HUD Purchase Cards: Poor Internal Controls Resulted in Improper and Questionable Purchases
Published: 2003-04-11T00:00:00

Fast Facts:

Highlights:
section_title: Why GAO Did This Study
paragraphs: Due to the Department of Housing and Urban Development's (HUD) increasing use of purchase cards and the inherent risk associated with their use, Congress asked GAO to audit the purchase card program concentrating on assessing internal controls and determining whether purchases being made are a valid use of government funds.
section_title: What GAO Found
paragraphs: Significant internal control weaknesses in HUD's approximately $10.6 million purchase card program resulted in improper, potentially improper, and questionable purchases in fiscal year 2001. Because of these internal control weaknesses, there was often inadequate documentation supporting many purchases GAO reviewed, and as a result, GAO was unable to determine whether these purchases were a valid use of government funds. GAO also found that HUD's remedial action plan for its purchase card program does not adequately address all the control weaknesses we identified. These weaknesses created an environment in which improper purchases could be made with little risk of detection and likely contributed to the $2.3 million in improper, potentially improper, and questionable purchases GAO identified. GAO found improper and potentially improper purchases totaling about $1 million where HUD employees either split or appeared to have split purchases into multiple transactions to circumvent cardholder limits. GAO also found that HUD employees lacked adequate supporting documentation for about $1.3 million in questionable purchases including those from vendors not expected to engage in commerce with HUD, purchases made on holidays and weekends, and $74,500 in portable assets such as computer equipment and digital cameras. In these instances, it was not possible to determine what was purchased, for whom, and why. The problems GAO identified with HUD's purchase card program leave the agency vulnerable to wasteful, fraudulent, or otherwise improper purchases. Unless HUD makes specific improvements to its review and approval process, requirements for documentation and record retention, monitoring process, and remedial action plan, the department remains susceptible to fraud, waste, and abuse.

section_title: Letter
paragraphs: The use of purchase cards at the Department of Housing and Urban  Development (HUD) has been steadily increasing over the last several  years.  During fiscal year 2001, purchase cards were used to make over  24,000 purchases totaling more than $10 million compared to over 14,000  transactions totaling more than $7.6 million in fiscal year 1997.  Purchase  cards are available to federal agencies under a General Services  Administration (GSA) SmartPay Master Contract and may be used to make  purchases with minimal paperwork.  GSA administers the master contract  and also provides purchase card program guidance for government  agencies on its GSA Web site.  Individual agencies are required to  administer their own purchase card programs and set the parameters for  use by authorizing employees, establishing dollar limits, and monitoring  usage.  The benefits of using purchase cards versus traditional contracting  and payment processes are lower transaction processing costs and less  “red tape” for both the government and the vendor community.  While we  support the use of a well-controlled purchase card program to streamline  the government’s acquisition processes, it is important that agencies have  adequate internal controls in place to protect the government from fraud,  waste, and abuse.
Given HUD’s increasing use of purchase cards and the inherent risk in their  use, we were asked to assess HUD’s purchase card activities.  Specifically,  we were asked to determine if (1) HUD’s existing controls over the  purchase card program provide reasonable assurance that improper  payments will not occur or will be detected in the normal course of  business and (2) payments for purchase card transactions are properly  supported as a valid use of government funds.  During the course of our  work, the Office of Management and Budget (OMB) issued a memorandum  requiring all agencies to develop a remedial action plan to manage the risk  associated with purchase card usage.  Because of this memorandum’s  relevance, we expanded our work to include determining whether HUD’s  remedial action plan effectively addressed its internal control weaknesses.
subsections: section_title: Background
paragraphs: HUD’s purchase card program is part of the governmentwide commercial  credit card program established to simplify federal agency acquisition  processes by providing a low-cost, efficient vehicle for obtaining goods and  services from vendors.  According to Federal Acquisition Regulation (FAR)  Part 13.201(b), government purchase cards should be used for  micropurchases, which are purchases up to $2,500.  The Department of the  Treasury also requires agencies to establish approved uses and limitations  on the types of purchases and spending limits.  GSA administers the master  contract and HUD’s purchase card policy was derived from the GSA  governmentwide credit card program and tailored by HUD to meet its  specific needs.  During the period of our review—October 2000 through  September 2001—HUD was operating under a policy dated October 1995.   HUD is currently updating its purchase card policy.
