09 - 102 USNH PCard Roles and Responsibilities

The Cardholder acts as an agent of the University System and its member institutions for activity specifically related to the Purchasing Card.  Cardholders collaborate with the PCard Managers and Campus PCard Administrator to ensure USNH serves its communities in an efficient, effective and ethical manner. For proper segregation of duties, USNH and Campus PCard Administrators cannot hold the role of Campus PCard Manager or carry a PCard. In addition, Campus PCard Managers who are also Cardholders cannot manage their own card(s) or feed their transactions to Banner Finance.

The responsibility for the proper use of a PCard rests first with the Cardholder; second with the Cardholder’s supervisor or the Financial Manager of the responsible organization assigned to the PCard (if other than the Cardholder); and third with the next higher level of authority to the Financial Manager (usually the individual to whom the Finance Manager reports). Parties signing a PCard application have agreed to adhere to all system and institutional policies and procedures, as well as to use the Purchasing Card in compliance with the information set forth in the USNH PCard Guide, USNH Purchasing, and USNH Business expenditures policies.

These include, but are not limited to:

• Safeguarding assets of the institution in such a way as to avoid fraud, abuse and waste of any kind
• Exercising sound judgment regarding the resources at their disposal and exhibiting integrity regarding all transactions with which they are involved
• Acting in the highest of moral standards to avoid any real or perceived conflict of interest
• Obtaining and providing all documentation necessary to support the business purpose of the purchase, and
• Preventing unnecessary exposure to fraud by refraining from transmitting the 16 digit card number electronically using unencrypted electronic communication methods such as email, instant messaging, chat, SMS, Fax, etc.

The USNH or Campus PCard Administrator may suspend or terminate any card where the  Cardholder fails to follow these procedures or fails to provide proper supporting documentation. Reinstatement of a suspended card before expiration of the suspension term or terminated card requires campus CFO or designee approval. A Cardholder will be required to reimburse USNH for any unauthorized or unsubstantiated purchases. In addition, fraudulent use of the card may result in disciplinary action up to and including termination of employment and criminal prosecution.

A. Cardholder Responsibilities

1. Completing the online Cardholder training course before obtaining the card (Procedure 9-105, Obtaining a Purchasing Card)

2. Completing a Cardholder Acceptance Agreement before each card issuance or renewal to document understanding of PCard policies and that you agree to comply with them

3. Activating the PCard with the bank (Procedure 9-105, Obtaining a Purchasing Card) and setting up a pin number that you can remember for any chip and pin transactions

4. Keeping the physical card secure and not transmitting the card information electronically via a website or email that is not encrypted

5. Directing all business-related purchases to a USNH campus address or to an off-campus location pre-approved by the campus CFO or designee

6. Not using the assigned card for personal “holds” or personal purchases, even when the intent is to reimburse the University System

7. Not allowing others to use your PCard unless you hold a department card designed to be used by more than one individual

8. Reporting a lost or stolen card immediately (Procedure 9-112, Lost or Stolen Cards)

9. Maintaining compliance with allowable purchases and limits (Procedure 9-103, Using a USNH PCard)

10. Complying with sponsoring agency’s policies when purchasing for a sponsored project, and obtaining approval from the Principal Investigator of the sponsored project purchasing the good or service as grant related purchases are still subject to Uniform Guidance Cost Principles – Note that due to federal requirements prohibiting doing business with parties that are suspended or debarred, grant related purchases of $25,000 or more from a single vendor must use a purchase order rather than a PCard.

11. Reviewing transactions on your daily PCard notice for accuracy, following up with the vendor to resolve disputed items and reporting any suspicious activity on your PCard to the bank as soon as detected, but no later than 60 days from the bank date of the transaction listed on your daily notice.

12. Informing your PCard Manager and Campus PCard Administrator when suspicious activity is reported to the bank.

13. Providing supporting documentation to your PCard Manager as the charges occur, but no later than seven business days after the transaction bank posting date.

14. Reviewing transactions on your monthly PCard notice upon receipt and ensuring supporting documentation for all transactions has been provided to your PCard Manager, as well as resolving all issues such as missing receipts, missing or inadequate business purpose support, and required approvals, no later than the 10th of the month following your Monthly PCard Statement notice which is emailed to Cardholders on the first business day of the month.

15. Ensuring supporting documentation complies with Procedure 9-110, Documentation and Record Retention) which requires the inclusion of the following:

• Bank confirmation e-mail of any disputed transaction
• Business purpose
• Cardholder name
• Cost and quantity of item(s) purchased
• Description of item(s) purchased
• Documentation of approvals (such as from the Principal Investigator or USNH Procurement) for any exceptions obtained
• Proof that goods or services purchased online were shipped to a campus or an approved address, and the Cardholder acknowledged their receipt
• Proper FOAPAL
• Vendor name

16. Understanding that not providing adequate supporting documentation in timely manner as described in No. 15 above will result in the suspension of the card until adequate supporting documentation is provided

17. Understanding that during the suspension period, the Cardholder is expected to make business purchases using personal funds and requesting reimbursement after the purchase has been made

18. Assisting in resolution of problems (Procedure 9-111, Disputed PCard Purchase Process)

19. Staying within your approved PCard limits

20. Making purchases only for USNH related business in compliance with USNH policies -PCards are not intended as a way to deviate from directives set forth in USNH’s Purchasing, Business expenditures or Travel policies.

21. Understanding that use of a Purchasing Card does not allow circumvention of compliance with purchasing from contracted suppliers, nor does it mean that the limitations or additional requirements around procurement thresholds can be ignored. The Campus Purchasing Departments negotiate and issue contracts that will provide “the best value” arrangements for goods and services. In order to assure the campus communities of the “best value”, purchases must be made from the contracted supplier whenever a contract exists.

22. When using a PCard to make a purchase through a contracted supplier, the Cardholder should emphasize to the supplier that this is a USNH, UNH, PSU, KSC or GSC purchase (whichever is applicable) to ensure that proper discounts and tax exemptions are applied.

23. Surrendering your card to your PCard Manager upon departure for extended leave (i.e. medical, sabbatical, etc), transfer, termination, or separation

24. Asking questions and providing feedback on the program

25. Understanding that failure to fulfill these responsibilities subjects the Cardholder to the consequences described in (Procedure 9-104, Violations and Consequences)

26. If you hold a Department Card you are responsible for the following:

• obtaining a description of products or services the borrower of the card intends to purchase along with the business purpose of the purchase,
• keeping a log of card usage and collecting supporting documentation for each purchase along with the return of the card itself, and
• ensuring all purchases are in compliance with this guide and informing your PCard Manager immediately if you detect an issue

27. If you hold a Travel card you also must follow all USNH Travel Policies as outlined in Section 07 of the USNH Financial Services Policies and Procedures.

B. PCard Managers Responsibilities

PCard Managers monitor purchasing activity for Cardholders under their responsibility for compliance with the USNH PCard guide. The PCard Managers also monitor compliance with more restrictive requirements imposed on Cardholders by their department. This monitoring should take place when a transaction is initially processed and before it sweeps into Banner Finance. The sweep date is set to be no later than the 24th of the month of the following month which is the date payment is due to the bank. PCard managers should complete the online training session and understand all of the Cardholder's responsibilities (Section A above).

All PCard Managers are responsible for:

1. Attending or completing an online training session

2. Establishing and monitoring (along with the department head) card eligibility and authorized limits (Procedure 9-105, Obtaining a Purchasing Card)

3. Verifying each Cardholder has completed training and has signed a Cardholder acceptance agreement prior to releasing the card - The agreement must be returned to the Campus PCard Administrator (Procedure 9-105, Obtaining a Purchasing Card)

4. Knowing all of the Cardholder's responsibilities (Procedure 9-102, USNH PCard Roles and Responsibilities)

5. Making sure the Cardholder is in compliance with the authorized uses of the card (Procedure 9-103, Using an USNH PCard and Procedure 9-105, Obtaining a Purchasing Card)

6. Communicating all changes in Cardholder account information to the Campus Card Administrator (Procedure 9-111, Disputed PCard Purchase Process and Procedure 9-112, Lost or Stolen Cards)

7. Regularly reviewing all purchases at least bi-weekly - The review of each purchase should be completed before the sweep date of the transaction.

8. Monthly review of all transactions that post to cards with a grant fund as the default to ensure all expenses were allowable on the grant 

9. Obtaining complete and accurate supporting documentation for each transaction posted to one of your Cardholder’s account  (Procedure 9-110, Documentation and Record Retention) and uploading the documentation to BDMS

10. Comparing questionable receipts to available level 3 data provided by the bank (for most transactions) and reporting any mismatch to the USNH PCard Administrator who will investigate and determine appropriateness of the transaction

11. Contacting the campus PCard administrator with any issues regarding the submitted documentation for purchases including missing receipts or questionable business purpose

12. Resolving all funding issues in a timely manner and distributing charges to correct FOAPAL as required (Procedure 9-109, PCard Transaction FOAPAL)

13. Reconciling all accounts under your responsibility on a monthly basis before the Banner sweep deadline which is the 24th after the close of the month

14. Working with Cardholders to investigate and resolve any discrepancies and communicating all unresolved or questionable activity to the department head, Campus PCard Administrator, and USNH PCard Administrator. (Procedure 9-110, Documentation and Record Retention) 

15. Ensuring documentation uploaded to BDMS includes the following (see section A.15):

a. Appropriate approvals accompanying all receipts (such as PI approval for grant purchases, procurement approvals when needed, and one-time exception approvals such as purchases of flowers)

b. The 5 W’s documented on all receipts (who, what, when, where, and why)

c. Documentation verifying that grant purchases are an allowable expense for the related sponsored awards

d. Documentation of corrective action for non-compliant purchases

16. Being accountable for all transactions that have swept and able to defend due diligence in reviewing documentation of amounts, FOAPALs charged, and related purposes

17. Working with the Campus PCard Administrator and USNH PCard Administrator to resolve problems and improve processes

18. Communicating all changes in policy and/or procedures to your Cardholders

19. Reviewing weekly reports of transactions made on cards belonging to Cardholders who are terminated and taking appropriate action

20. Complying with all audit requests for documentation in a timely manner (Procedure 9-110, Documentation and Record Retention)

21. Ensuring that a backup PCard Manager is assigned when the primary PCard Manager is not available.

C. Campus PCard Administrator Responsibilities:

• Distributing PCards, setting-up new cards, disseminating training emails to new Cardholders and fielding questions as needed
• Transmitting any Cardholder information updates (including tracking all applications, change forms and attestations)
• Managing closing, suspension and renewal of cards with the bank and in Banner Finance
• Monitoring Cardholder limits and card types for the campus
• Tracking Cardholder violations reported by PCard Managers and terminating cards when necessary
• Follow up with Cardholders to ensure all potential fraud notices are resolved within the timeframe provided by the bank for each instance
• Suspending or canceling PCards when a Cardholder has violations as defined under Procedure 9-104 Purchasing Card Violations and Consequences

D. USNH PCard Administrator Responsibilities:

• Making recommendations for program policies and procedure updates, and develop training materials for the online modules as needed
• Annually reviewing the list of Cardholders for inactivity and proposing PCard closings to campus Finance offices
• Annually reporting a summary of incidents of non-compliance that lead to suspension or cancellation of card to the USNH Controller and campus Finance Offices
• Reviewing questionable receipts against level 3 data
• Performing periodic reviews to ensure compliance with program guidelines
• Re-training Cardholders on PCard policies if the need arises

The USNH PCard administrator also serves as backup for all Campus PCard Administrators and has authority to administer cards at all campuses.