EFFECTIVE DATE: 08/22/2008
DURATION: This supplement is effective until superseded or removed. / 6309.32_4G13
Page 10 of 10
FSH 6309.32 – federal acquisition regulations
Chapter 4g13 – simplified acquisition procedures
/ Forest Service Handbook
Southwestern region (region 3)
albuquerque, new mexico
fsH 6309.32 – federal acquisition regulation
chapteR 4g13 – simplified acquisition procedures
Supplement No.: 6309.32-2008-1
Effective Date: August 22, 2008
Duration: This supplement is effective until superseded or removed.
Approved: faye l. kruegerDeputy Regional Forester / Date Approved: 08/22/2008
Posting Instructions: Supplements are numbered consecutively by handbook number and calendar year. Post by document; remove the entire document and replace it with this supplement. Retain this transmittal as the first page(s) of this document. The last supplement to this handbook was 6309.32-2004-1 to 6309.32.
New Document / 6309.32_4G13 / 11 PagesSuperseded Document(s) by Issuance Number and Effective Date / id_6309.32_2007-1 (02/07/2007) / 10 Pages
Digest: In order by code, summarize the main additions, revisions, or removal of direction incorporated in this supplement.
4G13.301-72 – Revises responsibilities for Regional Director, Acquisition Management, and administrative actions.
301-72 - Exhibit 01 – Updates administrative actions and reference to Human Capital Management (HCM).
301-72 - Exhibit 02 – Updates reconciliation responsibilities to 30 days from date of purchase
4G13.301 Government wide commercial purchase card.
Local Area Program Coordinators shall conduct audits in accordance with the Region 3 Internal Process Plan.
4G13.301-72 Responsibilities
(a) General responsibilities for the purchase card program:
(1) Individual units are responsible for accomplishing their micro purchasing, even under circumstances where certain cardholder privileges have been suspended or revoked.
(2) Cardholders are responsible for reconciling their accounts.
(3) The cardholder’s supervisor is responsible for the cardholder’s proper use of the card and checks (current check writers) and proper expenditure of funds. Supervisors shall recommend appropriate personnel action in the event of purchase card or convenience check abuse.
(b) Regional Policy:
(1) Ensure that the Local Area Program Coordinator (LAPC) function is staffed at a level and quality at which good performance can be attained.
(2) Provide adequate training and regional-level assistance for LAPC’s.
(3) Involve cardholder supervisors directly in the Purchase Card Program:
(i) Selecting who will have a card.
(ii) Monitoring card use and cardholder performance.
(iii) Keeping informed of Acquisition Management and Fiscal actions related to cardholder performance.
(4) Keep the Procurement Officials involved in management of the program.
(5) Ensure that Financial Management participates in audits and, where required, in necessary corrective actions.
(6) Supervisors of cardholders must follow the guidelines identified in 301-72 – Exhibit 01.
(7) To ensure cardholder compliance with regulation and policy, acquisition personnel will follow the administrative actions listed in 301-72 – Exhibit 01.
(c) Administrative Actions:
(1) An analysis of purchase card and check transactions indicate errors involving statute or regulation, and policy and procedure.
(2) 301-72 – Exhibit 01 shows the type of errors typically found in the micro-purchase program and the administrative actions, which are taken by acquisition personnel when these errors are discovered. Each situation requires analysis. For example:
(i) Is this an isolated incident or part of a pattern from this cardholder?
(ii) Is this occurring with many cardholders suggesting that there is a weakness in the training?
(iii) Does this seem to stem from a lack of knowledge?
(iv) Does this seem to stem from a lack of care?
(v) Does this seem to be deliberate?
(3) The administrative actions in 301-72 - Exhibit 01 apply only to administration of the cards. More severe administrative actions may be warranted based on the analysis of the given situation. In addition to these administrative actions, the employee may also be subject to disciplinary actions, including removal.
(4) Procedurally, once an error is discovered, the LAPC will gather the relevant information and review it with their respective Procurement Official. The appropriate administrative action will be taken at the lowest permissible level. Those that are reserved for the Director, Acquisition Management will be submitted with a written recommendation for appropriate action. Administrative actions associated with specific organizational levels are as follows:
(i) Ratification, Personal Use, and cancellation of the card – Director, Acquisition Management (See FSH 6309.32, 4G01).
