Census Bureau 

2010 Census: 

The Partner Support Program 

Lacked Adequate Controls 

for Monitoring Purchases 

and Ensuring Compliance 

Final Report No. OIG-11-013-A 

November 18, 2010 

FOR PUBLIC RELEASE 

Office of Audit and Evaluation

U.S. DEPARTMENT OF COMMERCE

Office of Inspector General

Report In Brief eport In Brief

U.S. Department of Commerce Offi ce of Inspector General

November 18, 2010

Census Bureau

2010 Census: The Partner Support Program Lacked 

Adequate Controls for Monitoring Purchases and 

Ensuring Compliance (OIG-11-013-A)

 

Why We Did this Review

Background

PSP was developed by the 

Census Bureau to complement 

the outreach efforts of Census’s 

partner organizations. Partner 

organizations include government, 

non-profit, and corporate or community organizations that formally 

pledged their commitment to 

share the 2010 Census message 

and mobilize their constituents 

in support of the bureau’s goal of 

achieving a complete and accurate 

count. 

Through its partners, Census 

tried to reach a wider audience of 

historically “hard-to-count” demographic groups. The bureau also 

sought to increase mail response, 

reduce undercounting, and communicate a consistent message 

about the decennial census.

Census worked with its partners 

in a variety of ways to spread the 

bureau’s message, including purchasing promotional items (such 

as pens, flyers, or caps) for the 

partners to distribute locally, and 

participating in festivals or other 

community events.

What We Found

What We Recommended

As part of our ongoing oversight 

of the 2010 census, the Office of 

Inspector General (OIG) audited 

purchases made under the Partner 

Support Program (PSP) to determine 

(1) whether Census Bureau employees effectively managed PSP 

purchases to prevent fraud, waste, 

and abuse; 

(2) whether bureau employees 

correctly followed PSP procedures; and 

(3) whether employees responsible for administering the program 

were adequately trained. 

While Census has several reports and systems in place to monitor purchases made for 

partners, few of the systems actually communicate with or reconcile to one another. 

This makes it difficult for Census headquarters to track purchases over the long term. 

Purchases that had been miscoded in some of these systems further hindered management’s ability to monitor the program. 

Some Census employees who had purchasing authority did not follow federal and 

Commerce acquisition guidelines and policies. For example, employees paid intermediary vendors with the understanding that the vendor receiving the payment would forward funds to the vendor providing the products or services. In other cases, employees 

placed and received large orders without authorization, failed to safeguard government 

purchase card account information, or did not properly document purchase details. We 

also discovered a potential conflict of interest between a partner and a vendor that had 

gone undetected until several purchases had already been made.

Finally, purchasing for the program started later than anticipated, and the program 

changed rapidly over its lifecycle. These factors made it difficult to train Census staff 

thoroughly and in a timely fashion. Although the bureau distributed written guidance to 

staff, the guidance was often unclear or misunderstood by them.

The last PSP purchase was approved in May 2010. Therefore, our recommendations focus on planning for future decennials. Should Census implement a similar promotional 

outreach program in 2020, we recommend the following:

1. Ensure that manual and automated tracking systems are fully functional and integrated, and that reconciliation with the financial accounting system is in place prior 

to implementing the program.

2. Improve management oversight of purchase card purchases to identify staff noncompliance with policies and procedures for both purchase cardholders and partnership staff.

3. Conduct timely training that reemphasizes federal and Commerce acquisition rules, 

such as split purchases, conflicts of interests, and other procedural rules; and provide manuals with updates and step-by-step processing transaction instructions. 
U.S. Department of Commerce Final Report OIG-11-013-A 

Office of Inspector General November 18, 2010 

Contents

Introduction ..................................................................................................................................... 1

Findings........................................................................................................................................... 3

I. Reporting and System Limitations Impeded Management’s Ability to Effectively 

Monitor Purchases .............................................................................................................. 3

II. Employees Did Not Comply with Federal Acquisition and Financial Policies and 

Program Guidelines, Leading to an Increased Risk of Improper Payments ....................... 4

