Change Number: 2022-1107
Effective Date: 11/07/2022

Chapter 1: The Government Purchase Card Program

1-1. Purpose

a. This document provides the procedures to be used within the Army to establish and manage the Army Government Purchase Card (GPC) program. Best practices are identified in Appendix A. Army activities may adopt more stringent internal control requirements than the requirements cited herein. However, as these are risk-managed programs, activities should maintain a proper balance between the control environment and ease of use to ensure that the benefits of the card continue to accrue. These procedures establish Army-wide standards designed to provide all Army activities with a foundation upon which to build specific standard operating procedures governing their programs.

b. Nonappropriated activities implement policies and procedures governing the Army’s morale, welfare, and recreation programs and general policies on Nonappropriated Fund Instrumentalities (NAFI). Chaplaincy activities implement policies and procedures governing Army Chaplain Corps activities. Army NAFIs/entities must operate within the parameters of these procedures.

1-2. Glossary

Acronyms and special terms are in the Glossary, Appendix J.

1-3. Background

The General Services Administration (GSA) awarded a multiple award schedule contract for U.S. Government commercial purchase card services. The contractor (hereinafter referred to as the “Servicing Bank”) provides commercial GPCs and associated services. The Army issues a task order to the servicing bank for its GPC services.

1-4. References

a. Federal Acquisition Regulation (FAR), Part 13 “Simplified Acquisition Procedures”

b. Defense Federal Acquisition Regulation Supplement (DFARS), Part 213.301 “Government-wide commercial purchase card”

c. Army Federal Acquisition Regulation Supplement (AFARS), Part 5113.2 “Simplified Acquisition Procedures”

d. Treasury Financial Manual, - Vol. I, Part 4, Ch. 4500, “Government Purchase Cards”

e. Department of Defense (DOD) Financial Management Regulation (FMR) Vol. 10, Ch. 23, “Purchase Card Payments”

f. DOD FMR Vol. 10, Ch. 23, Annex 1, “Purchase Card Certification Statements”

g. DOD FMR Vol. 10, Ch. 2, “Discount Offers and Rebates/Refunds”

h. DOD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs (DOD Guidebook)

i. OMB Circular No. A-123, Appendix B Revised

1-5. GPC Authority

a. The Chief of the Contracting Office (CCO) shall delegate micro-purchase procurement authority to individuals at the lowest level in accordance with FAR Part 1-603-3(b). This authority may be redelegated in writing to the Level 3 or 4 Agency/Organization Program Coordinator (A/OPC). Sample appointment letters are located at Appendix F.

b. Orientation and training on the Army purchase card program is a prerequisite to receiving a GPC.

c. Generally, only government employees can be cardholders. However, a number of exceptions apply:

(1) Under certain conditions, GSA can authorize contractors to establish cards directly with the issuing bank, if necessary. (DOD Guidebook page A-1). Requests for GPC by contractors working under cost type contracts shall be forwarded to the Army contracting officer for the cost-reimbursable contract. If the contracting officer determines that the contractors are eligible, the contractors must file a Request for Eligibility Determination with the GSA SmartPay contracting officer. (AFARS 5113.202-90(b)).

(2) Foreign nationals may be designated as accountable officials - Billing Officials (BOs) and Cardholders (CHs) provided they are direct hires, even though they may not be subject to pecuniary liability under U.S. law. Given the above, purchase cards may be issued to foreign national employees of the Army if they meet accountable official requirements (nomination and training). They are subject to the same disciplinary actions for card misuse as U.S. citizen employees, subject to host country agreements and local law. (DOD Guidebook page A-1 and DOD FMR Volume 5, Chapter 33, paragraph 330204)

(3) Junior Reserve Officer Training Corps (JROTC) Instructors are members of the Armed Forces in accordance with AR 145-2, paragraph 4-3, and may be designated micro-purchase procurement authority as GPC cardholders. (FAR Part 1-603-3(b))

d. Army cardholders who are ordering officers may be authorized to use the GPC as a payment instrument for orders made against Federal Supply Schedule contracts (FSS), Blanket Purchase Agreements (BPAs), DOD Indefinite Delivery/Indefinite Quantity (IDIQ) contracts that contain a provision authorizing payment by purchase card, or other contracts when authorized by the contracting officer.

