SECTION 7 - Purchasing

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SECTION 7.6 - The University P-Card

Date: December 2007
Approved: Senior Associate Vice President for Business and Finance

P-Card Administration	Obtaining a P-Card and P-Card Training	P-Card Roles and Responsibilities The P-Card Web SolutionT Software Roles External to the P-Card Web SolutionT Software Roles within the P-card Web SolutionT Software Restrictions on Multiple P-Card Roles Held by an Employee
Purchasing Guidelines Prohibited Purchases Restricted Purchases	Transportation Purchases and University Guest Hotel Rooms Air, Rail, and Bus Ticket Purchases Internal Controls for P-Card Transportation Purchases Hotel Room Purchases for Non-Employees and Events	Auditing P-Card Programs
Consequences for Cardholders and Departments Cardholders Departments	Exceptions

The University of Illinois Procurement Card, referred to as the P-Card (MasterCard™) simplifies purchase and payment for certain items costing $4,999, or less. The advantage of the P-Card is that the bank pays the vendors directly for purchases within a few days, and the University pays a single monthly payment to the bank for all University charges. The P-Card should be used by units whenever possible for purchases of supplies and small equipment, in accordance with applicable purchasing procedures, from any vendor that accepts MasterCard™.

P-Card purchases must be in compliance with all procurement, allowable expenditure and funding, payroll, and tax-related policies. (See related Sections 4, Payroll, 7, Purchasing, 8, Accounts Payable, 10, Cash Handling, 13, Accounting, 15, Employee Business Travel, and 18, Taxes for additional information. Also, see section below on P-Card holder and reconciler responsibilities.

Employees who participate in the P-Card program as Cardholders, Department Card Managers, Reconcilers, or Approvers assume serious fiscal and ethical responsibilities. Unit heads must ensure that these employees understand the responsibilities and that there are consequences for violations of P-Card policy, including both P-Card purchases and P-Card Web SolutionT software activities. Both the responsibilities and the consequences of violations are discussed later in the policy.

P-CARD ADMINISTRATION

The OBFS, Corporate Card Office (CCO) is responsible for the management of the University's P-Card Program. The Senior Associate Vice President for Business and Finance designates the Director, Corporate Card Operations, as the University P-Card Administrator, who is responsible for overall, University-wide management of the University's P-Card Program, including development and administration of policies and procedures for the program.

The individual cardholder is responsible for compliance with University policies and the Illinois Procurement Code. The OBFS, Purchasing Division is responsible for administrative decisions regarding procurement issues. The OBFS, University Payables is responsible for administrative decisions regarding travel and business entertainment charges.

Under the direction of the Director, Corporate Card Operations, the OBFS, CCO is responsible for day-to-day operational activities of the program, University-wide. The OBFS, CCO accepts all electronic applications from the P-Card department card managers (DCM) and submits them to the bank. Additionally, the OBFS, CCO sets up the P-Card DCM role in P-Card Web Solution™, which is the software used to manage P-Card transactions.

OBTAINING A P-CARD AND P-CARD TRAINING

Obtaining a P-Card and P-Card Training

To obtain a P-Card, an employee must complete the Procurement Card Authorization/Agreement and Application and have it approved by his or her department head or authorized fiscal officer. All new P-Card applicants are required to complete training on P-Card program policies and pass a certification quiz before being issued a P-Card. There are two options for completing the training and the certification quiz for new cardholders.

P-Card Self-paced Online Tutorial
The on-line tutorial and certification quiz can be accessed from the P-Card Training Web site. The link for the "On-line P-Card Training" should be selected and the user's Enterprise ID/Password must be entered to access the training. The on-line tutorial curriculum includes P-Card policies and the certification quiz.

Instructor-led Training class
Instructor-led training classes are available at all three campuses. The curriculum includes P-Card policies, use of the P-Card SolutionT software, and the certification quiz. Class schedules and registration are available from the OBFS Training Center.

Note: P-Card Applications will not be approved until the applicant has successfully completed training and the certification quiz.

P-CARD ROLES AND RESPONSIBILITIES

All units that utilize one or more P-Cards are required to have employees that function in the following roles:

1. Department Head
2. Financial Statements Reconciler
3. P-Card Web Solution™ software Department Card Manager (DCM)
4. P-Card Web Solution™ software Cardholder
5. P-Card Web Solution™ software Reconciler

Departments that wish to implement additional internal controls may also elect to have an employee that functions as an Approver in the P-Card Web SolutionT software. The Approver role in the P-Card Web SolutionT software is optional.

