Federal Election Commission

Office of Inspector General

Final Report

Inspection of the

Federal Election Commission’s

Travel and Purchase Card Programs 

February 2015

Assignment No. OIG-14-05
Office of Inspector General

Inspection of the FEC’s Travel and Purchase Card Programs

February 2015

The overall objective for this Office of Inspector General (OIG) inspection was to review and assess 

the Federal Election Commission’s (FEC) travel and purchase card programs to ensure proper 

controls are in place and operating effectively, and to ensure the FEC’s charge card management plan 

and standard operating procedures meet charge card requirements as prescribed by Office of 

Management and Budget (OMB) Circular A-123 (Management’s Responsibility for Internal 

Control), Appendix B (Improving the Management of Government Charge Card Programs, as 

revised) and the Government Charge Card Abuse Prevention Act of 2012 (Public Law 112-194).

The OIG conducted this inspection in accordance with the Council of the Inspectors General on 

Integrity and Efficiency (CIGIE) Quality Standards for Inspections and Evaluations, January 2011. 

Noteworthy Accomplishments

The Office of the Chief Financial Officer (OCFO) has:

• adequate controls in place for ensuring only authorized official travel related expenses that are 

in accordance to Federal Travel Regulations (FTR) are paid by the Agency;

• adequate controls in place to minimize the risk of fraudulent and/or unauthorized purchase 

card transactions; and

• developed a comprehensive charge card management plan that incorporates the elements 

prescribed by OMB Circular A-123, Appendix B and the Government Charge Card Abuse 

Prevention Act of 2012. 
Inspection of the FEC’s Travel and Purchase Card Programs – OIG-14-05 Page | 2

Inspection of the FEC’s Travel and Purchase Card 

Programs

TABLE OF CONTENTS PAGE

EXECUTIVE SUMMARY 3

INSPECTION RESULTS AND RECOMMENDATIONS 5

I. Travel Card Program 5

A. Inconsistent Application of FEC standard travel practices 5

B. Non compliant travel card purchases 7

II. Purchase Card Program 9 

APPENDIX A – BACKGROUND 

APPENDIX B – OBJECTIVES, SCOPE AND METHODOLOGY 

APPENDIX C – OFFICIAL MANAGEMENT RESPONSE TRANSMITTAL MEMO
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Executive Summary 

At the Federal Election Commission (FEC), the Office of the Chief Financial Officer (OCFO) has

overall responsibility for the FEC’s charge card management program. Currently the FEC uses travel 

charge cards, purchase cards, and fleet charge cards. The Chief Financial Officer (CFO) has 

delegated day to day management of the individually billed account (IBA)1 travel cards and fleet 

charge cards to the Director of Administrative Services, and day to day management of the purchase 

card program to the Director of Procurement. 

Based on the results of the FEC’s Office of Inspector General (OIG) standard annual risk assessment 

process conducted for fiscal year (FY) 2014, as well as to satisfy the OIG’s responsibility under the 

Charge Card Loss Prevention Act of 2012 (The Charge Card Act) to specifically assess charge card 

programs, the FEC IBA travel card and purchase card programs were selected for review2. 

The main OIG objectives for this inspection were to:

• assess the FEC's Charge Card Management Plan to ensure the plan is adequately designed to 

meet the requirements of OMB Circular A-123, Appendix B, and the Charge Card Act;

• ensure that internal controls to prevent and/or detect charge card fraud, abuse, or misuse are 

operating effectively; and

• ensure that card holders and approvers are complying with applicable charge card policies, 

procedures, regulations, and guidance.

 

Summary Results of the IBA Travel Card Program

Based on work performed during this inspection for the period under review (January 2013 to April 

2014), the OIG concluded that the FEC has adequately designed controls to ensure only official 

authorized travel-related expenses that are in compliance with the Federal Travel Regulations

(FTR) are reimbursed to employees. In addition, the OIG did not find any indications of 

potential travel card abuse. However, during the period under review, the FEC did not have a 

formal travel policy in place which increases the risk that internal travel related policies and 

procedures may not be consistently followed. Specifically, there were no internal policies related to 

cash advances, allowable expenses for local travel, and return weekend trips home during extended 

travel. We also identified a few travel card compliance issues, but in all instances reviewed, the 

employees’ reimbursements appeared to be for legitimate business expenses.

