u . s . d e p a rt me n t o f t h e i n t e ri o r f l e e t c a rd p ro g ra m p … · 2020. 6....

26
U.S. Department of the Interior Fleet Card Program Policy Issued by the Office of Acquisition and Property Management

Upload: others

Post on 21-Aug-2020

0 views

Category:

Documents


0 download

TRANSCRIPT

Page 1: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

U.S. Department of the Interior Fleet Card Program Policy

Issued by the Office of Acquisition and Property Management

Page 2: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

Fleet Card Table of Contents Issued by the Office of Acquisition and Property Management 1 Fleet Card Table of Contents 2 I. Overview and Policy 4

A. Overview 4 B. Program Policy 4

II. Roles and Responsibilities 4 A. Assistant Secretary for Policy, Management, and Budget 5 B. Director, Office of Acquisition and Property Management 5 C. Associate Director, Asset Management; Associate Director for Acquisition, Acquisition; Team Leader, Office of Acquisition and Property Management 6 D. DOI Bureau or Office Assistant Director for Administration or Equivalent 6 E. Charge Card Program Manager, Office of Acquisition and Property Management 6 F. Bureau Fleet Manager or Bureau Procurement Chief 6 G. DOI Charge Card Support Center at Interior Business Center 6 H. Business Integration Office 7 I. Bureau Fleet Lead Agency/Organization Program Coordinator (A/OPC) 7 J. Fleet A/OPC 8 K. Aviation Fleet A/OPC 9 L. Approving Official 9 M. Supervisor 10 N. Acting Approving Official, 10 O. Cardholder 11 P. Convenience Checkwriter (Aircraft Fleet Card) 11

III. Spending Limitations 12 A. Default Purchasing Limit 12 B. Split Purchases 12 C. Above the Micro-Purchase Threshold 13

IV. Authorized Use 13 A.Tolls and Toll Pass Transponders. 14 B. Bulk Fuel 14

V. Use Restrictions 14 A. Merchant Reward/Loyalty Programs 15 B. Convenience Check Restrictions 15

VI. Fraud, Misuse, Abuse, and Collusion 15 A. Defining Fraud, Misuse, Abuse and Collusion 16 B. Consequences of Fraud, Misuse, Abuse and Collusion 17 C. Roles and Responsibilities for Reporting Fraud, Misuse, Abuse and Collusion 18

VIII. Internal Controls 19 A. Overview of Requirements 19 B. Description of Controls 20 C. Execution of Internal Controls 21

IX. Account Establishment 21 X. Review and Approve 22

2

Page 3: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

XI. Methodology and Recordkeeping 23 XII. Account Reallocation 23 XIII. Training Requirements 23 XIV. System Resources 24

A. Bank Vendor Systems and Resources 24 B. Financial and Business Management System 25 C. Federal Personnel Payroll System 26

3

Page 4: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

I. Overview and Policy The purpose of the program overview and policy section is to provide an introduction to the DOI Fleet Card Program and describe applicable policies. A summary of the areas covered in this section is provided below.

A. Overview - view this section to be introduced to the DOI Fleet Card Program. B. Program Policy - view this section to access the DOI Acquisition, Assistance, and Asset

Policy (DOI-AAAP) which establishes this document as policy. The DOI-AAAP includes the policy purpose, scope, effective date, background, and actions for the DOI Fleet Card.

A. Overview The Fleet Card Program is established at DOI to provide payment tools for purchasing fuel, authorized repairs, parts, or services for government owned or leased vehicles, fueled appliances and equipment, small marine craft, and aviation, in support of official government business. Fleet cards are issued to a named cardholder, a specific vehicle or piece/group of equipment and responsible employee is indicated, and are only used to acquire fuel and maintenance for authorized vehicles and/or equipment. The fleet card may be assigned to either DOI-owned, GSA Dry lease, or commercially leased assets. DOI Aircraft Fleet Cards are assigned to the pilot. The fleet card program consists of the vehicle fleet card, miscellaneous fleet card, the aircraft fleet card, and aircraft fleet convenience checks. The DOI fleet card program allows transactions to be billed directly to the government, which qualifies for exemption from state sales tax in most states. The DOI Fleet Card Program is supported by a bank vendor through a task order under the General Services Administration's (GSA) SmartPay3 master contracts, and administered by internal DOI stakeholders through interfaces with the DOI Financial and Business Management System (FBMS). Fleet card transaction monitoring and reporting are carried out through the use of FBMS functionality and the bank vendor’s tools and systems. The DOI Fleet Card Program is established in accordance with the following references:

1. Executive Order 12931, Federal Procurement Reforms, dated October 13, 1994 2. Government Charge Card Abuse and Prevention Act of 2012 (Charge Card Act) 3. Saving Federal Dollars Through Better Use of Government Purchase and Travel Card

Act of 2015 4. Fraud Reduction and Data Analytics Act of 2016 5. Office of Management and Budget (OMB) Circular A-123, Appendix B, A Risk

Management Framework/or Government Charge Card Programs

B. Program Policy The following document establishes this DOI Fleet Card Program document as policy: DOI-AAAP-0158, DOI Fleet Card Program Policy.

II. Roles and Responsibilities A summary of roles and responsibilities as they pertain to the DOI Fleet Card Program is provided below. Bureaus have the flexibility to organize and manage their fleet card programs in a manner that best fits their mission needs; however, the individuals listed below must have the

4

Page 5: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

role and accountability level described. This section does not dictate supervisory relationships for fleet card program personnel. Separation of Duties. Separation of duties is key to the success of the DOI Fleet Card Program. Duties such as making purchases/reviewing transactions, approving transactions and statements, authorizing payments, and auditing transactions and statements shall be assigned to different individuals to maintain the integrity of the program. Some examples include:

● Account Holders/Cardholders are prohibited from serving as the Approving Official for their own transactions. (For the purposes of the Fleet Account, the individual signing the application as "Local Operator" or “Fleet Manager” is considered the "cardholder" who reconciles the account and prepares the certification or signs the statements.)

● A/OPCs are prohibited from oversight, reviews and audits, or changes to their own card account credit limits, assigned authorization groups, or other account controls. Those duties must be assigned to another A/OPC.

Description of Roles and Responsibilities

A. Assistant Secretary for Policy, Management, and Budget B. Director, Office of Acquisition and Property Management C. Associate Director, Asset Property Management; Associate Director, Acquisition;

Acquisition Team Leader, Office of Acquisition and Property Management D. DOI Bureau or Office Assistant Director for Administration or Equivalent E. Charge Card Program Manager, Office of Acquisition and Property Management F. Bureau Fleet Manager G. DOI Charge Card Support Center at Interior Business Center H. Business Integration Office I. Bureau Fleet Lead Agency/Organization Program Coordinator (A/OPC) J. Fleet Agency/Organization Program Coordinator (A/OPC) K. Aviation Fleet Agency/Organization Program Coordinator (A/OPC) L. Approving Official M. Supervisor N. Acting Approving Official O. Cardholder P. Convenience Checkwriter

A. Assistant Secretary for Policy, Management, and Budget This stakeholder has overall responsibility for establishing the DOI Fleet Card Program, monitoring program effectiveness, and ensuring the program complies with federal law, OMB directives, GSA guidance and Department regulations and policy.