III. Training on Procurement Processes Needs Improvement .................................................. 7

Recommendations: Looking Ahead to 2020 ................................................................................... 9

Summary of Census Comments and OIG Response ..................................................................... 11

Appendix A: Objectives, Scope, and Methodology...................................................................... 12

Appendix B: Bureau Response ..................................................................................................... 14
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Office of Inspector General November 18, 2010 

1 

Introduction

The Partner Support Program (PSP) was developed by the Census Bureau to complement the 

outreach efforts of Census’s partner organizations. Partner organizations include government, 

non-profit, and corporate or community organizations that have formally pledged their 

commitment to share the 2010 Census message and mobilize their constituents in support of the 

Census Bureau's goal of achieving a complete and accurate count. Through PSP, Census hopes 

to reach a wide audience of “hard-to-count” groups,1 increase mail response, reduce differential 

undercount,2 and communicate a consistent Census message.

Census recognizes that partners know their communities’ conditions and circumstances better 

than the bureau does, and have the appropriate connections at the national and community level 

to encourage participation in the census. In collaboration with partners who have direct access to 

specific groups the bureau considers hard to count, the bureau acquires promotional items (such 

as caps, tote bags, pens, posters, flyers, and t-shirts) and funds services (such as participant fees 

for festivals and parades, space and equipment rental, and event planning),3

 which the partners 

then use to promote the Census message among populations that have traditionally been 

undercounted. 

The funds for this program are to be used to support the basic activities of existing partners. For 

fiscal years (FYs) 2009 and 2010 the bureau allocated $24 million to this program, dividing the 

funds among its 12 regional census centers (RCCs; see figure 1 on page 2) based on a score 

representing enumeration difficulty. RCCs with higher scores received a larger portion of the 

program’s total allocation. 

Regional partnership staff work with eligible and active partners4

 to identify projects and assist 

the partners in completing and submitting the PSP application and funding request form. 

Recognizing that partnership staff in the regions were tasked with responsibly spending a large 

amount of resources in a relatively short time frame, the bureau also established a Partnership 

Procurement Unit at the National Processing Center (NPC), hiring 25 new procurement staff, 

called purchasing agents, and four clerks to assist regions with PSP funding requests.

 

1 Hard-to-count populations include but are not limited to the homeless, migrant farm workers, foreign-born individuals, African 

Americans, American Indians and Alaska natives, native Hawaiians and other Pacific Islanders, and linguistically isolated 

populations. 

2

 The net undercount is the difference between the number of people missed and the number of people counted twice, counted in 

the wrong place, or fabricated by an enumerator. The rates of undercount differ among geographic areas and between whites and 

nonwhites. This racial bias in the census undercount is known as the differential undercount. 

3

 Food and advertising constitute unallowable purchases for the program.

4

 Eligible partner organizations include those who demonstrate an active commitment to promote participation in the 2010 

Census. As of November 18, 2009, 1,809 partners were participating in the program.
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Office of Inspector General November 18, 2010 

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Figure 1. Regional Census Centers 

Source: Census Bureau website 

As part of our oversight of the 2010 census, the Office of Inspector General (OIG) audited 

purchases made under PSP to determine whether (1) Census Bureau employees effectively 

managed PSP purchases to prevent fraud, waste, and abuse; (2) bureau employees correctly 

followed PSP procedures; and (3) employees responsible for administering the program were 

adequately trained. For a complete outline of our objectives, scope, and methodology, see 

appendix A. 

We found that (1) multiple reports and systems, coupled with incorrectly coded PSP 

expenditures, made it difficult to identify the population of transactions and impeded 

management’s ability to effectively monitor purchases; (2) employees did not consistently follow 

acquisition and financial policies and program guidelines; and (3) training sessions were not 

adequate to ensure all Census staff understood the program and its purchasing processes. 

