U.S. DEPARTMENT OF COMMERCE

INTERNATIONAL TRADE ADMINISTRATION

Overseas Purchase Card Guidelines

Updated February 09, 2000

The purpose of this document is to transmit policy changes to International Trade Administration (ITA) Purchase Cardholders located outside the continental United States. "Overseas Purchase Card Guidelines" dated March 24, 1999 are rescinded.

This policy sets forth the management responsibilities and duties associated with administering the Department's Purchase Card Program. It outlines the responsibilities of cardholder and approving officials; sets forth limitations on the use of the card, billing and payment procedures. This policy applies to all ITA employees located outside the continental United States.

The purchase card should be used whenever possible to buy small purchases under the micro-purchase threshold of $2,500 for official business. Authorized purchases should also be made over this amount up to $25,000 by individuals designated as a Level I Contracting Officer with $25,000 single purchase authority. Foreign Service Nationals (FSN) may be designated as $2,500 cardholders. FSN cardholders are required to have an approving official that is a U.S. citizen. Personal Services Contractors (PSC) may not be cardholders. Personal use of the card is strictly forbidden.

MANAGEMENT RESPONSIBILITIES

a. The Director, Office of Organization and Management Support (OOMS) is responsible for the management of the Purchase Card Program for the International Trade Administration (ITA).

b. The Chief Financial Officer and Director of Administration (CFO/DOA) for ITA approves and nominates officers for Level I Contracting authority with the concurrence of the Deputy Assistant Secretary for International Operations, US&FCS.

c. The Head of Contracting Office (HCO) is the individual who manages the Purchase Card Program for the Department Procurement Executive. The HCO has the authority to add controls in any area to fulfill their responsibilities. The HCO is responsible for:

  1. Delegating Purchase Card authority and purchase limits in accordance with Commerce Purchase Card policies and procedures;
  2. Appointing cardholder approving officials to review cardholder accounts;
  3. Reviewing the Purchase Card Program at least once a year to ensure cardholders and approving officials use internal controls and follow proper procedures. A sample of the information to be covered in the annual review may be found in Audit Criteria.
  4. Ensuring that all cardholders whose single purchase limit is over $2,500 have received the appropriate training and have executed a "Procurement Integrity Certificate" on file.
  5. Ensuring the purchase card is being used properly by conducting periodic reviews and determine whether to withdraw delegations and appointment if misuse is found.
  6. Ensuring cardholders' statements reach DOI-NBC-DENVER for payment by the 20th of each month.
  7. Ensuring all cardholders possess requisite business acumen to make sound decisions, that they have completed required training and review their historical performance record before issuing purchase cards.

d. Citibank operates the Government wide Purchase Card Program and maintains all Government accounts and records.

e. A Commercial Officer located at Post or within the Region shall serve as the approving official for all cardholders (e.g., $2,500 and $25,000 single purchase authority). The Commercial Officer shall participate with OOMS staff in the review of audit findings, and implementation of corrective action as outlined in the audit report.

f. The Regional Directors, US&FCS, will submit nominations for Level I Contracting authority and Approving Officials in writing from the DAS/OIO to the Director, Office of Organization and Management Support.

g. Commerce Bankcard Center (CBC) is located in Kansas City, Missouri and is responsible for:

  1. Providing support for the operation and administration of the Department of Commerce Purchase Card Program;
  2. Processing Purchase Card applications, maintenance and cancellations; responding to statement and transaction related questions;
  3. Making temporary changes to purchase limits and merchant transaction activity codes;
  4. Monitoring "Questioned Items" and providing support throughout the disputes process;
  5. Operating a "Hotline" to support cardholders.

DELEGATIONS

The Deputy Assistant Secretary for International Operations, (DAS/OIO) and the appropriate US&FCS Regional Director may delegate $2,500 purchase authority to cardholders. Overseas cardholders are authorized $2,500 single purchase authority with a monthly billing cycle limit of $20,000. Only the HCO with the written approval of the CFO/DOA, may grant $25,000 single purchase authority with a monthly billing cycle limit of $50,000 on a case-by-case basis.

