omb charge card requirements - citigroup€¦ · 7. omb charge card requirements. omb circular...

2011 GSA SmartPay® Training Conference

OMB Charge Card Requirements

Robert S. RobbinsVice President, Citi

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A Winning Hand: Solutions, Savings and Sustainability with GSA SmartPayThe 13th Annual GSA SmartPay Training Conference, Las Vegas

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To ensure the best possible learning experience for participants, please adhere to the following house rules:

• Turn cell phones and pagers to vibrate• Hold questions to end of session• Ensure your participant badge is scanned to receive CLP credits− For each course− Must leave room and reenter

• Take advantage of opportunities to provide feedback − Please select the Citi Q&A icon on any Citi PC at the conference− Answers to be e-mailed after the conference within 60 days

House Rules


Federal Agencies

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This course is designed to assist you in achieving the following objectives:

• Learn effective controls to manage cardholders by setting policy and procedural requirements based on Office of Management and Budget (OMB) Circular A-123

• Review OMB Circular A-123 cardholder management and reporting requirements

• Discuss CitiManager cardholder management and reporting functionalities

Goals & Objectives

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Federal Agencies

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Cardholder Management and OMB Circular A-123

Using CitiManager to Manage Cardholders

Agenda

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Federal Agencies

1. Cardholder Management and OMB Circular A-123

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OMB Circular A-123, objectives include:

Facilitating effective internal controls with integrity and accountability

Consistent review of internal controls to streamline and standardize processes

Accountability and cooperation of the overall organization and current processes

Understanding organizational weaknesses to note and take corrective actions


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OMB Circular A-123, History of Appendix B

• August 2005, OMB issued Appendix B to OMB Circular A-123− Guideline for internal controls that reduce the

risk of fraud, waste and error in government charge card programs

• April 2006, revisions related to creditworthiness and technical changes

• January 2009, revisions related to mainly procurement cards and convenience checks


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OMB Circular A-123, Appendix B requirements are best practices for managing your cardholders

Standardize and consolidate card program requirements• Reduce administrative time and costs with payment process• Establish controls to mitigate fraud, misuse and delinquency• Improve financial and administrative benefits to government and

suppliers• Maximize rebates• Drive program effectiveness through data management• Evaluate the effectiveness of actions taken


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Must develop and maintain written policies and procedures to ensure system of internal controls

Update annually and submit copy of plan to OMB by 1/31– Key elements of card management plan– Identify key management officials and responsibilities– Process for appointment of cardholders and non-cardholders (AO, PA)– Implementing creditworthiness process– Describe agency training requirements– Policies and practices to monitor delinquencies, fraud, misuse and abuse– Implement Strategic Sourcing plan– Use Data to support program management– Documentation and Record Retention requirements– Outgoing cardholder processing– Continuous evaluation


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Includes AOPC, AO, other accountable officials and cardholders

• All program participants trained prior to appointment• Refresher training at minimum every three years• Participants to certify training requirements completed• Training certificates to be maintained per National

Archives and Records Administration (NARA) Schedule 1, Item 10a

• Training requirements vary by program type – purchase, travel, fleet, integrated

OMB Circular A-123, Appendix B – Training

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Responsibilities in implementing risk management controls, policies and practices include:

• Implement compliance with federal laws and agency regulations to monitor program effectiveness

• Ensure risk management plan is updated and effectively rolled out

• Monitor for account spend profile compliance and review for delinquency, misuse and abuse

• Communicate disciplinary policy and ensure appropriate enforcement including referral to Inspector General (IG)

• Establish proper internal controls for all purchases including micro-purchase threshold

• Compliance with property acquisition controls, “sensitive” property and federal inventory requirements

OMB Circular A-123, Appendix B – Risk Management

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Designed to identify financially responsible new individually billed travel card applicants – FICO (Fair Isaac Corporation) score of 660 and higher

• Scores of less than 660 dictate issuance of “restricted” cardOne or more of following must be imposed:− Card limit less than standard agency card− Reduced limit on individual transactions− Limit types of transactions− Limit time period dollar amount can be applied − Limit active status period permitted− Limit ATM use

