Violations and Prohibited Transactions

Prohibited Transactions

CASH

Cardholders cannot use the Procurement Card to obtain cash, such as money orders or traveler's checks. Cardholders are not to receive cash as a credit for the return of an item.

CASH-LIKE TRANSACTIONS

Cash like transactions, such as gift cards, are only allowable if purchased in accordance with the following PSC Procedural Statements: Gift Cards; Recognition and Training; and, Study Subject Payments.

DOCUMENTATION FAILURE

Failure to provide, within 30 days of the transaction date, the required receipt or sufficient documentation:

Cardholders are required to provide receipts for each purchase, unless the transaction amount is $25 or less and is not for an official function. If the Cardholder is unable to obtain a valid receipt, they may add a comment to the report, explaining why the receipt was unobtainable.  Multiple missing receipts may result in a violation.

FOREIGN COMPANY PURCHASES

Procurement Cards may be used to make payment to foreign companies only for purchase (not rental) of the following goods and services:

  • Supplies and other tangible personal property
  • Services performed entirely outside the U.S.

INAPPROPRIATE PURCHASES

All purchases on the Procurement Card must follow the PSC Procedural Statement Sensitive Expenses and (if appropriate) Official Functions. Departments contemplating purchases of official functions, gifts, flowers, alcohol, memberships, contributions, and/or other sensitive items should refer to those policies for clarification.

LIQUOR STORE PURCHASES

Cardholders cannot use the Procurement Card to purchase alcohol or other items at liquor stores.

NON-MANDATORY PRICE AGREEMENT VENDOR.

Cardholders are not to use the Procurement Card to purchase items otherwise covered by a mandatory price agreement. For a list of goods/services covered by such agreements, see the Commodity Listing.

Office furniture is covered by a mandatory price agreement per Colorado statute and therefore is a procurement card violation except in the following situations:

  • Office furniture from Colorado Correctional Industries (CCi);
  • Other office furniture if a written waiver has been provided by the Purchasing Agent for the specific furniture transaction.

For more information about furniture purchases, see How to Buy Furniture.

PERSONAL PURCHASES

Cardholders must immediately report any inadvertent personal purchase to their AOs and must immediately either reimburse the University or arrange for a credit transaction from the merchant. Documentation shall include proof of reimbursement by employee or credit by merchant.

Card abuse/employee fraud

Personal purchases not reported by Cardholders to their AOs immediately may be considered Suspected Fiscal Misconduct and may result in termination and possible prosecution. Any suspected fiscal misconduct or abuse of the card for personal purchases must be reported immediately to both PSC Commercial Card Administration and the CU System Department of Internal Audit.

PHONE CARDS/LONG-DISTANCE AND PAY-PHONE CALLS

The purchase of telephone calls is prohibited where there is no billing available from the merchant itemizing the calls.

PRE-PAID PARKING OR METER KEYS

Cardholders are not to use the Procurement Card to purchase Pre-Paid Parking or Meter Keys unless they are purchased directly from the University.

SHARING THE CARD

Cardholders shall not share their cards or card numbers with other individuals for use. Only the designated Cardholder is allowed to use his or her Procurement Card.

SPLIT PURCHASES

Under University Procurement Rules and State of Colorado Fiscal Rules, it is prohibited to split a purchase in order to circumvent Procurement Card limits. A split purchase is defined as:

  • The purchase of a single item costing over $5,000 (including shipping) with the purchase being divided (split) into more than one transaction; or,
  • The purchase of a group of items totaling over $5,000 (including shipping) for a single purchase need. A single purchase need identifies a group of items that are similar enough in nature to be purchased from a single source and that are all known to be needed at the time of the first purchase transaction. Purchases cannot be different delivery locations, differing functionality of the items, etc. For example: a Cardholder shall not purchase two $2,700 computers from a single source using two separate transactions if both computers are known to be needed at the time of the purchase (and, therefore, the total purchase need is known to be $5,400).