HUD’s purchase card policy states that purchase cards are intended to  procure general-purpose office supplies and other support needs.  The  policy requires each approving official to develop a preapproval process to  ensure that all purchase card transactions are authorized and in  accordance with departmental and other federal regulations.  The  approving official signifies that a cardholder’s purchases are appropriate by  reviewing and signing monthly statements.
As required by the Department of the Treasury, HUD’s purchase card policy  established approved uses and limitations on the types of purchases and  dollar amounts in its purchase card policy.  This policy also includes a  detailed list of items that cardholders are prohibited from buying with their  government purchase cards.  For example, purchase or rental of  nonexpendable property (generally defined as property of a durable nature  with a life expectancy of at least 1 year), meals, drinks, entertainment or  lodging, and construction costs exceeding $2,000 are generally prohibited.   Fiscal year 2001 single purchase limits for individual cardholders, which  are required to be established by the approving officials and approved by  the departmental directors, ranged from $100 to $80,000, and their monthly  limits ranged from $100 to $300,000.  HUD was in the process of  reevaluating and where applicable, lowering these limits.  Bank One  currently services the purchase card program at HUD.
Internal control is a major part of managing an organization and is key to  ensuring proper use of government resources.  As mandated by 31 U.S.C.  3512, commonly known as the Federal Managers’ Financial Integrity Act of  1982, the Comptroller General issues standards for internal control in the  federal government.  These standards provide the overall framework for  establishing and maintaining internal control and for identifying and  addressing major performance and management challenges and areas at  greatest risk of fraud, waste, abuse, and mismanagement.  According to  these standards, internal control comprises the plans, methods, and  procedures used to meet missions, goals, and objectives.
Control activities are the policies, procedures, techniques, and mechanisms  that enforce management’s directives and help ensure that actions are  taken to address risks.  Control activities are an integral part of an entity’s  planning, implementation, review, and accountability for stewardship of  government resources and achieving effective results.  They include a wide  range of diverse activities.  Some examples of control activities include  controls over information processing, physical control over vulnerable  assets, segregation of duties, proper execution of transactions and events,  and access restrictions to and accountability for resources and records.
section_title: Scope and Methodology
paragraphs: To determine whether HUD’s existing controls over the purchase card  program provided assurance that improper purchases would be detected or  prevented in the normal course of business, we interviewed HUD staff and  performed walk-throughs of the process.  We reviewed HUD’s policies and  procedures and prior GAO reports as well as reports by HUD’s Office of  Inspector General (OIG) and independent auditors on this topic.  To test  the effectiveness of internal controls, we selected a stratified random  sample of 222 purchase card transactions made during fiscal year 2001  totaling over $1.8 million from a population of purchase card transactions  totaling $10.6 million. To identify potential improper purchases we  requested and obtained fiscal year 2001 transaction data from Bank One  and used data mining techniques and other computer analyses to identify  unusual transactions and payment patterns in HUD’s fiscal year 2001  purchase card transaction data that may be indicative of improper  purchases.
In order to determine if fiscal year 2001 purchases were adequately  supported and for a valid government use, we requested and analyzed  supporting documentation for those transactions that we identified as  potentially improper and questionable.  While we identified some improper,  potentially improper, and questionable purchases, our work was not  designed to determine the full extent of improper purchases.
We requested comments from the Secretary of Housing and Urban  Development. We conducted our work from November 2001 through  November 2002 in accordance with generally accepted government  auditing standards, and we performed our investigative work in  accordance with standards prescribed by the President’s Council on  Integrity and Efficiency.
section_title: HUD’s Internal Controls over Purchase Cards Did Not Provide Assurance That Improper Purchases Would Be Prevented or Detected
paragraphs: HUD staff did not comply with key elements of its purchase card policies  that would have helped minimize the risk of improper purchases, including  (1) obtaining preapproval for purchases, (2) retaining adequate supporting  documentation, (3) conducting supervisory review of all purchases, and   (4) periodically reviewing purchase card transactions to ensure compliance  with key aspects of the department’s policy.  This created an environment  where improper purchases could be made with little risk of detection and  likely contributed to the $2.3 million in improper, potentially improper, and  questionable purchases we identified through our data mining efforts.
GAO’s Standards for Internal Control in the Federal Government states  that transactions and other significant events should be authorized and  executed only by persons acting within the scope of their authority.  This is  the principal means of assuring that only valid transactions to exchange,  transfer, use, or commit resources and other events are initiated or entered  into.  To address these internal control standards, HUD’s purchase card  policy contains fundamental controls designed to minimize the agency’s  exposure to improper purchases.  HUD’s policy requires each approving  official to establish a preapproval process for each cardholder to ensure  that all purchases are appropriate and for official government use.  Further,  HUD’s policy states that the approving official is required to review, certify,  and monitor all cardholder purchases to ensure that they have the  necessary approvals before purchases are made.  Additionally, HUD’s  purchase card policy requires that approving officials review each  purchase along with the applicable supporting documentation in order to  certify that the purchases were appropriate and a valid use of government  funds.
Based on our review of HUD’s purchase card process, we found that most  approving officials had not established a preapproval process to ensure the  appropriateness of purchases before they are made.  Only the Information  Technology Office routinely obtained authorization prior to purchasing  items with the purchase card.  The approving official’s review of each  purchase card transaction is one of the most important controls to ensure  that all purchases are a valid use of government funds.  We found that this  critical control was seriously compromised because of inadequate  supervisory review of supporting documentation by approving officials.  To  test the effectiveness of this key internal control, we selected and tested a  stratified random sample of 222 purchase card transactions made during  fiscal year 2001.  Of the total $1.8 million purchase card transactions  selected in the statistical sample, $1.4 million lacked adequate supporting  documentation for the approving official to determine the validity of the  purchase.  Based on the results of this sample, we estimate that $4,753,253  of the total sampled population of purchases ($10,590,461) made during  fiscal year 2001 lacked adequate supporting documentation.
Our Standards for Internal Control in the Federal Government states that  internal control activities help ensure that management’s directives are  carried out.  One such activity is the appropriate documentation of  transactions.  Internal control and all transactions and other significant  events need to be clearly documented, and the documentation should be  readily available for examination.  All documentation should be properly  managed and maintained.
We determined that some of HUD’s records supporting the purchase card  program were not properly managed or maintained.  For instance, HUD  could not provide a complete and accurate list of all approving officials.   When we attempted to contact cardholders and their respective approving  officials to request supporting documentation using the list the agency  provided, at least 28 approving officials provided written notification that  cardholders assigned to them according to HUD records were not their  responsibility.  According to HUD officials, the purchase card program  administrator is not routinely informed of changes in approving officials  and often does not have the time to update the list regularly.  Because HUD  does not know who should be approving purchases, there is an increased  risk of collusion as well as a general lack of accountability for ensuring the  proper use of government funds.
Another control activity that was available but not being used by HUD is  blocking Merchant Category Codes (MCC).  Blocking categories of  merchants allows agencies to prohibit certain types of transactions that are  clearly not business related, such as purchases from jewelry stores or  entertainment establishments.  During our review, we found that HUD was  not blocking any MCCs.  These blocks are available as part of HUD’s  purchase card task order, under the GSA SmartPay Master Contract with  Bank One.  Because HUD did not take advantage of this control, there were  no restrictions on the types of purchases employees could make during  fiscal year 2001—the period of our audit.  As a result of our audit work, on  March 6, 2002, HUD began using selected MCC blocks.
Our Standards for Internal Control in the Federal Government states that  internal control should generally be designed to assure that ongoing  monitoring occurs in the course of normal operations.  Internal control  monitoring should assess the quality of performance over time and ensure  that findings of audits and other reviews are promptly resolved.  Program  and operational managers should monitor the effectiveness of control  activities as part of their regular duties.