Atlanta 

Boston 

Charlotte 

Chicago 

Dallas 

Denver 

Detroit 

Kansas City 

Los Angeles 

New York 

Philadelphia 

Seattle 
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Office of Inspector General November 18, 2010 

3 

Findings

I. Reporting and System Limitations Impeded Management’s Ability to Effectively 

Monitor Purchases 

Census is required to monitor the purchases made by its employees to ensure requirements are 

met and to reduce the risk of fraud, waste, and abuse. However, Census’s ability to monitor 

purchases effectively was severely limited by numerous issues that resulted in incomplete or 

erroneous reporting or tracking of purchases. 

The bureau’s use of multiple reports and systems to track PSP purchases led to the logging of 

incomplete or erroneous information. Census used a combination of two manual reports (a 

weekly disbursement log and a disposition report) and six automated systems to monitor PSP 

activities and capture purchase card charges and purchase orders. Because of the accelerated 

schedule for implementing the program, Census chose to rely on these existing resources rather 

than designate a system to aggregate and track PSP expenditures. 

However, most of the reports and systems Census used do not reconcile to one another, nor do 

they interface with each other or with the financial accounting system; therefore, there was no 

single location from which all PSP information can be accessed. Instead, headquarters staff 

compiled a worksheet from the disbursement log data sent in by the regions. But the regional 

logs, which are not reconciled to a central Census Bureau system, sometimes contained errors, 

were incomplete, or contained amounts inconsistent with transaction information in the 

Commerce Purchase Card System (CPCS), the program used to track purchase card transactions. 

The bureau should improve its outreach program purchase tracking methods for the 2020 census. 

Manual and automated systems used for tracking PSP expenditures should be complete, reliable, 

and updated timely. Also, subsidiary records should reconcile to information recorded in the 

financial accounting system and in CPCS. 

Of the $5.7 million in anticipated credit card purchases cited by the bureau, only $4.8 million 

was coded as PSP purchases in CPCS, a difference of about $889,000 for FY2009. The 

difference between the data tracked in the CPCS and the information from the worksheet 

compiled at headquarters represents potential miscoded PSP transactions. The miscoded 

transactions resulted from account codes not being updated during the monthly account 

reconciliation process. Although Census sent a memorandum to RCC staff identifying the project 

numbers and task codes assigned to Census decennial activities, our review of records of 

approved purchase card transactions revealed that purchases were not consistently assigned the 

correct project numbers and task codes. The miscoded transactions hindered management’s 

ability to identify PSP purchases and increased the risk of improper spending on the program. 

For the next decennial, Census’s approving officials and cardholders should have procedures in 

place to ensure PSP expenditures are recorded to the correct project number and task code. 

Finally, several purchase cardholders did not comply with convenience check-writing practices, 

which increased the possibility of exceeding purchase limits and decreased the ability to disallow 

improper transactions. In order to mitigate risk and fraud exposure, the bureau imposed a $1,000 

not-to-exceed limit per convenience check. After reviewing years of data, the bureau concluded 

the $1,000 limit would cover most transactions. However, Census policy allows most 
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Office of Inspector General November 18, 2010 

4 

cardholders to spend up to $3,000 for a single transaction, resulting in purchasers writing 

multiple checks in increments of $1,000 or less to the same payee. Additionally, since PSP 

advocates the use of small businesses, some of which are unable to accept credit cards, the 

bureau’s staff wrote more checks than would have ordinarily been expected. For example, we 

identified seven instances in FY2009 in which purchase cardholders wrote multiple convenience 

checks to the same payee on the same day, and the total paid exceeded the $3,000 singlepurchase limit. 

The $1,000 limit resulted in additional costs because the servicing bank assesses a fee of 2 

percent of the value of each check. Moreover, when cardholders use convenience checks instead 

of purchase cards, the bureau employees responsible for monitoring purchase card transactions 

lose some of the oversight tools that would otherwise help them review costs and detect 

potentially unallowable transactions. To compensate for this uncertainty, the Department 

requires bureaus and agencies to conduct a 100 percent audit of convenience checks, resulting in 

additional cost and effort. The bureau should consider revisiting whether the $1,000-per-check 

limit on convenience checks will still be sufficient to cover purchases in future outreach 

programs. 

