09 - 110 Documentation and Record Retention

A. Documentation Requirements

For all PCard transactions, the official record of the transaction is loaded and maintained in the USNH imaging system by the PCard Manager. To accomplish this all valid receipts, along with required approvals and a description of business purpose supporting each purchase, should be imaged and uploaded to the Banner Document Management System (BDMS or Xtender). It is important to stress that the Cardholder is responsible for assuring that proper documentation is submitted as soon as possible, but no later than 7 business days from the date of purchase. Every effort should be made to upload supporting documentation to BDMS before the transaction sweeps to Banner Finance. If necessary, the uploaded file should be updated with new information until the full documentation includes enough information to support the purchase.

Collectively, the documentation MUST contain the following information:

1. Business purpose, including why it is allowable on the grant if needed (can be hand written)

2. Description of what was purchased

3. Date of purchase

4. Supplier name and location

5. Quantity and cost of each item purchased

6. Total cost of purchase

7. Evidence the purchase was delivered to a USNH campus address or to a specific pre-approved off campus location

8. Any approvals required by the USNH PCard Guide, USNH Purchasing, or USNH Business Expenditures (advertising, alcohol, awards, gifts, prizes and any services provided) policies, including approval for temporary changes to allowable purchases or dollar limits.

When submitting a legible scanned or imaged document, a cardholder is  certifying the scanned or imaged document is a true copy of the original. The cardholder should maintain the original documentation for at least 30 days after the transaction date.

As described in section B.8. of Procedure 9-102, USNH PCard Roles and Responsibilities, the PCard Manager is responsible for receiving complete and accurate supporting documentation from the Cardholder and uploading the support to USNH imaging system. Management, internal or external audit may audit PCard transactions, and may contact the department to provide any documentation missing from the USNH imaging system or to provide clarification on uploaded documents for PCard transactions included in the population under review. Lack of supporting documentation is a Cardholder violation, and the related items could be viewed as a personal purchase subject to the consequences outlined in Procedure 9-104, Purchasing Card Violations and Consequences.

The PCard Manager must demonstrate that Procedure 9-104, Purchasing Card Violations and Consequences has been followed in cases of non-compliance. Information on remedies applied should be stored along with other documentation supporting the transaction in USNH Imaging System and may include check number and date of the reimbursement, document number that recorded the reimbursement, and whether the card was suspended or revoked.

B. Acceptable Receipts

Each PCard transaction must be supported by one or more of the following forms of documentation:

1. Itemized cashier receipt

2. Supplier invoice

3. Credit card slip (with itemized pricing)

4. Copy of order form or application (with itemized pricing)

5. Packing slips are allowed only when provided with pricing detail or in conjunction with one of the above

A lack of detailed receipts for any purchase greater than $25 is a Cardholder violation and the related goods/services may be construed as a personal purchase and subject to investigation. A Lost Receipt Form may be completed as substitute documentation. This form of documentation is meant to be used on an exception basis and not as a regular means of documentation. If a pattern of regular use of the form is detected, the PCard may be revoked.

C. Business Purpose

The business purpose must be descriptive enough to clearly answer any questions regarding the necessity of the good or service purchased, and the benefit to USNH when applicable. It should be written so that a reader at some future time (e.g., an auditor reviewing the expense 2-3 years later) would have no questions about the activity and why it was a permissible USNH expense.

1. WHO: List the name(s) of the person(s) and their organization and/or department involved in the activity. A listing of specific individuals is not required if the participants can be labeled as an identifiable group – including the number of attendees (e.g., Faculty Senate; 12 in attendance). For large seminars and conferences, it is acceptable to estimate the number of attendees and not attach a list of attendees.

2. WHAT: Description of the activity that will be benefit from the good or service purchased

3. WHEN: Indicate the date or inclusive dates the activity took place. Specific dates may already be part of the item descriptions (ex. flight date and time). 