• Options other than credit score− Review SF85 P, Section 22 or SF86, Section 27

OMB Circular A-123, Appendix B – Creditworthiness

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Federal Agencies

660

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All payment obligations are to be paid on time and Prompt Payment Act requirements met

• Central Bill Programs− Establish strict internal controls for timely payments− Closely monitor delinquency reports− Contact appropriate personnel to address delinquency and

ensure controls are in management plan• Individual Bill Programs− Monitor delinquency reports and contact cardholders promptly

alerting to potential for disciplinary action − Implement split disbursement and salary offset procedures− Incorporate controls for IB travel in management plan

OMB Circular A-123, Appendix B – Delinquency Controls

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Data is essential for card managers to assess:

• Compliance with legislative and administrative requirements

• Effectiveness of efforts to mitigate fraud, waste and abuse

• Performance trends in managing costs

OMB Circular A-123, Appendix B – Metrics and Data Requirements

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Depending on Agency status, reporting to OMB and Office of Federal Financial Management (OFFM) are either quarterly or annually

• Statistical Reporting− Number of cards, number of active accounts− % of employees to cardholders− Net number of new accounts opened− Spend, refunds, % of potential refunds− Number of cases reported to for misuse/abuse− Number of disciplinary actions Officer of Inspector General

(OIG) for misuse/abuse− Number of disciplinary actions for convenience check

misuse− Additional reporting specific to purchase, travel and

convenience checks

OMB Circular A-123, Appendix B – Reporting Requirements

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Depending on Agency status, reporting to OMB and OFFM are either annually or biannually

• Narrative Reporting− Dates of most recent and next scheduled independent review− Description of process for monitoring delinquency including reports

reviewed and actions taken− Steps agency takes for voucher turnaround of travel expense

submissions (< 15 days)− Description of method to identify misuse including reports and

specialized information technology used− Future 12-month plan to enhance abuse, misuse and fraud detection

systems− Description of best practices employed for card program

OMB Circular A-123, Appendix B – Reporting Requirements

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OMB Report – Standard Elements

Meeting Reporting Requirements

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Federal Agencies

Number of Cases

Reported by Agency to the

IG

Net Number of New Accounts

(New Less Cancelled)

Dollars Spent

Refunds Earned

Percentage of Potential Refunds EarnedAgency

Number of Cards

Number of Active

Accounts

Percentage of Employees that are Cardholders

Number of Administrative and/or Disciplinary Actions

Taken for Card Misuse (Including Delinquency)

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Travel Card Reporting Elements


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3,000$3,001 -$5,000

$5,001 - $7,500 ≥ $7,501 ≤ $3,000

$3,001 - $5000

$5,001 - $7,500 > $7,501 ≤ $3,000

$3,001 - $5000

$5,001 - $7,500 > $7,501

Number of Travel Cards with Monthly and/or Transaction Limits

Percentage of Travel Cards with Monthly and/or Transaction Limits

Number of Travel Cards With ATM Withdrawal Limits

≤ $3,000$3,001 - $5000

$5,001 - $7,500 ≥ $7,501

Percentage of Travel Cards With ATM Withdrawal Limits

Percentage of Travel

Cardholders that Travel Less than 5

Times Annually

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Purchase Card Reporting Elements


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Number of Purchase Cardholders with

Contracting Warrants Above $3,000

Number of Purchase Cardholders with Transaction

Limits of $3,000 or More that Do Not Hold Contracting Warrants

Ratio of Purchase Cardholders to

Approving Officials (Span of Controll)

Average Number of PurchaseCard Transactions Reviewed per

Approving Official

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Refund management is critical to ensure you maintain cost-effective programs

• Payments incorporate sales, productivity and adjustments

• Review competitive landscape for sales and productivity refund rates

• Tag along to another agency task order – benefit from their pricing

• Ensure on-time payments for productivity• Initiate internal controls to maximize card use• Statutory authority dictates how refunds can be used

OMB Circular A-123, Appendix B – Refund Management

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Can be written to vendors not accepting purchase card, emergency incident response and compliance with Public Law 104-134

• Convenience checks may not be written to:− Vendors accepting purchase card− Vendors under another payment mechanism− Employee reimbursements− Cash advances− Salary payments, cash awards− Travel-related transportation tickets− Meals or lodging for employee travel except emergency incident

response

OMB Circular A-123, Appendix B – Convenience Checks

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• Must follow Federal Acquisition Regulations (FAR) Section 2.1– Supplies – $3,000– Services – $2,500– Construction – $,000