B. Director, Office of Acquisition and Property Management This stakeholder is responsible for the following items:

1. Issuing Department-wide Fleet Card Program policy. 2. Providing leadership, policy, and program oversight of the DOI Fleet Card Program.

5

Page 6: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

3. Serving as the DOI point of contact for the GSA, Office of Management and Budget (OMB), and the Government Accountability Office (GAO) regarding the Fleet Card Program.

4. Issuing appointment for Bureau Lead Agency/Organization Program Coordinators (A/OPCs).

5. Revoking appointment for Bureau Lead A/OPC.

C. Associate Director, Asset Management; Associate Director for Acquisition, Acquisition; Team Leader, Office of Acquisition and Property Management These stakeholders are responsible for assisting the Director, Office of Acquisition and Property Management, with all responsibilities listed above.

D. DOI Bureau or Office Assistant Director for Administration or Equivalent This stakeholder is responsible for the following items:

1. Providing overall organization oversight for the day-to-day activities of the bureau or office fleet card function.

2. Ensuring that organizational changes are communicated to the Bureau Lead A/OPC, so that changes do not negatively impact the financial system setup for the fleet card and structures for review and approval.

E. Charge Card Program Manager, Office of Acquisition and Property Management This stakeholder is responsible for the following items:

1. Serving as the lead for DOI’s purchase, travel, and fleet card programs. 2. Serving as the Charge Card Partnership Chair. 3. Providing advocacy and support to the Charge Card Support Center (CCSC). 4. Collaborating with A/OPCs to manage the DOI Charge Card Program. 5. Developing and communicating policies, procedures, and other guidance in support of

DOI’s strategic goals and government-wide initiatives. 6. Serving as Contracting Officer Representative (COR) for DOI’s task order with the bank

vendor. 7. Coordinating all program requirements and issues with the bank vendor.

F. Bureau Fleet Manager or Bureau Procurement Chief Depending on the bureau or office, the Bureau Fleet Manager may be the Bureau Procurement Chief (BPC) or other equivalent senior manager. This stakeholder is the accountable official for the fleet card program in her/his bureau or office and is responsible for ensuring compliance with the fleet card policy within the bureau or office. This stakeholder is specifically responsible for the following items:

1. Appointing approving officials if other than the employees supervisor on record. This responsibility can be delegated to the Bureau Lead/Alternate A/OPC.

2. Reviewing A/OPC notification of potential fraud, waste, abuse, or misuse of the fleet card in collaboration with fleet operational program managers and DOI OIG.

3. Ensuring that policies and procedures exist for the proper handling of unauthorized commitments i.e. split purchases.

G. DOI Charge Card Support Center at Interior Business Center This stakeholder serves as the operational arm of the DOI Fleet Card Program and is responsible for the following items:

6

Page 7: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

1. Providing operational and customer service support throughout DOI for the Fleet Card Program.

2. Providing policy and program input as subject matter experts on the fleet card. 3. Implementing and supporting DOI Fleet Card Program initiatives. 4. Serving as the liaison to the bank vendor for operational and technical bank issues. 5. Serving as the application administrator and hierarchy manager for bank vendor systems

and tools. 6. Serving as the application administrator for the brand’s data analytics tool. 7. Coordinating DOI migration and transition activities as necessary with GSA SmartPay3. 8. Providing or supporting fleet card role-based training. 9. Collaborating with stakeholders regarding internal control reviews.

H. Business Integration Office This stakeholder is responsible for the following items:

1. Providing technical support with FBMS as it relates to the fleet card program. 2. Processing and payment of fleet card transaction details associated with fleet card

purchases. 3. Maintaining business process to support fleet reporting requirements. 4. Maintaining fleet master data to support integration with fleet card activity. 5. Providing policy and program input as appropriate. 6. Coordinating card vendor interface file delivery to FBMS.

I. Bureau Fleet Lead Agency/Organization Program Coordinator (A/OPC)

This stakeholder must be an employee of the Department of the Interior and is responsible for the following items: 1. Issuing appointment letters for bureau Fleet A/OPCs. 2. Revoking appointment for bureau Fleet A/OPCs when responsibilities as described in

this policy are not satisfied. 3. Ensure mandatory approving official training is completed and approving officials receive

their appointment memo in DOI Talent. 4. Serving as the primary Bureau Lead/Alternate representative for bureau specific

technical and policy matters relating to the DOI Fleet Card Program. 5. Elevating issues as needed with both the bank and the Charge Card Support Center. 6. Serving as a liaison between account holders and the bank vendor Customer Service

Representative. 7. Overseeing application processing for new fleet card accounts. 8. Managing fleet card accounts to include hierarchy maintenance and all other elements of

cardholder profile data. 9. Ensuring cardholder/Approving Official relationships are accurate. 10. Ensuring the fleet card internal controls program is implemented and appropriately

reported to the Department as described in the Internal Controls section of this policy. 11. Ensuring fleet accounts are audited as required by DOI policy. 12. Reporting suspected fraud and misuse to the approving official/supervisor, the Charge

Card Program Manager, Office of Acquisition and Property Management, and the Office of Inspector General (OIG), as appropriate.

13. Terminating and suspending accounts when necessary.

7

Page 8: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

14. Using the bank's electronic access system and the brand’s online data analytics tools to perform account management, compliance reviews, and oversight, and including detecting improper or fraudulent purchases.

15. Providing guidance, ongoing advice, and assistance to A/OPC, approving officials/supervisors, cardholders, and fleet managers.

16. Ensuring that mandatory GSA fleet program manager training is completed. 17. Assisting with the development of DOI-wide fleet card policy. 18. Assisting the CCSC as necessary. 19. Ensuring DOI Fleet Card Program stakeholders adhere to federal laws and regulations

and DOI policies and procedures. 20. Developing supplemental bureau and office policies and procedures, as needed.

(Bureaus and offices are not required to develop their own fleet card manuals. However, if the bureau does have specific fleet card policies, the Bureau Lead A/OPC must be involved in the development, and the Bureau Fleet Manager should be the policy approving official. Bureau and office policy may be more restrictive than Departmental policy, but it cannot be less restrictive.)

J. Fleet A/OPC The Bureau Lead A/OPC can delegate certain authorities to A/OPCs in their bureau. This stakeholder must be an employee of the Department of the Interior, and the following delegated authorities may be included to this stakeholder:

1. Adhering to the appointment letter designated by the Bureau Lead A/OPC. The

subsequent responsibilities in this section may or may not apply to each A/OPC, depending on the written appointment letter.

2. Serving as the primary representative for bureau specific technical and policy matters relating to the DOI Fleet Card Program.

