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GUIDANCE
Procurement Guidance / T3.2.2.5 Commercial and Simplified Purchase Method
 

Issue Date (revision): July 2003 (rev. 11)

Section

Topics in the Section

A

Simplified Purchasing

1

    Purchase Card (Revised 07/2003)

2

    Reserved (Revised 01/2003)

3

    Reserved (Revised 01/2003)

4

    Credit Card Checks (Revised 07/2003)

5

    Blanket Purchase Agreement (BPA)

6

    Purchase Orders

7

    Considerations for Restricted Purchases

B

Clauses

C

Forms

D

Appendix (Revised 01/2003)

A. SIMPLIFIED PURCHASING

1. Purchase Card. (Revised 07/2003)

a. The FAA purchase card i.e., SmartPay Card, is the internationally accepted Mastercard credit card. The purchase card is issued through General Services Administration (GSA) contract with a credit card bank, e.g., Bank of America. FAA employees who receive training and a Delegation of Purchasing Authority (DPA) are authorized to use the card, within the specified dollar limits, to acquire products and services. (Revised 07/2003)

b. GSA is responsible for both administering the contract and dealing with the day-to-day operations of the Government-wide Purchase Card Program. The GSA Contracting Officer is the only individual authorized to alter the terms and conditions of the contract. Copies of the contract, GS-23F-980004, may be obtained from the following address: General Services Administration, Federal Supply Service, Services Acquisition Center FCXST, Washington D.C. 20406. The address of Bank of America is: Bank of America; Government Card Services Unit (GCSU); P.O. Box 1637; Norfolk, VA 23501-1637. The telephone number is 1-800-472-1424 or call collect to 1-757-441-4124 if outside the United States. (Revised 07/2003)

c. The FAA purchase card is intended to streamline procurement and payment procedures and reduce the administrative burden associated with traditional and emergency purchasing of products and services under the commercial and simplified acquisition procedures. The purchase card is used to pay for authorized government purchases and should be the "primary purchasing method" when vendors accept credit cards for commercial and simplified purchases, unless otherwise prohibited (See paragraph 1.f (4) Prohibited Purchases) (Revised 07/2003)

d. The card issuing bank, Bank of America has established an authorization process whereby the vendor checks via a telecommunications system each time the purchase card is used. This authorization ensures that the purchase is within the limits established for each individual account.

e. Delegations of Purchasing Authority. (Revised 07/2003)

(1) The Chief of the Contracting Office (COCO) in the regions, centers, and headquarters formally issues, in writing, a delegation of authority to a person(s) to act as the Agency Program Coordinator (APC) for their contracting office. The responsibilities of the APC include accountability for the following:

(a) ensuring that all approving officials and cardholders receive training on validation requirements (the GSA web-based training may be used) and comply;

(b) submitting approved purchase card forms to the card-issuing bank or electronically transmitting through the Electronic Account Government Ledger System (EAGLS);

(c) submitting changes for individual cardholder single purchase or monthly purchase limits to the card issuing bank in response to a written request from the approving official;

(d) submitting account cancellations to the card-issuing bank;

(e) coordinating the card re-issuance report with approving officials and informing the card-issuing bank which purchase cards should be reissued;

(f) working with the lines of business towards obtaining a desirable ratio of cardholders to approving official;

(g) establishing and maintaining a tracking system to monitor initial and/or refresher training of purchase cardholders and approving officials (See Appendix 4);

(h) ensuring that the cardholder receives the proper training on the policy and procedures for the use of the card, including cardholder accountability for the following:

(i) prior approval of card purchases (e.g. the cardholder obtains and documents the approval of the approving official and checks the funds available balance before the purchase is made; or the cardholder obtains the necessary written justification and approvals from the affected manager required to purchase or rent a restricted item). The cardholder will obtain written confirmation of any verbal approval within 10 days of receiving the verbal approval;

(ii) submission of receipts to the approving official;

(iii) designation of accounting classification code data (including correction of default object class code);

(iv) segregation of duties – key duties and responsibilities in authorizing, processing/recording, certifying availability of funds, and reviewing official agency transactions should be separated among individuals (this includes the individual who requests and documents the purchase cannot be the same individual who approves the purchase);

(v) completion of the required property management forms and submission to the applicable property management organization; and

(vi) identification and reporting of disputed items to the applicable accounting office.

(i) ensuring that approving officials receive proper training on the policy and procedures for the use of the card, including approving official accountability for the following:

(i) segregation of duties requirements – key duties and responsibilities in authorizing, processing/recording, certifying availability of funds, and reviewing official agency transactions should be separated among individuals (this includes the individual who requests and documents the purchase cannot be the same individual who approves the purchase);

(ii) validation of approved card purchases (to include review for potential split purchases);

(iii) validation of accounting classification code data (to include correction of default object class code);

(iv) reporting fraudulent or improper use of the card to the APC;

(j) Ensuring that all new and existing cardholders and approving officials sign a statement indicating that they have read, understand and agree to follow all local and national guidance covered in the purchase card training selected by a designated representative of the COCO.

(2) DPAs are formally issued, in writing, to non-warranted individuals in the requiring organizations by the COCO or designee. The delegation authorizes the use of the purchase card, and establishes a single purchase limit that the cardholder must not exceed. This means that cardholders must not split purchase card purchases in order to exceed the authorized single purchase limit.

(3) Cardholders are individual FAA employees within the requiring organizations who have received a DPA from the COCO or designee granting the use of the purchase card, after being trained on the proper use, financial control records, and property management restrictions of the purchase card.

(4) Each purchase cardholder must safeguard the card and account number. The purchase card must be used only by the individual whose name appears on the card. Allowing someone other than the cardholder to use the card is considered an unauthorized purchase action that is subject to disciplinary action as outlined in Federal Aviation Personnel Manual (FAPM) Letter 2635 and the Human Resources Operating Instructions (HROI) Table of Penalties.

(5) Each cardholder is authorized to use and maintain only one purchase card. Cardholders will not be issued nor allowed to maintain multiple purchase cards for any purpose (including the use of more than one purchase card to monitor specific accounting classification code spending). The APC shall cancel all multiple purchase card accounts.

(6) Approving officials are individuals within the requiring organizations who receive the same type of training as the cardholder on the proper use, financial control, and property management restrictions of the purchase card. The approving official approves purchases in advance and monitors the activities of the cardholders to ensure that purchases made by the cardholders are within applicable policies and procedures. The approving official is normally the cardholder’s immediate supervisor or a higher-level official. If an approving official is also a purchase cardholder, their supervisor or a higher-level official shall act as their approving official to avoid the possibility of an approving official approving their own purchases.

(7) Both approving officials and cardholders must fully understand their purchase card responsibilities and be properly trained in procurement policies and restrictions, finance requirements, and internal procedures, as well as property management and control, as follows:

(a) Procurement training. At a minimum, this should address labor laws, required sources of supply, conflicts of interest, and socio-economic policies of the FAA.

(b) Finance training. This should address the requirements for safekeeping of purchase cards and account numbers; funds availability; fund certification; retention of receipts for charges and credits for purchases, returns and disputed items; recordkeeping for purchase card purchases, and timely validation of monthly statements of account.

(c) Property control training. It is essential that purchases of non-expendable property be reported to the appropriate property control manager for inclusion in the property inventory and management system in accordance with FAA Order 4650.21C

(8) All cardholders and approving officials will take refresher purchase card training every two years from the anniversary date of the last or initial training. The refresher training will include key purchasing requirements such as documentation, segregation of duties, accounting classification code assignment, purchasing of high cost and/or sensitive items, and any recent policy changes.

f. Administrative Matters. (Revised 07/2003)

(1) GSA Purchase Limitations. The following purchase control limitations have been established by the GSA contract for each cardholder:

(a) Single Purchase Limit. Approving officials will determine and review on a quarterly basis (i.e. March, June, September, December) the cardholder’s single purchase limit to ensure that the limit coincides with actual need. Cardholder accounts that are not used within a one-year period will be cancelled, unless extended periods are authorized by the COCO. According to the GSA contract, the single purchase limits may not exceed $100,000. Within FAA, each COCO retains the authority to establish maximum purchase card single purchase limits for cardholders. (See paragraph 1.f(2) Agency Purchase Limitations)

(b) Billing Cycle Purchase Limit. The approving officials will assign the cardholder a billing cycle limit (i.e. monthly limit). Purchase limits may be assigned in increments of $100 up to $99,900. This purchase limit will apply to the cardholder’s monthly billing cycle.

(c) Merchant Activity Code. The APC will review the codes and will restrict specific categories to reduce the risk of fraud or misuse. All cardholders will use their purchase card in such a way so as not discredit in any manner the Federal Government.

(2) Agency Purchase Limitations. The COCO at each region, center, and headquarters (ASU-100) determines the maximum dollar level for DPAs to non-warranted individuals. Warranted contracting officers may make purchases up to $100,000 using the purchase card (if within their warrant limits).

(3) Documentation. All purchase card transactions made by a cardholder must be supported by a purchase approval, a certification of funds availability (see paragraph 1.h Availability of Appropriations for certification of funds), a sales slip or invoice, telephone log (for telephone purchases), check for availability from a mandatory source (see paragraph 1.g Selecting Potential Sources); if mandatory source is not available, then documentation of best value (i.e. contact 2 or more vendors); and a receiving report. Best value regarding purchase card use includes fair and reasonable price, functional specifications, delivery capability and warranty. The use of an individual procurement request (PR) form for each purchase card transaction is optional. All purchase card documentation shall be retained, by the purchase cardholder, for six years and three months from the date of purchase. Cardholders, who transfer to another office or terminate employment with the FAA for any reason, will notify the approving official and provide all purchase card documentation to them before transfer to a new office or separation from the Agency.

(4) Prohibited Purchases.

(a) The GSA contract stipulates that the purchase card may not be used for the following:

(i) Rental or lease of land or buildings. The purchase card may be used to purchase short-term commercial conference and meeting room space.

(ii) Cash advances, including money orders

(iii) Telephone services controlled by the GSA or the local Office of Information Services or Regional Communications Office. Telephone equipment may, however be purchased by the card.

(b) The COCO at each acquisition office has the authority to add other limitations; therefore, cardholders should contact the APC for additional information. All FAA acquisition offices have prohibited use of the purchase card for personal purchases or as identification when writing personal checks.

(c) The use of the purchase card for personal purchases or as identification when writing personal checks is prohibited.

(d) The use of appropriated funds for the following purposes is prohibited (For additional guidance concerning these prohibitions, consult legal counsel):

(i) Food items for meetings and conventions (except that a reasonable amount may be expended for light refreshments at award ceremonies);

(ii) Gifts to include store gift cards/certificates, office retirement

(iii) Membership fees;

(iv) Personal expenses and furnishings, this includes clothing, decorations, and food for personal use or consumption except as authorized by Human Resources Policy Manual (HRPM) 9.2. Note that the use of the purchase card to purchase an item of clothing that is required in order to perform job duties or functions is permitted, e.g. the purchase of a pair of safety shoes or a uniform. This purchase should be coordinated with the procurement office;

(v) Drinking water, except when a duly constituted public health authority pronounces the ordinary drinking water to be unsafe for human consumption at the site;

(vi) Subscriptions to publications or magazines, not relating to official duties;

(vii) Rental of aircraft by persons not in aircraft related positions;

(viii) Fans, air conditioning and cooling equipment, space heaters and heating equipment, except as properly installed for general use in connection with the maintenance and operations requirements for the site;

(ix) Water coolers, or vacuum cleaners and other household appliances, except as requisitioned for general use by the authorities charged with building maintenance and equipment.

(5) Restricted Purchases. Federal funds used to purchase or rent flat panel computer display monitors, plasma displays or personal data assistants (PDAs) require written justification from the affected associate or assistant administrator. The justification will address the need and cost-effectiveness of the purchase. The acquisition of high cost, high quantity items (e.g. computer equipment, hand-held radios, snowmobiles or any item over the amount of $500.00) or sensitive items should be centrally purchased within the region, center or headquarters line of business (LOB) to take advantage of the economies of scale and equipment standardization and be in accordance with FAA Order 4650.21C.

g. Selecting Potential Sources. (Revised 07/2003)

(1) Each cardholder must determine if the product or service is available through the mandatory sources of supply (Federal Prison Industries (UNICOR), National Industries for the Blind (NIB) or National Industries for the Severely Handicapped (NISH)) before making a purchase from the open market. A written waiver from UNICOR must be on file for furniture purchases from a commercial source as required by section T3.8.4, A.2 Mandatory Government Sources.

(2) The AMS stipulates that small businesses and small businesses owned and controlled by socially and economically disadvantaged individuals will be given reasonable opportunities to provide products and services purchased by the FAA; therefore, cardholders should purchase from these sources whenever possible except as required in section T3.8.4, A.2 Mandatory Government Sources.

(3) An appropriate number of vendors should be contacted to ensure quality products and services are delivered in a timely manner at the best value to the FAA consistent with the AMS policy 3.2.2.5.

h. Availability of Appropriations. The FAA shall comply with the Anti-Deficiency Act (31 U.S.C. 1341) and other fiscal laws. Restrictions on the purposes for which appropriated funds may be used come from a variety of sources, including the U.S. Constitution, appropriation acts, and decisions of the Comptroller General. Funds certification officers must provide a written allocation of funds availability. This can be done on a quarterly, semi-annual or annual basis. Cardholders are responsible for maintaining a revolving balance of available funds as each item is purchased. (Revised 07/2003)

i. Acquisition of Training Services. The FAA purchase card is encouraged for use to the maximum extent possible to acquire training by appropriate training coordinators, if they are delegated cardholders. It is important to ensure that proper coordination of training requirements has taken place prior to training being purchased, e.g. completed training checklist, needs assessment, and whether or not the training is being purchased by a training coordinator or not. (Revised 07/2003)

j. Tax Exemption. At the time of the purchase, cardholders should advise the merchant that the purchase is for official U.S. Government purposes and therefore is not subject to state or local tax. If the vendor wants to clarify this, the back of the card includes an 800 number that may be called for verification. Exceptions do exist for certain state taxes in certain states, i.e., New Mexico. For this reason, cardholders should contact legal counsel regarding applicability of any exemptions or other issues related to state or local taxes for specific information about excepted states. 

k. Validation of Purchases - Cardholder. Each cardholder is responsible for validating all card purchases and credit transactions itemized on the monthly statement to the accountable documents; i.e., the cardholder’s copy of sales slips, credit slips, and telephone order forms. These accountable documents must be verified to the cardholder statement to make sure that itemized purchase amounts are valid obligations and all credits for returned or disputed amounts are reflected on the monthly statement. If the cardholder’s statement reflects charges for purchases not received, the amounts in question should be disputed (See paragraph l. Deficiencies/Disputes/Damaged Equipment). Cardholders should also ensure that purchases on their statement include no sales tax. If sales tax is included, the tax should be disputed with the vendor. (Revised 07/2003)

(1) Approving Official. The approving official is responsible for ensuring that all cardholders validate purchases and credits itemized on the statement and that all purchases and credits include the proper accounting classification data. Approving officials must verify that all purchases were authorized and that copies of sales slips, credit slips, and telephone order forms are attached. The approving official must also notify the APC of any unauthorized use of the card.

(2) Finance Office. Finance offices receive monthly finance office reports from the card-issuing bank that reflects summary totals of all purchases and credits of each cardholder. The finance office report represents the invoice from the bank and should be date stamped when received. The finance office is responsible for certifying for payment all authorized card purchases.

l. Deficiencies/Disputes/Damaged Equipment (Revised 07/2003)

(1) If the cardholder finds a discrepancy that is the result of item shortage, receipt of a defective or damaged item, or receipt of the wrong item, the first step is to contact the vendor to seek resolution. The cardholder should request a replacement item or a credit from the vendor. The credit will appear on the cardholder’s account statement for the following month. The cardholder should return the defective, damaged or erroneous item to the vendor within 60 days of receipt.

(2) If the cardholder and vendor cannot reach an agreement on resolution of the discrepancy, then the cardholder must file a dispute form with the bank to formally dispute the purchase. The bank will credit the purchase cardholder’s account until the dispute is resolved.

m. Lost or Stolen Cards. (Revised 07/2003)

(1) Reporting Lost or Stolen Cards. The cardholder must report immediately the loss or theft of the purchase card to the APC, the approving official and the card-issuing bank in order to avoid liability for unauthorized purchases on the card. The necessary information to report to the card-issuing bank includes the cardholder’s complete name, card number, and purchases made on the date of loss or theft. In the event of theft, the cardholder should also provide the bank the date that the theft was reported to the police.

