oversight

Report 2012-008-PURC - Performance Audit of the Charge Card Program

Published by the Equal Employment Opportunity Commission, Office of Inspector General on 2013-03-26.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                              U.S. EQUAL EMPLOYMENT
                             OPPORTUNITY COMMISSION

                                        WASHINGTON, DC

                            PERFORMANCE AUDIT OF THE
                               CHARGE CARD PROGRAM

                                          MARCH 26, 2013




HARPER, RAINS, KNIGHT & COMPANY, P.A.
   CERTIFIED PUBLIC ACCOUNTANTS
       RIDGELAND, MISSISSIPPI
                                                    Prepared by Harper, Rains, Knight & Company, P.A.
                               For Equal Employment Opportunity Commission-Office of Inspector General

Table of Contents



Independent Auditors’ Report......................................................................................................2

Results in Brief ...............................................................................................................................2

Objective 1 — To determine whether internal controls are in place to detect and prevent
fraud, waste, abuse and misuse in the EEOC’s purchase card program. ................................4

Objective 2 — To evaluate the effectiveness of the processes and procedures over EEOC’s
purchase card program. Specifically, determine if procedures for issuing purchase
cards/convenience checks, monitoring the use of the purchase cards/convenience checks,
and providing training to employees having responsibilities for purchase cards/convenience
checks are adequate. ......................................................................................................................5

Objective 3 — To determine if the EEOC’s purchase card/convenience check program is
operating in compliance with laws and regulations. ...................................................................7

Recommendations ..........................................................................................................................7

Appendices ....................................................................................................................................10
   Appendix A ............................................................................................................................... 11
   Appendix B ............................................................................................................................... 13
   Appendix C ............................................................................................................................... 15
   Appendix D ............................................................................................................................... 16
Milton A. Mayo, Jr.
Inspector General
U.S. Equal Employment Opportunity Commission
131 M Street, NE
Washington, D.C. 20507

                                      Independent Auditors’ Report

We were engaged by the U.S. Equal Employment Opportunity Commission (“EEOC”), Office of
Inspector General (“OIG”), to conduct a performance audit of EEOC’s charge card program,
which includes both purchase and travel cards. EEOC uses purchase cards to reduce the
administrative cost of processing small dollar purchases and travel cards to reduce the cost of
official travel and for the convenience of the traveler.

Purchase and travel cards are at a high risk for misuse, fraud, waste, and abuse. Accordingly, if
the internal controls governing EEOC’s purchase and travel card programs are not sufficient,
properly designed, and fully implemented, EEOC will not be able to detect and prevent
fraudulent purchases or other improper uses and abuses of the cards.

Our audit objectives over the purchase and travel card programs were:

(1)    To determine whether internal controls are in place to detect and prevent fraud, waste,
       abuse and misuse in the EEOC’s purchase card program.

(2)    To evaluate the effectiveness of the processes and procedures over EEOC’s purchase card
       program. Specifically, determine if procedures for issuing purchase cards/convenience
       checks, monitoring the use of the purchase cards/convenience checks, and providing
       training to employees having responsibilities for purchase cards/convenience checks are
       adequate.

(3)    To determine if the EEOC’s purchase card/convenience check program is operating in
       compliance with laws and regulations.


                    Harper, Rains, Knight & Company, P.A. • Certified Public Accountants • Consultants
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                                          Prepared by Harper, Rains, Knight & Company, P.A.
                     For Equal Employment Opportunity Commission-Office of Inspector General

To perform our audit, we interviewed personnel at EEOC’s Central Services Division (CSD)
within the Office of the Chief Financial Officer (OCFO). We reviewed the existing EEOC charge
card policies and procedures, guidance issued by regulatory agencies, and charge card data
supplied EEOC’s third party service providers. We selected samples of the agency’s controls over
both the issuance and closing of purchase and travel cardholder accounts. We selected a statistical
sample of charge card activity made during fiscal years (FY) 2011 and 2012 to conduct control
and substantive tests over EEOC’s program. The audit work was completed in January 2013.

We conducted this performance audit in accordance with generally accepted government
auditing standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions
based on our audit objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives. Further background information
appears in Appendix A. Our complete scope, methodology, and criteria are contained in
Appendix B.

Results in Brief

EEOC has developed standard operating procedures (SOPs) for EEOC’s Government
Commercial Purchase Card and Government-wide Travel Card Programs on the proper use of
purchase and travel cards, however the version provided to us during our test period was out of
date and did not include any updates for the current accounting system in operation as of October
1, 2011. We did find that the SOPs were substantially compliant with OMB A-123, Appendix B;
however the documents did not address all requirements.