e. The GPC may provide a streamlined way of paying for contracts and other contracts than those listed above, but a contracting officer shall first determine that use of the GPC is in the best interest of the government (AFARS 5113.202-90(d)). See FAR Subpart 32.1110(d) and 32.1108 for instructions for use of the appropriate clause when payment under a written contract is made through use of the card. If payment under a written contract is made by the GPC, then the contracting officer shall insert the FAR clause 52.232-36, Payment by Third Party, in solicitations and contracts. Payment by a purchase card may also be made under a contract that does not contain the clause at 52.232-36, to the extent the contractor agrees to accept that method of payment. When the clause at 52.232-36 is included in a solicitation or contract, the contracting officer shall also insert the clause at 52.232-33, Payment by Electronic Funds Transfer—Central Contractor Registration, or 52.232-34, Payment by Electronic Funds Transfer—Other Than Central Contractor Registration, as appropriate.

f. The maximum single transaction dollar limit for the GPC for stand-alone purchases shall be the micro-purchase threshold as defined at FAR 2.101, DFARS 213.301(2) and AFARS 5113.270-90. The maximum single transaction dollar limit for contract payments against existing contracts shall be as identified in the contract and shall be within the limits defined in the CH written Delegation of Authority letter or the contracting officer’s warrant. In the event of an emergency need for contingency or humanitarian aid operations, the Executive Office of the President may sign into law an emergency procurement authority allowing increased GPC and convenience check limits and revised procedures in support of contingency and humanitarian aid operations. In such circumstances, the Director of Defense Procurement and Acquisition Policy also may authorize class deviations to allow organizations to deviate from the FAR and DFARS. Such deviations may include raising GPC spending limits. These contingency/emergency purchases require separate training and Delegation of Authority by the A/OPC on contingency/emergency procedures and authority must be issued/granted by the Chief of Contracting or other authorized person.

g. The GPC shall be used to pay for government-owned material or government-performed services received from other government sources (e.g. Defense Logistics Agency Document Services, GSA Global, and Defense Logistics Agency).

h. The GPC shall be used as a method of payment for all commercial training $25,000 and below. The Standard Form (SF) 182 must be completed for training up to $25,000. If training costs exceed $25,000, submit the training requirement to your local contracting office. A separate and dedicated training GPC card must be issued and used to purchase training. These GPC training cards are only used to purchase training requirements.

i.Where it is identified that the purchase is processed via a third party merchant (such as PayPal), the CH should make every attempt to choose another merchant with whom to procure the goods and/or services. If found necessary to procure using a third party payment merchant, the BO must ensure adequate supporting documentation showing that there was a detailed review of the purchase and that the use of the third party payment merchant was unavoidable.

1-6. Applicability

These procedures apply to all GPC purchases with cards issued by the Army. Non-Army tenant organizations issued Army GPCs or convenience checks by an Army contracting office are also subject to these procedures. All BOs, CHs, A/OPCs (at all levels), Resource Managers (RMs), Logisticians, and other stakeholders that participate in the GSA SmartPay Purchase Card Program under the Army Level 2 hierarchy are subject to these procedures. The policy established in this document supersedes previous guidance issued in the Draft Army Regulation (AR715-xx). Explanation of the Army level hierarchy is provided at 1-8.

1-7. Program Organization, Roles and Responsibilities

The general roles and responsibilities of the participants in the purchase card program are presented in the references listed in paragraph 1-4 and the following: AFARS 5113.201, Chapter 2 and Appendix A of the DOD Government Charge Card Guidebook; Volume 1, Part 4, Chapter 4500 of the Treasury Financial Manual; Office of Management and Budget (OMB) Circular 123, Appendix B Revised, Chapters 4.3, 4.4, and 4.8; 31 U.S.C. §3528 “Responsibilities and Relief from Liability of Certifying Officials; DOD Financial Management Regulation (DOD FMR) Volume 5, Chapter 33 “Departmental Accountable Officials, Certifying Officers and Review Officials”, and DOD FMR Volume 10, Chapter 23, paragraph 2303 and 2304.