The P-Card Web SolutionT Software

The University utilizes the P-Card Web SolutionT software to manage P-Card transactions. P-Card Web SolutionT software roles (DCM, cardholder, reconciler and the optional approver) are roles that have responsibilities using this software package. The Department Head and the Financial Statements Reconciler are not P-Card Web SolutionT software roles; these employees have responsibilities that are external to the P-Card Web SolutionT software.

Roles External to the P-Card Web SolutionT Software

1. Cardholder

The cardholder role is required. The department head or fiscal officer determines which employees in the department may have P-Cards. The department head may designate as many cardholders as she or he wishes; however, each cardholder may have only one card. Cardholders must be employees who have responsibilities for purchasing supplies and small equipment for their departments.

All new P-Card applicants are required to complete training on P-Card program policies and pass a certification quiz before being issued a P-Card. All existing Cardholders are required to complete training on P-Card program policies and pass a certification quiz before a new P-Card will be issued upon expiration of their existing P-Card.

Note: Students, including graduate students, may not be cardholders. Students, including graduate students, may not be reconcilers, DCMs, approvers, or delegates for any of the P-Card functions or roles, or have access to the P-Card SolutionT software.

The P-Card may be used only for University purchases, and the cardholder is personally responsible for all charges made on his or her P-Card. A P-Card may be used only by the person to whom it is issued. It may not be loaned to others, including employees in the same department. It is strictly prohibited to place a P-Card account number on file with any vendor unless otherwise specifically stated by policy. This includes the use for recurring payments (such as, subscriptions, dues, memberships, etc.) or on-demand use where the P-Card account number is retrieved from the vendor's database, customer profile, or account, and not uniquely provided with each transaction. The cardholder, and only the cardholder, must present or provide his/her P-Card or account number to the vendor each time a transaction is made. A cardholder who misuses or fraudulently uses the P-Card will be subject to investigation, disciplinary action, and/or termination of employment by the University, and may be subject to criminal prosecution.

Cardholder Responsibilities

By accepting and using a P-Card, a Cardholder agrees to:

• Notify the bank issuing the P-Card (by calling number on back of P-Card), the cardholder's DCM, and the OBFS, CCO immediately if the P-Card is lost or stolen. (The cardholder's department may be liable for all charges incurred until the P-Card is reported lost or stolen to the bank.)
• Make purchases of small equipment or supplies competitively where practical. Cardholders are encouraged to use Prime and Preferred Suppliers when possible.
• Consider performance, quality, suitability, delivery, and service when choosing vendors.
• Make purchases that are for University projects or activities and comply with any funding restrictions applicable to the C-FOAPAL. This includes restrictions outlined for grants and contracts funds and gift and endowment income funds. (All P-Card purchases for small equipment and supplies must be in compliance with Sections Section 7.2, Purchase of Goods and Services, 8.13, Allowability and Funding of Certain Expenditures and 8.12, Business Meals and Refreshments.)
• Understand and comply with the list of prohibited and restricted purchases in this policy.
• Provide complete shipping instructions when placing orders to vendors, and ask vendors to include receipts with the shipment. (Receipts should include the vendor's name, amount of order, date, and an itemized description of the item(s) purchased.)
• Pay no sales tax on purchases from vendors registered in Illinois. ("University of Illinois" and the University's sales tax exemption number are printed on P-Cards.) Cardholders should emphasize the University's tax exempt status and exemption number when placing orders. Purchases from vendors outside of Illinois may or may not be exempt. The University has sales tax exemptions in 24 states. These states are listed and links to their exemption letters, including the Illinois letter , are available in Section 18.6, Sales and Use Tax. Some states may limit the products or services to which the exemption applies.