II. Employees Did Not Comply with Federal Acquisition and Financial Policies and 

Program Guidelines, Leading to an Increased Risk of Improper Payments 

Direct Partner Support purchases, which partners initiate in order to effectively reach a specific 

hard-to-count group, are made using government purchase cards and cannot exceed the 

government’s $3,000 limit for micro-purchases. Figure 2 summarizes the bureau’s business 

process for staff to follow when making Direct Partner Support purchases. By contrast, Special 

Initiatives purchases, also used in PSP, are initiated by one of the RCC directors in support of 

that region rather than a specific partner. Special Initiatives purchases can exceed $3,000; there 

are no limits on products and services purchased, and a government purchase order can be used. 

Figure 2. Overview of the Direct Partner Support Purchase Process 

 

Source: OIG 

Application submitted

• Partnership specialists 

(PS) promote the 

program to eligible 

partner organizations

• Partner organizations 

complete and submit to 

the PS a PSP 

application

• PS forwards to RCC 

management

Application reviewed

• Regional director or a 

delegate, such as an 

area regional Census 

manager, reviews 

applications

• RCC forwards approved 

applications to the NPC 

or to a purchase 

cardholder at the RCC

• PS and partner notified if 

the application is denied

Approved applications 

processed

• Cardholder notifies 

partner of approval, 

orders products/services 

from the vendor

• Cardholder is notified of 

delivery and acceptance

• Cardholder pays the 

vendor

• RCC staff update the 

contact database 
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Office of Inspector General November 18, 2010 

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Although the bureau launched PSP in May 2009, most regions did not begin spending until July. 

The volume of Direct Partner Support purchases increased significantly between August and 

December 2009. The NPC began processing Special Initiatives purchases in late August 2009. 

While our audit included FY2009 and FY2010 purchases, the majority of the transactions 

selected and records examined apply to FY2009. 

We identified cases in which partners, employees, and purchase cardholders did not act in 

accordance with federal and bureau purchase policies and did not follow procedures properly. 

We found a broad range of types of noncompliance in several regions, including the following 

examples: 

• Purchase cardholders failed to comply with policy by paying intermediary vendors with 

the understanding that the vendor receiving the payment would forward funds to the 

vendor providing the products and services. We identified 11 payments totaling $25,713 

that showed no affiliation between the vendors that provided the products or services and 

those that received the payments. In 10 cases, a vendor that did not have a terminal on 

which to run credit transactions processed the purchase using a neighboring business’s 

credit card terminal.5

 Although it is permissible for parent companies and affiliates to 

process charges on vendors’ behalf, purchase cardholders should not pay vendors that did 

not provide products or services. For example, rather than running transactions on 

another vendor's terminal, if the vendors providing the products or services do not have 

terminals of their own, they should be paid using convenience checks. If an unexpected 

charge appears on the cardholder’s statement or on the CPCS purchase log, the 

cardholder should dispute the charge. 

• In one region, partnership staff placed a large order (for 23,000 t-shirts to be distributed 

at concerts) before obtaining the proper written approval. The regional director signed the 

required order form weeks after—and the contracting officer signed the purchase order 

months after—the staff received the t-shirts. While written justification for not complying 

with contractor selection and acquisition requirements6 had been included in the files, it 

was dated over 50 days after the shirts had been received. Without an approved purchase 

order, NPC’s finance staff could not legally pay the contractor for the products, even 

though the region had already accepted them. In the future, controls should be in place to 

ensure purchases and other significant events are authorized and executed only by 

cardholders and authorizing officials.7

• Of the FY2009 purchase card transactions coded to PSP, we identified 171 occurrences 

of cardholders placing multiple orders with the same vendor on the same day for very 

similar products, which if combined were well above the $3,000 micro-purchase limit. 

