Purchasing Card Policies Manual

14.0 Compliance

The Procurement & Contracting Services Department along with the Financial Services Office (FSO) Financial Compliance section has an established process for notification of possible PCard non-compliance and violations. 

Non-Compliance and Violations may result in, but are not limited to, one or more of the following; verbal or written warnings; suspension or cancellation of the PCard; disciplinary action (including loss of employment); and civil or criminal penalties.

Reference: Purchasing Policy 1.2 - General Acquisition and Violation Procedures. 

14.1 Pyramiding

Pyramiding, or fragmenting, is making a purchase greater than $5,000 and paying for the item(s) in separate payments of less than $5,000 over an interval of time, to avoid the mandatory competitive selection process.  Individual purchases to any merchant may not exceed $5,000.   Purchases exceeding $5,000 must be made as a result of a competitive solicitation in accordance with Purchasing Policy 4.5. Intentional fragmenting of a purchase to avoid the solicitation process will result in cancellation of the PCard and (in addition to any other disciplinary action) may result in civil or criminal penalties.

14.2 Not Approved

Approver review process is required. In UAccess Financials Approver review relates to the Fiscal Officer Approval.

14.3 Not Reconciled

Reconciliation process is required.  If a transaction has not been reconciled the PCard Office will send out a notification of possible non-compliance.   If requested documentation is not submitted to the PCard Office within the noted time frame the PCard will be suspended until such time as the documentation is submitted and has satisfied the requirement.

14.4 Single Established PCard Limit Violations

A Single Purchase Violation is making a purchase greater than the established single transaction limit assigned to your PCard.  This violation includes splitting the transaction to avoid the established single transaction limit on your PCard and paying for the item(s) in separate payments. * If the single transaction limit is $5,000 this may be subject to PCard Policy 14.1 Pyramiding violation.

14.5 Unauthorized Sharing of a PCard

A unauthorized Sharing of a PCard includes but is not limited to; allowing another person to use an Individual PCard, Department PCard being checked out and then given to another individual to use, unauthorized physical check out process of a Department PCard being  performed by an individual other than the Responsible Cardholder on file.

14.6 Purchase Rewards

Purchase rewards received from a PCard purchase are the property of The University of Arizona, not the cardholder.  Purchase rewards from a merchant may include, but are not limited to, the following: rebate checks, store reward cards, promotional items, etc. Any reward should be turned into the department Reconciler/Business Manager and any rebate checks deposited into the University account from which the purchase was originally made.

14.7 FSO PCard Compliance
14.7.1 Links to FSO (Restricted commodities/personal purchases/University Policies/FPP Policies) http://www.fso.arizona.edu/ and http://www.fso.arizona.edu/compliance/pcard.

14.8 University of Arizona's Misuse of Assets Policy

All staff must comply with the University of Arizona - Misuse of University Assets Policy and report any suspected misuse of the PCard.

The PCard is to be used for University of Arizona business only, not for personal use. All transactions made using the PCard must benefit and support the
University's mission of education, research and public service.

The Department Head, Liaison, Reconciler, Approver and Cardholder must comply with the provisions of The University of Arizona's Misuse of University Assets Policy and report immediately any suspected misuse of the PCard.  Suspected misuse must be reported to any Manager or Supervisor in the chain of authority (Director, Department/Unit Head, Dean, or appropriate Vice President) and to the PCard Office.

If it is determined through investigation that a purchase violates the Misuse of University Assets Policy, the responsible party(s) is subject to disciplinary action.

Reference: Misuse of University Assets Policy and Human Resources Policy #420


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