 1 Individual travel cards distributed to agency employees for official FEC business.

2 The OIG did not review either the FEC’s one centrally billed travel card, due to low risk, or the fleet charge cards, as 

this process was reviewed under the OIG’s Audit of the Commission’s Property Management Controls: 

http://www.fec.gov/fecig/property.pdf.
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During the course of this inspection, the OIG acknowledges that Management has made significant 

progress to improve the travel card program as follows:

• The Administrative Services Division (ASD) has drafted a Travel Card Program Policy that 

describes, but is not limited to, the process for obtaining a travel card, travel card holders 

responsibilities, and the controls in place around the physical travel card;

• The ASD has implemented monitoring controls to review and detect inappropriate use and 

abuse of travel card activity; and

• The OCFO has drafted and is in the process of finalizing the FEC Travel Manual (The Travel 

Policy) to formally document how the agency will implement and comply with the FTR, the 

Charge Card Act, and OMB A-123, Appendix B.

As the FTR states that each agency must have a travel policy to document how the agency will 

implement and comply with the FTR, the OIG strongly encourages the FEC to finalize and 

implement the travel policies in a timely manner. The OIG has also provided Management with 

additional suggestions to further enhance the processes and controls for the travel card program 

which are detailed in a separate Management Letter.

 

Summary Results of the Purchase Card Program

Currently, only six FEC employees have been issued purchase cards. Purchase cards are mainly used 

for micro-purchases (up to $3,000 per transaction) including training, professional services, and 

supplies. There are two OCFO purchase card holders that also make other types of purchases against 

an established contract or approved purchase order (PO) up to their single purchase limit or 

simplified acquisition threshold of $150,000 (whichever is lower). All purchase card holders are 

required to either obtain an approved training request (if applicable), an approved purchase 

requisition, and/or an approved purchase order before the transaction can be made. Given the current 

volume of purchase card transactions and the internal controls around the approval and payment 

process, the OIG concludes that the potential risk of fraudulent purchase card transactions is 

minimal at this time. 

OIG did identify a few additional process improvement and best practice suggestions that have been 

provided to Management in a separate Management Letter.
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Inspection Results & Recommendations

I. Travel Card Program3

The OIG assessed the controls over the travel card program and performed detailed testing of 

travel vouchers as follows:

• The OIG judgmentally selected and reviewed one travel voucher for each of the top 10 

travelers who had the most transaction activity from the period of January 2013 to 

April 2014; and 

• The OIG reviewed the travel card activity report obtained from the Administrative 

Services Division to look for unusual or inappropriate transactions. From this report, 

OIG judgmentally selected 20 transactions that could potentially be inappropriate 

charges and obtained the related travel vouchers. In total, the OIG reviewed thirty (30)

travel vouchers.

Based on work performed, the OIG concludes that controls around the travel card program are 

adequately designed to ensure only authorized travel expenses that are in compliance with the 

Federal Travel Regulations (FTR) are reimbursed to employees. Also, employees are 

generally complying with standard operating procedures and the FTR. Listed below are areas 

to strengthen controls and minor compliance issues that were identified:

A. Inconsistent Application of FEC Standard Travel 

Practices 

For the period under review, there was no formal FEC 

directive for travel or a travel card program policy in place. Therefore, there was no

written guidance for the OIG to use to confirm if employees were in compliance with 

internal travel practices that are allowable under the FTR but at the discretion of the 

agency. For compliance purposes, the OIG referred to the FTR and information obtained 

during interviews with the OCFO and the ASD related to the FEC’s standard operating 

procedures (SOPs). 

The OIG was informed that the FEC follows the General Services Administration’s 

(GSA) SmartPay Program,

4 and notes that the Office of the Chief Financial Officer’s

accounting manual includes a brief overview of how travel should be requested, approved, 

and processed for payment.

 3 The scope for the travel card program review and testing included the process, controls, and transactions related to 

individually billed (IBA) travel cards only. 

4 GSA SmartPay Program is the largest government contracted payment solution that issues travel cards and purchase 

cards that generate annual refunds based on total spending to participating agencies. There are standard guidelines that 

agency employees have to follow. 

FEC travel program 

requirements and 

standard practices 

were not documented.
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However, FEC travel requirements were not memorialized to clarify how the agency will 

require its employees to comply with the general rules described in the FTR, including but 

not limited to the following: 

1) When cash advances are allowed;

2) Protocol for booking airfare while on official business travel at a temporary duty 

(TDY) assignment;

3) What constitutes local travel and when local travel is reimbursable via the travel 

card (e.g., minimum mileage from home, transportation during training);

4) How the cost incurred for returning home on weekends during a TDY assignment

should be handled; and

5) What type of business related expenses (e.g., shipping, supplies, equipment)

incurred during official travel can be paid with the travel card.