3. Serving as a liaison between account holders and the bank vendor customer service representative.

4. Overseeing application processing applications for new fleet card accounts. 5. Managing fleet card profile data, accounts to include hierarchy maintenance and all

other elements of profile data. 6. Ensuring cardholder/approving official relationships are accurate. 7. Managing program risk through internal controls and oversight. 8. Overseeing the proper use of the fleet card for vehicle operation and maintenance. 9. Auditing fleet accounts as required by DOI policy. 10. Reporting suspected fraud and misuse to the supervisor and the Bureau Lead A/OPC. 11. Terminating and suspending accounts when necessary. 12. Using the bank's electronic access system and the brand’s data analytics tool to perform

account management, compliance reviews, and oversight, including detecting improper or fraudulent purchases.

13. Providing guidance, ongoing advice, and assistance to approving officials, supervisors and those using fleet cards.

14. Completing required GSA Fleet Card Training for Program Managers 15. Ensuring DOI Fleet Card Program stakeholders adhere to federal laws and regulations

and DOI policies and procedures. 16. Providing input to bureau and office supplemental guidance and procedures, as needed.

8

Page 9: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

K. Aviation Fleet A/OPC This stakeholder may have cards issued to aircraft or pilots. This stakeholder must be an employee of the Department of the Interior, and the following delegated authorities may be included to this stakeholder:

1. Adhering to the appointment letter designated by the Bureau Lead A/OPC. The

subsequent responsibilities in this section may or may not apply to each A/OPC, depending on the written appointment letter.

2. Serving as the primary representative for bureau specific technical and policy matters relating to the DOI Fleet Card Program.

3. Serving as a liaison between account holders and the bank vendor customer service representative.

4. Overseeing application processing applications for new aviation fleet card accounts. 5. Managing fleet card profile data, accounts to include hierarchy maintenance and all

other elements of profile data. 6. Ensuring card holder/approving official relationships are accurate. 7. Managing program risk through internal controls and oversight. 8. Overseeing the proper use of the fleet card for aviation operation and maintenance. 9. Auditing aviation fleet accounts as required by DOI policy. 10. Reporting suspected fraud and misuse to the supervisor and the Bureau Lead A/OPC. 11. Terminating and suspending accounts when necessary. 12. Using the bank's electronic access system and the brand’s data analytics tool to perform

account management, compliance reviews, and oversight, including detecting improper or fraudulent purchases.

13. Providing guidance, ongoing advice, and assistance to approving officials, supervisors and those using aviation fleet cards.

14. Completing required GSA Fleet Card Training for Program Managers 15. Ensuring DOI Aviation Fleet Card Program stakeholders adhere to federal laws and

regulations and DOI policies and procedures. 16. Providing input to bureau and office supplemental guidance and procedures, as needed. 17. Serving as the cardholder when appropriate.

L. Approving Official The Approving Official should be the cardholder’s first-line or second-line supervisor, or Fleet Manager, except in certain limited circumstances. See Section II. Roles and Responsibilities above for Separation of Duties and Section F. Bureau Fleet Manager or Bureau Procurement Chief, for appointing Approving Officials other than the employee’s supervisor. This stakeholder is responsible for the following items:

1. Completing mandatory Fleet Program Manager training and being appointed as an approving official.

2. Overseeing cardholder fleet card activity, by reviewing monthly statements of account and supporting documentation for cardholders under your purview and verifying the validity of all purchases listed on the cardholder's statement of account, and signing and dating the approved statements within 30 days of the statement closing date. Statements are available for download from the bank’s electronic access system monthly on the 20th of each month.

9

Page 10: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

3. Signing and dating the statements and maintaining, electronically or physically filing the documents according to bureau policy in such a manner that approved statements can easily be retrieved for audit or bureau review purposes.

4. Monitoring cardholder actions to ensure fleet cards are only used for official government business, and that purchases are accurate and appropriate.

5. Ensuring cardholders within your span of control understand and follow the DOI Fleet Card Policy and fleet card regulations and laws.

6. Taking appropriate action to address instances of misuse; and ensuring all questionable transactions are resolved in coordination with the A/OPC.

7. Developing and maintaining records showing questioned transactions, the investigation conducted and the resolution of that investigation, including disciplinary action taken or referral to the OIG.

8. Ensuring that cardholders follow the mandatory source requirements established in FAR 8.002 Priorities for Use of Mandatory Sources and 41 CFR § 101-26.602 - Fuels and packaged petroleum products obtained from or through the Defense Logistics Agency or established by DOI or within the Bureau.

9. Assisting A/OPCs and cardholders with their responsibility to obtain, maintain, and retain complete documentation of all purchases.

10. Ensuring cardholders who issue convenience checks (Air Fleet Card only) collect IRS Form W-9 information from the payee and enter the vendor IRS Form W-9 information in FBMS.

11. Ensuring cardholders report lost or stolen convenience checks promptly to you, DOI’s servicing bank and the bureau A/OPC.

12. Ensuring cardholders report lost or stolen fleet cards promptly to you, DOI’s servicing bank and the bureau A/OPC.

13. Ensuring cardholders notify their A/OPC if the cardholder is departing the organization, moving to a new organization code, or is going on extended leave, in accordance with Bureau exit procedures.

M. Supervisor Even in circumstances where the approving official is not the cardholder’s supervisor, this stakeholder will have the following roles and responsibilities:

1. Overseeing fleet cardholders and the fleet card program in their organization. 2. Counseling cardholders within his/her span of control regarding regulations, and misuse

and abuse. 3. Notifying the A/OPC of employee separations (permanent and temporary) and approving

official changes. 4. Reviewing and approving cardholder applications and determining the cardholder’s need

for fleet cards. N. Acting Approving Official, In cases where the approving official will be unavailable for a substantive period of time, there may be an acting approving official. This stakeholder is responsible for completing the Approving Official training prior to assuming the duties of an acting approving official and approving any transactions or signing any cardholder statements. The duration of acting does not matter, but bureaus should avoid naming an acting approving officials for short-term absences (e.g. due to official travel), because of the administrative burden associated with

10

Page 11: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

changing the approving official. The acting approving official must inform the A/OPC regarding the acting duties.

O. Cardholder For the purposes of the Fleet Account, the individual signing the application as "Local Operator" or “Fleet Manager” is considered the "cardholder" who reconciles the account and prepares the certification or signs the statements. This stakeholder may have cards issued to fleet vehicles, aircraft, pilots, vessels, heavy equipment, miscellaneous equipment, and GSA Dry leased vehicles. This stakeholder must be an employee of the Department of the Interior. This stakeholder is responsible for the following items:

1. Completing mandatory Fleet Program Manager training and applying for the fleet card after obtaining supervisor approval.

2. Complying with all spending limitations, federal laws and regulations, and DOI Fleet Card policy.

3. Reviewing cardholder statements of accounts within 30 days of the end of the statement date to ensure all transactions are accurate, valid, and incurred for official government business, and attaching supporting documentation for each transaction. Statements are produced monthly on or about the 19th of each month.

4. Signing their statements and providing their statements and supporting documentation to their approving official.

5. Contacting the merchant to resolve invalid transactions, within 60 days of the transaction, prior to disputing transactions in the servicing bank’s electronic access system.