For example, on one business day seven cardholders in one region incurred 

86 transactions, each below the $3,000 threshold, which resulted in a vendor receiving 

 

5

 One of the 11 payments we reviewed was to a third party processor (in this case, GoogleTM), which is an allowable practice in 

certain circumstances and when documented in compliance with Department policy. The Commerce Acquisition Manual, Ch. 

1313.301, requires the following documentation: merchant name, third party processor name, transaction amount, and a brief 

statement explaining why it was necessary to purchase the product or service from that merchant.

6

 According to the justification for not complying, the partner needed the t-shirts quickly so they could be distributed at three 

concerts in July and August 2009. 

7

 Department of Commerce, Office of Financial Management. Accounting Principles and Standards Handbook, Section 6.0.03. 
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$91,000 for promotional items. The bureau’s position is that this did not break the law or 

Department policy because the purchases represent unique orders that happen to have 

been acquired from the same vendor on the same day. Based on a legal review of this 

issue, we determined the fragmentation of promotional item requirements into micropurchases is likely inappropriate because in many instances the bureau placed 

consecutive orders with the same vendor for very similar products, which, if combined, 

were well above $3,000. Although the acquisition regulations permit use of streamlined 

procedures for filling needs below a purchase threshold of $3,000, the acquisition of 

items above $3,000 is subject to additional financial controls and competitive procedures 

to protect the government’s interests. Purchase cardholders should follow the Commerce 

Acquisition Manual (CAM), which requires that cardholders comply with spending limits 

and not “split requirements.” 8 Also, incurring repeated small-dollar charges, as occurred 

frequently with the PSP, potentially goes against one of the purposes of simplified 

acquisitions, which is to minimize administrative costs. 

• An apparent conflict of interest between a partner and a vendor was discovered after the 

partner, rather than the cardholder, had already ordered the products. The partner and the 

vendor that provided the promotional items are brothers and share office space. Between 

September 11 and November 2, 2009, this vendor received three orders for multiple 

partners totaling almost $9,000 in PSP purchases. Although the micro-purchase card rules 

allow flexibility, the Commerce Acquisition Regulation (CAR) and the Federal 

Acquisition Regulation (FAR) require that the contractor disclose actual or potential 

organizational conflicts of interest, even when the award has already been made.9

 In this 

case, however, the vendor did not follow this requirement. As part of partnership program 

training in future decennials, management should remind partnership staff with 

procurement and acquisition responsibilities to be alert for potential conflicts of interest. 

Only cardholders, not partners, should place orders. 

• Purchase cardholders sometimes sent to the vendor, by fax, the purchase card account 

number, card expiration date, name on the card, and three-digit security code on the back 

of the card. Purchase cardholders had little to no assurance that the vendor would keep 

this information confidential. Although purchase card accounts that were obtained 

specifically for PSP have been deactivated, in the future purchase cardholders should 

better safeguard account information. 

• Partnership staff did not consistently follow PSP business processes and guidelines 

regarding disbursement of program funds and limits on partner participation, resulting in 

32 partners in three regions receiving products and services above the amount allowed; 

partnership staff in the field did not consistently forward the necessary documentation to 

purchase cardholders, causing delays in processing requests; and some cardholders paid 

in advance for goods and services, which in most cases does not comply with Department 

policies. We reviewed documents—such as packing lists, receiving reports, photographs, 

 

8 CAM, Ch. 1313.301 §3.1 and appendix A. 

9 CAR §§ 1309.507-2(a), 1352.209-71; FAR Subpart 9.5. Under FAR, an “organizational conflict of interest” may arise when, 

due to other activities or relationships with other persons, a person is unable or potentially unable to render impartial assistance or 

advice to the government, the person’s objectivity in performing the contract work is or might be otherwise impaired, or the 

person has an unfair competitive advantage. FAR § 2.101.
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Office of Inspector General November 18, 2010 

7 

and e-mail—related to those purchases we audited that had been paid in advance. Our 

review demonstrated that the products or services had either been received or were in the 

process of being received. Cardholders should not pay without ensuring receipt and 

acceptance of goods and services. Also, regions should ensure their cardholders do not 

pay for products and services in advance. 