4. WHERE: Give the location of the activity

5. WHY: Why was the activity done and how did it benefit USNH?

6. How Much?  A breakdown of individual charges is required when more than one item is included on a single receipt.

D. Approvals

There are some instances where pre-approvals are needed for PCard purchases. Below are the most common of these items:

1. Purchases made to a sponsored program require PI or project director approval as appropriate

2. Purchases of items listed as unauthorized via PCard when there is no other means to purchase the item must be pre-approved by the campus CFO or designee

3. Purchase of services lasting more than 2 days requires USNH Procurement pre-approval

4. Temporary limit increases or MCC code allowances must be pre-approved by the campus. CFO or designee before the campus PCard Administrator can make the change

5. Certain departments may have additional restrictive requirement imposed on the Cardholders

Evidence of all required approvals, including approvals for temporary exception to standard limits and MCC restrictions must be uploaded to USNH imaging system along with receipts and a description of the business purpose.

E. Reconciliations

Cardholders and PCard Managers receive the follow notices to help them monitor and reconcile PCard transactions:

1. Daily notice - The daily notice lists transactions posted to the card by the bank on the previous day.

The Cardholder should promptly review the daily notices and ensure all transactions are recognized. If a transaction is not recognized, the Cardholder should follow up with the vendor and report transactions from unrecognized vendors to the bank. These notices are the first opportunity for the Cardholder to identify fraudulent transactions, make sure supporting documentation is available for actual purchases, and provide the backup to the PCard Manager.

The PCard Managers also receive these notices and use them to keep track of supporting documentation.

2. Weekly notice - In addition, PCard Managers receive a weekly PCard notice listing all the transactions that were swept to Banner in the week prior, and a listing of transactions made with cards of inactive employees

3. Monthly notice - The Monthly PCard Notice listing all PCard transactions for the calendar month and serves as a reminder for Cardholders to send documentation to the PCard Manager.

The Cardholder should review this notice and make sure all supporting documentation for all transactions have been submitted to the PCard Manager. Documentation not timely submitted may result in the PCard Manager issuing a warning letter which may be followed by suspension of card if not cured.

For each transaction on the monthly e-mail notice the PCard Manager should indicate whether:

a) The item is in dispute

b) A lost receipt form was provided

c) Any violation was noted, and if so what type

d) The questionable receipt does not match the associated Level 3 data

The PCard Manager should ensure supporting documentation for all transactions is imaged in BDMS, as well as sign and file the monthly notice no later than 25 days after the close of the month. This signed monthly notice serves as evidence of PCard Manager review in the event these transactions are audited. A copy of the reviewed is forwarded to the USNH PCard Administrator at Banner.PCard@unh.edu.

F. Continuous Monitoring of Transactions

USNH and campus PCard Administrators may also review Cardholder activity periodically during the month to ensure purchases are allowable, within the Cardholder's limits, and supported with proper documentation. The PCard Manager should be aware of unusual transactions or patterns, such as a sudden increase in activity or purchases from odd suppliers. Should an item or series of purchases look unusual or unsupported, the PCard Manager should pursue the issue with the Cardholder immediately. Any unresolved issues should be reported to the USNH and campus PCard Administrators when identified.

G. Record Retention

PCard Managers are responsible for imaging the backup documentation and loading it into the USNH imaging system (BDMS/Extender) to support each Purchasing Card transaction. The PCard Manager should ensure imaged documents are clear, readable and attached to the correct transaction. The retention periods described in USNH Procedure 02-211 Financial Records Retention Periods apply to imaged, as well as hard-copy, documents.

All purchases made with grant/contract funds are subject to the annual Uniform Guidance audit and any agency audits required for the related grant. All audit requests should be conducted through the Campus Finance Office or Business/Financial Service Center for the applicable unit. All backup should be available in the USNH Imaging System, and in cases where backup cannot be found in the system, requests should be sent to the PCard Manager for completion/submission. The PCard Manager is expected to be able to retrieve the required data quickly and easily.  All PCard purchases are also subject to review by USNH management and/or Internal Audit, as well as federal, regulatory and other granting agencies.