6. Disputing suspicious transactions attaching any supporting documents using Citibank’s electronic access system, CitiManager.

7. Following bureau/office exit clearance procedures to ensure account closure when leaving the organization.

8. Reporting suspected misuse or abuse of fleet cards or convenience checks to their Approving Official/Supervisor, A/OPC, and OIG.

P. Convenience Checkwriter (Aircraft Fleet Card) Convenience checkwriters are a subset of aircraft fleet cardholders. This stakeholder is responsible for all of the responsibilities listed above in subsection O. Cardholders and those listed below:

1. Applying for convenience checks. 2. Complying with spending limitations established for convenience check purchases,

federal laws and regulations, and DOI Charge Card policy. 3. Following bureau exit clearance procedures to ensure that unused checks are destroyed

and account is closed when leaving the organization. 4. Tracking outstanding checks that may appear as transactions on future billing

statements. 5. Complying with convenience check policy restrictions as outlined in Section V Use

Restrictions, subsection D. Convenience Check Restrictions. 6. Collecting IRS Form W-9 tax form from vendor prior to issuing a convenience check, and

coordinating with bureau finance office for exemptions. 7. Following bureau or office processes for ensuring IRS Form W-9 tax form information is

entered into FBMS.

11

Page 12: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

III. Spending Limitations Click on the links below to view the relevant policy sections.

A. Default Purchasing Limit B. Split Purchases C. Above the Micro-purchase Threshold

A. Default Purchasing Limit Cardholders may use the fleet card to make purchase transactions when the aggregated amount does not exceed the micro-purchase threshold, which is currently set at $10,000 (see the FY18 NDAA, Section 805). If the information in section conflicts with the most recent version of the Federal Acquisition Regulation (FAR), the current FAR thresholds for micro-purchases will supercede this policy. See FAR Subpart 13.2 and FAR Subpart 2.1. This default purchasing limit applies to most purchases of supplies, equipment, materials, and goods with the exceptions listed as outlined below:

1. $10,000 for goods, supplies and services that do not fall under the Service Contract Labor Standards or the Construction Wage Rate Requirements statute (see 48 CFR § 22.403-1 - Construction Wage Rate Requirements statute). These services are those that meet the definition of “learned professional services” (see DOI-AAAP-0083, Acquire "Learned Professional" Services at DOI). Note: purchases made with aviation fleet card convenience checks may not “be used for an amount in excess of one half of the micro-purchase threshold.” So, the maximum amount a convenience check can be used is $5,000 (see FY18 NDAA, Section 806).

2. $2,500 for services that fall under the Service Contract Labor Standards (SCLS) (See FAR Subpart 22.10, FAR Subpart 2.1 and 41 USC 67.) The Code of Federal Regulations (CFR) 22.1003-4, Administrative limitations, variations, tolerances, and exemptions, allows for these exceptions to the SCLS:

a. Automobile or other vehicle (e.g., aircraft) maintenance services (other than contracts or subcontracts to operate a Government motor pool or similar facility).

b. Maintenance, calibration, repair, and/or installation (where the installation is not subject to the Construction Wage Rate Requirements statute, as provided in 29 CFR 4.116(c)(2)) services for all types of equipment where the services are obtained from the manufacturer or supplier of the equipment under a contract awarded on a sole source basis.

B. Split Purchases Cardholders are prohibited from splitting purchases to circumvent the purchasing limits. Examples of prohibited split purchases are:

1. Intentionally divided into two or more separate purchases to avoid exceeding the single purchase limit.

2. A single cardholder makes multiple purchases from the same merchant where the aggregate total amount exceeds the single purchase limit, and the total was known at the time of the first purchase.

3. A single cardholder purchases the same/similar item(s) from multiple merchants on the same day. The total purchase amount exceeds the single purchase limit, and the total was known at the time of the first purchase.

12

Page 13: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

4. Multiple cardholders under the same supervisor/approving official purchase the same/similar item(s) to fulfill one requirement where the aggregate total amount exceeds the single purchase limit, and the total was known at the time of the first purchase.

C. Above the Micro-Purchase Threshold Use of the fleet card above the micro-purchase threshold is prohibited. IV. Authorized Use This section describes the authorized use of the fleet card at DOI. Failure to ensure strict compliance with this section and federal procurement regulations may result in card suspension or disciplinary action. Fleet cards cannot be used as a substitute for the acquisition process. The fleet card must be used in accordance with FAR 22.1003-4(d)(1) and FAR 13.301. The fleet card must only be used by a federal government employee and other authorized users with valid state license, either a driver, operator, or pilot authorized to use the assigned fleet equipment. The primary email address associated with the fleet card must be the cardholder’s official Department of the Interior address ending in .gov or .edu. The secondary email address associated with the fleet card can be an official Department of the Interior group email address ending in .gov or .edu. Use of personal email addresses with the fleet card are prohibited. The fleet card is mandatory for use for the items described below as long as the conditions listed in FAR 22.1003(d)(2) are met.

1. Supplies or services directly related to the operation and maintenance of vehicles, equipment, boats, ocean-going vessels, aircrafts, and miscellaneous equipment that are either owned or commercially leased by DOI and to which the card is assigned.

2. To procure aviation fuel, fuel related supplies, landing/airport fees and ground services on DOI-owned aircraft and DOI-contracted aircraft.

Per OMB Circular A-123, Appendix B, the fleet card is used to purchase “fuel, authorized repairs, parts, or services for government owned or leased vehicles, fueled appliances and equipment, small marine craft, and aviation” to include oil, other vehicle fluids, vehicle charging for electric vehicles, and minor maintenance or repair items or services under the micro-purchase threshold. Vehicles includes boats and ocean-going vessels. Fleet cards cannot be used to purchase property or equipment that accompanies a vehicle but is not permanently affixed. See Section V Use Restrictions below. The purchase card must be used for purchasing such property or equipment. The miscellaneous fleet card should be used for equipment supplies and services and for the maintenance of small motorized equipment, e.g., lawn mowers, chain saws, miscellaneous equipment supplies or services for motorized small equipment. This includes oil, fuel, and minor maintenance or repair items or services under the micro-purchase threshold. The miscellaneous fleet card should be used on approved General Services Administration (GSA) no mileage rate (dry lease) vehicles under an interagency maintenance and reimbursement agreement with DOI. No mileage rate (dry lease) vehicles are those that GSA

13

Page 14: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

does not provide a fleet card for the purchase of fuel and maintenance. No mileage rate (dry lease) leases exclude maintenance and fuel costs. DOI employees are authorized by the Department of Defense (DOD) to use the DOD Air Card for DOI owned aircraft. The use of the DOD Air Card is governed by DOD policies and procedures.

A.Tolls and Toll Pass Transponders.

1. Toll Pass Transponders. a. The purchase card is the preferred card to use to purchase toll passes; however,

the fleet card can also be used, provided that its use is allowed by bureau policy and if toll transactions are properly reallocated in FBMS.

b. In circumstances where toll roads or bridges do not have toll attendants to collect tolls, and the road or bridge uses a camera to record the license plate of the government vehicle, the purchase card remains the preferred card to use to pay the tolls, although the fleet card may also be used to pay the tolls, subject to the restrictions listed above in 1.a.

