P-Card Program Update – Small Dollar Purchases

Change in State Law:

The Utah Legislature revised the Utah Procurement Code (laws affecting the University of Utah purchasing practices) during the past legislative session. Most of the changes become effective on May 1, 2013. The Purchasing Department is working jointly with the Board of Regents, Office of General Counsel and other schools in the state to ensure that new University Policies and Procedures and those of other state institutions of higher education conform to the new state law. We will be formally communicating these changes in procedure and policy to the campus during the coming months.

A number of changes to the code involve specific and detailed language with regard to how procurements are to be carried out by state entities. One of the areas addressed in more detail by the new code specifically addresses small dollar transactions, which include P-cards as well as other methods (Limited Purchase Orders, Payment Requests, Reimbursements, etc.).

The new law includes penalties for persons who knowingly and intentionally split small dollar transactions to circumvent bidding requirements. University Rule R3-100D prohibits spitting transactions and current state law prohibits this practice.

Special Audit of Potential Split Transactions:

The Purchasing Card program at the University actively audits all cardholders at least annually. In the past, a few cardholder violations have been identified where transactions were split into one or more payments to circumvent card limits resulting in cancellation of cards or other penalties.

The University is currently conducting an audit of all P-Card (and other small dollar) transactions for the past 18 months to ensure that this practice (splitting transactions that violate bid limits or card limits) is not occurring. As questions regarding potential violations are identified, cardholders and reconcilers may be contacted to resolve these issues. Most of these contacts will be via email and it is important that any potential questions raised by P-Card auditors are resolved in a timely manner.

If you have any questions or would like to discuss an apparent splitting of a transaction that you have discovered, please contact Glendon Mitchell, Associate Director of Purchasing at 801-587-3784 or Jane Scott, P-card Manager at 801-581-6622.

As a reminder, individuals with responsibility for the monthly review of P-card holder transactions are acknowledging that expenditures were incurred for official University business and were in accordance with University policies. Thank you for your continued appropriate use of this important procurement tool and please share this information with others in your department.

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