Question:

What consequences do you have for out-of-compliance transactions?

P-card removal
HR Reports
Termination in extreme circumstances

no

Cardholders receive Out of Compliance form that will be signed by a Supervisor in order to active card. Three forms can result in loss of card.

Suspension of p-card.

We use the "third strike rule." We try to first educate on policy and procedure. If they continue to misues the card, the card is shut off. It's a case by case basis and always involves our Associate Vice President for repeat offenders.

A point system, so many points in a time period and card is revoked

warning to card holder, then warning to cardholder + budget manager, then card suspension alert. reimbursement for out of compliance transactions required, if not completed within the 30day time frame card is suspended til reimbursement received

slap on the wrist!

1 warning - 2nd warning - review of all transactions before purchase 3rd warning - removal.

no one questions right now.

Suspension of cards

Card suspension

Instances of non-compliance are tracked and users are contacted with reminders of policy and procedures. Accounts are suspended and/or cancelled if in violation too many times per policy and procedures.

Card suspension, suspension of cards to entire programs if warrented

Accounts are suspended until transactions are approved.

First and Second Offenses we ask them to take the item out of use and return it if possible for a refund and they are reminded of acceptable and unacceptable P-Card purchases. Further offenses may involve the cardholders management notification and could result in additional training requirements. If continues past that it may result in loss of card use.

Misuse of Card/Program UWF must safeguard its assets and protect its funds from misuse and fraud. All members of the UWF community involved in the use or administration of the PCard program have a responsibility to report known or suspected misuse of the PCard or the PCardprogram.1.Controller’s Office, P&C, or any individuals suspecting or having identified misuse of the PCard will report such to the appropriate Supervisor. Controller’s Office and P&C will also notify Internal Audit and Management Consulting Services ("IAMC") to proceed with further investigation. 2.Alternately, if fraud is suspected at any time, the information and documentation will be forwarded immediately to IAMC for further investigation. Supervisors shall take no action to resolve any alleged misuse before consulting with IAMC. Upon completion of IAMC's investigation, IAMC will report its findings to the Supervisor, P&C Director, PCard Auditor, Associate Vice President for Human Resources, General Counsel, and other supervisors asappropriate.3.All parties will handle reports of and investigations of suspected misuse or fraud in a confidentialmanneruntiltheUniversitymakesafinaldeterminationoffinalaction.

Consequences of Misuse

Thefrequencyofmisuseandtheintentbehindsuchmisusewilldictatetheseverityofconsequencesforeach infraction. The department will provide documentation and information to support each infraction. Controller’s Office, P&C, and/or IAMC will review the information and documentation and consult with the Office of Human Resources and the Office of the General Counsel to determine the appropriate consequence for each infraction.

1. Sporadicminorinfractionsorinfractionsfoundtobeunintentionalshallbenoticedinwritingby either IAMC or P&C to the Cardholder and the Supervisor. This notice is intended as preventative/corrective measure.

2. Cardholders will immediately reimburse UWF for all inappropriate charges. If the reimbursement is not made to the University within seven (7) calendar days, the University may deduct the amount from any monies due to the Cardholder, including Cardholder's salary. However, reimbursement by Cardholder will not prevent disciplinary action or criminal action if appropriate.

3. The PCard will be deactivated, and may be required to re-attend PCard training before the PCard may be reactivated.

4. A pattern of misuse by the same Cardholder shall be referred to IAMC for investigation.

5.Depending on the severity of misuse, the following additional consequences may apply:
(i) PCard limits will be reduced.
(ii) PCard will be revoked;(iii)Cardholder's PCard Delegates and Approvers will be changed.
(iv) Disciplinary action against the Cardholder and/or their Delegates and Approvers may occur. Disciplinary action may include employment termination;
(v)Criminalprosecution.

Tiered system. 1st offense - written warning, 2nd offense 30 day suspension of pCard, 3rd offense removal from the program for one year. Disciplinary action is up to the individuals department.

Program users receive infractions for being out of compliance. This includes both the cardholders and the approvers. Anyone apart of the p-card program can receive an infraction. The first infraction they have to re-watch the training video and pass a test; the user receives their first demerit. With the second infraction, a write up is completed (called an infraction report) and the user receives a second demerit. A third infraction results in cancelation of their p-card program privileges (i.e. if they are a cardholder, their card is cancelled and they can no longer use it , and if they are an approver, they are no longer allowed to approve card transactions and those duties are relegated to another department approver or their supervisor and potential other disciplinary actions). All program participants have the right to appeal to the City Manager and the Finance Director.

In the 25 years that I have been the Administrator of this program we have one instance where a cardholder knowingly made a charge for personal use and he ended up being terminated. Not for this instance but the situation was much larger.
The only compliance problem that we have every now and then is getting invoices/documentation for the transaction. We have a 3 strike rule. The 1st time - shame on you.
The 2nd time - take the card away for 30 days.
The 3rd time - you don't have a card. Use your personal card and go through the trouble of getting reimbursed. We have never had to do the 3rd strike.

Warning, suspension or closing of the account

Consequences vary depending on the severity of noncompliance with policy. For non-compliance not related specifically to approvals, see examples below:

Individual other than the cardholder uses the Pcard: card is suspended/inactivated for 30 days upon first offense, and cancelled completely upon subsequent offenses.

Card is used to purchase from a category restricted by policy: cardholder receives written warning/reminder for first 2 offenses, and then upon 3rd offense card is inactivated/suspended for 10 business days

Card is used for personal expenses: for first offenses, card is suspended for 10 business days and cardholder is required to reimburse the organization. For additional such offenses, card is immediately cancelled and user is ineligible to participate in program in the future, and may be subject to possible termination of employment

$100 fine

They receive a formal warning notifying them that they are out-of-compliance on the first occurrence. The second time, they must complete the PCard training again and their supervisor is notified. They lose their PCard after the third offense in a 12-month rolling period. After 6-months, the department director may request a reinstatement of those privileges.

Temporary and/or permanent suspension of PCards. Reimbursement of transactions to the district if applicable.

Cards are suspended if deadlines are not met. We also hold the right to cancel the card.

Audit transactions, Coaching and possible card suspension

Written occurrences sent to cardholder and cc'ed to direct supervisor.

1st & 2nd infraction - email sent to cardholder and supervisor
3rd infraction - card is suspended for 30 days

card suspension; working on a corrective action matrix

Depends of the issue. Minor infractions will result in a formal written warning. Serious infractions will result in card suspension.

handled on a case by case basis

email reminders of policy or required to pay back. Habitual non-compliance could result in card privilege being removed.

1st time - warning
2nd time - suspension
3rd time - card termination for one year

we see if anything can be done to correct them, write memoranda for the record