As a result, we identified the following charges that were either not consistent with FEC 

standard practices or the standard practice was not consistently applied:

• two employees used their travel card to obtain multiple cash advances during a 

single extended business trip while also utilizing the travel card to pay for meals;

• one cardholder charged non-travel business expenses (2 hand held scanners); and

• return trips home during extended travel were not reimbursed in the same manner. 

For example, one cardholder was reimbursed for airfare related to a return trip 

home during extended travel while other employees received the equivalent of 

M&IE per diem in lieu of the cost of airfare.

According to the Federal Travel Regulation, each Agency should have a travel policy that 

clarifies and identifies how the agency will implement and comply with the regulations. In 

addition, per FTR § 301-51.200(a), cash advances are for “...expenses that as a general 

rule cannot be charged and must be paid using cash...” 

Management is in the process of finalizing a travel manual (The Travel Policy), and a 

travel card program policy. The OIG has reviewed the draft policies and found that all 

aspects of the FTR have been addressed. The OIG also provided feedback on the draft 

travel policies. 

Recommendation

1a. The Travel Policy and Travel Card Program Policy should be finalized and approved

in a timely manner and distributed to all employees via email as well as posted to the

FEC’s intranet website (FECNet). 
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Management Response:

Management concurs with the recommendation. Management will post the Travel 

Policy and Travel Card Program Policy to FECNet and will distribute the policies via 

e-mail within 30 days of approval. 

OIG Comment:

The OIG looks forward to reviewing Management’s corrective action plan to ensure it 

fully addresses this recommendation.

1b. FEC Travel Policy should limit and specify the circumstances that allow travel

cardholders the ability to use their travel card to obtain cash advances via ATMs. 

Management Response:

Management concurs with the recommendation. The agency will incorporate guidance 

that is more specific and include examples in the FEC Travel Policy to ensure 

employees clearly understand when ATM cash advances are allowable accordance 

with Federal Travel Regulations. 

OIG Comment:

The OIG looks forward to reviewing Management’s corrective action plan to ensure it 

fully addresses this recommendation.

B. Noncompliant Use of Travel Cards

We found the following instances of noncompliance:

• three employees charged personal items (1 airfare, 3 

Metrorail charges) on travel cards totaling $521; and

• seven employees charged airfare on their individually billed travel card (3 for 

approved business travel and 4 for weekend return trips home during extended travel). 

The OIG notes that FEC standard practice is that all airfare should be charged on the 

centrally billed travel card.

5

However, for all instances noted above, the OIG verified that the employees did not 

submit personal charges and only received reimbursement for allowable business 

expenses. 

As previously mentioned, the FEC did not have written travel policies, and travel card 

activity was not being monitored for compliance/misuse during the period under review. 

The OIG acknowledges that the ASD has since implemented monitoring controls to detect 

travel card misuse and/or abuse. 

 5 FEC’s Finance Office processes airfare for all FEC employees on approved official business travel via one centrally 

billed agency account. 

No indication of 

gross negligence, 

fraud, or abuse was 

found. 
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According to OMB Circular A-123, Appendix B, and the Charge Card Act, the FEC must 

ensure that internal controls around travel cards are effective to prevent and detect abuse

and misuse, and to ensure compliance with applicable laws, regulations, and guidance.

The risks of not having effective internal controls include:

• intentional or unintentional improper use of travel cards by employees, which 

might not be detected in a timely manner;

• employees could be potentially abusing the cash advance privilege for personal 

use, which violates the FTR and increases the amount of cash advance fees paid by 

the agency; and

• internal standard travel practices may be inconsistently applied, which could result 

in employees not receiving equitable reimbursement for similar travel expenses 

incurred.

The OIG has provided Management with feedback on the travel card monitoring process. 

Once the travel policies and monitoring controls have been fully implemented, the OIG 

anticipates that they should be effective in detecting and deterring potential misuse/abuse 

of travel cards and reduce all the risks mentioned above.

Recommendation 

2a. Management should ensure that travel card monitoring control activity is adequately

documented. 

Management Response:

Management concurs with the recommendation. To ensure travel card monitoring 

activity is adequately documented the Agency / Organization Program Coordinator

(A / OPC), within the Finance Division and the A / OPC, within the Administrative 

Services Division will maintain supporting documentation to support each month the 

monitoring control activity takes place and any actions taken to notify employees and 

their supervisors of any infractions identified. If there is evidence of fraud, waste or 

abuse the matter will be submitted to the OCFO who will report the matter to the 

Office of Human Resources (OHR) and the OIG for investigation, if applicable. The 

OCFO will maintain a record of any notifications submitted to the OIG or OHR.