Exceptions

  • The single purchase need maximum limit of $5,000 does not apply to purchases from University departments. For example: It is acceptable for a department to place orders exceeding $5,000, using multiple transactions, with internal campus vendors (CU Imaging Services, CU Continuing Education, etc.).
  • Multiple conference registrations or training classes are not considered to be violations under the split purchases policy. Rather, event registration fees are considered to be the total of the individual registration fee. For example: It is acceptable for a Cardholder to register six people (six individual registrations), at $1,000 per registration, using six different transactions.

TAX ON PURCHASES

Cardholders are required to inform each merchant of the University's status as a tax-exempt organization. Taxes being charged consistently on a Cardholder's transactions may indicate the Cardholder is not letting vendors know that the University is tax exempt.

TRAVEL AND TRAVEL-RELATED EXPENSES

The purchase of most travel-related expenses for both employees and non-employees is prohibited on the Procurement Card. This includes:

  • Airfare;
  • Meals while in travel status;
  • Car Rental; and,
  • Lodging.

Exceptions

  • Cardholders may use the Procurement Card to pay for conference/event registration fees. Registrations that include a lodging deposit as part of the registration may be purchased on the Procurement Card. Separate charges for lodging - that is, lodging that is not included on the conference registration form - cannot be paid on the Procurement Card.
  • Cardholders may use the Procurement Card to purchase ground transportation for groups or for individual non-employees. This includes taxi services, shuttle services, bus passes, vehicle and driver services, other transportation services, and parking.
  • Cardholders may use the Procurement Card to purchase lodging from University of Colorado-owned facilities for either employees or non-employees.
  • Cardholders may use the Procurement Card to purchase restaurant meals if the meal is part of an Official Function and is in accordance with the PSC Procedural Statement Sensitive Expenses.

UNALLOWABLE SPONSORED PROJECT PURCHASES

Cardholders are not to use the Procurement Card to purchase any items that will be charged to a sponsored project unless those items are in accordance with the terms of the specific grant or contract.

UNSUBMITTED TRANSACTIONS

All transactions are required to be assigned to a report and submitted to an Approving Official within 30 days of the transaction date. The Commercial Card Office will run a report once a month of all unsubmitted charges and issue violations accordingly.

 

Violation Points

All departmental procurement card program participants - Cardholders, Delegates, and Approving Officials - are required to know and follow Commercial Card Program policies, including those defining program violations and their consequences.

Department Review for Violations

It is the responsibility of the AO (sometimes with the assistance of the department's delegates) to review transaction documentation in order to identify possible violations in card use. This review must be conducted for all transactions in each cycle period.

  • With the exception of Unsubmitted Transactions, If the AO determines that a violation has occurred, he or she must issue a Violation Notification form to the Cardholder. The form must be signed by the AO, faxed to Commercial Card Office, and retained in the department's files. Unsubmitted transaction violations will be issued directly by the Commercial Card Office.
  • If the AO feels uncomfortable asking a Cardholder to sign the Violation Notification form, the AO can send in the form without the Cardholder's signature. AOs (or other University personnel) may also contact PSC Commercial Card Administration directly and confidentially.
  • PSC Commercial Card Administration regularly audits transactions for possible violations and requests specific documentation to determine if a violation has occurred.

Consequences: Violation Points

PSC Commercial Card Administration will issue 50 points to the Cardholder for each of the following types of Procurement Card violations.

  • Cash Transactions
  • Contracts Without an Authorized Signature
  • Inappropriate Purchases
  • Personal Purchases (Card abuse/Employee Fraud)
  • Phone Cards/Long-Distance and Pay-Phone Calls
  • Pre-Paid Parking and Meter Keys
  • Sharing the Card
  • Split Purchases
  • Travel and Related Expenses
  • Unallowable Sponsored Project Purchases

Other violations may only warrant a violation warning unless chronic abuse is noted by the Commercial Card Administration. If chronic abuse is noted, violation points will be issued. The PSC Commercial Card Administration will use their discretion to determine whether chronic abuse exists and how many violation points will be issued. In severe cases, cards made be immediately suspended or revoked.

  • Cardholders with 150 or more violation points will have their cards suspended for a period of six months and will be required to complete Procurement Card Cardholder training before their cards can be reinstated.
  • Cardholder points will be eliminated 2 years after the points were assessed.
  • Violation points will remain in effect even if the Cardholder transfers to a different department.

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