R 231708Z MAR 12

ALCOAST 142/12
COMDTNOTE 7043
SUBJ: PURCHASE CARD POST PAYMENT AUDIT, IMPLEMENTATION OF THE
PURCHASE CARD TRANSACTION WORKSHEET (PCTW), AND STATEMENT
CERTIFICATION
A. DEPARTMENT OF HOMELAND SECURITY OFFICE OF INSPECTOR GENERAL
OIG-11-101 AUGUST 2011 REPORT
B. PURCHASE CARD TRANSACTION WORKSHEET (PCTW), FORM DHS-1501
C. DHS COMPONENT PURCHASE CARD TRANSACTION REVIEW  (REV 07/11)
1. BACKGROUND: IN AUGUST 2011, THE DHS OFFICE OF INSPECTOR GENERAL
(OIG) ISSUED REF (A) REGARDING DHS MANAGEMENT OF PURCHASE CARDS.  THE
REPORT STATED DHS GENERALLY HAD AN ADEQUATE FRAMEWORK FOR INTERNAL
CONTROLS TO MANAGE ITS PURCHASE CARD PROGRAM.  HOWEVER, THE
DEPARTMENT NEEDS TO IMPROVE ITS IMPLEMENTATION OF SOME INTERNAL
CONTROLS TO MITIGATE THE INHERENT RISK ASSOCIATED WITH PURCHASE CARD
USE.  SPECIFICALLY, THE REPORT STATED THE DEPARTMENT NEEDED TO
STRENGTHEN ITS POST PAYMENT AUDIT PROCESS.
2. THE OIG FOUND THAT 93PCT OF THE DHS TRANSACTIONS REVIEWED DID NOT
COMPLY WITH AT LEAST ONE OF THE INTERNAL CONTROL ELEMENTS BASED ON
OMB REQUIREMENTS.  FOR USCG, 87PCT OF TRANSACTIONS FAILED THE REVIEW
BECAUSE THEY DID NOT HAVE SUFFICIENT SUPPORTING DOCUMENTATION.
3. IN MAY 2011 DHS IMPLEMENTED THE USE OF REF (B) TO IMPROVE
DOCUMENTATION FOR PURCHASE CARD TRANSACTIONS.  DUE TO THE ANTICIPATED
IMPACT TO USCG CARDHOLDERS (CH), COMDT (CG-9131) NEGOTIATED DELAYED
IMPLEMENTATION TO 23 JANUARY 2012.
4. ACTION: IN RESPONSE TO OIG REPORT, DHS CFO IMPLEMENTED STRONGER
POST-PAYMENT AUDIT PROCEDURES WITH REF (C) WHICH UTILIZES THE 27
ATTRIBUTES USED BY THE OIG DURING THEIR REVIEW.  USCG CARDHOLDER AND
APPROVING OFFICIALS (AO) SHALL REVIEW THESE ATTRIBUTES AND ENSURE
THAT PURCHASE CARD TRANSACTIONS COMPLY.
5. EFFECTIVE 23 JAN 2012, REF (B) SHALL BE USED FOR EACH PURCHASE
CARD TRANSACTION UNDER THE MICRO-PURCHASE THRESHOLD (MPT).
INSTRUCTIONS FOR THE USE OF THIS FORM WERE PROVIDED VIA PURCHASE CARD
NOTICE (PCN) ON 23 DECEMBER 2011.  THE PCTW SHOULD BE THE COVER SHEET
FOR ALL USCG PURCHASE CARD FILES WHERE THE TRANSACTION DOES NOT
EXCEED THE MPT.  THE PCTW DOES NOT REPLACE THE PURCHASE REQUEST (PR)
OR DOC 32. ALTHOUGH CERTAIN FIELDS ON THE PCTW ARE ALSO FOUND ON THE
PR OR DOC 32, ALL THREE (3) DOCUMENTS MUST BE PART OF A COMPLETE
TRANSACTION FILE. IN CASES WHERE APPROVALS AND OTHER INFORMATION ARE
OBTAINED VIA A PR, DOC 32 OR EMAIL, THE CH MAY STATE (SEE ATTACHED)
ON THE CORRESPONDING PCTW FIELD.
6. FOR THE PURCHASE OF SUBSISTENCE (FOOD), INSTRUCTIONS WERE PROVIDED
VIA PCN, SUBJ: PCTW UPDATE-FOOD SERVICE, ISSUED ON 17 FEBRUARY.  THE
FOOD SERVICE CH MUST COMPLETE ALL REQUIRED DOCUMENTATION INCLUDING A
PR AND PCTW-DHS REF (B) FOR FOOD SERVICE RELATED PURCHASES FOR EACH
MONTH. ONLY ONE (1) REF (B) IS REQUIRED FOR EACH MONTH AS LONG AS THE
COMBINED TOTAL OF ALL PURCHASES IS EQUAL TO OR LESS THAN THE ORIGINAL
ESTIMATED AMOUNT FOR THE MONTH.  ALL RECEIPTS/INVOICES SHOULD BE
ATTACHED AND FILED WITH THE PR, PCTW AND MENU.  FOR AUDITING
PURPOSES, ALWAYS SUBMIT THE PR, PCTW, AND MENU WITH SIGNATURES AND
DATES, ALONG WITH RECEIPTS/INVOICES.
7. CARDHOLDERS SHALL VERIFY THEIR MONTHLY STATEMENTS IN A TIMELY
MANNER TO ENSURE THEIR AO IS ABLE TO CERTIFY THE STATEMENT WHEN AO
ACCESS BEGINS. THE AO SHALL CERTIFY CH STATEMENTS UNDER THEIR
HIERARCHY AFTER THE 16TH OF THE MONTH, BUT BEFORE THE 26TH. FAILURE
TO CERTIFY THE MONTHLY STATEMENTS MAY RESULT IN DEACTIVATION OF ALL
CARDS UNDER THAT AO, WHICH WOULD UNFAIRLY AFFECT CARDHOLDERS WHO HAVE
PROPERLY VERIFIED THEIR STATEMENTS. COMDT (CG-9131) RECOGNIZES
CIRCUMSTANCES MAY EXIST WHERE THE CARDHOLDER IS NOT ABLE TO VERIFY
THEIR STATEMENT ON TIME, CARDHOLDERS SHALL COORDINATE THESE INSTANCES
WITH THEIR AO AND ALTERNATE ORGANIZATION PROGRAM COORDINATOR (A/OPC).
8. ADDRESS ALL QUESTIONS TO GWEN STROGEN-BOOZER, COMDT (CG-9131)
(202) 475-3766 OR BY EMAIL GWENDOLYN.STROGEN-BOOZER (AT) USCG.MIL.
9. MS. CLAIRE M. GRADY, SENIOR PROCUREMENT EXECUTIVE AND HEAD OF
CONTRACTING ACTIVITY, SENDS.
10. INTERNET RELEASE AUTHORIZED.