SPCC Non-Compliances & Consequences
Inappropriate Card Use, Infractions, and Subsequent Consequences Policy
In an effort to protect the integrity of the University’s Purchase Card (P-Card) program, maintain accountability, and ensure all UMW and State policies and procedures are upheld, internal and external reviews are regularly performed on the University’s Small Purchase Charge Card (SPCC) Program. A consequence of failure to pass such reviews and audits could be loss of its P-card program. The Procurement Services Department’s overall goal is to support Cardholders and Approvers in order to avoid such an outcome.
The following is a list of various Card Use Non-Compliant Infractions or Non-Compliant Findings and resulting Consequences that a Cardholder or Approver may receive following a review of their transactions. No matter the reviewer, it is the responsibility of the SPCC Program Administrator to evaluate any non-compliant findings and take immediate and appropriate action.
| Major State Non-Compliance Findings (serious state-level infractions) | Consequences* |
| -Paying a late invoice w/o PRIOR DOA approval –Splitting orders to circumvent purchasing regulations -Purposefully making inappropriate/disallowed -Purchases allowing another individual to use your SPCC | -1st Occurrence: 30 Day Card Suspension -2nd Occurrence: 60 Day Card Suspension -3rd Occurrence: Card Revocation |
Splitting orders – intentionally splitting one purchase into multiple transactions in order to circumvent single transaction limit threshold set on the Cardholder profile. Ex: Cardholder’s STL is $5,000 and charges a $6,000 purchase in two transactions of $3,000 each.
| Minor State or Internal Non-Compliance Findings | Consequences* |
| -Missing required documentation for the payment card file**, as appropriate to the purchase, including but not limited to: -Certified Micro Business Quotes (or adequate justification), contract references, competition exemption references -eVA Purchase Order documentation -Proper required approvals: cabinet approvals, IT request approvals, Travel pre-approvals, business meal and food approvals, Sodexo waivers, gift log forms, etc. -Invoices/Receipts -Failure to provide responses or card files in internal or external audit/review requests by the stated deadline -Full Credit Card Number information on any written document (fax, email, mail, etc.) -Swept Transactions – transactions not allocated/signed off on that are not in dispute or missing receipts to confirm reconciliation -Not following any terms stated in User Agreement -Purchasing retail club memberships or membership renewals, including but not limited to: BJ’s Wholesale, Costco, Sam’s Club, Amazon Prime, etc. | -1st Occurrence: Written Notice -2nd Occurrence: Refresher Training (in person or online shall be determined by the PAs) -3rd Occurrence:15 Day Card Suspension -4th Occurrence: 30 Day Card Suspension -5th Occurrence:60 Day Card Suspension -6th Occurrence: Card Revocation |
* It is not the responsibility of Procurement Services to determine an alternate payment process solution upon suspension or revocation of a card for any department or division. It will be considered a personnel matter between the Cardholder or Approver’s Supervisor, Director, Chair, Dean, or other hierarchical management and Human Resources as applicable and necessary.
** Missing required Payment Card File documentation will result in an automatic non-compliant finding. Missing documentation must still be provided to the internal UMW reviewer within the time period requested to complete the file.
Important to Note: In cases where an Approver causes a non-compliant infraction to occur (such as causing transactions to be swept in Works by not signing off by the deadline), consequences such as written notices and training shall be applied to the Approver. However, if card suspension or revocation is the appropriate action for the infraction, the consequence shall be applied to the Approver’s Cardholder as the actions affect the entire department.
| Additional Situations |
| Additionally, the SPCC card may be suspended and/or revoked as a result of: -Inactivity -Request by Cardholder’s Supervisor/Budget Director -Determination made by Procurement Services due to continued non-compliance of policies and procedures |