(2) Card Re-issuance. The card issuing bank will issue a new card to the cardholder within two working days from the time that the loss or theft is reported. A cardholder who reports more than one incident of loss or theft within a 12-month period will require authorization from the COCO in order to have another card re-issued.

n. Accounting Classification Code Adjustments. Each cardholder has a primary use or "default" accounting classification code based on the primary use of the card, i.e., whatever the office is primarily purchasing. For example, Flight Standards offices may have a primary use of the card for aircraft rental. The card may be used for purchases other than the "primary use" purpose; however, the action will require a different accounting classification code assignment. All cardholders and approving officials are required to review the monthly bank statements upon receipt each month. The cardholder is required to assign the correct object class code for each item purchased. The approving official is required to review the statement for accuracy, the potential for split purchases, and approve each individual transaction. 

o. Cardholder Non-Compliance. The purchase card privileges of any cardholder found to be non-compliant with purchase card guidance twice in a six-month period will be suspended for six months. The cardholder’s privileges may be restored upon completion of remedial training or permanently revoked. The purchase card is considered government property. The FAA will comply with the FAPM Letter 2635 Code of Conduct & Discipline Order, HRPM 4.1 on Standards of Conduct, and HROI Table of Penalties for any purchase cardholder misuse and/or fraud of government property. (Revised 07/2003)

2. Reserved. (Revised 01/2003)

3. Reserved. (Revised 01/2003)

4. Credit Card Checks (Revised 07/2003)

a. Training. Both the credit card check approving official and check writer (prior to approving or making a purchase) require training. The approving official should contact the regional Agency Program Coordinator (APC) to schedule training.

b. Credit Card Check Usage. A check can be issued when the service or goods for which payment is being made is operationally critical, cost effective and consistent with FAA procurement policies. Credit card checks are to be issued only in "exceptional situations" when the use of payment mechanisms such as an automated clearinghouse, a government purchase card, or a government issued travel credit card are not feasible. Credit card checks carry a different prohibition than that of the purchase cards. Specific examples of appropriate credit card check usage are found in Appendix 1. (Revised 07/2003)

(1) Credit card checks may only be used: 

(a) Where the political, financial, or communications infrastructure does not support payment by EFT in a foreign country;

(b) Where the payment is to a recipient within an area designated by the President or an authorized agency administrator as a disaster area;

(c) Where paying by EFT would jeopardize military or law enforcement operations or national security interests;

(d) Where a cost-benefit analysis shows that making non-recurring payments by EFT are not justified;

(e) Where an agency’s need for goods and services is of such unusual and compelling urgency that the Government would be seriously injured unless payment is made by a method other than EFT; or

(f) When there is only one source for goods or services and the Government would be seriously injured unless payment is made by a method other than EFT.

(2) Credit Card checks may not be used for:

(a) The issuance of travel advances when the government-issued travel charge card is revoked or cancelled due to delinquent payment or for personal reasons;

(b) Cash.

c. Authorization Level. (Revised 07/2003)

(1) Purchases using credit card checks must be approved in advance by the second level approving official who approves purchase card purchases. The credit card check-approving official must initial the check register to verify that the payee does not accept the purchase cards and that the issuance of the credit card check meets at least one of the requirements listed above under the section 4.b Credit Card Check Usage.

(2) If the approving official is not located at the same site as the person authorized to issue the check (check writer), verbal approval, followed by written documentation, is satisfactory. A copy of the written documentation authorizing the purchase must be provided to the check writer. A copy of the Credit Card Check Approval Form is included as Appendix 2. If the second level approving official is not readily available, another individual at that level or higher may approve the use of the check, provided that he/she can attest that the need clearly follows the guidelines stated above.

(3) If the check writer is providing the check to another employee who will actually be giving the check to the vendor/merchant/individual, and the latter employee is in a different line of business than the check writer, then the approving official will be the second level approving official of the employee paying the vendor/merchant/individual rather than the secondlevel approving official of the check writer.

d. Issuing a Credit Card Check.

(1) Credit card checks are carbon checks. The following information should be entered in the appropriate space on the check and must be written, printed in ink or typed. Except as otherwise authorized, checks shall only be used for officially approved purchases and issued only by the individual whose name appears on the check.

(2) Date: Enter the date on which the credit card check was issued to vendor for purchase. The date can be spelled out (e.g., August 27, 1999) or written (8/27/99). Do not predate or postdate a credit card check.

(3) Pay to the Order of: Enter the name of the payee. (Individuals may not issue credit card checks payable to themselves.)

(4) Amount. The dollar amount of the credit card check must be written and spelled out in the space provided, (e.g., "$126.39" and spelled out as "one hundred and twenty-six and 39/100," followed by a horizontal line out to the end of the space provided).

(5) Memo. (additional information). Enter information pertinent to the purchase, e.g., radar parts, pavement repair, emergency plumbing.

(6) Authorized Signature. Sign in the space provided. Your signature should be in the same format as the name printed on the credit card check, (e.g., if first, middle, and last names are spelled out in full rather than initials being used, your signed name must also be spelled out in full).

e. Spending Limitation. (Revised 07/2003)

(1) Credit card checks access the same single purchase and monthly spending limits established by the lines of business (LOBs). The established monthly limit will cover purchases made by both the purchase card and the credit card checks. Approving officials will determine the appropriate dollar amount of single purchases limits to be established for each cardholder, however, each credit card check issued cannot exceed $2,500.

(2) A pre-established dollar "not to exceed" limit of $2,500 will be printed on the checks. Under no circumstances shall a check be written over that amount.

f. Knowing Your Balance. Cleared credit card checks are deducted from the monthly limit when they actually clear the bank, not when they are written. Monthly limits are renewed on the 20th of each month. You are responsible for tracking your individual available balance and reconciling cleared credit card checks. Remember any transactions made with your purchase card will also be counted toward your monthly balance. The following is important.

(1) Allow time for each credit card check to clear, which may overlap billing cycles;

(2) Ensure the monthly limit is sufficient to cover written checks; and

(3) At the beginning of each billing cycle, credit card checks that appear on the statement as cleared should be deducted from your balance.

IMPORTANT NOTE: This account is different from your personal checking account because unused balances do not accumulate. Exceeding your limit will result in credit card checks being returned for insufficient funds.

g. Safeguarding and Accountability of Blank Credit Card Checks.

(1) For security purposes, the following items are preprinted on the face of all credit card checks:

(a) Name and work address of the authorized credit card check holder;

(b) Legend: NOT VALID FOR MORE THAN THE ESTABLISHED SINGLE PURCHASE LIMIT;

(2) Credit card checks shall be safeguarded in accordance with FAA Order 1600.6, FAA Security Risk Management Program. When not in use, checks are to be kept in a secured area, i.e., locked safe or cabinet or another secured environment approved by the servicing security element to protect them from being stolen or misused.

i. Staying Within Your Purchase Limit. It is imperative that single purchase and monthly limits not be exceeded.

j. Insufficient Check Fees. The financial institution does not charge a fee for insufficient checks, however, the vendor may charge a fee. This fee may vary depending upon the vendor.

k. Liability of Fraudulent Use.

(1) The agency is responsible for all proper charges made with the purchase card or credit card check (by a cardholder) but is not liable for any unauthorized use. Unauthorized use means the use of an account/card by a person other than the cardholder who does not have actual, implied, or apparent authority for such use and from which the cardholder receives no benefit. The cardholder and the designated billing office is responsible for notifying the financial institution when possible unauthorized use of the credit card checks has occurred.

(2) If unauthorized use has occurred, the liability of the cardholder shall not exceed the lesser of $50 or the amount of money, property, labor, or services obtained before notification to the financial institution. Notification, either by telephone or in writing, must be given to the financial institution with pertinent information regarding the unauthorized use. The financial institution will not determine whether a purchase is authorized or made during official government business.

l. Employee’s Liability of Fraudulent Use. Disciplinary actions for theft, fraud, or intentional misuse of credit card checks by an employee will be imposed based on the applicable penalty(s) outlined in FAPM LTR 2635, Conduct and Discipline, as well as penalties and/or legal charges brought upon by the financial institution.

m. Reporting Lost or Stolen Purchase Card and Credit Card Checks. To safeguard against intentional misuse, lost or stolen purchase cards and credit card checks must promptly be reported.

n. Destroying Purchase Cards and Credit Card Checks.

(1) When an account has been cancelled, all related purchase cards and unused check numbers should be recorded and then immediately destroyed. All valid written, unused, and lost/stolen check numbers are to be reported to the financial institution. The financial institution will place stop payment on invalid checks.

(2) Once the financial institution has been notified to cancel an account, checks attempting to post after the closure date will be declined. The financial institution security associates and bank representatives will investigate each check to determine if floating checks were written by the account holder and valid for payment. If the check is valid, the checks will post to the new account number, if not, the checks will be returned for non-payment and further investigated by the financial institution.

o. Maintaining Your Credit Card Check Register. A credit card check register should be maintained to record each credit card check transaction. The credit card check number, date issued, the payee, a description of the purchase, the emergency credit card check amount, and the account fee can be entered. A copy of the Credit Card Check Register is included as Appendix 3.

p. Maintaining Receipts and Record Retention. The carbon copy of the check, the merchandise receipt and invoice must be turned in for each purchase and matched against the credit card check register. Records should be retained in the office and then archived according to the agency’s Vital Record and Retention Manual. Records include the monthly statement of account, your credit card check register, receipts, and all supporting documentation.

q. Account Fees. The fees associated with writing a credit card check will be charged back to the individual check writer’s LOB and will appear on the monthly statement.

r. Billing Statement. The monthly purchase card and credit card check statement will show the merchant/vendor name, the amount of the check, and the check number of all cleared checks.

s. Reconciling Your Account. The monthly statement must be cross-checked with your credit card check register, carbon copy of the check, receipt, invoice, and your internal log to ensure that the register and statement amounts are the same. Any discrepancies must be resolved immediately with the financial institution. Keep in mind that cleared checks that may appear on the statement may be checks written the prior month.

t. Returned Merchandise:

(1) If there is a need to return an item to a vendor, do not accept cash or a store credit made out to the check holder. If a refund is issued in the form of store credit, it must be made out to the Federal Aviation Administration and used for a future valid purchase.

(2) In the event a refund check is received, it must be forwarded to the servicing accounting office for deposit within one business day. The original accounting classification code should be provided to credit the funds accurately.

u. Reporting Expenditure Data. In order to determine the effectiveness of the program, data will be required to monitor credit card check usage.

5. Blanket Purchase Agreement (BPA)

a. A BPA is a simplified method of filling anticipated repetitive needs for products or services by establishing "charge accounts" with qualified sources of products/services. It should be considered for use when other purchase techniques such as a contract, credit card, and purchase orders, are not available or appropriate. Contracting Officers may establish BPAs for items of the same type concurrently with more than one vendor. There is no maximum limitation established for BPAs, however, if it is anticipated at the start that the total orders against a BPA will exceed $100,000 it will be subject to the public announcement policy. In addition, any individual order against a BPA exceeding $100,000 would also be subject to the public announcement policy.

b. The following terms and conditions should be considered for BPAs:

(1) Description of Agreement. A statement that the vendor shall furnish products or services, described in general terms, if and when requested by the Contracting Officer, or the authorized representative, during a specified period and within a stipulated aggregate amount, if any.

(2) Extent of Obligation. A statement that the FAA is obligated only to the extent of authorized purchases actually made under the BPA.

(3) Purchase Limitation. A statement that specifies the dollar limitation for each individual purchase under the BPA.

(4) Notice of Individuals Authorized to Purchase under the BPA. The Contracting Officer will furnish to the vendor a list of individuals authorized to purchase under the BPA, identified either by title of position or by name of individual, organizational component, and the dollar limitation per purchase for each position title or individual.

(5) Clauses. The BPA should include any prescribed clauses applicable to the dollar thresholds of particular order against the BPA, i.e., Service Contract Act.

(6) Delivery Tickets. A requirement that all shipments under the BPA, except subscriptions and other charges for newspapers, magazines, or other periodicals, will be accompanied by delivery tickets or sales slips with the following information as a minimum: name of contractor, BPA number, date of purchase, purchase number, itemizes list of products or services furnished, quantity, unit price, and extension of each item, and date of delivery or shipment.

(7) Invoices. Invoices are to be submitted at least monthly.

c. In keeping with the purpose of a BPA, a purchase request is not required to be submitted for each purchase. The Contracting Officer, or authorized user, may make purchases based upon an oral request or a memorandum from an authorized requisitioner from the program/originating office. Oral requests should be confirmed in writing by the requisitioning office as a matter of record.

d. Each person in a program office who is authorized to make purchases under a BPA, should receive guidance from the contracting office on the limitations of authority and responsibilities associated with using the BPA. Whenever a change occurs which affects an authorized user of a BPA, the program/originating office should notify the Contracting Officer and request the BPA be modified to reflect the proper data.

e. The Contracting Officer should review a sufficient random sample of the BPA files at least annually to ensure that authorized procedures are being followed. Only Contracting Officers or those persons designated by the Contracting Officer may place purchases against a BPA. Any purchase made by an unauthorized person, or any purchase placed against a BPA which exceeds the authorized limitation, may be considered an unauthorized procurement.

f. In accordance with Office of Management and Budget (OMB) Circular A-120, the same person may not place the call, receive supplies or services, and authorize payment. The same person may perform two of the functions, but not all three.

g. A BPA is considered complete when purchases under it equal its total dollar limitation or when the stated time period expires.

6. Purchase Orders

a. The purchase order is a simplified form for ordering supplies and services which allows the vendor to invoice using the same form. Purchase orders should be issued on a fixed-price basis. An unpriced purchase may be issued for supplies or services when it is impractical to obtain pricing in advance of issuance of the purchase order.

(1) Purchase orders should contain the following information:

(a) Trade and prompt payment discounts that are offered;

(b) The quantity of supplies or services ordered;

(c) Inspection provisions; origin or destination;

(d) A determinable date by which delivery of supplies or performance of services is required; and

(e) Information for use by Accounting should be requested by the preparer of the purchase order as follows:

(i) Vendor’s SSN or taxpayer identification number (TIN);

(ii) Vendor’s business status as one of the following classifications:

(A) Individual/sole proprietorship;

(B) Corporation;

(C) Partnership; or

(D) Other (specify);

(f) The Contracting Officer’s signature. Facsimile signatures may be used in the production of purchase orders by automated methods.

(2) An unpriced purchase order may be appropriate when:

(a) It is impractical to obtain pricing in advance of issuance of the purchase order; or

(b) The purchase is for repairs to equipment requiring disassembly to determine the nature and extent of repairs; the material is available from only one source and for which cost cannot be readily established; or the order is for supplies or services for which prices are known to be competitive but exact prices are not known (e.g., miscellaneous repair parts, maintenance agreements).

(3) Unpriced purchase orders may be issued by using written purchase orders or electronically. A realistic monetary limitation, either for each line item or for the total order, should be placed on each unpriced purchase order. The monetary limitation becomes an obligation subject to adjustment when the firm price is established. The contracting office should follow-up each order to ensure timely pricing. The Contracting Officer or designated representative should review the invoice price and, if reasonable, process the invoice for payment.

(4) The Contracting Officer should require written acceptance of a purchase order when it is desired to consummate a binding contract before the contractor undertakes performance.

(5) A purchase order may be modified. Each purchase order modification should identify the order it modifies and should contain an appropriate modification number. The Contracting Officer determines when it is necessary to obtain a contractor’s written acceptance of a purchase order modification. Purchase orders may be modified by using:

(a) Standard Form 30, Amendment of Solicitation/Modification of Contract;

(b) An agency-designed form or an automated format; or

(c) A purchase order form.

(6) A purchase order may be terminated. If the purchase order has been accepted in writing by the contractor, the termination should be processed in accordance with the termination clauses. If the purchase order has not been accepted in writing by the contractor, the Contracting Officer should notify the contractor in writing that the purchase order has been canceled and request the contractor’s acceptance of the cancellation. If the contractor accepts the cancellation and does not claim that costs were incurred, no further action is required. If the contractor does not accept the cancellation or claims that costs were incurred, the Contracting Officer should process the termination in accordance with the termination clauses.

(7) The Contracting Officer may print on the purchase order form the clauses they consider to be generally suitable for their purchases. The following forms may be used for purchase orders:

(a) Optional form 347, Order for Supplies or Services;

(b) Optional form 348, Order for Supplies or Services Schedule-Continuation; or

(c) Other agency generated or contractor provided forms.

(8) The Contracting Officer should obtain the corporate status information of the vendor.

7. Considerations for Restricted Puchases

a. This guidance is concerned with providing information and reference points to assist FAA acquisition personnel or FAA requiring organizations in ascertaining whether a particular item of equipment or of service would constitute a permissible purchase using Federal funds. There is no iron clad rule or list which can be readily developed which would serve to delineate in each and every case whether a particular purchase is permissible for Federal funding. However, the application of common sense and the wise exercise of discretion, fortified by an examination of appropriations laws and related decisions of the Comptroller General, should fill the breach.

b. The General Accounting Office (GAO) has enunciated a "necessary expense" doctrine. This doctrine is described more fully in Volume I, Second Edition, of "Principles of Federal Appropriations Law," issued by GAO, Office of the General Counsel, dated July 1991. This publication states, in part, that for an expenditure to be justified under the necessary expense theory, it must meet certain tests, including, but not confined to, the test that: "The expenditure must bear a logical relationship to the appropriation sought to be charged." In other words, it must make a direct contribution to carrying out either a specific appropriation or an authorized agency function for which more general appropriations are available" (page 4-16 in the cited document).

c. By projection, this doctrine makes unallowable items of expense which can be reasonably construed as covering items or services which are to meet personal convenience and are not for a necessary governmental function. Determinations in this area in respect to questioned or questionable items should be made by the Contracting Officer in consultation with the legal counsel. Almost any listing of prohibited items of purchase is subject to exceptions. To quote the above cited GAO issuance, "The Comptroller General has never established a precise formula for determining the application of the necessary expense rule. In view of the vast differences among agencies, any formula would almost certainly be unworkable. Rather, the determination must be made essentially on a case-by-case basis" (Page 4-15 of the publication.)

d. For the guidance of FAA, the following examples are given of prohibited items of purchase (however, this is not a complete list): (Revised 12/1999)

(1) Drinking water, except when a duly constituted public health authority pronounces the ordinary drinking water to be unsafe for human consumption at the site.