2. Tolls. a. Toll charges are reimbursable charges for temporary duty (TDY) and local travel.

Cardholders on TDY/local travel driving a fleet vehicle should use their travel card to make individual toll payments.

b. Those individuals in a local travel status without a travel card should pay the toll with personal funds and be reimbursed by submitting an Optional Form 1164, Claim for Reimbursement for Expenditures on Official Business, in accordance with bureau or office procedures.

c. The third, least preferred option if the individual does not have a travel card or funds to pay the toll is to use the fleet card to pay the tolls, subject to the restrictions listed above in 1.a.

B. Bulk Fuel To refuel vehicle mounted fuel tanks less than 500 gallons, the miscellaneous fleet card or purchase card can be used. FAR 8.002 Priorities for Use of Mandatory Sources and 41 CFR § 101-26.602 - Fuels and packaged petroleum products obtained from or through the Defense Logistics Agency proscribe the Defense Logistics Agency (DLA) as the mandatory source of supply for bulk fuel purchases, which DLA Energy defines as annual amounts of fuel above 10,000 U.S. gallons per type of fuel. For purchases from DLA Energy, the purchase card may only be used by a contracting officer when bulk fuel is procured using the purchase request process. V. Use Restrictions The use of the vehicle fleet card, miscellaneous fleet card, and the aircraft fleet card is restricted to official government fleet transactions that comply with all Department, bureau, and office policies. These cards are prohibited for the following purposes:

14

Page 15: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

 

1. Purchasing property and equipment for the vehicle that is not permanently affixed to include snow plow blades, law enforcement light bars, motorized lift gates, and lane marking paint systems.

2. Travel-related expenses for the driver’s travel. 3. Convenience items at gas stations not related to the vehicle. 4. Personal expenses, services, convenience items, and commuting expenses. 5. Purchase fuel, oil, supplies, services or repair for GSA-leased vehicles that come with

their own fleet card. 6. Purchase fuel, oil, supplies, services or repair for privately owned vehicles. 7. Purchase of bulk or warehouse stock (i.e. oil filters, air filters, belts, etc.)

A. Merchant Reward/Loyalty Programs Use of merchant reward/loyalty programs with the GSA SmartPay Fleet Card is permitted only if the benefits and rewards of the program accrue to the government in a manner to benefit the government agency and not to the cardholder for personal use. Bureaus can further restrict the use of these programs. Those with fleet card program responsibilities should refer to the language in CFR Title 5 – Standards of Ethical Conduct for Employees of the Executive Branch for further information. Questions about ethics rules should be directed to your bureau or office Ethics Official. See also GSA SmartPay Smart Bulletin #24, Rewards Program Policy and Guidance.

B. Convenience Check Restrictions While use of convenience checks is sometimes necessary for fleet aircraft, individuals should limit use of convenience checks because Public Law 104-134, The Debt Collection Improvement Act of 1996 requires that, with limited exceptions, Federal payments be made through electronic means. The Department of the Treasury has ruled that checks are not electronic funds transfer (EFT) compliant. The following actions are prohibited for the use of convenience checks:

1. Issuing a convenience check to vendors who accept the fleet card. 2. Issuing a convenience check to oneself or to cash. 3. Payments to other Government agencies. 4. Employee reimbursements. 5. Cash advancements. 6. Issuing salary payment, cash award or any transaction processed through the payroll

system. 7. Issuing a convenience check to a DOI employee. 8. Issuing a cash advance, advance payment, or reimbursement. 9. Issuing a spot award or incentive to contractors or contract employees. 10. Issuing a convenience check for travel tickets or expenses, including meals, lodging and

rental or lease of vehicles. 11. Purchasing anything prohibited for purchase with a fleet card.

VI. Fraud, Misuse, Abuse, and Collusion All participants in the DOI Fleet Card Program are responsible for preventing fraud, misuse, abuse and collusion. See these sections below to learn more about each topic.

15

Page 16: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

A. Defining Fraud, Misuse, Abuse and Collusion B. Consequences of Fraud, Collusion, and Misuse or Abuse C. Roles and Responsibilities for Reporting Fraud, Collusion, and Misuse or Abuse

A. Defining Fraud, Misuse, Abuse and Collusion 1. Fraud. OMB Circular A-123, Appendix B differentiates between internal and external

fraud and provides the below definitions.

a. Internal Fraud - “Any felonious act of corruption or attempt to cheat the Government or corrupt the Government's agents by Government Charge Card Program officials. Use of the Government purchase, travel, fleet or integrated charge card(s) to transact business that is not sanctioned, not authorized, not in one's official government capacity, not for the purpose for which the card was issued, not as part of official government business.” As described in this policy, controls must be established to monitor the following processes: application, transaction, review and approve, and fleet card management. See the Internal Controls section for more information on internal controls and see Consequences of Fraud, Collusion, and Misuse or Abuse section to learn about the potential outcomes of fraudulent activity.

b. External Fraud - “Any felonious act of corruption or attempt to cheat the Government or corrupt the Government's agents by someone other than Government officials. Otherwise known as third party fraud.” External fraud includes non-account holder fraud which includes:

i. Account/Card never received – A new or replacement card has been mailed to the account holder but was not received. This may be due to a third party interception.

ii. Lost or Stolen Account/Card iii. Altered or counterfeit cards – This occurs when third parties obtain

account information and used that information to make purchases with an altered or counterfeit card.

iv. Account takeover/ Identity theft – In this case, the account holder’s identity has been compromised and a third party has requested a new account by providing confidential information about the account holder.

2. Misuse. OMB Circular A-123, Appendix B defines misuse as: “Unintentional use of the

purchase, travel, fleet and/or integrated charge card in violation of the FAR, DFARs, FTR, Agency Supplements, or Agency Policies/Procedures. These actions are the result of ignorance and/or carelessness, lacking intent, to include honest mistakes.” Examples of misuse include:

a. Mixing up a government purchase card with one’s personal credit card and making a charge unintentionally.

b. Using a fleet card instead of a purchase or travel card or vice versa. See Consequences of Fraud, Collusion, and Misuse or Abuse section to learn about the potential outcomes of activity that involves misuse and abuse.

16

Page 17: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

3. Abuse. OMB Circular A-123, Appendix B defines abuse as:defines abuse as,“intentional use of the purchase, travel, fleet and/or integrated charge card in violation of the FAR, DFARS, Agency Supplements, or activity . . . [Government Fleet Card] policies/procedures. Evidence of intentionality shall be inferred from repeat offenses of the same violation, following administrative and/or disciplinary action taken for this violation.” An example of abuse is using the fleet card to purchase fuel for privately-owned vehicle See Consequences of Fraud, Collusion, and Misuse or Abuse section to learn about the potential outcomes of activity that involves misuse and abuse.