• Create an Order Log the P-Card Web SolutionT software for each transaction made with a P-Card. An Order Log is to be created immediately following each transaction. The cardholder may have access to the P-Card Web SolutionT software to do this personally or may be required to provide the necessary information to another individual that has been delegated to perform this function for the Cardholder within the P-Card Web SolutionT software, other than the cardholder's reconciler. Each entry to the Order Log must contain the following information:
  • Transaction date for the purchase;
  • Brief description of the item(s) purchased;
  • Name of the vendor from whom the item(s) were purchased; and
  • Total dollar amount of the transaction.
• Provide the cardholder's reconciler with original receipts for all P-Card transactions. If the purchase is for a business meal or refreshment, the P-Card Order Log and the receipt must contain the names of all attendees and their business affiliation (for University employees the headquarters of the employee must be stated), the business purpose of the meal, and a statement that no alcohol was charged to the P-Card, unless allowable in accordance with Restricted Purchases. This information must be entered in the Comments section of the Order Log in the P-Card Web SolutionT software. See Section 8.12, Business Meals and Refreshments for additional information regarding allowable limits.
• Not engage in stringing or making successive purchases to avoid circumventing the P-Card's assigned single transaction limit regardless of whether the purchase is with one or several vendors. The practice of "stringing" orders is a direct violation of the Illinois Procurement Code.
• Verify that small equipment and supplies purchased with his/her P-Card are received and follow up with the vendor on any delivery problems, discrepancies, or damaged goods.
• Provide the unit with all documents related to the P-Card purchase, including packing lists, any exception approvals that were obtained for a restricted purchase, and competitive quotations.
• Handle any returns of purchases made on the P-Card as credits to the P-Card.

2. Department Head

This role is required. The department head has overall budgetary responsibility for the department's P-Card program and is responsible for following sound business practices. The department head assigns P-Card roles to employees within the department, balancing control and operating convenience in those designations. Regardless of the size and organization of the department maximum separation of duties must be maintained. If a department is small, the department head may designate an employee from another department to be the Reconciler for his/her cardholders. The department head retains final responsibility for control of the program in his/her department. An essential part of this control is the department head's responsibility, or delegation of responsibility, for review and reconciliation of monthly financial reports and statements.

3. Financial Statements Reconciler

This role is required. The department should designate an employee with no P-Card roles to review and reconcile monthly financial reports and statements. This review may also be performed by the department head. Financial reports and statements contain a record of each P-Card purchase made during the month. Department heads must ensure that the employees who review transactions are familiar with business policies and procedures, so their review of P-Card expenditures is thorough and they are sufficiently informed to make determinations regarding appropriate P-Card expenditures and that the appropriate C-FOAPAL has been used for each transaction. Employees performing the reviewing function are expected to make inquiries regarding P-Card transactions regardless of their position in the department relative to that of the P-Card holder.

Roles within the P-Card Web SolutionT Software

1. Department Card Manager

This role is required. The department head appoints a DCM for the department and notifies the OBFS, CCO of the appointment. The OBFS, CCO provides the DCM access to the P-Card Web SolutionT software. The DCM is responsible for general supervision and administering of the program and is also the principal contact person in his/her department for information related to the P-Card program, including relevant University policies. The DCM is also responsible for elevating and reporting any questionable or non-compliant P-Card activity to his/her department head and the CCO.

Training in the use of the P-Card Web SolutionT software and knowledge of the OBFS Business Policies and Procedures is required for all DCMs. All DCMs must attend the OBFS, CCO instructor-led training prior to the OBFS, CCO providing them with access to the P-Card Web SolutionT software. DCMs, in turn, are responsible for ensuring that employees in their departments with a P-Card role receive appropriate training.

DCM responsibilities include:

• Performing all required DCM functions in the P-Card Web SolutionT software;
• Supervising, administering and monitoring the P-Card program for their assigned business unit(s);
• Requesting new cards as needed and making necessary changes to existing cards;
• Setting limits for each cardholder based on a review of actual purchasing needs and responsibilities as follows:
• Number of transaction allowed in one day;
• Number of transactions in a billing period;
• Dollar Limit per transaction (maximum $4,999 - see the Exceptions sub-section for the procedures to request exceptions); and
• Dollar limit in a billing period (maximum $25,000 - see the "Exceptions sub-section" for the procedures to request exceptions).
• Determining which employees need access to the P-Card Web SolutionT software;
• Ensuring that the Procurement Card Authorization/Agreement and Application forms are completed, signed, and submitted by the cardholder, and approved by the department head or authorized fiscal officer;
• Ensuring that the original application is retained by the department and a copy is faxed to the OBFS, CCO;
• Ensuring that cardholders, reconcilers, and approvers are properly trained and perform their duties in an accurate and timely manner; and
• Collecting P-Cards and handling related termination procedures of P-Card privileges for staff members who are terminating employment with their department or the University or who no longer need P-Card privileges in the department. This includes notifying the OBFS, CCO of the employee's departure or change in job responsibilities.