(ii) Reduction of the Single Purchase Limit (SPL) to $1 – LAPC/RAPC for unreconciled accounts. Other infractions, Procurement Official.
(iii) Letter(s) to cardholder – Procurement Official.
(iv) E-mail to cardholder – Local Area Program Coordinator.
(5) The tables are divided into two sections. The first table describes those actions required by law or regulation, and the second table describes actions required by policy or procedure.
(i) Cancel card means to revoke the cards and/or checks and close out the account.
(ii) Card to $1 means: The single purchase limit is reduced to $1. If the cardholder were also a check writer, check-writing authority would also be reduced to $1.
(iii) Ratification means following the regional procedures for ratification. It is recognized that paying the bill is not dependent on the outcome of the ratification process. Rather, the process is necessary because the purchase (or set of purchases) is actually outside the cardholder’s authority and thus becomes an “unauthorized commitment”.
(iv) Supervisor means the cardholder’s first line supervisor.
(v) Treat as new application means that the former cardholder must take the current required training.
(vi) Split purchase means splitting requirements into several purchases to avoid the cardholder’s delegated single purchase limit.
(vii) Personal preference means unjustified procuring of a supply or service from other than a mandatory source or procuring an extravagant service or supply where an appropriate one already exists.
(viii) Personal use means use of the card for other than official government purposes.
(ix) Procurement Official means Lead Contracting Officer or Zone Lead Contracting Officer or RO Lead Contracting Officer.
301-72 – Exhibit 01
–
Statutory/Regulatory Issues
Problem / 1st Occurrence / Repeat occurrence within a 12-month period
Split Purchase / Ratification; card to $1 for 60 days. Reinstatement only on supervisor request and Procurement Official Approval. (Statement of Facts and consideration by Procurement Official.) / Ratification; cancel card; after 12 months, supervisor may request another card; treat as new application.
Exceed authority / Ratification; card to $1 for 60 days. Reinstatement only on supervisor request and Procurement Official Approval. (Statement of Facts and consideration by Procurement Official.) / Ratification; cancel card; after 12 months, supervisor may request another card; treat as new application.
Personal Preference / Letter to employee (cc: supervisor) explaining error. Cancel card. * / N/A
Personal Use / Letter to employee (cc: supervisor) with statement of facts. Letter from supervisor to Regional Office, Director of AQM, for consideration of reinstatement. * / Cancel card; after 12 months, supervisor may request another card; treat as new application.
Mandatory Source Violation / Letter to employee (cc: supervisor) explaining error. Card to $1 for 30 days. Reinstatement only on supervisor request and Procurement Official Approval. / Letter to employee
(cc: supervisor) explaining error; card to $1 for 60 days; reinstatement only on supervisor request and Procurement Official Approval.
301-72 - Exhibit 01—Continued
Statutory/Regulatory Issues
Problem / 1st Occurrence / Repeat occurrence within a 12-month period
Purchase contrary to law or regulation (See PCMS Guide and Micro-Purchase Guide) / Letter to employee (cc: supervisor) explaining error. Card to $1 for 30 days. Reinstatement only on supervisor request and Procurement Official Approval. / Letter to employee
(cc: supervisor) explaining error; card to $1 for 60 days; reinstatement only on supervisor request and Procurement Official Approval.
Purchase w/o necessary approvals (such as, Advisory & Assistance, and SF182) / Letter to employee (cc: supervisor) explaining error; 30 days to present proper approval. Failure to obtain approval, card to $1 for 30 days or until approval obtained, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval. / Letter to employee
(cc: supervisor) explaining error; 30 days to present proper-approval. Failure to obtain approval, card to $1 for 60 days or until approval obtained, which-ever is longer. Reinstatement only on supervisor request and Procurement Official approval.
Unauthorized use of card for travel related expenses / Letter to employee (cc: supervisor) explaining error. Card to $1 for 60 days. Reinstatement only on supervisor request and Procurement Official approval. / Cancel card; after 12 months, supervisor may request another card; treat as new application.
Other policy violations / Letter to employee (cc: supervisor) explaining error. Card to $1 for 60 days. Reinstatement only on supervisor request and Procurement Official approval. / Cancel card; after 12 months, supervisor may request another card; treat as new application.
