Procurement Card Policy

A. Purpose

The University of Rochester Procurement Card, hereafter referred to as ‘Pcard’, is a VISA credit card issued through US Bank.  The Pcard is a delegated Procurement authority granted to individual department employees to be used solely for the business purposes of the University of Rochester per the guidelines outlined under the Approved and Restricted Use section. It shall not be used for any personal purchases or individual employee travel.  It is a valuable tool for quickly and efficiently managing resources by concentrating low-dollar, low-risk purchases in a less paper-intensive process. The card is issued in an employee’s name and the charges are paid directly by the University.

This policy outlines the card guidelines and requirements, including eligibility, procurement card types, required approvals, allowable purchases, restricted purchases and corrective actions for noncompliance with program policy and procedures.

This policy is designed to ensure the Pcard’s appropriate use, consistent with the objectives of the University’s overall internal control framework, designed to protect University assets and ensure budgetary controls.

B. Scope

This policy applies to staff, faculty, and graduate students and certain eligible purchases as defined within the program guidelines.

C. Definitions

a. Cardholder: Authorized University of Rochester employee who has been issued a Pcard and is authorized to make purchases in accordance with program policy. This individual’s name appears on the card.

b. Pcard Approver: Department representative (independent of the cardholder) that is responsible for financial review, approval, and oversight of department Pcard activity.

c. Pcard Administrator: Procurement representative responsible for management, coordination, and support of the overall University Pcard program.

d. Pcard: Visa credit card issued through US Bank

e. Monthly Transaction Limit: The established credit limit for the card during a single billing cycle. The limit is refreshed at the beginning of each billing cycle.

f. Single Transaction Limit: The maximum dollar amount that can be spent on a single card purchase.

g. Standard Pcard: General procurement card that allows for low-cost, low risk purchases up to $5,000 per single purchase, except where excluded by program policy (reference Appendix A).

h. Event Card: Specialized Pcard subset designed to facilitate payment of university event-related expenses (as noted in Appendix A).

i. Group Travel Card: Specialized Pcard subset that is intended to facilitate frequent travel for larger groups (defined as 3 or more people attending the same event/function) on university business (see Appendix A).

j. Declining Balance Card: A card that has a finite value for the lifetime of the card and does not have a renewable balance every monthly billing period.