2. Cardholder

This role is required. An Order Log is required to be created in the P-Card Web SolutionT software for each transaction made with a P-Card. An Order Log is to be created immediately following each transaction. The cardholder may have access to the P-Card Web SolutionT software to do this personally or may be required to provide the necessary information to another individual that has been delegated to perform this function for the Cardholder within the P-Card Web SolutionT software, other than the cardholder's reconciler. Each entry to the Order Log must contain the following information:

• Transaction date for the purchase;
• Brief description of the item(s) purchased;
• Name of the vendor from whom the item(s) were purchased; and
• Total dollar amount of the transaction.

Note: Students, including graduate students, may not be cardholders. Students, including graduate students, may not be reconcilers, DCMs, approvers, or delegates for any of the P-Card functions or roles, or have access to the P-Card SolutionT software.

3. Reconciler

This role is required. Sound business practices require that an individual other than the cardholder review all purchases made by the cardholder. To expedite operations, this review may be made after the purchase, but a review at some time before the transactions are posted to the Banner Financial System is a critical part of maintaining internal control.

The department head assigns a reconciler for each cardholder. One reconciler may be assigned to multiple cardholders. Reconcilers match each cardholder's Order Log created in P-Card Web SolutionT software with transaction information sent electronically by the bank and the original receipt. Transaction information is downloaded from the bank daily into P-Card Web SolutionT software.

Reconciler responsibilities include the following:

• Check the P-Card Web SolutionT software for items to be reconciled once each day.
• Review and reconcile each transaction with the Order Log and with the original receipt within seven (7) business days of its appearance in P-Card Web SolutionT software.
• Ensure that the proper C-FOAPAL was used for the purchase; assign the correct C-FOAPAL, if necessary. Expenditures must comply with any restrictions applicable to the C-FOAPAL. This includes all restrictions specified for gift and endowment income funds and grant and contracts funds. (If a C-FOAPAL is not assigned, the transaction is charged to the default C-FOAPAL established for that cardholder.)
• Initiate corrective action if the charge is inappropriate or inconsistent with University policies and procedures.
• Ensure the purchase follows established department and University policy regarding retention of records for the purchases (see Section 1.4, Retention of Financial Records).

4. Approver

This role is optional. The department head may assign an approver for each cardholder in the department; however, this role is optional. The approver does not approve the transaction itself because the transaction has already been charged to the P-Card by the time the approver sees the charge transaction details. The approver's main responsibility is to verify that the charge made is a proper expenditure of University funds and to verify that the C-FOAPAL used is correct before loading into the Banner general ledger.

Approver responsibilities include the following:

• Check P-Card Web SolutionT software for items to be approved at least once each day;
• Review the C-FOAPAL used for a particular transaction within two three (3) business days of being reconciled;
• Initiate corrective action if the charge is inappropriate or inconsistent with University policies and procedures;
• Ensure that the correct C-FOAPAL has been used for the purchase; and
• Approve the reconciled transaction in P-Card Web SolutionT softwareT.

Restrictions on Multiple P-Card Roles Held by an Employee

Following are some restrictions that apply to an employee(s) who may have multiple P-Card roles:

• No one employee may hold all five (5) of the required roles (DCM, Financial Statements Reconciler, Cardholder, the P-Card Web SolutionT software Reconciler and P-Card Web SolutionT software Approver).
• The Financial Statements Reconciler may not hold the role of the P-Card Web SolutionT software Reconciler or the P-Card Web SolutionT software Approver.
• The Cardholder may not hold the role of the P-Card Web SolutionT software Approver or Financial Statements Reconciler for his/her own P-Card transactions.
• Subject to the restrictions above, the Department Head may hold the role of the Financial Statement Reconciler.
• Subject to the restrictions above, the Department Head or DCM can hold the role of P-Card Web SolutionT software Approver or P-Card Web SolutionT software Reconciler.

PURCHASING GUIDELINES

Due to administrative controls and/or legal requirements, limitations apply to the use of the P-Card.

Prohibited Purchases

P-Cards may not be used for the purchase of the following items. See Section 8.13, Allowability and Funding of Certain Expenditures for a more comprehensive list of expenditures that are not allowed from various or any fund sources.