HUD’s purchase card policy requires the department to perform annual  program reviews and report the results, including findings and  recommendations, to the purchase card program administrator.  However,  HUD officials could locate only one such report.  This November 2001  report, prepared by a consultant, identified problems that were similar to  the findings previously reported by the OIG in February 1999.  Both  reports documented problems with weak internal controls and insufficient  supporting documentation.  The consultant’s report also noted that HUD  was not performing the periodic program reviews required by its policies  and that employees were making improper split purchases.  HUD  management agreed with the findings in the OIG report and developed and  implemented an action plan to address the identified weaknesses.   According to HUD OIG staff, its recommendations were implemented and  have been closed since September 30, 2000.  However, based on our  findings, corrective actions taken at that time were not effective.  The  results of our control testing indicate that HUD’s lack of internal control  over the purchase card process allows continued vulnerability to wasteful,  fraudulent, or otherwise improper purchases by employees using  government purchase cards.
section_title: Control Weaknesses Contributed to Improper, Potentially Improper, and Questionable Purchase Card Transactions
paragraphs: Poor internal controls created an environment where improper purchases  could be made with little risk of detection.  We define improper purchases  as those purchases that include errors, such as duplicate charges and  miscalculations; charges for services not rendered; multiple charges to the  same vendor for a single purchase to circumvent existing single purchase  limits—known as split purchases; and purchases resulting from fraud and  abuse.  We define questionable purchases as those that, while authorized,  were for items purchased for a questionable government need as well as  transactions for which HUD could not provide adequate supporting  documentation to enable us to determine whether the purchases were  valid.
We identified 88 transactions totaling about $112,000 that were improper  split purchases.  For example, one cardholder purchased nine personal  digital assistants and the related accessories from a single vendor on the  same day in two separate transactions just 5 minutes apart.  Because the  total purchase price of $3,788 exceeded the cardholder’s single purchase  limit of $2,500, the purchase was split into two transactions of $2,388 and  $1,400, respectively.  These improper split purchases violate provisions of  the Federal Acquisition Regulation and HUD’s own purchase card policy,  which prohibits splitting purchases into more than one transaction to  circumvent single purchase limits.  We received documentation from some  cardholders confirming that they split their purchases because they  exceeded their single purchase limits, while one cardholder claimed the  vendor independently split the purchases.
We identified an additional 465 purchases totaling over $913,000 where  HUD employees made multiple purchases from a vendor on the same day.   Specifically, cardholders made multiple purchases totaling over $2,500 on  the same day from the same vendor.  Although we were unable to  determine definitively whether these purchases were improper, based on  the available supporting documentation, these transactions share similar  characteristics with the 88 split purchases, and therefore we consider these  transactions to be potentially improper.
We also found 2,507 transactions, totaling about $1.3 million, with vendors  that would not routinely be expected to engage in commerce with HUD.  In  order to determine whether these questionable purchases were a valid use  of government funds, we requested supporting documentation for each  purchase.  HUD was able to provide us with adequate supporting  documentation for 1,324 transactions totaling about $412,000.  The  department was unable, however, to provide adequate support for the  remaining 1,183 transactions (47 percent of total transactions requested)  totaling about $869,000 (67 percent of total dollars requested).   Additionally, we found 940 transactions, totaling about $554,000, where the  purchases were made either on a weekend or holiday.  We requested  supporting documentation for each of these transactions.  HUD was able to  provide us with adequate support for 645 transactions totaling about  $189,000.  HUD was unable to provide adequate support for the remaining  295 transactions (31 percent of total transactions requested) totaling over  $364,000 (66 percent of total dollars requested).  In these instances, we  were unable to determine what was purchased, for whom, and why.
Some examples of the questionable vendor transactions for which we did  not receive adequate support included over $27,000 to various department  stores such as Best Buy, Circuit City, Dillard’s, JCPenney, Lord & Taylor,  Macy’s, and Sears; over $8,900 to several music and audio stores including  Sound Craft Systems, J&R’s Music Store, Guitar Source, and Clean Cuts  Music; and over $9,700 to various restaurants such as Legal Sea Food, Levis  Restaurant, The Cheesecake Factory, and TGI Fridays.  Additional  examples of questionable or potentially improper purchases we found  include $25,400 of “no show” hotel charges for HUD employees who did not  attend scheduled training and $21,400 of purchases from vendors who  appear to have been out of business prior to the purchase.   Because HUD  was unable to provide adequate documentation for these purchases, we  consider them to be a questionable use of government funds and therefore  potentially improper purchases.