OIG Comment:

The OIG looks forward to reviewing Management’s corrective action plan to ensure it 

fully addresses this recommendation.

2b. Once the travel related policies are approved, Management should ensure monitoring

control parameters are updated to ensure compliance with the most current internal 

policy and standard practices. 
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Management Response:

Management will review travel related policies annually to ensure policies are up-todate and adequately reflect internal policy and standard practices. Additionally, 

supervisors responsible for the oversight of FEC personnel responsible for monitoring 

travel control parameters will perform periodic reviews to ensure the reviews are 

performed timely in accordance with FEC travel policies. 

OIG Comment:

The OIG looks forward to reviewing Management’s corrective action plan to ensure it 

fully addresses this recommendation.

II. Purchase Card Program

The OIG assessed the controls over the purchase card program and performed detailed testing 

of 35 purchase card transactions. Based on work performed, the OIG concludes that controls 

around the purchase card program are adequately designed to ensure improper and/or 

unauthorized charges should be detected and not paid with government funds.
Inspection of the FEC’s Travel and Purchase Card Programs – OIG-14-05 Page | 1

APPENDIX A - BACKGROUND

The Federal Election Commission (FEC) participates in the General Services Administration’s (GSA) 

SmartPay Program. FEC uses three types of charge card programs for official purchases; travel

cards, purchase cards, and fleet cards. Under the GSA Master Contract, FEC uses Citibank as the 

travel card and purchase card provider. The Chief Financial Officer (CFO) has overall responsibility 

for FEC’s charge card management program. 

The government laws/regulations/guidance that are applicable to FEC charge card programs are:

• The Federal Managers’ Financial Integrity Act (FMFIA);

• The Office of Management and Budget’s (OMB) Circular A-123, Appendix B;

• The Charge Card Abuse and Loss Prevention Act of 2012 (Public Law 112-194);

• OMB Memorandum M-13-21, Implementation of the Charge Card Abuse and Loss 

Prevention Act of 2012;

• Federal Travel Regulations (FTR); and 

• Federal Acquisition Regulations (FAR)

According to OMB A-123, Appendix B and the Charge Card Abuse and Loss Prevention Act of 

2012, the FEC is required:

“to establish and maintain safeguards and internal controls for purchase cards, travel cards, 

fleet integrated cards, and centrally billed accounts.” 

Each agency must develop a charge card management plan that outlines how the agency will 

implement the related requirements. The purpose of the charge card management plan is to guide the 

agency to achieve and maintain appropriate use of charge cards, and to document how the agency 

will maintain adequate internal controls to reduce the potential for delinquency, misuse, and fraud. 

The charge card management plan must be updated and submitted to OMB annually.

The Charge Card Act is consistent with other statutory responsibilities to avoid improper payments, 

but also establishes additional reporting and audit requirements as outlined in the OMB 

Memorandum M-13-21, as follows:

• Agency’s Management must submit semi-annual reports of purchase card violations to OMB

(if Agency meets the $10 million purchase card spending threshold);

6

• Agency’s Office of Inspector General must perform, at least annually, an assessment of all 

charge card programs;

 6 As of FY 2014, the FEC did not meet the $10 million purchase card spending threshold and therefore is not required to 

submit a purchase card violation report.
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• Agency’s Office of Inspector General must perform audits of travel cards (if prior year travel 

card spending meets the $10 million threshold);

7 and

• Agency’s OIG must submit an annual purchase and travel card audit recommendation status 

report to OMB. 

The FEC uses two types of travel cards; the centrally billed account (CBA) travel cards and 

individually billed account (IBA) travel cards. The Office of the Chief Financial Officer (OCFO) has 

overall responsibility for the CBA travel card (which is used to pay for airfare for official travel and 

other fees associated with the Travel Management Center), and the Administrative Services Division

(ASD) is the Agency/Organization Program Coordinator (A / OPC) responsible for the IBA travel 

card program (travel cards used by and billed directly to employees). 