• Purchases from University employees, their spouses, parents, or children.
• Purchases from business concerns of which an employee (or an employee's spouse, parent(s) or children) is a sole or principal owner, major officer, or primary employee.
• Purchases when the vendor requires an agreement or any contract to be signed by an authorized University representative.
• Purchases when the vendor requires a deposit.
• Employee expenses while in travel status, except for the purchase of air, bus and rail transportation (see the section Air, Rail, and Bus Ticket Purchases below). Travel status expenses are all expenses that must be reimbursed on an Employee Travel/Miscellaneous Reimbursement Form. They include:
  • Airport shuttles
  • Automobile rentals and replacement fuel
  • Hotel rooms and services
  • Payment or reserving of hotel rooms
  • Limousines
  • Parking
  • Per diem allowance
  • Personal or University vehicle fuel
  • Tolls
  • Taxi cabs

Specific items as follows:

• Attorney Fees
• Capital Development Board purchases
• Cash advances
• Charter bus and charter air services
• Chemicals as specified (See List of Chemicals for specific precursor and chemicals/toxins not allowed for purchase with P-Card)
• Consultant Fees or expenses
• Drugs and pharmaceuticals (unless prior approval has been granted by the OBFS, Purchasing Division).
• Fuels (including but not limited to alcohol, ethanol, gasoline, diesel, kerosene, propane, fuel oil, aviation, and any other combustible liquid or gas.)
• Furniture with a unit cost of $500 and above
• Gifts to other University units or external organizations (see Section 8.13, Funding and Allowability of Certain Expenditures for additional further information).
• Gift Certificates and Gift Cards (See Section 8.13, Funding and Allowability of Certain Expenditures for information on how to purchase gift cards or gift certificates.)
• Health Care Provider Fees
• Imported goods that must go through customs
• Independent Contractor Fees
• Lab or specialty gases (examples: liquid nitrogen, helium)
• Laboratory animals (for UIC, purchase through the Biologic Resource Laboratory; for UIUC, purchase through the Division of Animal Resources.).
• Laminar flow fume hoods and biological safety cabinets
• Maintenance Contracts
• Professional and Artistic Services
• Radioactive materials
• Recombinant deoxyribonucleic acid (RDNA)
• Services involving labor, including installation charges, indemnity, and/or insurance requirements (examples: tent rental, catering, on-site repairs)
• Trade-in of equipment that is inventoried
• Vehicle purchases or rentals (such as, autos, trucks, and cycles)
• Weapons, ammunition, or detonating equipment or material

Restricted Purchases

P-Cards may be used for the following items when corresponding requirements are met.

Alcoholic beverages may be purchased according to the policy established in Section 8.12, Business Meals and Refreshments.

Business Meals may be purchased according to the policy established in Section 8.12, Business Meals and Refreshments.

Computer software may be purchased if the vendor does not require a signed license agreement or contract. At UIS and UIUC contact CITES, at UIC contact ACCC for assistance.

Flowers/floral arrangements for employees may only be purchased for certain occasions. (See Section 8.13, Allowability and Funding of Certain Expenditures for additional information.)

Food and beverage supplies and small electrical appliances for official office reception areas are allowable if the purchase is in compliance with Section 8.13, Allowability and Funding of Certain Expenditures.

Internal transactions - The use of the P-Card for "internal" transactions is allowable for units that sell primarily to external customers, including auxiliaries and activities. For example, use of the P-Card is allowable at Campus Union Operations, University-owned bookstores, campus convenience stores, Conferences and Institutes, Division of Intercollegiate Athletics, and other University sponsored programs and events. However, gift cards and gift certificates may not be purchased from either internal operations or external vendors with a P-Card (see Prohibited Items above).

Off-campus repair of equipment by corporations may be charged on a P-Card if the amount of the repair is known in advance to be less than the cardholder's maximum per transaction limit.

Postage Stamps cannot be purchased with a P-Card if the purchase is from State funds. All postage stamps purchased from State funds must be perforated with a block "I" for identification purposes. Non-perforated stamps purchased from a Post Office or other mailing service, including on-line providers, are allowable on the P-Card only if purchased using institutional, gift and endowment, and service plan funds. For additional information see Section 8.13, Allowability and Funding of Certain Expenditures, Postage Stamps.

Rentals or leases from corporations may be made using a P-Card if they will not result in multiple payments, including deposits, or if a contract or agreement is not required. (Rental of motor vehicles with a P-Card is prohibited - see Prohibited Purchases section.)