We also have concerns about HUD’s accountability for computer and  related computer equipment bought with purchase cards because of the  large volume of transactions for which it did not have appropriate  documentation.  For example, our testing revealed that HUD employees  used their purchase cards to buy portable assets, such as computer  equipment and digital cameras, totaling over $74,500 for which they have  provided either no support or inadequate support.  In HUD’s August 28,  2002, purchase card remedial action plan, discussed in more detail in the  next section, HUD acknowledged that items bought with purchase cards  were not being consistently entered in the department’s asset management  system.  As a result, portable assets became vulnerable to loss or theft.  In  our follow-up work, we plan to determine whether these items are included  in HUD’s asset management system and are being appropriately  safeguarded.
section_title: HUD’s Remedial Action Plan to Correct Purchase Card Program Deficiencies Lacked Specificity
paragraphs: OMB’s April 18, 2002 memorandum, M-02-05, requires all agencies to  develop remedial action plans to manage the risk associated with purchase  card usage.  Agencies were required to submit their plans to the Office of  Federal Procurement Policy no later than June 1, 2002.  HUD’s remedial  action plan was submitted to OMB on May 31, 2002.  Our review of HUD’s  remedial purchase card action plan found that it did not address all the  weaknesses we identified.  Although HUD’s plan includes steps for  resolving and preventing a number of potential problem areas, including  the need for (1) adequate monitoring, (2) more frequent internal audits,   (3) accountability and penalties for misuse of cards, (4) updating the  agency handbook, (5) spending limits in line with purchasing requirements,  (6) adequate program records, including proper approving officials, and   (7) entering property purchased with purchase cards in the inventory  system, the plan falls short in other key areas.
For example, the plan did not include requirements for (1) a robust review  and approval function for purchase card transactions, focusing on  identifying split purchases and other inappropriate transactions, (2) a  process to periodically assess the effectiveness of the review and approval  process, and (3) specific documentation and records to support the  purchase card transactions.  In addition, the remedial plan lacked specifics  as to how and when HUD would implement it. On August 16, 2002, OMB  returned HUD’s remedial action plan and asked that a timeline be  incorporated.
HUD submitted a new plan to OMB on August 28, 2002.  While the revised  remedial action plan includes a broad timeline for completion of each  objective, we found that it still does not adequately address key control  weaknesses we identified, in part because it lacks specific steps necessary  to fully address identified problem areas.  In addition, the revised remedial  action plan does not require the program administration staff to begin  designing a monitoring plan to assess HUD’s compliance with key aspects  of its purchase card policy until the second quarter of fiscal year 2003 and  does not give an estimated date for when this key internal control will be  implemented.  Additionally, the revised plan does not specifically identify  who is responsible for developing or implementing any of the proposed  improvements.
section_title: Conclusions
paragraphs: The problems we identified with HUD’s purchase card program leave the  agency vulnerable to wasteful, fraudulent, or otherwise improper  purchases.  The remedial action plan prepared by HUD is an important first  step toward addressing the control weaknesses we identified.  At the same  time, much still remains to be done to effectively control the inherent risk  in HUD’s purchase card program.  HUD management will have to  effectively follow through on its implementation plan and expand the plan  to improve its review and approval process, requirements for  documentation and record retention, monitoring process, and remedial  action plan or HUD will continue to be susceptible to misuse of  government funds.
section_title: Recommendations for Executive Action
paragraphs: To strengthen its internal control over the purchase card program and  reduce HUD’s vulnerability to improper purchases, we recommend that the  Secretary direct the Assistant Secretary for the Office of Administration to  take the following actions:  implement the preapproval requirement in the existing purchase card   develop and implement a robust review and approval function for  purchase card transactions, focusing on identifying split purchases and  other inappropriate transactions, and on performing a detailed review of  relevant supporting documentation for each purchase;  update the list of approving officials and their designated cardholders  quarterly to ensure accuracy and completeness;  establish specific requirements for documentation and records to  support all purchase card purchases;  develop and implement a formal monitoring process to periodically  assess the effectiveness of the enhanced review and approval process;  revise the remedial action plan for purchase cards to include the  specific steps necessary to fully implement the above five  recommendations; and  follow up on the purchases we identified for which cardholders did not  provide adequate supporting documentation to determine the validity  and the propriety of the purchases.
section_title: Agency Comments and Our Evaluation
paragraphs: In written comments on a draft of this report, which are reprinted in  appendix I, HUD agreed that further improvements are needed to  strengthen the department’s purchase card controls.  Although HUD did  not specifically agree or disagree with our individual recommendations, the  actions being taken or planned by the agency address five of our seven  recommendations.
