Non-compliance Penalties

Compliance Assessments

Obtaining a PCard is a privilege based on trust that the card will be used in a responsible and appropriate manner. If a University employee is in a position to obligate the University, that employee is entrusted with the responsibility of protecting the University from harm.   Fraudulent or intentional misuse of the card will result in revocation of the card, personnel actions against the Cardholder, and/or possible criminal charges. Therefore, in order to obtain a PCard, an applicant must first attend a training session.

The Procurement Card Coordinator will make regular Compliance Assessments of Cardholders in order to determine compliance with PCard policies and procedures. The Coordinator will review sales receipts, credit card slips, tear sheets, statements of business purposes, etc. All supporting documentation, will be scrutinized.

As the Coordinator is conducting Compliance Assessments, the Cardholders will receive written notice if any violations have been discovered. Failure to comply delays posting to the general ledger. 

A violations database is maintained in order to track excessive or reoccurring violations.

Non-Compliance Penalties and Card Termination

Automatic 90-day SUSPENSION for 1st offense

  • Restricted = Purchase of items on the restricted list or making a personal purchase. 
  • Sharing Card = Allowing someone other than the cardholder to use the card.
  • Split Transaction = Not adhering to the $2,500 maximum daily vendor transaction limit.

Automatic 30-day SUSPENSION for 1st offense

  • Delinquent = Online Approval, Expense Report and/or supporting documentation is delinquent, i.e. submitted after deadline.
  • Invoice/Receipts/Credit = A detailed receipt must accompany the statement and report.
  • Specific and complete description of goods not provided. Must include the 5 Ws – Who? What? When? Where? Why? For official meetings or Registration for events such as conferences.
  • Tax = Cardholder paid sales tax on an item. Must get credit from Vendor or refund the tax amount by CHECK payable to TWU.
  • Food/refreshments = allowed on local accounts only - Food Purchase Justification Form
  • Slips and receipts = must be taped (no staples) to 8 ½” x 11” sheets for scanning purposes. Long receipts need to be cut and taped. Tape should not be applied over merchant’s name or dollar amount.
  • Tear Sheet = copy of ad showing date it ran or published is required for all advertising.
  • NSF = Insufficient funds in account provided.

Additionally, the University reserves the right to terminate a cardholder's TWU PCard at any time. Non-compliance to University, State and/or Federal procurement policies and procedures will be grounds for revocation of cards.  Non-adherence to policies and procedures may result in revocation of all procurement cards in a division or department. Repeated errors will result in the card being deactivated.

If the cardholder violates any procurement card procedures outlined in these guidelines, the Program Coordinator may provide one on one instruction or the card can be suspended or cancelled at the Program Coordinator’s discretion. If the card is suspended, the cardholder will be subject to a pre-determined waiting period and will be required to attend training again before the card will be reactivated. In the event the card is cancelled, the cardholder may not reapply for one calendar year.

Repeated violations may result in the card being permanently terminated at the Program Administrator’s discretion.  If any cardholder activity appears fraudulent or abusive, the cardholder AND the Account Approver/Manager may be subject to personal liability and/or disciplinary action, which may include termination of employment or possible criminal penalties.

While these are the consequences of TWU non-compliant PCard transactions, we will continue to collaborate with the department to determine appropriate consequences, and within reason will flex with campus department needs. TWU must maintain compliance with all applicable policies and procedures. 

Page last updated 2:32 PM, January 13, 2020