Signs may be purchased if there is no installation to be done by the vendor and if the unit has written approval in advance that the sign meets campus and Americans with Disabilities Act (ADA) requirements. (At UIC, obtain approval from Facilities Management; at UIS, obtain approval from Physical Planning and Operations; at UIUC, obtain approval from Project Planning and Facility Management.)

Space heaters may be purchased if the unit has obtained approval from the Facilities Management (UIC); Physical Planning and Operations (UIS); or Operation and Maintenance Division, Chief Engineer, Mechanical Sections, (UIUC).

Typesetting, printing, and binding (including office forms) may be purchased if the department has complied with applicable portions of the Illinois Procurement Code and any campus regulations governing such purchases (see Section 7.2, Purchase of Goods and Services, Printing Requirements for further information).

Telecommunication equipment (other than phones or answering machines) may be purchased if the department receives approval from Academic Computing and Communications Center (ACCC) (UIC), Telecommunications (UIS), or Campus Information Technologies and Educational Services (CITES), (UIUC), for the purchase. Additionally, at UIUC, networking equipment (wired and wireless) that must be connected to the campus network requires approval by CITES, Network Design Office (NDO) prior to purchase.

TRANSPORTATION PURCHASES AND UNIVERSITY GUEST HOTEL ROOMS WITH THE P-CARD

Air, Rail, and Bus Tickets

Purchases of airline, rail, and bus tickets with the P-Card are allowable with certain restrictions. The department head must designate a P-Card holder(s) in his/her department for transportation purchase authorization. The designated individual(s) must be authorized by the OBFS, CCO to participate in the P-Card transportation purchase program. Once authorized, this individual(s) may make all P-Card transportation purchases for his/her department.

Process - When a designated cardholder uses the P-Card for purchase of air, rail, or bus travel, his/her P-Card is charged directly for the cost. The vendor will submit detailed travel transactions to MasterCard© and MasterCard© will provide the University descriptive detail of the purchase. The Reconciler must verify that the C-FOAPAL used for the purchase is accurate before reconciling the transaction and subsequent loading into the Banner general ledger.

Internal Controls

Departments must establish appropriate internal controls to reconcile travel purchased using the P-Card to the traveler’s Employee Travel/Miscellaneous Reimbursement Form. Controls include: (1) noting the P-Card transaction number on a copy of the ticket or itinerary provided by a travel agency or on a printout of the confirmation from an Internet travel provider, (2) attaching a copy of the ticket or the itinerary to the Employee Travel/Miscellaneous Reimbursement Form within 60 days of the completion of the travel, and (3) noting the P-Card transaction number and the amount of the prepaid travel on the reimbursement form.

Department reconcilers must promptly review and reconcile all travel transactions purchased for their departments with the P-Card and make all necessary adjustments, such as ticket refunds. The department must also reconcile the P-Card transaction number to the monthly financial statements.

(See Section 15.1, Travel Regulations and Section 15.9, Air, Rail, and Bus Transportation for additional information.)

Hotel Room Purchases for Non-Employees and Events

The use of the P-Card to book hotel rooms for non-employees and/or meetings rooms for events that do not require a contract is restricted to selected cardholders who have transportation authorization.

Non-employees include but are not limited to visiting speakers and candidates interviewing for faculty and staff positions.

AUDITING DEPARTMENT P-CARD PROGRAMS

The OBFS, CCO, and internal and external auditors may conduct periodic reviews of P-Card use. P-Card violations that will result in a review of cardholder privileges include but are not limited to:

• Use of the card for unallowable purchases;
• Lack of documentation of purchases;
• Unacceptable documentation of purchases;
• Late documentation of purchases;
• Failure to reconcile charges;
• Use of a P-Card by individuals other than the Cardholder; and/or
• Placing the P-Card account number on file with any vendor.

Cardholders who misuse or fraudulently use the P-Card will be subject to investigation, disciplinary action and/or termination of employment, and may be subject to criminal prosecution. The University is authorized to deduct from the cardholder's salary any personal charges made on the P-Card.