a. Level 2 – A/OPC duties:

(1) administering the Army GPC Program;

(2) establishing policies and guidelines;

(3) designing and maintaining hierarchies and approving subordinate A/OPCs;

(4) ensuring effective surveillance within the ACOMs, Army Service Component Commands, Direct Reporting Unit;

(5) serving as a liaison with Army organizations, the Servicing Bank, the PCPMO, and GSA; and,

(6) managing and implementing technical enhancements (developing, testing and deployment of GPC hardware/software/networking systems enhancements).

b. Level 3 – A/OPC duties: Alternate Level 3 A/OPC duties are the same as the Primary Level 3 A/OPC.

(1) implementing, administering, and monitoring the ACOM GPC program subject to DOD and Army policies;

(2) serving as a liaison with Army Headquarters, the Servicing Bank, ACOM staff, and field organizations;

(3) keeping Level 2 A/OPC apprised of GPC Program trends and issues as they arise;

(4) providing program support to ACOM and installation Level 4 A/OPCs;

(5) establishing and implementing ACOM-specific policy and guidelines;

(6) disseminating GPC Program-related information to Level 4 A/OPCs

(7) developing and writing GPC program internal control requirements, reporting mechanisms and surveillance plan.

(8) participating in GPC programs meetings sponsored by US Bank and Headquarters;

(9) tracking training requirements for Level 4 A/OPCs (see section 2-2);

(10) ensuring all Level 4 A/OPCs and Alternates hold appointment letters

(11) leading systems implementation at Command level;

(12) maintaining GPC Program documentation: Level 4 A/OPC training records, appointment letters, certifications, etc.;

(13) ensuring all Level 4 A/OPCs meet education, training and certifications requirements (see Section 1-8(b));

(14) coordinating GPC program changes with Level 2 A/OPC, including hierarchy changes, Level 3 appointments, etc.;

(15) responding to all data calls timely and with concise, current data;

(16) overseeing Level 4 A/OPC program controls, including BO account reviews, semi-annual surveillance, etc; and,

(17) Manage agent numbers: periodically assess the ongoing need for agent numbers.

c. Level 4 - A/OPC duties: Alternate Level 4 A/OPC duties are the same as the Primary Level 4 A/OPC.

(1) managing the day-to-day operation of the GPC Program at the installation/organization;

(2) assisting CHs and BOs in fulfilling their responsibilities;

(3) ensuring local agency training is provided to CHs and BOs via an appropriate training method (i.e. classroom, VTC, electronic, etc.) prior to participation in the GPC program;

(4) ensuring installation-specific training is provided to CHs on property accountability procedures (in coordination with local Property Book Officers);

(5) ensuring an alternate billing official is in place;

(6) oversight responsibilities that may not be redelegated (e.g. annually reviewing BO and CH accounts, span of control);

(7) maintaining delegation of authority appointment letters and a current listing of all CHs and BOs under the Level 4 A/OPC’s jurisdiction;

(8) determining annually each CH’s continuing need to maintain an account;

(9) issuing purchase cards in controlled limited quantities to authorized personnel with a demonstrated need to make purchases when reasonably necessary to meet operational requirements;

(10) cancelling accounts with no activity for six months; or

a) set the single purchase limit to $1 in the event of unauthorized activity/fraud on the account.

b) receive justification in writing when individuals are deployed or other authorized absence for six months or longer;

c) receive justification in writing from BOs when accounts that have little activity must remain open in the event of an emergency service outage, emergency repair, contingency, etc.

(11) developing and implementing local procedures to identify and make CHs aware of unauthorized and prohibited items from purchase with the GPC;

(12) ensuring completion of the following training for all CHs and BOs (see Section 2-2 for training links);

a) mandatory Defense Acquisition University (DAU) initial GPC training

b) local specific agency training through any authorized training method deemed appropriate by the activity

c) mandatory refresher training every two years

d) mandatory annual ethics training

e) U.S. Bank Access Online web based training

(13) maintaining training records including a database of all completed training;

(14) monitoring bank transaction reports to disclose potential prohibited or improper use, and taking immediate action to address suspected legal or policy violations;

(15) monitoring bank transaction declination reports to identify potential fraud activity;

(16) conducting an annual review of each assigned BO’s records and procedures ensuring a minimum representative sample size review of 25% of all transactions;

(17) reviewing transactions and buying logs within four months of newly appointed CHs; and,

(18) processing requests for user identifications and passwords for the Servicing Bank’s Electronic Access System (EAS).

d. Level 5 Billing Official duties: Alternate BO duties are the same as the Primary BO, and should only be performed in the absence of the Primary BO.

(1) BO should be in the CH’s direct chain of command;

(2) providing written approval/disapproval of purchases to the CH;

(3) reconciling invoices and timely certifying the billing statement for payment and verifying payments to be legal, proper, necessary, and correct in accordance with government rules and regulations;

(4) ensuring CHs fulfill their responsibilities by conducting an annual review of all CHs:

(5) reporting questionable transactions to the Level 4 A/OPC and/or appropriate authorities for investigation;

(6) recommending in writing appropriate GPC credit limits to the Resource Manager and Level 4 A/OPC for CHs under the BO’s oversight;

(7) reviewing CH’s statement and approving CH statement in the CH’s absence within the required time frames;

(8) identifying and communicating billing discrepancies to the bank’s transaction dispute point of contact when the CH is unavailable - for Access Online users;

(9) retaining an electronic (printable) or manual copy of each billing statement, and maintaining with the billing statement all original supporting documentation, receipts, logs, invoices, delivery tickets, approvals, etc. for six years and three months after final payment;

(10) reviewing and reconciling CH statements against receipts and documentation;

(11) notifying the Level 4 A/OPC (in most cases 30 days prior to the event) to close any CH accounts for individuals who have transferred, terminated, are in “absent without leave” status, retired or have otherwise no further need for use of the GPC;

(12) notifying the Level 4 A/OPC of any lost, stolen or compromised cards (in addition to the CH’s immediate notification of the Servicing Bank) and submitting a report to the Level 4 A/OPC within five business days to detail the circumstances of the lost, stolen or compromised card;

(13) resolving any questionable purchases with the CH;

(14) certifying billing statements electronically within 5 business days for electronic data interchange (EDI) enabled accounts for Access Online users, and forward the official invoice to the Paying Office for payment in the case of manually paid accounts within 15 days of receipt;

(15) ensuring designation of the proper line of accounting;

(16) ensuring an Alternate BO is appointed;

(17) notifying the Level 4 A/OPC to terminate or reassign a BO account to a new BO prior to the BO’s reassignment to other duties and/or departure from the installation/activity;

(18) ensuring adequate funding exists prior to approving the purchase;

(19) working with the bank to resolve payment issues; and,

(20) performing an annual review of CH files using the checklist in Appendix D, Section 2 (separate review from the mandatory annual A/OPC review of BOs)

e. Level 6 C ard holder duties:

(1) making authorized purchases;

(2) collecting and maintaining the required documentation;

(3) maintaining files and records;

(4) rotating merchants when practicable;

(5) verifying independent receipt and acceptance of goods and services;

(6) verifying the establishment of the legitimate government need;

(7) complying with required sources:

(a) FAR Part 8 and DFARS 208 Required Sources of Supply/Service

(b) Utilize mandatory BPAs to purchase office supplies

(c) Utilize CHESS for IT hardware and software purchases;

(d) Section 508 of the Rehabilitation Act of 1973, as amended (29 U.S.C. §794d)

(e) Environmentally Preferable Purchasing (EPP). FAR Part 23.

(8) obtaining all required pre-purchase approvals in support of requirements;

(9) Screen all requirements for their availability from the mandatory Government sources of supply (i.e. Office Supplies - FSSI BPAs on Army Corridor of DOD EMALL);

(10) verifying receipt/acceptance of purchased goods or services received including tracking of partial shipments and components that must be received within the dispute window;

(11) reviewing and reconciling monthly statements;

(12) resolving unauthorized, erroneous, or questionable transactions with merchants;

(13) disputing questionable transactions and disputing with the merchant any unresolved transaction for which a charge occurred during the prior billing cycle(s) but the item(s) have not been received, and tracking the dispute to completion;

(14) notifying the BO of unusual/questionable requests and disputable transactions;

(15) maintaining physical security of the GPC (and convenience checks) to avoid unauthorized use, allow no one but the CH to use the GPC, and do not release the GPC account number to entities other than a merchant processing a transaction;

(16) notifying the BO of a lost, stolen, or compromised GPC within one business day so the BO can meet the requirement to submit a report to the Level 4 A/OPC within five business days;

(17) maintaining the Servicing Bank’s electronic access system (EAS) purchase log throughout the billing cycle, reconciling all transactions, and approving the statement of account within three business days of the end of the billing cycle;

(18) maintaining a manual purchase log if the electronic purchase log is not accessible;

(19) ensuring adequate funding is available prior to the purchase;

(20) properly allocating the transactions to the proper line of accounting;

(21) checking with the Property Book Officer to determine what is considered pilferable property to be recorded in the property control systems records or which items can be placed on a hand receipt;

(22) ensuring all pilferable and other vulnerable property receipts are provided to the supporting Property Book Officer (PBO) within five working days to enable the PBO to establish accountability and asset-safeguarding controls by recording the asset in the property control system records;

(23) notifying the BO prior to departure, when you are on leave or travel and are not available to promptly sign and forward the CH statement of account. Forward all sales receipts and credit vouchers to the BO; and,

(24) providing to the BO upon departure the disposition of CH records and transfer all CH records to the BO with all statements, supporting documentation, receipts, logs.

f. Resource Managers (RMs) fund GPC purchases using the General Fund Enterprise Business System (GFEBS), and in the case of organizations on legacy systems, continue to use the “bulk” method in lieu of creating and citing unique accounting classifications for each individual GPC purchase. The bulk funding method requires a periodic (monthly, bimonthly, quarterly, or annually) fund reservation, through obligation, equal to the anticipated purchases for that period. Bulk funds may be assigned as a single line of accounting to each CH account to cover anticipated GPC purchases for a specified period. The Resource Manager’s duties:

(1) Provide a system of positive funds control by coordinating credit and cycle limits with the BO and Level 4 A/OPC;

(2) establishing funding for each account, at either the CH or BO level; non-applicable to U.S. Army Corps of Engineers;

(3) assisting the Level 4 A/OPC in establishing and maintaining BO and CH accounts in the Servicing Bank’s EAS; non-applicable to U.S. Army Corps of Engineers;

(4) assigning default and alternate lines of accounting as appropriate;

(5) ensuring obligations are posted prior to invoicing for non-EDI accounts;

(6) assisting with resolving accounts that are in a delinquent status and providing payment information when requested;

(7) assisting the Level 4 A/OPC with the surveillance of assigned accounts;

(8) monitoring GFEBS daily to identify account payment issues to prevent and resolve GPC payment delinquencies, correct Intermediate Document (IDOC) errors, and provide payment information upon request; and,

(9) providing guidance and training to installation RMs, certifying officials, and cardholders on GFEBS processes.

g. Defense Finance and Accounting Service (DFAS) duties:

(1) maintaining the DD Form 577 for certifying officials;

(2) receiving and processing EDI transaction sets 821, Obligation Files; and 810, invoice files, and notifying the responsible installation or activity when the corresponding files are not received;

(3) notifying the installation/activity, within one day, of rejects and interest penalties assessed to individual accounts (confirm-does this happen);

(4) receiving and processing requests for manual payments; for example, bank system rejects and non-EDI accounts; and,

(5) assisting in resolving GPC payment issues.

h. Property Book Officer duties:

(1) Ensuring established property control and accountability procedures are developed and disseminated to all personnel who are entrusted with the acquisition of Army property and equipment;

(2) Assisting the A/OPC in review of the purchase card account to ensure that property accountability procedures are being followed;

(3) Compliance with accountability procedures in AR 710-2, AR 735-5;

(4) Promptly record in agency property systems, sensitive and pilferable property purchased with the GPC; and,

(5) Determining the accounting requirements for the GPC purchased property, such as nonexpendable or controlled (requires property to be accounted for on property book records), durable (requires control when issued to the user) and expendable (no requirement to account for on property book records).

