Non-Compliance and Penalties

Non-Compliance 

  • Multiple notifications to a single cardholder/department for insufficient budgets by the Office of Procurement and Contract Services may result in revoking all card privileges.
  • Non-adherence may result in revoking the individual or departmental cardholder privileges. All non-compliance will be monitored. Non-compliance includes, but is not limited to, incorrect reports, late receipt of documentation, unacceptable purchases and lack of documentation to back up expenditures.
  • Non-compliance may be documented with a Non-Compliance Form.
  • Cardholders/reconcilers will receive a warning if there are findings in the PCard report. They will then have seven days from the day the email is sent to correct the issue. After seven days, the error may be subject to disciplinary action listed below.
  • Non-compliant PCard transactions will be subject to disciplinary action up to, and including, the cancellation of PCard privileges.
    • The First Non-compliant Transaction: If the Cardholder/Reconciler does not correct the issue within seven (7) days, the Cardholder/Reconciler and the Account Manager will be notified of the non-compliant transaction(s) and PCard privileges may be suspended for 30 days.
    • The Second Non-compliant Transaction(s): If a second non-compliant notification is received within a six-month period, the Cardholder/Reconciler, the Account Manager and the Director/Department Head will receive notification of the non- compliant transaction(s) and the PCard privileges may be suspended for ninety days.
      • The Cardholder/Reconciler, Account Manager, Director /Department Head and the Vice President/Provost/Associate Vice President will receive notification that upon a third non-compliant transaction(s) the PCard privileges may be cancelled.
    • The Third Non-compliant Transaction(s): If a third non-compliant notification is received within a six-month period, the Cardholder/Reconciler, the Account Manager, Director/Department Head and Vice President/Provost/Associate Vice President will receive notification of the non-compliant transaction(s) and the PCard privileges may be cancelled.
    • While these are the consequences of TWU non-compliant PCard transactions, we will continue to collaborate with department Account Managers to determine appropriate consequences, and within reason will flex with campus department TWU must maintain compliance with all applicable policies and procedures.
  • A violations database is maintained in order to track excessive or reccurring violations.

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Violation Process 

First ViolationOccurs when the cardholder/reconciler has not resolved an infraction within seven (7) business days after notification.
Cardholder/reconciler and approver will be notified by email and the PCard privileges may be suspended for thirty (30) days.
Second Violation Occurs on the second occasion a cardholder/reconciler has not resolved an infraction within seven (7) business days after notification. PCard is suspended for ninety
(90) days, and the cardholder/reconciler, the approver, and the department head will be notified by email. PCard training will be required.
Third Violation Occurs on the third occasion a cardholder/reconciler has not resolved an infraction within seven (7) business days after notification. Cardholder/reconciler, approver, department head, and Vice President/Provost/Associate Vice President will be notified that a third and final infraction has occurred. The PCard may be cancelled.
Multiple Infractions Cardholders/reconcilers who repeatedly commit infractions may be subject to card suspension and/or required retraining, even if the infractions are being actively resolved within seven (7) business days after notification.
Multiple Suspensions If a PCard is suspended three (3) times for any combination of infractions within the
violation period, the PCard may be cancelled.
Violation Period The period of time for calculating number of violations is six months from the first notification email.

Page last updated 1:27 PM, July 9, 2020