301-72 - Exhibit 01—Continued
Statutory/Regulatory Issues
Problem / 1st Occurrence / Repeat occurrence within a 12-month period
Failure to reconcile in 30 days. (Time starts from date of purchase.) / E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 30 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval. / 2nd occurrence: E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 60 days or correction, which-ever is longer; reinstate-ment only on supervisor request and Procurement Official approval.
3rd occurrence: Cancel card. Supervisor may request reinstatement after 12 months; treat as new application.
Failure to reconcile within 60 days. (After card reduced to $1. Time starts from date of purchase.) / Cancel card. Supervisor may request reinstatement after 12 months. / N/A
Incomplete reconciliation (such as, no/inadequate item description; no Debt Collection Act Waiver citation; no attempt to change Budget Object Codes) / E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 30 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval. / E-mail to employee
(cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 60 days or correction, whichever is longer; reinstatement only on supervisor request and Procurement Official approval.
Incorrect budget object codes (valid attempt) / E-mail to employee (cc: supervisor) explaining error; 15 days to correct. Failure to correct, card to $1 for 30 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval. / E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 60 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval.
301-72 - Exhibit 01—Continued
ADMINISTRATIVE ACTIONS –Statutory/Regulatory Issues
Problem / 1st Occurrence / Repeat occurrence within a 12-month period
Inadequate or non-existent documentation / E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 30 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval. / E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 60 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official approval.
Use of incorrect funds (such as, Accounting Information) / Budget to take the lead in seeking correction. E-mail to employee (cc: supervisor); 15 days to correct. Failure to correct, card to $1 for 30 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official Approval. / Budget to take the lead in seeking correction. E-mail to employee (cc: supervisor) 15 days to correct. Failure to correct, card to $1 for 60 days or correction, whichever is longer. Reinstatement only on supervisor request and Procurement Official Approval.
* Refer to Human Capital Management (HCM) for possible disciplinary action. These problems may result in criminal or disciplinary action in addition to the Administrative Actions. Reference DPM Chapter 751, Amendment 230, Guide for Disciplinary Penalties. http://www.usda.gov/da/employ/apsd/dpm751a502working.pdf
301-72 - Exhibit 02
Guideline for Supervisors of Micro-Purchasers
Congress established the concept of micro-purchases (those up to $3,000 for supplies, $2,500 for services, $2,000 for construction), and stated that the purchase card would be the tool of choice for making micro-purchases.
(a) Requesting Cards and Checks
To exert proper control and management over the micro-purchase activity, cardholders’ first line supervisors need to be involved. This guideline will assist supervisors to understand their role in managing the program.
Following is a list of questions to consider in deciding whether or not you need your employee to have a purchase card:
Yes / NoDoes employee’s work assignment require frequent purchase of supplies or services—at least once a month on average?
Does employee’s work assignment require providing lodging and meals for his/her crew on fire assignments?
Is employee located at a work site away from other micro-purchasers?
Does work group have anyone else to handle micro-purchase transactions?
Does your work group need a backup person for micro-purchase transactions when the principal micro-purchaser is not available?
The authority to do micro-purchasing carries with it the responsibility to reconcile the transactions within 30 days from the date of purchase through the Purchase Card Management System (PCMS):
Yes / NoDoes the cardholder have reasonable access to PCMS?
Are you willing to give the cardholder the time necessary to reconcile the account on a regular basis
Are you willing to monitor the cardholder’s micro-purchasing activities to the extent that you know what is being bought, how much is being spent, and that the account is being properly reconciled each month?
Do you feel you have an adequate knowledge of general acquisition rules as they apply to micro-purchasing so that you can monitor your micro-purchasers and do not inadvertently ask the micro-purchaser to make a transaction which violates regulation or policy?
301-72 - Exhibit 02--Continued
(b) Monitoring your Micropurchaser(s)
Although micro-purchasers are responsible for the actions they take in using the micro-purchase tools, you as the supervisor are responsible for the actions of your employees. If you are the fund holder for the money being used, you are also ultimately responsible for the proper expenditure of those funds. Because of these responsibilities, you may be well served to monitor your micro-purchaser’s use of the cards and checks. Here are some ways you might do that: