Reporting Non-Compliant Transactions
This section walks through how the university supports financial accountability. It starts with a look at how financial compliance is reviewed, then covers how to self-report PCard violations using the Self-Reporting Violations form. It also explains what happens when policy violations aren’t self-reported.
Financial Compliance Review
Compliance is everyone's job and must be a part of everyone's everyday work activities. The Financial Compliance works to ensure that university policy and procedure is followed, and when applicable, actions are taken for any non-compliant actions are detected. The team:
- Administers the PCard and Departmental Compliance Review.
- Consults with departments regarding business processes, best practices and compliance, and suggest process changes to increase operation efficiency and control of the PCard
- Reviews university responses and follow-up actions on compliance reviews
- Provides guidance and education on appropriate use of the university PCard.
- PCard monthly compliance review is detective control to ensure transactions follow university polices as well as ABOR, local, state and federal policies.
See Internal Control.
Monthly Review
Financial Compliance generates a file each month with a set number of transactions to review from the previous month.
All PCard transactions are included in the total population, which generates a statistically random sample that is not based on a single criterion such as dollar amount, department number, or vendor. It is compiled by the total population to reflect a sample that represents the whole as an internal control to evaluate risk.
- The review/follow-up process is set in place to give departments the opportunity to submit the information required by policy/procedures while training them on those policies. This is the initial step in ensuring that documentation is adequate, appropriate, and legitimate. It also assists in the case of an audit.
- An email is sent to the liaisons and fiscal officers, allowing them one week to respond.
- The department is responsible for providing answers and updating documentation based on the request; failure to respond leads to temporary or permanent suspension.
Self-Reporting
A Self-Report Violation form (whether overt or unintentional) must be completed when a cardholder, liaison, reconciler, or fiscal officer identifies a non-compliant transaction, such as:
- Using a PCard for any other purpose which is against university policy or
- Using a PCard for personal purchase
- Personal purchase, such as preferred seating, early bird check-in, optional charges (such as insurance) on rental vehicles, alcohol purchase, donations, gifts, tipping over 20% of the total bill, or any purchase without a valid University business purpose, etc.
- These expenses must always be reimbursed to the university. Please note that this list is not all-inclusive
- Reimbursement can be completed by creating a Cash Receipt showing the credit to the original Account and Object Code expense or similar proof if the deposit was auto posted.
- If the employee requests a payroll deduction, provide the amount. Reimbursements of $100 or more may be split over more than one pay period.
- If reimbursement to the university was not completed when the self-report violation form was sent to Financial Compliance, a payroll deduction will automatically be processed.
If there is a credit/refund from the vendor for the charges expended, please do not fill out a Self-Reporting Violation form. Instead, please cross-reference the transaction on both eDocs in UAccess Financials (i.e., the eDoc on which the original purchase was reported and the eDoc on which the refund is reported).
- A refund should only be requested from the vendor for a transaction that cannot be paid with university funds.
- Do not request a refund for a PCard transaction and then request that the expense be paid by another university payment mechanism; this will not cancel the violation.
The Self-Reporting Violation form can be completed in Concur by a delegate but must be submitted by the responsible cardholder.
- The user responsible is the individual for whom the charges are incurred.
A Self-Reporting Violation carries the same weight as a violation issued by Financial Compliance. Depending on the severity and number of violations, suspension or collection of the card may occur. Failure to self-report can lead to closing of the card and suspension of the PCard program for the violating department.
Non-Compliance Violation
Financial Compliance initiates a Notification of Financial Compliance PCard Violation based on non-compliance with university, ABOR, state, and/or federal policies.
Upon finding a transaction as being noncompliant, either by the department or by Financial Compliance, the violation will be processed and completed. The notification is sent to the cardholder, liaison, and fiscal officer for review.
- A Non-Compliance Notification does not require signatures or departmental approval.
- The cardholder can provide additional information or documentation for further review.
- The PCard is automatically suspended for three months.
- Self-reporting a transaction after Financial Compliance identifies a non-compliance transaction and requests clarification or informs the cardholder or department does not prevent the card from being suspended.