4. Collusion. Collusion occurs when individuals illegally cooperate or conspire in order to

cheat or deceive others. For the purposes of fleet cards, collusion occurs when two or more persons cooperating or conspiring to commit fraud or to intentionally misuse or abuse a fleet card. See Consequences of Fraud, Collusion, and Misuse or Abuse section to learn about the potential outcomes of activity that involves collusion.

B. Consequences of Fraud, Misuse, Abuse and Collusion Consequences of acts of fraud, misuse, abuse and collusion are described below.

1. Acts of fraud, misuse, abuse and collusion with the fleet card or convenience checks may result in immediate cancellation of the card and disciplinary action against the involved stakeholder(s) as required by the Government Charge Card Abuse Prevention Act. The range of disciplinary actions varies with the severity of the infraction and will be applied in accordance with Departmental and bureau/office guidelines. Part 370 of the Departmental Manual (370 DM 752) addresses discipline and adverse actions.

2. Intentional misuse of the card will be considered an attempt to commit fraud against the United States Government. As described in 18 U.S.C. 287, the individual may be subject to a fine of not more than $10,000, or imprisonment for not more than five years, or both. Cardholders may be held personally liable to the government for the amount of unauthorized transactions, plus interest and debt collection fees for intentional misuse or abuse of the purchase, travel, or fleet card. Supervisors, approving officials, individuals that collude to misuse or abuse the card or to commit fraud, or individuals who use his or her position or authority to cause misuse or abuse of the card, may be subject to fines and imprisonment as well as the disciplinary actions and prosecution described below. The following actions are possible administrative and legal consequences for fleet card infractions:

a. Counseling employee b. Removing fleet card privileges c. Suspending card d. Cancelling card e. Issuing a written reprimand f. Offsetting the individual's salary to collect full cost of unauthorized purchases

including administrative expenses g. Suspending employee h. Terminating employee

17

Page 18: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

i. Referral to legal authorities for additional civil action and/or criminal prosecution.

C. Roles and Responsibilities for Reporting Fraud, Misuse, Abuse and Collusion Roles and responsibilities described below apply to reporting suspected fraud, misuse, abuse and collusion in the Fleet Card Program.

1) Employees are responsible for immediately reporting suspected fraud, misuse, abuse, and collusion of fleet cards or convenience checks to the A/OPC and elevating unresolved questionable purchases to the A/OPC in the event an unauthorized purchase is suspected or observed, or there is a purchase that is still in question after review of supporting account holder documentation.

2) Employees with knowledge of fraud, waste, abuse, misconduct, or mismanagement involving the U.S. Department of the Interior can also contact the Office of Inspector General's hotline. See https://www.doioig.gov/oig-hotline-forms for more information.

3) The A/OPC will initially notify the Bureau Lead A/OPC and the supervisor and approving official of unresolved questionable purchases.

4) The supervisor and approving official are responsible for taking the following actions: a) Immediately gather facts and discuss the incident with the employee. b) Notify the A/OPC (if not already notified) and other appropriate personnel in

accordance with DOI and bureau policy. c) Follow one of the two processes described below depending on the outcome of

the facts gathered. i) If facts indicate the incident was unintentional or did not result in loss to

the government, provide counsel to the employee and report to Agency/Organization Program Coordinator to ensure the employee reimburses the government for the unauthorized transaction or purchase.

ii) If facts indicate the incident is intentional, inform the Office of Human Resources and report the incident to the Office of the Inspector General by following instructions for reporting suspected fraud at the following link: Office of Inspector General Hotline or calling 1-800-424-5081.

(1) In accordance with OMB Circular A-123, Appendix B, In cases of suspected fraud, charge card managers must refer these instances to independent organizations (e.g., the agency's Office of Inspector General (OIG) or the Department of Justice) for investigation.

5) If the supervisor or approving official completes their review of the facts and circumstances and determines the incident was intentional, the Bureau Lead A/OPC will notify the following stakeholders:

a) Bureau Fleet Manager b) DOI Charge Card Program Manager c) Servicing Human Resource Employee Relations Office d) Servicing Bank e) Office of Inspector General (in coordination with the supervisor and approving

official) 6) The A/OPC will also conduct the following actions as necessary and prescribed above:

a. Temporarily limit, suspend, or cancel fleet card privileges in coordination with the employee’s supervisor.

b. Monitor the situation to ensure all steps are completed and the issue is resolved.

18

Page 19: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

c. Document all cases of card misuse or abuse in the servicing bank’s data mining system.

d. Provide consultation to stakeholders as necessary.

VIII. Internal Controls The purpose of the internal control section is to provide stakeholders with information regarding the system of internal controls for the DOI Charge Card Program. Information provided in this section is considered mandatory; bureaus and offices must implement information provided in this policy section. A summary of the areas covered in this section is provided below.

A. Overview of Requirements - view this section to learn more about the policy governing internal controls at the DOI and overall bureau and office requirements.

B. Description of Controls - view this section to learn more about the controls required to be tested annually by bureaus and offices.

C. Execution of Internal Controls - view this section to learn more about the required use of use Citibank’s CitiManager and Visa IntelliLink Compliance Management System.

A. Overview of Requirements Internal Controls are tools to help program and financial managers achieve results and safeguard the integrity of their programs. Effective internal control provides reasonable assurance that significant risks or weaknesses that could adversely affect the agency’s ability to meet its objectives would be prevented or detected in a timely manner. A system of internal controls over the DOI Fleet Card Program is a process that includes measures such as policies and procedures, checks and balances, monitoring and reviews to prevent waste, fraud and misuse associated with DOI Charge Cards. Internal controls are necessary to ensure the achievement of organizational objectives; operational effectiveness and efficiency; reliable financial reporting; and compliance with laws, regulations and policies. The Government Charge Card Abuse and Prevention Act of 2012 (Pub.L.112-194) (Charge Card Act) requires all Executive Branch agencies to establish and maintain safeguards and internal controls to prevent waste, fraud, and abuse of purchase cards, travel cards, fleet cards, and other centrally billed accounts. Appendix B of OMB Circular A-123, A Risk Management Framework/or Government Charge Card Programs, prescribes policies and procedures to agencies regarding how to maintain internal controls that reduce the risk of fraud, waste, and error in government charge card programs. The information provided in the internal control section is designed to create specific controls which complement the annual requirements established in the fiscal year internal controls guidance by the Office of Acquisition and Property Management and the Office of Financial Management and meet the requirements of Appendix B of OMB Circular A-123.

Bureaus and offices will establish, monitor, assess and periodically review their controls to ensure cardholders, approving officials, A/OPCs and others with Fleet Card Program responsibilities adhere to applicable requirements. Bureaus and offices are required to provide annual assurance to the Office of Acquisition and Property Management (PAM) that controls described in the Description of Controls section exist and are regularly monitored. Assurance

19

Page 20: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

shall be demonstrated by testing the controls using data sampling, system reports, and other types of information gathering and verification as necessary.