1-8. Management of the GPC Program

a. Responsibility for the establishment and operation of an agency’s GPC program is delegated to the agency’s Senior Contracting Official (SCO). The SCO, or in activities that do not have a SCO, the Chief of the Contracting Office (CCO), designates a Level 3 A/OPC and an alternate(s) who once appointed is dedicated to the GPC Program within their agency/organization.

b. The SCO or CCO forwards the Level 3 A/OPC Appointment Letter to the Level 2 A/OPC using the template found at Appendix F. The letter delegates responsibility for managing the agency GPC program and details responsibilities, training and certification requirements, and grade level preferences for the Level 3 A/OPC role. The Level 2 A/OPC reviews the nomination and ensures the Level 3 A/OPC meets all requirements of the position. Once approved, the Level 2 A/OPC provides written endorsement and coordinates Level 3 A/OPC appointment with the servicing bank. The Level 2 A/OPC is the final approval authority for agency Level 3 A/OPC appointments.

c. SCOs must ensure adequate resources are dedicated to the GPC program within their agency/organization to ensure successful management of the program. Adequate GPC resources refer to an agency’s efficient and effective deployment of assets (such as number of personnel, training, funding, facilities, knowledge and skills, etc.) when and where needed to meet agency requirements in compliance with the laws and regulations governing the GPC Program. Adequate resources must be deployed to reasonably ensure that programs achieve their intended results; resources are used consistent with agency mission; programs and resources are protected from fraud, waste, and mismanagement; laws and regulations are followed; and reliable and timely information is obtained, maintained, reported and used for decision making.

d. Individuals meeting the following criteria may be appointed as Level 3 or 4 A/OPCs for the GPC Program; GPC knowledge, training, and experience, basic contracting knowledge and/or acquisition training. The Defense Acquisition Workforce Improvement Act (DAWIA) requires the Department of Defense to establish education and training standards, requirements, and courses for the civilian and military workforce. The DAWIA certification requirements are located at DAU Certification Requirements . DAWIA contracting or purchasing certification includes a training, education, and experience requirement. The Army requires Level 3 and Level 4 A/OPCs to be DAWIA Level II certified in contracting. A/OPCs that are not DAWIA Level 2 certified in contracting must either complete the DAWIA Level 2 contracting training requirement within 24 months or achieve DAWIA Level 2 certification in purchasing within 24 months of being assigned to the Level 3 or Level 4 A/OPC position. This requirement is effective immediately upon appointment of all A/OPCs. Although the Level 3 A/OPC position typically warrants a minimum equivalent grade of GS-13 or higher, the grade depends on the responsibilities, complexity, and volume of the program. In addition to certification requirements, Level 3 and 4 A/OPCs are required to have completed the training requirements detailed in Section 2-2.

e. The SCO management responsibility authority for the GPC Program is further delegated to the CCO. The CCO must ensure adequate resources are dedicated to the GPC program within their installation/activity to allow effective administration of the program. The CCO coordinates with the local personnel office(s) to ensure procedures are established requiring individuals involved in the GPC Program to clear through the Level 4 A/OPC when they out-process from the installation. The Level 4 A/OPC is appointed at a sufficient grade/rank to exercise their authority depending on the responsibilities, complexity, and volume of the program. Only individuals who meet the criteria in paragraphs 1-8(d) may be appointed as A/OPCs for the GPC Program.

a. The Level 3 and 4 A/OPCs must have the following knowledge, skills, and abilities:

(1) understanding of the relevant policies, procedures, and commercial contracting practices;

(2) understanding of the relevant procurement laws and regulations;

(3) understanding of what constitutes and authorized purchase transaction;

(4) understanding of procurement methods and standards;

(5) ability to communicate, organize, and manage effectively;

(6) basic analytical and computer skills;

(7) ability to summarize data, draft reports and write effectively using proper grammar, punctuation, and tone;

(8) ability to analyze, research, and provide concise recommendations to the chain of command on required actions to anticipate, prevent, or correct problems in business processes that are supported by the GPC.