III. Training on Procurement Processes Needs Improvement 

The bureau offered training to partnership staff in the regions and to those responsible for 

administering the program in May and October 2009. Twenty-one of the 47 cardholders in the 

RCCs who had PSP purchasing responsibilities attended the training on May 20, 2009. The 

25 purchasing agents and four clerks in the NPC Partnership Procurement Unit were trained on 

July 1, 2009. Some of the regional managers who were not purchase cardholders but were 

responsible for reviewing and approving program expenditures attended training. Their presence, 

while valuable, was not the focus of our evaluation of the training. 

These training sessions were not adequate to ensure all Census staff understood the program and 

its purchasing processes. We interviewed two deputy regional directors, three assistant regional 

census managers, and 12 purchase cardholders to determine whether they understood the 

allowable uses of PSP funds, purchase card procedures, and acquisition requirements. Eight of 

the cardholders did not have previous government purchase card experience. The inexperienced 

cardholders at the RCCs believed the training was insufficient. 

There were rapid changes in how the program operated and little time for the bureau to respond 

with appropriate training and communication to its field staff. Although written guidance was 

distributed to purchase cardholders, some of the content was unclear or misunderstood. For 

instance, cardholders found the guidance on split purchases lacked clarity. The bureau also did 

not anticipate some of the scenarios and challenges of using purchase cards to expedite payments 

for the program, many of which were described in finding II. Initial PSP training may have 

excluded topics and specific guidance that the cardholders needed. As a result, purchase 

cardholders in the regions felt after the initial training that it was left to them to figure out how to 

process PSP transactions. 

Census created a business process model in which NPC purchasing agents would process PSP 

purchases for 11 of the 12 RCCs. (One RCC opted out of this model.) The NPC purchasing 

agents were in place and functioning later than expected, leaving an even shorter window of time 

for the RCCs to use their portion of the $10 million allocated to the program in FY2009. As a 

result, 7 of the 12 RCCs processed the majority of FY2009 micro-purchases locally and the NPC 

staff was underutilized. 

Recognizing that some topics were either overlooked or inadequately covered in the first round 

of training, the bureau responded by conducting another training session on October 14, 2009. 

Staff we interviewed following that training felt it was especially relevant and an improvement 

compared to the initial training. 

To improve training for future outreach programs, the bureau should ensure training is timely 

and includes topics such as vendor selection (for example, rather than using the same vendor 

repeatedly to provide a good/service, widen the pool and purchase from other vendors), split 
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8 

purchases, conflicts of interest, and the other procedural issues we have addressed in this report. 

Census training should also provide updated step-by-step instructions on processing transactions 

from beginning to end. It should include internal control requirements in written manuals and 

desk procedures. 
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Office of Inspector General November 18, 2010 

9 

Recommendations: Looking Ahead to 2020

The final PSP promotional item was approved in May 2010. The next opportunity to implement 

a promotional outreach program like PSP will occur during the 2020 decennial, and it is critical 

that Census acknowledge the problems that occurred in 2010 in order to plan and operate more 

effectively for the next decennial. We recommend the following for a 2020 promotional outreach 

program: 

1. Ensure that manual and automated tracking systems are fully functional and integrated, 

and reconciliation with the financial accounting system is in place prior to program 

implementation. Make available to managers in the regions financial reports that will 

allow them to compare actual program purchases to the budget so that they and their 

partnership staff can spend the amount allocated within the expected time frame. 

2. Improve management oversight of purchase card purchases to identify staff noncompliance with policies and procedures for both purchase cardholders and partnership 

staff. Staff responsible for reviewing and approving program applications should ensure 

that products and services closely align with the program’s objectives. Managers in the 

regions with supervisory authority, such as assistant regional census managers and 

partnership coordinators, should be held accountable for and enforce compliance. Finally, 

create a policy stating that employees must comply with program guidelines or face 

disciplinary action, including suspension and termination, and communicate these 

expectations to employees. Enforce written policies limiting Direct Partner Support 

purchases to $3,000 per vendor per purchase. 