Bureaus and offices are encouraged to share best practices regarding established internal controls for the DOI Charge Card Program with the Office of Acquisition and Property Management for possible Department-wide adoption. B. Description of Controls The controls provided below are separated into the following four processes: application, transaction, review and approval, and fleet card management. These controls are required to be established and monitored by bureaus and offices to provide annual assurance to the Office of Acquisition and Property Management. 1. Application Process (see section XI. Account Establishment)

a. Control must exist to ensure cards are issued to a named cardholder, a specific vehicle or piece/group of equipment and responsible employee is indicated, and are only used to acquire fuel and maintenance for authorized vehicles and/or equipment.

b. Control must exist to ensure cardholders and approving officials complete the required purchase card training in DOI Talent.

c. Control must exist to ensure the application for a government issued fleet card is completed by each employee and approved by her or his supervisor and documentation of supervisory approval is maintained.

d. Control must exist to ensure the A/OPC assigned to the office reviews and processes each fleet card application accurately.

e. Control must exist to ensure A/OPCs are the only individuals authorized to process fleet card applications.

2. Transaction Process

a. Control must exist to prevent or promptly detect a cardholder who makes improper transactions, which may include splitting purchases (see section III. Spending Limitations, C. Split Purchases) buying outside of business line authority, spending over authorized limits (see section III Spending Limitations), and purchasing prohibited goods and services (see section V. Use Restrictions).

b. Control must exist to ensure convenience checkwriters are not writing checks for amounts greater than the limits established in Section III A. Default Purchasing Limit.

c. Control must exist to ensure convenience checks are not being used for the purposes listed in section V. Use Restrictions B. Convenience Check Restrictions.

d. Control must exist to ensure cardholders are not purchasing any product or service for personal benefit rather than for a fleet-related need.

e. Control must exist to ensure disputed purchases and discrepancies between receipts and other supporting documentation and the statement of account are resolved.

f. Control must exist to ensure cardholders are seeking tax exemption on service, parts, and supplies and making good faith attempts to recover any state sales taxes paid.

3. Review and Approve Process (see section X. Review and Approve)

20

Page 21: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

a. Control must exist to ensure cardholders review transactions within 30 days of the statement date. Statements are produced on the 20th of each month

b. Control must exist to ensure proper supporting documentation accompanies fleet card statements from the cardholder to the approving official.

c. Control must exist to ensure the approving official reviews and approves or disapproves fleet card transactions within 30 days of the end of the statement date.

d. Control must exist to ensure a cardholder is not the approver of her or his own transactions regardless of review and approve methodology.

4. Charge Card Management Process

a. Control must exist to detect and deter fraud, abuse and misuse and to ensure appropriate actions are taken in instances of fraud, abuse or misuse.

b. Control must exist to ensure that accounts are closed as required. Accounts should be closed when the asset is entered in to FBMS as a Personal Property Disposal Record (PPDR) or set as inactive.

c. Control must exist to ensure lost, damaged, or stolen cards or convenience checks are properly addressed.

d. Controls must exist to ensure steps are taken to recover the cost of any illegal, improper, or erroneous purchases or payments, including as necessary, through salary offsets.

e. Control must exist to ensure the approving official has direct knowledge of the cardholder’s role and the ability to verify receipt of goods or services.

f. Control must exist to ensure the number of cardholders and approving officials assigned to an A/OPC is reasonable based on the volume of cardholder activity and organizational structure.

g. Control must exist to ensure that responsibilities of an approving official and A/OPC do not overlap.

h. Control must exist to ensure the assignment of duties is separated by individuals; this may include the following duties: authorizing, approving, and recording transactions; receiving assets; approving cardholder statements; making payments; and reviewing or auditing.

i. Control must exist to ensure cardholders, approving officials and A/OPCs take initial fleet card training prior to receiving a card or assuming their duties and take refresher fleet card training at least every three years.

C. Execution of Internal Controls Bureaus and offices must use Citibank’s CitiManager reports and Visa IntelliLink Compliance Management System’s analytics, rules, reports, and case management functionality to identify, flag and review suspicious transactions, create cases as appropriate, track responses and corrective actions, and record them in IntelliLink for auditor review. Bureaus and office should execute and take action on the results of the Department-level rules, at a minimum, on a monthly basis. See section XIV. System Resources for more information on these systems. Please refer to the annual Internal Control Guidance for more detailed instructions and due dates. IX. Account Establishment To establish a new account and apply for any type of fleet card, cardholders must follow the steps provided below. As described in Section II Roles and Responsibilities, paragraph P

21

Page 22: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

Cardholder, a cardholder for the purposes of the Fleet Account is the individual signing the application as "Local Operator" or “Fleet Manager” is considered the "cardholder" who reconciles the account and prepares the certification or signs the statements.

1. Obtain Supervisor approval prior to being issued a fleet card; 2. In DOI Talent, complete the GSA SmartPay mandatory Fleet Program Manager training

review the DOI Charge Card Program Agreement of Responsibility, and certify compliance with both documents. (see Training section for more information);

3. Upload the training certificate from the GSA SmartPay training into DOI Talent; 4. Contact the bureau or office A/OPC to determine the application process to be used, e.g.

bulk upload or online application. 5. If using the online application, the bureau or office A/OPC will provide the bank vendor

system access code and passcode; and 6. Complete the bank vendor online application process for a fleet account using the

vehicle, aircraft, pilot, heavy equipment identification; input the correct approving official/supervisors contact information and budget account code information.

Bureaus should retain documentation of the supervisor’s approval in accordance with bureau processes. X. Review and Approve A. Cardholders and Convenience Checkwriters Cardholders and convenience checkwriters shall review their cardholder statements of accounts within 30 days of the statement date to ensure all transactions are accurate, valid, and incurred for official government business, and provide supporting documentation for each transaction. Statements are generally produced on the 20th of each month. Cardholders may review their transactions in CitiManager’s Transaction Management System (CTMS) module throughout the month and do not have to wait to identify and report suspicious transactions. Cardholders and convenience checkwriters who identify suspicious transactions shall dispute them using CitiManager. Once cardholders and convenience checkwriters have conducted their review, they will sign and date their statements and provide their statements and supporting documentation to their approving official. Cardholders are prohibited from serving as the approving official for their own transactions. While completing these reviews within 30 days is the minimum standard, a best practice is for cardholders and convenience checkwriters to review their statements within five business days of the statement date to expedite transaction disputes and reallocations. B. Approving Officials (AO) The AO shall review the cardholder’s/convenience checkwriter’s statements and supporting documentation for accuracy and to identify any suspicious transactions and approve or disapprove fleet card transactions and statements within 30 days of the end of the statement closing date. If the AO identify suspicious transactions, they will send the statements and supporting documentation back to the cardholder for additional information. Once the AOs have conducted their reviews and approved cardholder statements, they will sign (digitally or manually) and date the statements. AOs shall ensure the approved statements and supporting documentation are maintained and electronically or physically filed according to bureau policy in

22

Page 23: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

such a manner that approved statements can easily be retrieved for audit or bureau review purposes. C. Consequences for not Conducting Review and Approve The proper and timely execution of the Review and Approve process is an integral part of cardholder, convenience checkwriter, and approving official responsibilities under DOI’s Charge Card Program and an essential part of DOI’s internal controls. The failure of a cardholder, convenience checkwriter, or approving official to complete one’s responsibility to review and approve transactions as outlined above can result in:

1. Suspending or cancelling the fleet card or cards 2. Suspending an Approving Official from serving as an Approving Official 3. Revoking an Approving Official’s Appointment as an Approving Official

In addition to these DOI Charge Card Program penalties, Part 370 of the Departmental Manual (370 DM 752) addresses additional potential discipline and adverse actions that can be taken. XI. Methodology and Recordkeeping The Review and Approve requirements can be conducted using paper or digital (e.g. Adobe PDF files) statements and supporting documentation. If a paper process is used, the final approved statement and supporting documentation can be filed as paper documents or the documents can be scanned and maintained electronically. Additionally, bureaus can upload signed statements and supporting documentation in Citibank’s electronic access system, CitiManager, in the Citibank Transaction Management System (CTMS) module. To comply with OMB Managing Government Records Directive M-12-18, which requires that to the fullest extent possible, agencies eliminate paper and use electronic recordkeeping, electronic documents are the best practice. Regardless of the way statements and supporting documentation are maintained, they should be easily retrieved for audit or bureau review purposes. The retention period shall be in accordance with the relevant Federal regulations, including the National Archives and Record Administration (NARA) regulations and the Federal Acquisition Regulation (FAR). XII. Account Reallocation The Financial and Business Management System (FBMS) is the system of record for tracking cost allocation of fleet card transactions. Bureaus and offices must ensure that charges are reallocated to the correct account in FBMS. Sufficient information must be provided to ensure accuracy in financial reporting by associating charges to the appropriate account assignment (funding, responsible cost center or object class, etc.) or relevant referencing object (Work Order, Asset record, etc.). This information is communicated as hand-written instructions on a statement copy, electronically on a PDF copy of the statement, through email correspondence to an individual with reallocation capability (role-based authority) in FBMS, or through other bureau processes. XIII. Training Requirements DOI uses the GSA-developed training to meet the OMB training requirements for both initial and refresher training. This training is located in DOI Talent. There are separate courses for the

23

Page 24: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

purchase, travel, and fleet card. In addition, there are designated courses for cardholders, approving officials and A/OPCs. This training is located in DOI Talent. All fleet cardholders, approving officials, supervisors, and A/OPCs are required to complete the following actions, at a minimum, prior to appointment or card issuance:

● Complete the Fleet Card Training course for their role (cardholder, Approving Official, A/OPC) in DOI Talent.

● Complete refresher training in DOI Talent every three years to continue to participate in the DOI Fleet Card Program.

● Cardholders: Certify that they have read and will comply with the Charge Card Agreement of Responsibility in DOI Talent. During refresher training, recertify that they have read and will comply with the Charge Card Agreement of Responsibility

● Approving Officials: Download and retain the Approving Official Appointment Letter. ● A/OPCs: Read the Fleet Card Policy and thoroughly understand Cardholder and AO

responsibilities and procedures for identifying and reporting fraud, abuse and misuse. A/OPCs are also required to participate in training on:

● CitiManager to include the CitiManager Transaction Management (CTMS) module and CitiManager Custom Reporting System (CCRS) module.

● Proper card management (account set-up, authorization controls, account close-out) ● VISA IntelliLink Compliance Management System (rules, reports, case management)

Training can consist of participation in on-site classes, webinars, on-demand web-based content, review of job aids, and attendance at the annual GSA SmartPay Training Forum. XIV. System Resources The purpose of the system resources section is to provide users with a one-stop shop for system resources as they pertain to the DOI Fleet Card.

A. Bank Vendor Systems and Resources - view this section for bank vendor systems and resources for the DOI Fleet Card.

B. Financial and Business Management System (FBMS) - view this section for FBMS resources for the DOI Fleet Card.

C. Federal Personnel Payroll System (FPPS) - view this section for FPPS resources as they pertain to the DOI Fleet Card.

A. Bank Vendor Systems and Resources The DOI Fleet Card Program is supported by Citibank through a task order under the General Services Administration's SmartPay 3 master contract. Citibank and Visa manage the systems which interface with a variety of DOI systems. The links below have a variety of resource information.

1. CitiManager and the Citibank Transaction Management (CTMS) module allows Cardholders to access account information, review statements, manage alerts, dispute transactions and upload receipts. CitiManager and CTMS allows A/OPCs to efficiently manage the fleet card program. A/OPCs have varying entitlements in the CitiManager to perform the following functions:

a. View accounts, statements, balances, and transactions.

24

Page 25: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

b. Dispute transactions. c. View authorizations and declines. d. Review, approve, or reject new cardholder applications. e. Perform account maintenance. f. Create, activate and deactivate users. g. Assign applications and companies. h. Set passcodes. i. Manage alerts. j. Manage the account profile. k. View and print reports.

2. Citibank Custom Reporting System (CCRS). In addition to CitiManager and CTMS,

CCRS is another module available that allows A/OPCs to create queries with wizards and download data into spreadsheet, database or word processing format. CCRS can provide:

a. Online access to over 600 data elements, including level III detail b. Stored customizations by user for faster report set-up c. E-mail notification so you can retrieve reports at your convenience d. The ability to schedule reports to run when you need them e. The capability to “drill down” to deeper levels of detail

3. Visa IntelliLink Compliance Management is DOI’s data-analytic, web-based data mining

system for the DOI Charge Card Program. DOI will use the system as an essential part of the Charge Card Program internal controls. Primary users are the Charge Card Support Center and Bureau Lead A/OPCs. Visa IntelliLink provides the following capabilities:

a. Allows rules to be set tracking certain types of transactions; b. Generates a sample transaction data set for review; c. Employs predictive and analytical capabilities to identify card program misuse

and abuse; d. Identifies transactions that may need further investigation; e. Offers reporting on, and analysis of, fleet card transactions; and f. Combines rules and predictor scores to provide a “one-stop-shop” to manage

each program.

B. Financial and Business Management System The Financial and Business Management System (FBMS) interfaces with the bank's charge card system on a daily basis to capture card transaction activity. Training is required as a prerequisite to gain access to the FBMS fleet card data and business processes. This training is dependent on the end-users capability and role in FBMS. Only identified A/OPC's and necessary Financial management staff will be granted the roles necessary to access this information See FBMS training on the FBMS Hub.

1. Financial and Business Management System - use this link to access the proprietary system which integrates acquisition and financial data at the DOI. Note, this link is only accessible inside the DOI firewall.

25

Page 26: U . S . D e p a rt me n t o f t h e I n t e ri o r F l e e t C a rd P ro g ra m P … · 2020. 6. 18. · T h e F l e e t Ca rd P ro g ra m i s e st a b l i sh e d a t DO I t o p

2. FBMS Hub - use this link to access FBMS resources and additional information. Note, this link is only accessible inside the DOI firewall.

C. Federal Personnel Payroll System The Federal Personnel Payroll System (FPPS) data is used to help manage the bank's hierarchy system to closely match DOI's organizational structure. This allows for proper scope of view and responsibilities in the bank's system.

26