracking system as required by policy. The DOI took corrective action 

to improve its documentation and tracking of purchase card training. 

Key Action: Train all cardholders and approving officials on their 

roles and responsibilities, including the requirement to report all 

suspected fraud, waste, and abuse immediately to the OIG. In 

addition, train all reviewers on fraud indicators and reporting 

requirements to combat misuse. 

CARES Act Flash Report • No. 2020-FIN-055 • Issued August 25, 2020 4