3. Conduct timely training that reemphasizes federal and Commerce acquisition rules, such 

as split purchases, conflicts of interests, and other procedural rules; and provide manuals 

with updates and step-by-step instructions. 

When reviewing PSP files in several RCCs, we observed a few practices that indicated Census 

field staff had taken the initiative to implement and follow quality assurance standards. Census 

can take practices such as these into consideration when developing future PSP training 

programs, processes, and procedures:

• In its PSP files, one RCC included reports from Census’s integrated partnership contact 

database. The reports indicate whether the partner is active and eligible to participate in 

the program. This demonstrates that the partnership staff updated the database as 

management intended.

• Another RCC created and sent to vendors a letter confirming and authorizing production 

of promotional items funded by PSP. The letter described the terms and conditions of the 

order, including a statement that the bureau is a federal agency and payment will be 

rendered after the product is received and verified. Regional staff, the cardholder, and the 

vendor signed the letter. 

• The supervisor at the Partnership Procurement Unit required NPC purchasing agents to 

use a checklist and include it in their Direct Partner Support files. The checklist is an 

administrative tool reminding the purchasing agents of the documents to obtain and steps 
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10 

to follow. The checklist helps to ensure the information and documents required to 

complete a purchase are received. 
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Office of Inspector General November 18, 2010 

11 

Summary of Census Comments and OIG Response

In its response to our draft report, Census did not dispute our findings and recommendations. The 

bureau provided additional information related to the first audit finding and made general 

comments about the second and third findings: 

1. With respect to our finding that the multiple reports and systems used for the PSP 

program did not reconcile, Census stated that all approved PSP transactions were entered 

into the Integrated Partner Contact Database (IPCD) and that these transactions were then 

compared to reports generated by two Commerce systems. 

2. In our second finding, regarding compliance with federal acquisition and financial 

requirements, Census stated that third party payers were utilized and acquisitions 

completed in compliance with CAM 1313.301. The predominant third party payers used 

were PaypalTM and Google, and Census requested that we include the number of 

incidents in relation to the total number of charges made. 

3. Census clarified that some of the regional managers attended purchase card training; we 

have added that information to the body of the report. 

The full Census response is included as appendix B of this report. 

OIG Response 

We considered the bureau’s response in preparing this final report and made a few modifications 

to the details of the report. However, we reaffirm our findings and recommendations. 

Specifically, with respect to the first finding, Census stated that reports generated by two 

Commerce systems are compared to purchases from the IPCD. Our review found that the IPCD 

was not consistently updated and PSP transactions were sometimes not recorded in the IPCD. 

Our analysis of IPCD information for 15 partners with promotional item purchases found 

transaction information for only 2 of the 15 partners in the database. Our review also found 

incorrectly coded transactions in the Commerce purchase card system. Therefore, Census’s 

requirement to enter promotional item purchases into the IPCD and compare transaction codes 

from multiple systems does not constitute a strong internal control. 

We continue to maintain that Census did not fully comply with CAM 1313.301. Purchase 

cardholder files did not, as required by the CAM, “...document the purchase card file with the 

name of the merchant, the name of the third-party processor, the amount of the transaction, and a 

brief statement explaining why it was necessary to purchase the product or service from that 

merchant.” We have included the number of transactions in which this requirement was not 

followed in the body of the report. 
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Appendix A: Objectives, Scope, and Methodology

The objectives of the audit were to determine whether (1) Census Bureau employees effectively 

managed Partner Support Program (PSP) purchases to prevent fraud, waste, and abuse; 

(2) bureau employees correctly followed PSP procedures; and (3) employees responsible for 

administering the program were adequately trained. 

We used the region-specific partnership plans; policies, procedures, and other written guidance 

the bureau disseminated to its staff; information from interviews; and procurement records in 

PSP files to evaluate the PSP proposal process, gain an understanding of Census purchase card 

and purchase order policies and procedures, and identify oversight or monitoring controls over 

purchase card transactions and purchase orders. We worked with the bureau’s two agency 

program coordinators and with two staff at the Bankcard Center to understand how they manage 

the bureau’s purchase card program and monitor transactions. 