ELIGIBILITY AND TRAINING

Officers nominated to receive $25,000 single purchase authority are proposed by the DAS/OIO. The DAS/OIO must attach a copy of the Certificate of Training for the Simplified Acquisitions Procedures training and the test score results to the VISA Purchase card forms for officers nominated to be $25,000 cardholders and Foreign Service Nationals designated to be $2,500 cardholders. OOMS ensures the proposed officer(s) has no history of unauthorized commitments, possesses the requisite business acumen to make sound decisions, has completed Simplified Acquisition Procedures training, and has successfully completed the qualifying examination. The employee's historical performance which includes their responsibility, ethics and record shall be reviewed before a card is issued. $25,000 single purchase authority will be granted only to those officers who satisfy the aforementioned requirements. Foreign Service Nationals are required to attend Simplified Acquisition Procedures training, and successfully complete the qualifying examination before a $2,500 single purchase card may be issued.

STANDARDS OF CONDUCT

Cardholders and approving officials must comply with applicable standards of conduct. Employees who knowingly misuse the purchase card for personal or other unofficial use are subject to administrative actions, remedies and penalties. If any misuse is found, the cardholder, approving official, relevant Regional Director and OOMS shall inform the DAS/OIO. OOMS, the CFO/DOA and HCO shall determine appropriate action to be taken.

APPROVING OFFICIAL RESPONSIBILITIES

  1. Designate officers as cardholders for $2,500 cards;
  2. Request monthly limit increases through OOMS;
  3. Ensure the cardholder immediately reports missing, lost and/or stolen cards to OOMS, and the CBC;
  4. Maintain accurate records regarding the Purchase Card Program and update account information as appropriate;
  5. Review cardholder monthly statements for authorized use;
  6. Ensure accounts are properly closed when officers leave the US&FCS or the Post. This includes accounts for cardholders who resign, retire or who are terminated and leave the US&FCS before the billing cycle has ended;
  7. Report misuse to OOMS;
  8. Ensure monthly statements are received in NBC-DENVER by the 20th of each month;
  9. Appoint an alternate approving official in writing to act in his/her absence. Attach a memo with the monthly statement so that NBC-DENVER accounting will know who is authorized to sign the monthly statement in the approving official's absence, and;
  10. Ensure cardholders report accountable property purchased with the Card to the US&FCS Regional Property Custodian. Accountable property is property that is valued at $5,000 or above or designated as "sensitive". Property designated as sensitive is: photocopy machines, video cameras, video cassette recorders, televisions, adp equipment (e.g. personal computers, central processing units, laptop computers, disk drives, printers, plotters), facsimile machines, portable telephones and cellular telephones.

CARDHOLDERS RESPONSIBILITIES

  1. Use the purchase card only for authorized official purchases. Cards may not be used by any person other than the person designated on the card;
  2. Report lost or stolen cards promptly to the approving official, and the CBC at (816) 823-3847. You may fax questions to the CBC at (816) 823-3850;
  3. Stay within the assigned single purchase limit. No split purchases are allowed. A split purchase is defined as a purchase where a cardholder intentionally divides what should be a single purchase into two or more separate purchases/transactions occasions to avoid exceeding the single purchase limit;
  4. Maintain a purchase card ordering log for BOTH O&A and Deposit Fund transactions. Cardholders will use 1 purchase card to acquire items using O&A and Deposit funds. Deposit Fund purchases shall be limited to the purchase of goods and services relating to trade events with approved fiscal plans and budget authorization cables. See Attachment A for sample log;
  5. Contact the CBC at (816) 823-3847 or by fax at (816) 823-3850 for assistance if the purchase card is rejected while making a purchase;
  6. Always request exemption from in-country sales tax, U.S. sales tax and value added tax. If a merchant requires a U.S. tax exempt certificate, contact the CBC. Tax exempt letters for some states are available on the WEB at http://pub.fss.gsa.gov/services/gsa.smartpay. The U.S. Government tax exempt number for the International Trade Administration is 4486. In-country sales tax exemptions are granted upon presentation of diplomatic identification. Value added tax (VAT) exemption is usually granted where the purchase price exceeds a certain dollar amount and when a VAT exempt certificate is issued by the U.S. Embassy and is presented to the merchant, and;
  7. Keep the purchase card in a secure place.