D. Program Guidelines and Requirements

1. Eligibility
   • Cardholder must be a University staff member, faculty, or graduate student.
   • Undergraduate students and non-employees are not eligible to apply for a card.
   • Existing cardholders may NOT take their Pcard with them to a new position if transferring departments.
   • Cardholders may NOT hold multiple Pcard types. (e.g. cannot have both a standard Pcard and an Event/Group Travel Card)
   • The card can only be used by the person whose name is embossed on it. Any delegation of use or sharing of the card with other individuals is strictly prohibited and will result in the potential suspension or cancellation of the card as outlined under Corrective Actions for Noncompliance.
2. Types of Procurement Cards: The University allows potential cardholders to choose from several types of cards depending upon the amount and types of purchases that will be made.
   • Standard Pcard: General procurement card that allows for low-cost, low risk purchases up to $5,000 per single purchase, except where excluded by program policy (reference Appendix A). Monthly credit limits are determined by the department, based on anticipated need/usage, and renew at the start of every monthly billing cycle.
   • Event Card: Specialized Pcard subset designed to facilitate payment of University event-related expenses (as noted in Appendix A). Applications for these cards will only be approved at the discretion of the Pcard Administrator and will generally be limited to departments and employees that coordinate a high volume of University events. Where Event Card privileges are being sought, a detailed justification explaining the potential events, participants, and dollar amounts should be submitted with the Card Authorization request. For Event Cards, the single purchase limit will equal the requested monthly credit limit.
   • Group Travel Card: Specialized Pcard subset that is intended to facilitate frequent travel for larger groups (defined as 3 or more people attending the same event/function) on university business (reference Appendix A). Applications for these cards will only be approved at the discretion of the Pcard Administrator and will generally be limited to departments that have high volumes of travel with larger groups (e.g. Center for Study Abroad, Modern Languages & Cultures, Athletics, etc.) Where Group Travel Card privileges are being sought, a detailed justification explaining the travel, group participants, and expected dollar amounts should be submitted along with the Card Authorization request. For Group Travel Cards, the single purchase limit will equal the requested monthly credit limit.                                                                                   
   • Declining Balance Card: A card that has a finite value for the lifetime of the card and does not have a renewable balance every monthly billing period. Cards have a transaction limit of $5,000 per purchase and will expire once funds are depleted.
3. Card Application and Approval Requirements 
   • UR Departments can request a Pcard by completing the Pcard Authorization Request Form. Department Head or Department Chair and Divisional Finance Officer approval is required for all new card requests.
   • A Pcard Approver must also be designated for regular, timely review and approval of all transactions. The Pcard Approver must be an individual with an appropriate level of departmental budgetary authority.
   • Pcard holders and Pcard Approvers are required to complete and pass mandatory training modules in MyPath prior to receiving their Pcard and/or approver access.
   • Cardholders must reconcile their Pcard transactions regularly, and Pcard Approvers must complete approvals within Workday Procurement. Pcard transactions are required to be verified and approved by the end of the following month in which the transaction posted. Additional procedures & guidelines for Pcard approvals are established in Appendix B, ‘Pcard Verification Requirements’.
   • Cardholders are required to comply with an annual recertification providing verification and authorization of continued access to the Pcard Program. Recertification is completed using the Pcard Annual Recertification Form.
4. Card limits
   • Since the University of Rochester, not the individual employee, will pay for the purchases made with the Pcard, additional controls have been added to the card accounts. These limits are imposed at the point of sale when the card is swiped.
     • Individual Transaction Limits: The University’s maximum limit on standard Pcard purchases is $5,000 per transaction. Under no circumstances should the cardholder “split” the cost of a single purchase into multiple payments to circumvent the per transaction limit on the card. This is considered a violation of policy (reference Corrective Actions for Noncompliance).
       • Note: If any exception to the single purchase Pcard limit needs to be made, the cardholder must request a temporary increase prior to making the purchase utilizing a fully signed copy of the Pcard Transaction Exception Form. This option should be used only in rare circumstances where there is an urgent business need that cannot be otherwise met utilizing other procurement/payment options. The Pcard Administrator reserves the right to question or deny any potential request to a user’s single purchase limit.
     • Monthly Credit Limits: When requesting new cards, this should be determined at the discretion of the appropriate department administrator(s) and Department Heads based on anticipated usage/need, which may differ for each individual department or division. Requests for monthly limits more than $25,000 will require additional departmental justification.
       • Note: Monthly credit limits may be increased (or decreased), either temporarily or permanently, if the level of spend and compliance warrant, and there is reasonable business justification for the change. The department can make this request utilizing the Pcard Change Form.
   • Merchant Activity Type Limits: Specific types of businesses identified by a high-risk Merchant Category Code (MCC) are restricted on the Pcard to prevent potentially fraudulent activity by outside parties.
   • Policy Limits: In addition to the limits that are controlled at the point of sale by the card, the University also limits the use of the card through policy. The card must not be used with certain vendors or commodities except through a pre-authorized exception basis (reference Appendix A for a list of categories not allowable on Pcard.)
5. Program Guidelines
   • All purchases must be made in accordance with University policy. Only purchases for approved vendors or commodities can be made via the Pcard (reference Appendix A, ‘Approved and Restricted Use’)
   • A single purchase cannot be “split” or into multiple payments to circumvent the single transaction limit of the Pcard.
   • The Pcard is to be used for authorized business expenses only; it is not for personal use. Use of the card for personal purchases is considered fraudulent and will result in the suspension of the card and possible termination of employment and legal action (as noted in Corrective Actions for Noncompliance)
   • Although specific uses of the Pcard are referenced as subject to audit, the University reserves the right to audit any and every use of a Pcard.
   • Additional guidelines for cardholders and department approvers are listed in greater detail in the procedural document General Pcard Procedures (Appendix C).
6. Corrective Actions for Noncompliance
   • • Cardholders and Pcard Approvers must remain compliant with Pcard Program policies and procedures to assure continued eligibility to participate in the program.
     • Staff may be subject to corrective action for Pcard misuse and noncompliance with program policy. Depending on the severity of the action, corrective measures may include mandatory re-training, card suspension or cancellation, termination of employment from the University, and possible legal action.
     • Below are examples of Pcard misuse or policy noncompliance and the corresponding corrective action:

Lending or Sharing of a Pcard	Corrective Action
Any instance of a cardholder permitting another individual to use their card is a significant violation as knowingly sharing use of a card will negatively impact a cardholder or department’s ability to dispute unauthorized charges and identify fraudulent transactions.	First Occurrence: Cardholder will receive a written warning, with recommendations from Pcard Administrator on how to modify internal procedures to prevent a reoccurrence. Card will also be suspended for 5 business days. Second Occurrence: Cardholder must re-complete program training. Card will be suspended for a period of 30 days. Third Occurrence: Card will be terminated, and cardholder deemed ineligible for future participation in the Pcard program for a period of 12 months.
Splitting a Transaction/Exceeding the Pcard Purchase Limit without Authorization	Corrective Action
The cost of a single purchase or payment of an invoice must not be split into multiple payments to circumvent the per transaction limit on the card. Merchants can (and do) force through or split transactions without verification of a cards’ limits. Cardholders and Pcard Approvers should be aware if an order or payment would total more than the single transaction limit. If a transaction may exceed the card limit, cardholders are strongly encouraged to utilize the Pcard Transaction Exception Form to provide to the Pcard Administrator in advance of the purchase, to provide proper documentation for an audit trail.	First Occurrence: Cardholder and Pcard Approver will receive a written warning, with recommendation from Pcard Administrator on how to prevent a reoccurrence in the future. Second Occurrence: Cardholder must re-complete program training. Card will be suspended for a period of 10 business days. Third Occurrence: Card will be suspended for 30 days, and the department will be subject to a follow-up audit review by Purchasing, University Audit, or others.
Purchase from a Restricted Category	Corrective Action (within 12-month timeframe)
Defined as any purchase/payment on Pcard from a category listed as ‘restricted’ in Appendix A, that did not have pre-authorization & approval from the Pcard Administrator via the Pcard Transaction Exception Form. Restricted categories are defined as purchases/payments that present a higher physical or financial risk to the organization and therefore generally not appropriate for payment via credit card of any kind.	First Occurrence: Cardholder and Pcard Approver will receive a written warning, with recommendation from Pcard Administrator on how to prevent a reoccurrence in the future, and counseling on the most appropriate method of purchase/payment to utilize. Second Occurrence: Cardholder and Pcard Approver must both re-complete program training. Card will be suspended for a period of 10 business days. Third Occurrence: Cardholder, Pcard Approver, and Department Head will be notified that the card in question will be suspended for a period of 30 days. Department will also be subject to a follow-up audit review by Purchasing, University Audit, or others, (each subsequent occurrence of restricted use within a 12-month period will result in additional suspensions of 10 business days)
Failure to Follow Pcard Verification Procedures within Required Timeframe	Corrective Action
All Pcard transactions must be fully verified and approved within the following month after the transaction is loaded into Workday. Failure of cardholder and/or Pcard Approver to upload appropriate and sufficient supporting backup documentation/receipts to substantiate a Pcard transaction, or failure to include a completed Pcard Missing Receipt Form to provide reasonable justification of why transaction backup was not included. Failure of cardholder and/or Pcard Approver to follow transaction verification & approval procedures as stated in Appendix B, ‘Pcard Verification Requirements’ The importance of ensuring Pcard activity is properly verified, reviewed, and approved cannot be understated.  Failure to do so puts the University at risk of fraud or misuse of resources.	If transactions have not been fully verified within the end of the following month of posting in Workday: Card in question will be suspended (set to $1 limit) and will be unusable until cardholder and Pcard Approver have addressed all unverified activity. Cards that have been on suspension for greater than 90 days will result in the immediate cancellation of the card.  Department may be subject to a follow-up investigation by University Audit. Cardholder will be deemed ineligible for future participation in the Pcard program for a period of 12 months.
Failure to Communicate Change in Status	Corrective Action
Instance where a Cardholder or Pcard Approver fails to communicate cardholder termination, transfer, or other extended leave, and the card remains an active risk/liability to the University through potential unauthorized use.	First Occurrence: Card in question will be immediately cancelled. If staff member was only on leave and will have continued need of a card upon their return to work, they will need to submit a new Pcard Authorization Request Form.
Use of the Pcard (or other University resources) for Personal Purchases or Personal Benefit	Corrective Action
Can be classified under the following: Use of Pcard for personal expenses Submitting an expense report to claim reimbursement for a business expense already paid via Pcard Utilizing the University’s Amazon Business Account for non-business expenses Such policy violations are classified either as accidental use (where a cardholder may have inadvertently selected their Pcard instead of a personal credit card for an in-person or online personal expense, or submitted an expense report for reimbursement in error after an expense was already paid using their Pcard), or willful misrepresentation/fraud (where an end user deliberately utilizes University resources for personal financial gain). While it is understood that accidents can happen, departments must be made aware that absolutely no exceptions can be made, and that appropriate corrective measures will be taken (reference chart at right).	First Occurrence (Accidental): If the purchase is deemed to be accidental in nature, the cardholder will receive a written warning, with instructions for how to reimburse the University, and recommendations for how to prevent a reoccurrence in the future. Card will also be suspended for a period of 10 business days. Second Occurrence (Accidental): Cardholder must re-complete program training, and provide proof of reimbursement to the University. Department Pcard Approver must work with the Cardholder to develop an actionable plan for preventing a third such instance. Written copy of plan must be provided to the Pcard Administrator. Card will also be suspended for 30 days. Third Occurrence (Accidental): Card will immediately be cancelled. Cardholder will be instructed to immediately reimburse the University and will be deemed ineligible for future access to the program in perpetuity. Department may also be subject to further investigation by University Audit. First Occurrence (Willful Fraud): Card will immediately be cancelled. Cardholder will be instructed to immediately reimburse the University for all misappropriated funds and will be deemed ineligible for future access to the program in perpetuity. Department may also be subject to further investigation by University Audit and Department of Public Safety and subject to performance management up to and including possible termination of employment and criminal prosecution.

Appendices

• Appendix A: Approved & Restricted Use
• Appendix B: Pcard Verification Procedures
• Appendix C: General Pcard Procedures