• Must be written for exact amount of purchase• Applicable 1099 requirements apply• Agency must maintain written policies and

procedures for convenience checks

OMB Circular A-123, Appendix B – Convenience Checks

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Federal Agencies

2. Using CitiManager to Manage Cardholders

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CitiManager is the single sign-on system to access all electronic tools to support managing cardholders

• Applications− Cardholder Management Module− Reporting Module− Statements and Payments

• Library• CLASS

Using CitiManager to Manage Cardholders

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Federal Agencies

OMB Charge Card RequirementsRob Robbins

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Federal Agencies

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Thank you for attending!

Visit the Citibank Welcome Center– Level 3 Foyer – West– National Industries for the Blind will have a

display of products– Conference Slide Show – come see yourself

shine!

Visit the Citibank One-on-One Lab – Lido Room 3101 A/B

Visit the Citibank Mini Sessions – Lido Room 3001 A/B

Citi Q&A – Tell us your thoughts

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Reminders


Federal Agencies

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Schedules Available at the Welcome Center Federal Agencies


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Interactive Training Events – GSA


Citi offers Computer Based Training (CBT) via the Citi Commercial Card Learning and System Support (CLASS) in CitiManager.

Visit home.cards.citidirect.com and from the Web Tools Tab select the CLASS link

Please contact your Account or Client Manager if you are interested in setting up a training session. Training can be conducted at a Citi Training Location, On-site at your office or via the Web.

Regional Citi Training Locations– Norfolk, VA– Washington, DC

Federal Agencies

Terms & Disclosures

Tuesday, July 28, 2009

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IRS Circular 230 Disclosure: Citigroup Inc. and its affiliates do not provide tax or legal advice. Any discussion of tax matters in these materials (i) is not intended or written to be used, and cannot be used or relied upon, by you for the purpose of avoiding any tax penalties and (ii) may have been written in connection with the "promotion or marketing" of any transaction contemplated hereby ("Transaction"). Accordingly, you should seek advice based on your particular circumstances from an independent tax advisor.

Any terms set forth herein are intended for discussion purposes only and are subject to the final terms as set forth in separate definitive written agreements. This presentation is not a commitment to lend, syndicate a financing, underwrite or purchase securities, or commit capital nor does it obligate us to enter into such a commitment. Nor are we acting in any other capacity as a fiduciary to you. By accepting this presentation, subject to applicable law or regulation, you agree to keep confidential the existence of and proposed terms for any Transaction.

Prior to entering into any Transaction, you should determine, without reliance upon us or our affiliates, the economic risks and merits (and independently determine that you are able to assume these risks) as well as the legal, tax and accounting characterizations and consequences of any such Transaction. In this regard, by accepting this presentation, you acknowledge that (a) we are not in the business of providing (and you are not relying on us for) legal, tax or accounting advice, (b) there may be legal, tax or accounting risks associated with any Transaction, (c) you should receive (and rely on) separate and qualified legal, tax and accounting advice and (d) you should apprise senior management in your organization as to such legal, tax and accounting advice (and any risks associated with any Transaction) and our disclaimer as to these matters. By acceptance of these materials, you and we hereby agree that from the commencement of discussions with respect to any Transaction, and notwithstanding any other provision in this presentation, we hereby confirm that no participant in any Transaction shall be limited from disclosing the US tax treatment or US tax structure of such Transaction.

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Although this material may contain publicly available information about Citi corporate bond research, fixed income strategy or economic and market analysis, Citi policy (i) prohibits employees from offering, directly or indirectly, a favorable or negative research opinion or offering to change an opinion as consideration or inducement for the receipt of business or for compensation and (ii) prohibits analysts from being compensated for specific recommendations or views contained in research reports. So as to reduce the potential for conflicts of interest, as well as to reduce any appearance of conflicts of interest, Citi has enacted policies and procedures designed to limit communications between its investment banking and research personnel to specifically prescribed circumstances.

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omb charge card requirements - citigroup€¦ · 7. omb charge card requirements. omb circular...

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