Overview of the IBA Travel Card Program

The OCFO is responsible for authorizing, approving, and certifying travel expense payments. In 

addition, the OCFO determines the governing policies over the proper use of the travel card. The 

ASD is responsible for managing the travel card program and serves as the liaison between the 

Agency and the travel card contractor. The ASD is also responsible for:

• establishing new accounts;

• coordinating the issuance of travel cards;

• distributing new and replacement cards;

• canceling and destroying cards for terminated employees;

• training cardholders; 

• monitoring and following-up on delinquent accounts; and

• monitoring travel card activity for improper use and abuse.

Currently, there are 126 active IBA travel card holders. The travel card must be used for all official 

travel expenses, to the extent the card is accepted, including lodging, transportation (excluding 

airfare), rental cars, meals, and other travel related expenses. Charges are billed directly to the 

employee. With the exception of the Audit Division and the Commissioners, most travel card holders 

are infrequent travelers (less than once or twice per year). Travelers must request and obtain an 

approved travel authorization (TA) before initiating official travel. The TA form must be signed by 

the employee’s supervisor and then submitted to the OCFO - Budget Office to ensure the office has 

sufficient budgeted funds for official travel. Once the travel has been approved by the OCFO, the 

travel request is assigned a travel authorization number. Employees will not be reimbursed for travel 

expenses without a TA number. 

When the employee returns from travel, they must complete a travel voucher (TV) along with 

required documentation (itemized hotel bill and any charges over $75) within seven days, which is 

then reviewed and approved by the appropriate supervisor/division head and forwarded to the OCFO.

 7 As of FY 2014, the FEC did not meet the $10 million travel card spending threshold, and no purchase card threshold 

established for audit purposes. Therefore, the OIG uses the annual risk assessment process to determine the scope, 

frequency, and type of audit, inspection, or review to be conducted.
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An OCFO financial analyst reviews the travel voucher for completeness and verifies lodging and 

M&IE per diem rates agree to the official GSA rate table. The financial analyst also ensures that 

other travel related expenses agree with supporting receipts (if required) and are allowable according 

to the FTR. The financial analyst then approves the TV for payment. The FEC will reimburse 

employees for authorized and allowable travel expenses in accordance with GSA’s Federal Travel 

Regulation (FTR), FTR Part 301.52 requirements.

Overview of the Purchase Card Program

The Acting CFO has delegated the Procurement Director as the A/OPC for the purchase card 

program. Currently only six FEC employees have been issued purchase cards. All purchase card 

holders, with the exception of the two cardholders that work in Procurement and one OCFO financial 

analyst, use the purchase card for micro-purchases only (a single purchase limit of $3,000), which 

complies with the Federal Acquisition Regulation (FAR)

8

. The other three purchase card holders use 

the purchase cards for micro-purchases as well as other purchases against an established contract or 

approved purchase order (PO) up to their single purchase limit or simplified acquisition threshold of 

$100,000 (whichever is lower).

9

Per the FEC’s purchase card policy (ProcPro 030), all purchases made with a purchase card, with the 

exception of training-related charges, must be preapproved via a formal purchase request and/or PO 

no matter the amount (per the FAR, micro-purchases do not require competitive price quotes or POs). 

Training-related expenses must have an approved training request (TA). Any purchase made against 

a PO must be approved by the contracting officer and the funds must be obligated before it can be 

processed for payment. Once the consolidated bill is generated by the vendor, each purchase card 

holder is responsible for reviewing an electronic copy of their charges and verifying that all 

transactions are legitimate and for the correct amount. The card holder must approve the bill and 

complete a receiving report for all charges by PO. The receiving report certifies that the order is 

complete and related goods or services were received. This information is then forwarded to an 

OCFO financial analyst who performs the monthly purchase card reconciliation and approves and 

certifies the payments. The purchase card monthly reconciliation entails listing each purchase card 

transaction from the consolidated billing statement along with the related PO included on the 

individual receiving reports received by the cardholders, verifying there is an approved PO in the 

purchasing system, and ensuring that the PO/TA amount has been obligated. Only approved charges 

that have been obligated will be certified for payment processing. Actual payment of the consolidated 

purchase card bill is done by the GSA. Before the purchase card bill is paid by the GSA, each 

transaction is verified in the FEC financial system to ensure it has been obligated. 

 8 These limits comply with the FAR section 2.101, which states that actions below the micro-purchase threshold are for 

procurements less than $3,000 for goods, $2,500 for services, and $2,000 for construction that may be awarded without 

soliciting competitive quotations.