(2) Subscriptions to publications or magazines, not relating to official duties.

(3) Clothing (or personal apparel of any description); requirements for special type clothing necessitated by agency need should be coordinated with the procurement office.

(4) Rental of aircraft by persons not in aircraft related positions.

(5) Fans, air conditioning and cooling equipment, space heaters and heating equipment, except as properly installed for general use in connection with the maintenance and operations requirements for the site.

(6) Water coolers, or vacuum cleaners and other household appliances, except as requisitioned for general use by the authorities charged with building maintenance and equipment.

B. CLAUSES

None applicable.

C. FORMS

See FAST Procurement Toolbox for applicable forms.

D. APPENDICES (Revised 01/2003)

Appendix 1 Appropriate Use of Credit Card Checks
Appendix 2 Credit Card Check Approval Form
Appendix 3 Credit Card Check Register
Appendix 4 Purchase Card Training Database (Added 01/2003)

 

Appendix 1. APPROPRIATE USE OF CREDIT CARD CHECKS (Added 07/2000)

 

Scenarios

Examples of Preferred Payment Methods

Allow Check Use

Comments

Emergency salary payment (disaster declared)

· Deposit to employee’s account

· Treasury check to employee

Yes

Treasury waiver allowed where payment is to a recipient within an area designated by President or an authorized agency administrator as a disaster area.

Advance salary payment to new employee

· Deposit to employee’s account

· Treasury check to employee

No

 

Local travel

· Deposit to employee’s account

· Treasury check to employee

· Employer-provided transit cards

No

 

Reimburse gas when privately-owned vehicle is used for local travel

· Deposit to employee’s account

· Treasury check to employee

No

 

Purchase fuel & main-tenance for government-owned vehicles

· Purchase credit card

· Deposit to employee’s account

· Treasury check to employee

 

Limited

Treasury waiver allowed where there is only once source for good or service and the Government would be seriously injured unless payment is made by a method other than electronic funds transfer (EFT).

 

Non-local travel (including travel advances)

· Travel credit card

· Deposit to employee’s account

· Treasury check to employee

 

Limited

If employee is new or travels less than once every 18 months, a check may be used if there is 1) not sufficient time to request an electronic deposit to the traveler’s account, & 2) travel cannot be delayed without serious injury to the Government.

 

 

Scenarios

Examples of Preferred Payment Methods

Allow Check Use

Comments

 

Payments to State/local governments

· Purchase credit card

· Deposit to payee’s accou

· Deposit to employee’s account

· Treasury check to employee

 

Limited

Treasury waiver allowed where there is only one source for good or service and the Government would be seriously injured unless payment is made by a method other than EFT.

Real property acquisitions from others involving Department of Justice

· Deposit to payee’s account

· Treasury check to payee

 

Limited

Use of credit card check allowed only if such payment is required by Justice.

Radar located on farm. Farmer mows lawn or removes snow around radar

· Purchase credit card

· Deposit to payee’s account

· Deposit to employee’s account

· Treasury check to employee

 

Limited

If there is not a reasonable, cost-effective alternative to the farmer mowing the grass or removing snow, a credit card check may be used. Although every effort should be made to use or establish an account with a financial institution to which payments can be electronically deposited.

 

Rent aircraft, aircraft simulators

· Purchase credit card

· Deposit to payee’s account

· Deposit to employee’s account

· Treasury check to employee

 

Limited

Treasury waiver allowed when there is only once source and Government would be seriously injured unless payment is made by a method other than EFT.

 

 

Scenarios

Examples of Preferred Payment Methods

Allow Check Use

Comments

Rent equipment at locations where vendor doesn’t accept credit cards & transporting equipment from another site is cost prohibitive.

· Purchase credit card

· Deposit to payee’s account

· Deposit to employee’s account

· Treasury check to employee

 

Limited

Treasury waiver allowed: 1) when there is only one source (perhaps due to remote location) & Government would be seriously injured unless payment is made by a method other than EFT, 2) when there is a need that is unusual and compelling, or 3) when the source is significantly less costly than others.

 

Payment for required physicals for employees

· Purchase credit card

· Deposit to payee’s account

· Treasury check to payee

· Deposit to employee’s account

· Treasury check to employee

Limited

Treasury waiver allowed: 1) when there is only one source (perhaps due to remote location) & Government would be seriously injured unless payment is made by a method other than EFT, 2) when there is a need that is unusual and compelling, or 3) when the source is significantly less costly than others.

 

Payment to vendors for

training

· Purchase credit card

· Deposit to payee’s account

· Treasury check to payee

· Deposit to employee’s account

· Treasury check to employee

 

Limited

Treasury waiver allowed when there is only one source and Government would be seriously injured unless payment is made by a method other than EFT, or when there is a need for the training that is unusual and compelling.

 

Expert witness fees

· Purchase credit card

· Deposit to payee’s account

· Treasury check to payee

· Deposit to employee’s account

· Treasury check to employee

 

Limited

 

Treasury waiver allowed when there is only one source and Government would be seriously injured unless payment is made by a method other than EFT, or when there is a need that is unusual and compelling.