1. Comply with items (1)-(7) listed under $2,500 Cardholder Responsibilities in addition to the following items;

2. Determine and document that the price is fair and reasonable for purchases over $2,500.

  1. The determination that a proposed price is reasonable should be based on competitive quotations. If only one response is received, or the price variance between multiple responses reflects lack of adequate competition, a statement should be included in the cardholder's file giving the basis of the determination of fair and reasonable price. The determination may be based on a comparison of the proposed price with prices found reasonable on previous purchases, current price lists, catalogs, advertisements, similar items in a related industry, value analysis, the cardholder's knowledge of the item being purchased or any other reasonable basis.
  2. When other than price related factors are considered in selecting the supplier, the cardholder should document the file to support the selection decision. Cardholder may evaluate quotations or offers based on price alone or price and other factors e.g., past performance or quality.
  3. If only one source is solicited, an additional notation shall be made to explain the absence of competition.
  4. Simplified documentation practices should be used. For instance, the cardholder should establish and maintain informal records of oral price quotations in order to reflect clearly the propriety of placing the order at the price paid with the supplier. In most cases, this will consist merely of showing the names of the suppliers contacted and the prices and other terms and conditions quoted by each.
  5. Cardholder should retain data supporting purchases using simplified acquisition procedures to the minimum extent and duration necessary for management review purposes.
  6. Although the documentation requirements above are not required to support micro-purchases (purchases under $2,500), the cardholder shall ensure the price is fair and reasonable.

NOTE: All Government purchases over the micro-purchase threshold of $2,500 up to the "Simplified Acquisition Threshold of $100,000" are by law reserved for small businesses. This includes purchases made with the Purchase Card. When preparing to make a purchase over $2,500, inquire first as to the size of the business e.g., small or large. A large business should only be used when items required for purchases cannot be provided by a small business. The cardholder must document the file for using a large business over the micro-purchase level. Documentation should address attempts to locate small businesses.

LIMITATIONS

The Purchase Card may not be used for the following:

  1. Cash advances;
  2. Rental or lease of land and/or buildings;
  3. Janitorial or yard maintenance services;
  4. Personal convenience items such as coffeepots, membership fees, parking tickets, business cards, personal fines;
  5. Fuel, oil, services, maintenance and repair to vehicles not owned by the US&FCS;
  6. Purchase or lease of vehicles;
  7. Rental or lease of vehicles while on official travel;
  8. Airline, bus, boat, train tickets or other travel related tickets;
  9. Building services and alterations;
  10. Travel meals, drinks or lodging and;
  11. Representational expenses e.g., items related to the conduct of official entertainment as defined by the Chief of Mission.

ITEMS REQUIRING SPECIAL AUTHORIZATION AND APPROVAL

Trade Events

Cardholders and Approving Officials must have an approved fiscal plan and budget cable authorization from the Regional Director, US&FCS BEFORE THE FOLLOWING ITEMS MAY BE PURCHASED:

a. Meals and or drinks for overseas trade event hospitality

b. Paid advertisements in newspapers or other publications for overseas trade events

Documents that approve the purchases shall be maintained in the Purchase Card files and a copy submitted with the monthly statement. The Event ID number shall be noted next to each transaction that appears on the statement and in the Purchase Card Log.