9 According to the FAR, POs are used for awards that are issued based on competitive price quotes/proposals for actions 

above the micro-purchase thresholds. Actions below the micro-purchase threshold may be awarded without soliciting 

competitive quotations and do not require a purchase order. 
Inspection of the FEC’s Travel and Purchase Card Programs – OIG-14-05 Page | 1

APPENDIX B - OBJECTIVES, SCOPE AND METHODOLOGY

Objectives

The OIG’s objectives for this inspection were to:

• ensure that card holders and approvers are complying with applicable charge card policies, 

procedures, regulations, and guidance;

• ensure that effective internal controls are in place to prevent and detect charge card fraud, 

abuse, or misuse;

• assess the FEC's Charge Card Management Plan to ensure the plan is adequately designed to 

meet the requirements of OMB Circular A-123 – Appendix B and the Charge Card Loss 

Prevention Act of 2012; and

• ensure current and planned FEC internal policies and standard operating procedures are 

aligned with the Charge Card Management Plan.

Scope

The scope of the inspection included review of the FEC’s travel card and purchase card programs. 

We assessed the current processes and procedures in place as of June 2014, and the scope for detailed 

testing purposes was from January 2013 through April 2014 (covering parts of FYs 2013 and 2014).

Methodology 

The OIG conducted the following inspection steps:

• Reviewed applicable laws, regulations, and guidance related to charge card programs;

• Reviewed the FEC’s policies and procedures related to the travel card program and the 

purchase card program;

• Reviewed the FEC’s charge card management plan and evaluated against the OMB A-123, 

Appendix B, and the Charge Card Act to ensure adequate and in compliance;

• Interviewed OCFO (program office for travel voucher processing and purchase card program)

and Administrative Services employees (program office for travel cards) to gain a better 

understating of the FEC’s internal control processes;

• Performed observation of the OCFO travel voucher review and approval process and the 

monthly purchase card reconciliation process to determine if processes were operating as 

designed.
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• Obtained Citibank travel card activity report, identified the top 10 travelers who had the most 

transaction activity from January 1, 2013 to April 15, 2014, and judgmentally selected one 

travel voucher to review from each top ten traveler and performed the following: 

o Ensured the travel vouchers was properly completed;

o Ensured only authorized and allowable travel expenses were included for 

reimbursement;

o Ensured that per diem rates agreed to applicable GSA Smartpay rate tables and total 

per diems accurately calculated;

o Ensured that supporting documentation (e.g. receipts/hotel bill) was submitted where 

applicable; and

o Determined if cash advances were properly used.

• Obtained travel card activity report from January 1, 2013, to April 15, 2014, to review for 

potential unusual or inappropriate charges, judgmentally selected 20 transactions and obtained 

the applicable travel voucher, and performed the following:

 

o determined if the employee submitted the charge on the travel voucher for 

reimbursement; 

o reviewed receipt (if submitted) for description of expense and to determine if related 

to an allowable travel expense; or

o if charge not included on travel voucher, followed up with employee to confirm if 

charge was a personal expense and to obtain explanation for personal charge. 

• Performed an on-the-spot review of travel charge cards physically on hand in the ASD and 

performed follow-up procedures to identify if:

o there were any expired cards on hand;

o travel card holders had been notified that their card had arrived and was ready for pick 

up; and

o there were cards on hand for card holders who requested cards be canceled. 
Inspection of the FEC’s Travel and Purchase Card Programs – OIG-14-05 Page | 3

• Obtained Citibank purchase card activity report and judgmentally sampled 35 purchase card 

transactions for the six purchase card holders with activity during the test period. We 

judgmentally selected the 35 purchases based on transaction amount, merchant code category, 

purchase descriptions, and dates to ensure a cross section of transactions and performed the 

following:

o requested and reviewed supporting documentation to ensure transaction amounts 

agreed to invoice/receipt/PO; and 

o determined that purchases were authorized prior to charging and represent legitimate 

business expenses.
 

THE FEDERAL ELECTION COMMISSION 

Washington, DC 20463 

January 30, 2015

MEMORANDUM 

To: Lynne McFarland, Inspector General 

FROM: Judy Berning, Acting Chief Financial Officer 

SUBJECT: Management Response to Charge Card Inspection Report 

Please find attached the management response to the Charge Card Inspection Report and 

related findings as provide in the draft document sent by the Office of Inspector General 

on January 15, 2015. 

Please contact me at extension 1217 should there be additional questions. 

cc: India Robinson, Administrative Services Division Manager 

 
 

or toll free at 1-800-424-9530 (press 0; then dial 1015) 

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Visit or write to us at 999 E Street, N.W., Suite 940, Washington DC 20463 

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