Consequences – Detailed Guidelines
The consequences of misuse or mismanagement of the card program are grouped into four categories, depending on the type and severity of infractions found. Within each of these categories, one or more instances of non-compliance found in a single transaction will count as one infraction. New instances of non-compliance within the same category count as repeat infractions if the new errors are found to have occurred within twelve months of the earlier assessment results memo.
CATEGORY 1
Infractions in Category 1 include missing or incomplete supporting documentation and processing errors in BFS, such as:
- Purchase: insufficient evidence of authorization, failure to conceal card number in transaction documentation
- Reconciliation: insufficient description of the purchase, insufficient evidence of receipt, failure to ensure that sales/use tax is properly recorded in BFS
- Approval: failure to approve in BFS within transaction staging period
First infraction: The department is expected to correct the problem on a go-forward basis, but will not be asked to respond directly to Assessments or Card Program Services. Notification of findings goes to cardholder, the Authorized and Delegated Signers.
Second infraction: The cardholder and/or reconciler(s) and/or approver(s) involved must complete re-training. Notification of findings is same as for a first infraction.
Third infraction: The department must prepare a corrective action plan to be approved by Card Program Management, in consultation with Assessments. If a plan is not submitted by the specified deadline, the cardholder’s account and/or related reconciler and/or approver roles will be suspended pending an approved plan. The head of the Division is included in notification (e.g., Dean or Director).
Fourth infraction: The cardholder’s account is terminated and/or the reconciler and/or approver role is revoked in BFS, depending on the type of infraction. The individuals involved will hold no role in the program for period of one year. Additional departmental penalties may apply (see Category 4 below). Controller is included in notification.
CATEGORY 2
Infractions in Category 2 are considered delegation errors, and include delegation violations such as:
- Cardholder: purchase of restricted items, splitting purchases to stay within delegated dollar limits, allowing someone else to use the card
- Approver: failure to immediately notify Card Program Services when Category 2 violations occur.
First infraction: Cardholder and/or Approver must complete re-training within ten business days or the card will be suspended, with reinstatement upon completion of training. Notification of findings includes Cardholder, Approver, Business Officer and/or Authorized Signer.
Second infraction: Immediate suspension of the card account – reinstatement occurs when Card Program Services approves a written corrective action plan from the department. The head of the Division is included in notification (e.g., Dean or Director).
Third infraction: The card account is terminated and/or the Approver role is revoked. The individuals involved will hold no role in the program for period of one year. Additional departmental penalties may apply. Controller is included in notification.
CATEGORY 3
Fraud or willful misuse of the card includes the use of the card to make personal purchases, even if the intention is to reimburse the University.
First infraction: The card account is terminated. Notification includes department management, head of Division, the Controller, Audit & Advisory Services. Other consequences may include disciplinary action, up to and including termination of employment.
CATEGORY 4
Errors noted in Category 4 are considered department delegation errors, and may involve forms and procedures. Repeated failure to adequately manage the card program within a department may result in suspension of all cards and/or revocation of reconciler and approver roles. Notification includes department management, control unit, the Controller, Audit & Advisory Services.
This page last updated 07/10/2014