We interviewed staff at the National Processing Center (NPC), and at the Seattle, Philadelphia, 

New York, Chicago, and Los Angeles regional census centers (RCCs). We conducted file 

reviews onsite at the NPC, Philadelphia, New York, Chicago, and Los Angeles RCCs. We 

obtained and scrutinized the PowerPoint® slides and other written guidance distributed to 

purchase cardholders at training, and evaluated whether the content of the written materials was 

adequate. 

To determine the regions to include in the site visits, we considered the amount allocated to each 

region—focusing on the regions with the highest PSP budget and regions with significant hardto-count populations. We included the NPC because business process flow charts provided by 

the bureau indicated the NPC would handle Direct Partner Support purchases for 11 of the 12 

regions. The Los Angeles RCC opted out of this model up front, deciding it would use regionally 

held purchase cards for micro-purchases initiated in its region. 

Direct Partner Support Purchases 

We determined that the computer generated data provided in the Commerce Purchase Card 

System (CPCS) was reliable, accurate, and complete by comparing payments the Census Finance 

Division disbursed to the bank to the purchase card charges in the CPCS transaction data we 

received from the bureau’s Acquisition staff. As we reviewed transactions we observed that the 

information such as the vendor name, purchase or transaction date, and amount as cited on 

source documents agreed to CPCS. 

Using computer-aided audit techniques, we analyzed the purchase card data and identified the 

highest risk transactions for review. Our transaction selection methodology involved applying 

fraud indicators to the population of purchase card charges to identify possible improper 

expenditures. Specifically, we considered purchases made on holidays and weekends, online 

purchases and purchases from third party billing services such as Paypal and Google, unusual 

vendor names and unexpected vendor category codes, transactions near the micro-purchase limit, 

multiple credits to the same vendor, convenience checks, multiple transactions with the same 

vendor and on the same purchase date, and even purchases in $50 increments. Included in the 
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228 transactions reviewed were the purchases with the highest number of hits on the fraud 

indicators.10 We did not use a statistical sample. 

Special Initiatives Purchases 

Procurement staff at the NPC and at Census headquarters provided scanned images of the 

purchase orders. We judgmentally selected 13 orders, valued at $868,443.66 in obligated funds. 

We included in the review purchase orders exceeding $50,000 and to contractors whose 

names are unfamiliar and in our judgment are unusual given the types of purchases we expect for 

the program. 

Internal Controls and Compliance with Laws and Regulations 

Our audit included an evaluation of the bureau’s internal controls and compliance with laws and 

regulations as they relate to simplified acquisition procedures, financial management and 

procurement. Key criteria we considered in conducting the audit included Federal Acquisition 

Regulation Parts 7 and 13, Office of Management and Budget Circular No. 123 appendix B, 

General Accounting Office (GAO) - Audit Guide - Auditing and Investigating the Internal 

Control of Government Purchase Card Programs GAO-03-678G (2003), Commerce Acquisition 

Manual 1313.301, Commerce Office of Financial Management Cash Management Policies and 

Procedures Handbook and Accounting Principles and Standards Handbook, and program 

guidance disseminated by Census headquarters. We obtained an understanding of the 

management controls over program purchases by interviewing managers and purchase 

cardholders and reviewing policies and procedures. We met our audit objectives by testing 

transactions. 

Audit Authority 

The audit was conducted under the authority of the Inspector General Act of 1978, as amended, 

and Department Organization Order 10-13, dated August 31, 2006. We conducted this 

performance audit in accordance with generally accepted government auditing standards. Those 

standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to 

provide a reasonable basis for our findings and conclusions based our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our findings and conclusions 

based on our audit objectives. 

 

10 We reviewed 213 out of 3,268 FY2009 transactions, and 15 transactions from the first quarter of FY2010. 
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Appendix B: Bureau Response

 
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(OAE-19782)