GRATUITIES

Cardholders and Approving Officials must have an approved fiscal plan and budget cable authorization BEFORE gratuities may be purchased. A gratuity is defined as an item that is $20.00 or less in value and is restricted to persons NOT employed by the United States e.g., foreign business partners. Gratuities are limited to those foreign countries where the exchange of items is customary and to those instances where it is necessary for the promotion or advancement of ITA's mission. The expense must be incurred in the foreign country or area of assignment. Purchases made in the United States for use overseas are strictly forbidden.

PURCHASE CARD AS A METHOD OF PAYMENT

The Purchase card may be used as a method of payment when ordering against Blanket Purchase Agreements; Indefinite Delivery, Indefinite Quantity type contracts; GSA Federal Supply Schedule contracts; and other similar contractual arrangements, provided the order does not exceed the delegated single purchase threshold and the contract contains appropriate language authorizing the use of the purchase card as a method of payment.

PLACING AN ORDER

When placing an order, the cardholder should ensure that the merchant:

  1. Is a small business (if making a purchase over the micro-purchase threshold of $2,500);
  2. Provides total charges, including shipping and handling costs, if applicable;
  3. Includes a packing slip if the order is shipped;
  4. Includes the cardholder's name, office billing address and office telephone number on the shipping label.

RECEIPT OF SUPPLIES AND SERVICES

  1. For partial deliveries where the full amount appears on the "Statement of Account", the cardholder should authorize payment only for the part of the shipment actually received and should note on the "Statement of Account" that a partial delivery has been received. The cardholder must contact the merchant to determine the status on the remainder of the shipment. The cardholder should follow up with the merchant as necessary and make every effort to resolve the partial delivery before contacting the CBC. If the partial delivery becomes a dispute, contact the CBC for assistance. If the delivery of the remaining supplies will take more than 30 days, the cardholder should ask the merchant to credit the account. If the merchant will not credit the account or if negotiations with the merchant are unresolved, the cardholder must complete a "Statement of Questioned Item" form and submit it with any supporting documentation to the CBC.
  2. Cardholders should promptly return any damaged or unacceptable supplies. If the merchant agrees to replace the item and the new item is acceptable, the cardholder should authorize payment on the "Statement of Account" in accordance with normal procedures. If the merchant refuses to replace the item, the cardholder should follow the instruction in c below.
  3. The cardholder should, whenever possible, obtain a credit voucher from the merchant when returning supplies and attach a copy of the voucher to the "Statement of Account" on which the credit appears. If the merchant is unwilling to issue a credit voucher, the cardholder should note the returned purchase(s) on the "Statement of Account and indicate the item was returned. The cardholder should also complete a "Statement of Questioned Item" form and submit the documentation to CBC within 45 days of the invoice. See attached sample.
  4. If a merchant delivers supplies to a central receiving area, the cardholder should arrange with the receiving area to inspect the supplies immediately. If someone other than the cardholder signs a delivery receipt for the items purchased, the cardholder must determine when the goods were received and note the receipt and inspection of items on the file copy of the Purchase Card Ordering Log.

The Commerce Bankcard Center (CBC) will provide assistance to resolve or reconcile account problems.

REPORTING ACCOUNTABLE PROPERTY

Cardholders must report accountable property purchased with the Card to the US&FCS Regional property custodian assigned to provide property support to the cardholder's duty station. Cardholder's should become familiar with the property accountability thresholds of the Department. Accountable property is property that is valued at $5,000 or above or designated as "sensitive" regardless of the dollar value. Property designated as sensitive are: photocopy machines, video cameras, video cassette recorders, televisions, adp equipment (e.g. personal computers, central processing units, laptop computers, disk drives, printers, plotters), facsimile machines, portable telephones and cellular telephones.