For example, in response to our recommendation to implement the  preapproval requirement in the existing purchase card program, HUD  stated that it has always had an effective preapproval process in its field  offices through the Automated Client Response System (ACRS).  While we  agree that this system is available for use, during our review of supporting  documentation, we found no evidence that cardholders were utilizing this  system.  To improve its preapproval process at its headquarters, HUD  stated that it has implemented the mandatory use of HUD Form 10.4,  Requisition for Supplies, Equipment, Forms, Publications, and  Procurement Services.
In addition, to enhance its review and approval function, HUD said it had  provided mandatory training in January 2003 to approving officials on the  procedures for reviewing and approving cardholder statements.  HUD also  said that it was working with Bank One to provide training to cardholders  and approving officials on the use of the automated purchase card system  and the monitoring tools available through Bank One.  HUD also stated that  as of January 2003, a review of the approving officials will be performed  and the Agency Program Coordinator will make the necessary changes  quarterly to ensure the list is accurate and complete.
To ensure proper supporting documentation is maintained for all  purchases, HUD also noted that it provided training to cardholders and  approving officials starting in January 2003.  Additionally, HUD stated that  in October 2002, a staff person was assigned to begin performing planned  internal reviews and random spot reviews of purchase card transactions  with reports to be issued on an interim basis as the reviews are completed  to ensure that proper management and internal controls are maintained  over the authorization of purchases and use of the purchase card.  These  actions will be helpful in strengthening the purchase card controls at HUD.
HUD did not state what, if any, action it planned to take regarding the two  remaining recommendations.  Regarding our recommendation to revise its  remedial action plan, HUD stated that the plan adequately met the  requirements set forth by OMB.  While the plan may address the elements  required by OMB, we do not believe it lays out an adequate approach for  resolving identified control weaknesses.  As discussed in the report, the  plan lacks the specific steps necessary to fully implement the proposed  changes to strengthen internal controls.
Concerning follow-up on inadequately supported purchases we  identified,  HUD stated that it had provided documentation when asked and would  provide more if necessary.  On July 8, 2002, we provided HUD with a  compact disk containing all transactions for which we received either no  support or inadequate support during our fieldwork and allowed an  additional 3 weeks for the agency to provide the supporting  documentation. We have not received any additional supporting  documentation since then.  It is our view that HUD has a fiduciary duty to  follow up on the inadequately supported purchases, which total about   $2.1 million and represent 57 percent of the total purchase transactions we  tested, to ensure their propriety.  HUD offered several additional technical  comments, which have been incorporated into this report as appropriate.
This report contains recommendations to you.  The head of a federal  agency is required by 31 U.S.C. 720 to submit a written statement on  actions taken on these recommendations to the Senate Committee on  Governmental Affairs and the House Committee on Government Reform  and Oversight within 60 days of the date of this report.  You must also send  a written statement to the House and Senate Committees on  Appropriations with the agency’s first request for appropriations more than  60 days after the date of this report.
We are sending copies of this report to the Chairmen and Ranking Minority  Members of the Senate Committee on Governmental Affairs and the House  Committee on Government Reform, the Director of Office of Management  and Budget; and other interested parties.  We also will make copies  available to others upon request.  In addition, the report will be available at  no charge on the GAO Web site at http://www.gao.gov.
Should you or your staff have any questions on matters discussed in this  report, please contact me at (202) 512-8341 or by E-mail at  calboml@gao.gov.
section_title: Comments from the Department of Housing and Urban Development
section_title: GAO Contacts and Staff Acknowledgments
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section_title: Acknowledgments
paragraphs: In addition to the contact named above, Sharon Byrd, Lisa Crye, Sharon  Loftin, and Julie Matta made key contributions to this report.
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