CONSEQUENCES FOR CARDHOLDERS AND DEPARTMENTS

Violations of P-Card purchase policies or failure to accurately complete required P-Card Web SolutionT activities may result in consequences for both Cardholders and Departments. Examples of policy violations and noncompliant activities include, but are not limited to: the purchase of prohibited items (for example, gift cards and professional and artistic services); allowing transaction to auto-reconcile in the P-Card Web SolutionT software; allowing a P-Card to be used by someone other than the employee to whom it is issued; not providing supporting documentation for P-Card purchases (for example, no receipts); and splitting or stringing transactions.

Cardholders

When policy violations by a particular cardholder are identified during the reconciling, approval, and/or the DCM review processes, the following procedures should be followed by the DCM and the department head:

• When the first incidence of noncompliant activity occurs by a particular cardholder, a written warning is issued jointly by the DCM and the Department Head to the cardholder; a copy is placed in the cardholder's department file; and a copy is faxed to the CCO (217-239-6735). The documentation must include details of the offense(s) along with the Document ID number(s) that begin with "PC" for the offending transaction(s).
• If a second incidence of noncompliant activity occurs, a written notice is issued jointly by the DCM and the Department Head to the cardholder; a copy is placed in the cardholder's department file; and a copy is faxed to the CCO. The CCO will suspend the cardholder's P-Card for the remainder of the current billing cycle through the next full billing cycle.
• If noncompliant activity continues after the P-Card is reinstated, the P-Card shall be suspended up to one year or may be canceled.
• A DCM or department head may forego all of these steps if the incident is severe enough and request that the P-Card be suspended or canceled immediately.
• If noncompliant activity is discovered by the CCO, the CCO may impose the same actions using the three step process as stated above, including immediate suspension and/or cancellation, after conferring with the cardholder, the DCM, and the Department Head.

Note: The CCO notifies the campus EAVP or AVP when a P-Card is either temporarily suspended or canceled. University Audits is also notified immediately if the situation warrants.

Departments

The CCO may impose consequences for any of the following occurrences:

• Transactions are allowed to auto reconcile and/or auto approve;
• Repeated noncompliance with any University or OBFS policy by the cardholder and/or the department;
• Improper documentation;
• Failure of the DCM to perform due diligence per the above and report and act on all noncompliant activity by the cardholder as it occurs; and
• Failure of the DCM and/or department to comply with the action plan and performance goals established as a result of previous non-compliant activity within the department.

The following steps and consequences will be initiated should any of the above incidences occur:

• Upon initial discovery or tracking of repeated occurrences of cardholder noncompliant activity, the CCO will schedule a meeting with the DCM and the department head to review the issue(s). An action plan to modify behavior with specific performance goals will be developed and agreed to by the department and the CCO. Retraining of cardholders and employees with assigned support roles in the P-Card process will be conducted by the CCO at the department level, when necessary.
• A communication will be sent to the campus EAVP or AVP outlining the issue(s) and the action plan. University Audits will also be engaged if the situation warrants.
• If behavior is not modified prior to a second review or all goals are not met, the DCM, the Department Head, and the campus EAVP or AVP will be notified and the P-Cards for the entire department may be suspended for at least one full billing cycle or canceled.
• After a third review, if behavior is still not modified or all goals are not met, the DCM, the Department Head and the EAVP or AVP will be notified and the P-Cards for the entire department may be suspended for up to one year or canceled.

EXCEPTIONS TO POLICIES AND PROCEDURES

The Executive Assistant Vice Presidents for Business and Finance (UIC or UIUC) or the Assistant Vice President for Business and Finance (UIS), or delegates, are authorized to make exceptions to this policy.

All requests for exceptions to P-Card policies must be submitted to the OBFS, CCO using the P-Card Exception Request form. Based on the exception criteria, the OBFS, CCO routes the request to the appropriate unit(s)/employee(s) for review and notifies the requestor via email of the approval/denial of the request.

Due to the complexity of some requests, the exception may need to be reviewed by multiple University units/employees before a decision can be made; therefore, a minimum of ten (10) business days should be allowed for processing and routing. Failure to follow this procedure will result in an audit finding if the properly executed P-Card Exception Request form is not on file with the OBFS, CCO and a copy of the email notification of the exception approval from the OBFS, CCO is not in the cardholder's department records.

Note: If the exception includes a per transaction limit of $5,000 or more, the cardholder is required to submit an annual Statement of Economic Interest to the University Ethics Office, who will forward it to the Secretary of State, State of Illinois. The department head is responsible for providing such names to the University Ethics Officer upon approval of the exception.