BILLING AND PAYMENT OF PURCHASE CARD TRANSACTIONS

a. Monthly statements must be received at NBC-DENVER by the 20th of the month. The statement billing cycle closes by the 21th of each month. Arrangements have been made with the bank to send statements direct to cardholders located overseas. If a cardholder does not receive a statement within 15 business days after the close of the billing cycle, the cardholder must contact the CBC and request that a replacement statement be faxed to them.

b. Cardholders MUST include the following documents and notations with their statement:

  1. original receipts
  2. purchase card log
  3. credit receipts
  4. questioned item forms
  5. write the appropriation, cost center, project code and object class on the statement next to each transaction i.e., 001/XXXXXX/XXXX
  6. include the memo that appoints an alternate Approving Official (when appropriate)
  7. write the description of the item purchased on the statement next to each transaction
  8. statements of work ($25,000 cardholders only)
  9. sole source justifications ($25,000 cardholders only)
  10. evidence of competition and price quotes ($25,000 cardholders only)
  11. notice of posting ($25,000 cardholders only)

SEE ATTACHED SAMPLES

c. Card purchases are subject to the Prompt Payment Act. Cardholders and approving officials must ensure that certified and verified statements are promptly submitted to NBC-DENVER for payment by the 20th of each month to avoid late penalty fees. If a cardholder knows in advance that he/she will be absent and not available to reconcile the monthly statement, the cardholder must forward all appropriate documentation (logs, original sales receipts, credit vouchers, etc.) to the approving official. The approving official shall reconcile and send the statement to ITA Accounting.

d. Cardholders and approving officials shall use the most expedient means for sending monthly statements to NBC-DENVER by the 20th of each month e.g., mail or international courier service such as Federal Express or DHL).

e. Statements should be addressed to:

DOI-NBC-DENVER
ATTN: ITA Payments
Building 53, Entrance S-1
Denver Federal Center
Denver, Colorado 80225-0046
USA
303-236-0390

RECONCILIATION OF ACCOUNT

The cardholder shall:

  1. Review all information for accuracy. If a transaction is billed incorrectly, the cardholder should provide an explanation of the "Statement of Account" and fill out a "Questioned Item" form and submit it to the CBC;
  2. Describe each item listed on the Description line of the statement in enough detail to recognize the item;
  3. Attach any special approvals or authorizations to the statement;
  4. Put the account code for each transaction on the accounting code line, if different from the code listed at the top of the statement;
  5. Attach original sales or shipping receipts to the statement;
  6. Attach the Purchase Card Order Log;
  7. Certify the statement by signing it;
  8. Forward the statement and attachments to the approving official in sufficient time to permit careful review and ensure the statement is received by the approving official in time for forwarding to NBC-Denver by the 20th of the month;
  9. Keep copies of all documents.

The Approving official shall:

  1. Review cardholder's statements, verifying that all items are necessary Government purchases and comply with all applicable acquisition guidance;
  2. Resolve any outstanding questions, verify, certify, and sign each cardholder statement;
  3. Ensure the original, certified and approved statement is sent to NBC/DENVER by the 20th of each month, to avoid prompt payment penalties;
  4. Ensure Questioned Item form along with supporting documentation is submitted to the CBC and attached with the statement sent to NBC-DENVER.

RECORDS MAINTENANCE

Purchase card records must be retained for 39 months after the end of the fiscal year in which the transactions occurred.

PROBLEMS AND TECHNICAL QUESTIONS

If your Purchase Card is rejected while trying to make a purchase contact the Commerce Bankcard Center at (816) 823-3847 or by fax at (816) 823-3850.

Questions on appropriate use of the card should be directed to the ITA Purchase Card Coordinator in the Office of Organization and Management Support at (202) 482-5436 or by fax at (202) 482-1584.

AUDIT CRITERIA

The Office of Organization and Management Support will conduct audits of overseas cardholders and approving officials. Findings shall be reported and reviewed with the Regional Director and where appropriate the DAS/OIO, CFO/DOA and HCO. The audit criteria are listed below:

Transactions:

Competition:

Documentation:

Prompt Payment:

Cardholder Activity:

Limits:

Personal Property: