404.5 P-Card Post Review Program

PROGRAM: The Program Administrator or Program Coordinator/designee will be responsible for monitoring the Procurement Card Program and departmental transactions to ensure that:

• All Budget Authorities, Business Managers, Card Custodians, and Card Users have completed the required training, and complete ongoing training when changes in System and/or changes in campus policy.
• Transactions are processed in a timely manner
• Monthly bank statements are reconciled directly with Banner transaction feeds from the bank
• Verify that there are no prohibited transactions; including non-business and/or personal transactions
• Departments are reporting questionable transactions to both the Budget Authority and Program Administrator in a timely manner
• The Budget Authorities are reviewing all procurement card charges for appropriateness as well as reviewing  and signing of the monthly log reconciliation and bank statement.
• Departments are maintaining a card usage log for multi-user cards
• All cards and card numbers are appropriately safeguarded
• Annual review of card usage frequency
• Annual review of card activity spending levels

CARD REVIEW: The Program Administrator and/or designee(s) will conduct unannounced and announced procurement card reviews throughout the year. The Program Administrator or designee(s) may audit one or more cards assigned to the department, inclusive of group travel and fuel cards.  Unannounced reviews may be planned by management at any point in time throughout the year.  Reviews may be conducted if there is evidence or reports of fraudulent activity, questionable activity, or prohibited transactions. Procurement Card reviews will provide an opportunity to answer departmental questions and review policy. The intent of the PSU audit plan is to review each procurement card in each department at least annually. 

Each review will consist of the following items:

• Security of card   
• Current signature sheet
• Card Log review
• Reconciliation of receipts to the bank statement
• Required signatures on activity log and bank statement
• Unauthorized or fraudulent charges
• All authorized users, Custodian, Business Manager and Budget Authority trained and passed p-card test

All findings will be documented using the PSU Procurement Card Department Audit Checklist.  Each review will conclude with the Program Administrator and/or designee(s) meeting with the Card Custodian and Budget Authority (if deemed necessary) to review findings and answer any questions.  Any follow up actions and time lines will be identified and a follow-up review may be required.  A memorandum, via email, summarizing any findings and results will be prepared with copies to the Card Custodian, Budget Authority and/or Dean as well as University Financial Services management.  Any recommendations for improvement to internal control will be noted in the memo. 

PURCHASES ON GRANTS: In addition, Research and Strategic Partnerships will conduct post audit reviews of transactions posted to sponsored projects through the Banner P-Card module. Research and Strategic Partnerships will review the transactions for allowability on individual sponsored projects and adherence to Cost Accounting Standards in general. Research and Strategic Partnerships staff will run audit reports on a monthly basis for particular account codes. A high level review will be conducted for expressly unallowable costs and high risk purchases that are frequently unallowable charges on grants. The high level review will also monitor expenditures for exceptions to the Cost Accounting Standards requirement of consistent treatment of costs. The audit reports will be distributed to Research and Strategic Partnerships staff assigned to individual awards who will review the transactions for compliance with individual award terms and conditions, budget availability, and sponsoring agency policy. Research and Strategic Partnerships staff will contact departments to obtain backup documentation and/or justification for individual transactions as needed. On a periodic basis, Research and Strategic Partnerships may conduct a post-audit review of cards that are associated exclusively with sponsored projects or may contact Campus Accounting Services for information relating to audit reports performed by that unit.

TRANSACTION REVIEW: The Card Custodian is responsible for the timely distribution of charges to the appropriate account codes through the Banner P-Card module; which feeds nightly.  If a transaction is left undistributed an email notification will be sent to the Card Custodian.  The Program Administrator will monitor all undistributed transactions and will determine if notification to the Budget Authority is necessary.  A meeting may be requested at the discretion of the Program Administrator or the Manager of Campus Accounting Services if transactions are not distributed timely.  Repeated failure to post transactions in a timely manner may result in the card being suspended or revoked.

EXCEPTIONS: All exceptions must be submitted in writing via email to the P-Card Administrator in Campus Accounting Services.  In the rare case that an exception is granted, it must be documented in writing with the appropriate approvals; which depending on the exception may require the Vice President of Finance or Administration or designee.

FINANCIAL IRREGULARITIES: All employees of Portland State University are expected to report known or suspected financial irregularities within their responsible unit at the time they become aware of the incident.  Any financial Irregularity (as defined by policy) discovered through the procurement card review process will be reported to the “Institutional Designated Administrator” in accordance to the PSU Financial Irregularity Policy. 

MONITORING REQUIREMENTS: In addition to the review program, PSU maintains a formal compliance monitoring program that will include the following:

• Reviewing transaction data for compliance on a set schedule
• Reviewing account codes used for procurement card charges for potential inappropriate purchases
• Reviewing transaction descriptions for distributions made within the procurement card module for potential inappropriate purchases
• Reviewing usage frequency of each card at least annually for inactive or infrequently used accounts, documenting action taken
• Assessing procurement card provider monitoring system(s) and implementing as deemed appropriate and cost-effective
• Reviewing card activity levels at least annually and resetting card spending levels accordingly

TRAINING PROGRAM REQUIREMENTS: The Program Administrator will ensure that all card custodians, business managers, budget authorities and card users who authorize payments have been provided initial training and/or pass the online PSU PCard Test.  Card custodians, business managers, budget authorities and card users must complete ongoing training when changes in Program policy dictate.  Failure to complete the required training will result in revocation of the authority to use the card.