Reimbursement for passports & immunizations

· Deposit to employee’s account

· Treasury check to employee

No

 

 

 

Scenarios

Examples of Preferred Payment Methods

Allow Check Use

Comments

 

FEDEX/UPS delivery with

COD

· Purchase credit card

· Deposit to payee’s account

· Treasury check to payee

· Deposit to employee’s account

· Treasury check to employee

 

No

 

One-time need for electrician, painter, plumber, etc. without bank account

· Purchase credit card

· Treasury check to payee

· Deposit to employee’s account

· Treasury check to employee

 

Limited

Treasury waiver allowed: 1) when there is only one source (perhaps due to remote location) & Government would be seriously injured unless payment is made by a method other than EFT, 2) when there is a need that is unusual and compelling, or 3) when the source is significantly less costly than others.

Tuition assistance

· Deposit to employee’s account

· Treasury check to employee

No

 

Award to employee

· Deposit to employee’s account

· Treasury check to employee

No

 

To reimburse an employee, the employee would complete a SF-1164, "Claim for Reimbursement for Expenditures on Official Business," and reimbursement would be made by direct deposit to the employee’s account or by a Treasury check (see footnote 2).

When an employee does not want to be paid or reimbursed by an EFT method based on the waivers stated in 31 CFR 208.4, including "where an individual determines, in his or her sole discretion, that payment by electronic funds transfer would impose a hardship due to a physical or mental disability or a geographic, language, or literacy barrier, or would impose a financial hardship," reimbursement will be by Treasury check and not by credit card check, unless the political, financial, or communications infrastructure does not support payment by Treasury check, for example, during a declared disaster.

When paying vendors and individuals for providing goods and services, payment by EFT is required unless one of the waiver criteria stipulated in 31 CFR 208.4 applies. Since payment by Treasury check is a non-EFT method, its use must be supportable by waiver as required by 31 CFR 208.4. Payment by Treasury check is preferable to using a credit card check.

A credit card check can be issued when the service or good for which payment is being made meets the criteria set forth in 31 CFR 208.4 (see footnote 2), and is operationally critical, time critical, cost effective and consistent with FAA procurement policies. Because of the inherent inefficiencies and costs associated with processing a paper document, and because there are better controls associated with electronic payments, checks are to be issued only for "exceptional situations" when other payment mechanisms, like the purchase and travel credit cards, are not possible.

Based on 31 CFR 208.4 as implemented by the Department of the Treasury in September 1998, non-electronic funds transfer (EFT) methods may be used:

where the political, financial, or communications infrastructure does not support payment by EFT in a foreign country;

where the payment is to a recipient within an area designated by the President or an authorized agency administrator as a disaster area;

where paying by EFT would jeopardize military or law enforcement operations or national security interests;

where a cost-benefit analysis shows that making non-recurring payments by EFT are not justified;

where an agency’s need for goods and services is of such unusual and compelling urgency that the Government would be seriously injured unless payment is made by a method other than EFT; or

when there is only one source for goods or services and the Government would be seriously injured unless payment is made by a method other th

Appendix 2 – CREDIT CARD CHECKS APPROVAL FORM (Added 07/2000)

This form is to be completed when verbal approval has been granted in advance of a purchase by the second level supervisor.

Date verbal approval authorized

 

Name of credit card check writer:

 

Name of individual who provided check to vendor/merchant/payee:

 

Vendor/merchant/payee’s name:

 

Did vendor/merchant accept the purchase credit card?

 

Reason for authorizing the use of the credit card check:

 
   
 

Second level Approving Official’s Name/Signature

 

Appendix 3 - CREDIT CARD CHECK REGISTER (Added 07/2000)

Name: __________________________

Account Number: ___________________

Date: __________________________

YES

NO

Note: As a suggestion, if you have situations when the reason is the same for single or multiple vendors, you may want to develop

a list of reason codes at the bottom of the form and put the reason code number in the justification block

 

Appendix 4 - PURCHASE CARD TRAINING DATABASE (Added 01/2003)

Assigned Organization Employee Name Location Initial Training Date Refresher Training Date Last 6 Digits of Purchase Card No. Single / Monthly Spending Limit Supervisors Name
AAF-300 Joe Doe ANE Regional Office 05/22/95 02/16/99
02/16/02
200000 $10,000(s)
$25,000(m)
John Smith
ANI-1 Jane Doe AAL FTW SSC 02/01/99 03/12/03 11111 $5,000(s)
$10,000(m)
Jane Smith
AFM-800 Tom Jones Headquarters 02/02/94 11/22/97
09/15/02
22222 $25,000(s)
$50,000(m)
Tom Smith
ACT-51 Mary Brown ACT Logistics 07/07/01   123456 $10,000(s)
$25,000(m)
Sallie Jones
AMQ-300 Lucy Bird AMQ Ops & Maintenance 10/10/93 10/08/96
10/12/99
10/15/02
54544 $10,000(s)
$25,000(m)
Her Gordon
AEA-55 Freddie Mac AEA Contract 05/15/02   88994 $10,000(s)
$25,000(m)
Oscar Meyer
ASO-22 Willy Wonka ASO Acct. Ops 04/19/00   54654 $10,000(s)
$25,000(m)
Millie Norman
AGL-54 Rocky Moon AGL Sup Servs 06/20/96 05/20/99
07/26/02
56555 $10,000(s)
$25,000(m)
Madge Hair
ACE-300 Jean Bandaid ACE Med Serv 01/24/97 03/19/00 22154 $10,000(s)
$25,000(m)
Howard Troy
ASW-620 George Green ASW Safety Std 09/18/98 10/10/01 54545 $10,000(s)
$25,000(m)
Troy Ackman
AWP-420 Sky Coral AWP Resource Mgt. 02/09/95 02/18/98
03/03/02
54545 $10,000(s)
$25,000(m)
Siera Surfer
ANM-53 Renee News ANM Acq. 08/28/02   24123 $10,000(s)
$25,000(m)
Dan Ruther