Our audit found deficiencies in key controls related to the charge card program, such as support
for issued cardholder accounts, account activation and closure support, approvals of transactions,
required training, charge card limits, and supporting documentation for transactions. These
violations of policies were generally unnoticed due to a lack of oversight and monitoring
procedures in place to ensure internal controls are operating effectively. HRK issued nine (9)
Statement of Fact (SOF) Memorandums to EEOC concerning the identified deficiencies and best
practices.

Though EEOC’s SOPs substantially comply with OMB A-123, Appendix B and other Federal
guidance, the identified deficiencies in the operating effectiveness of internal controls over
EEOC’s charge card programs suggest that significant steps be taken to ensure that controls are
operating effectively.

We recommended EEOC update their SOPs to the current operating environment and establish
oversight and monitoring controls to address identified weaknesses.

EEOC Response

EEOC generally concurred with our findings and stated it is taking actions to address the
effectiveness of the internal control environment over the charge card program.


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                                          Prepared by Harper, Rains, Knight & Company, P.A.
                     For Equal Employment Opportunity Commission-Office of Inspector General

EEOC’s responses are included in their entirety as Appendix D.

Auditor Conclusion

Management’s responses, once implemented, should strengthen the Agency’s control
environment over charge card activity and address the deficiencies identified in our performance
audit. However no audit procedures have been applied to management’s responses presented in
this report.




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                                         Prepared by Harper, Rains, Knight & Company, P.A.
                    For Equal Employment Opportunity Commission-Office of Inspector General

Results and Findings

Objective 1 — To determine whether internal controls are in place to detect and prevent
              fraud, waste, abuse and misuse in the EEOC’s purchase card program.

We found EEOC has standard operating procedures (SOPs) CSD-704 and 705 covering the
Government-wide Travel Card and Government Commercial Purchase Card programs,
respectively.

       Finding No.1 – Lack of internal controls in place to ensure policies and
       procedures over the charge card program are current and sufficient.

While we found EEOC to have SOPs, the documents provided were dated as of June 2011. On
October 1, 2011, EEOC moved from the Department of the Interior’s Business Center (IBC)
accounting system (Momentum) to Global Computer Enterprises’ (GCE) Financial Cloud
Solutions (FCS). While EEOC has updated their SOPs as of November 12, 2012, these updated
SOPs were never provided to the auditor and EEOC operated under the outdated SOPs for all of
FY 2012.

In addition, we found EEOC lacked the following OMB A-123, Appendix B requirements in
their SOPs:

   •   Timely payments of travel card payments and disciplinary actions for untimely payments.
   •   OMB Memorandum on Strategic Sourcing requirements.
   •   Certain requirements for convenience checks, such as 1) reconciliation of check register
       information to transaction data on statements and 2) procedures for cardholders and/or
       custodians of the property to follow when property is determined to be missing, stolen or
       damaged.

The lack of these OMB requirements, in and of themselves, does not indicate a lack of
compliance, however it does identify weakened policies and procedures to detect and prevent
fraud, waste, abuse and misuse.

       Finding No.2 – The internal controls over the operating effectiveness of EEOC
       charge card policies and procedures are not operating effectively.

We identified two key deficiencies in EEOC’s internal control over the operating effectiveness
of the charge card program: (1) heavy reliance on third party providers to implement and manage
the program with no oversight at EEOC; and (2) lack of monitoring of the controls identified in
the SOPs. During our testing, EEOC personnel were unable to provide support for issuance of
cardholder accounts, approvals of cardholder transactions, and documentation of required
training of active cardholders. EEOC personnel indicated this information is maintained solely
by its service providers. We could not find any evidence that EEOC monitors the cardholder
information for accuracy or completeness or that they have any oversight of activities conducted
by the service provider.

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                                          Prepared by Harper, Rains, Knight & Company, P.A.
                     For Equal Employment Opportunity Commission-Office of Inspector General


Objective 2 — To evaluate the effectiveness of the processes and procedures over EEOC’s
              purchase card program. Specifically, determine if procedures for issuing
              purchase cards/convenience checks, monitoring the use of the purchase
              cards/convenience checks, and providing training to employees having
              responsibilities for purchase cards/convenience checks are adequate.

       Finding No.3 – Non-compliance with required charge card training policy and
       procedures.

We tested the effectiveness of the documentation of training controls over new and existing
accounts by requesting supporting documentation supporting the timely completion of training.

For new accounts, we haphazardly selected a statistical sample 28 accounts out of a universe of
762 to test the documentation of the certification of completion of initial GSA SmartPay
Purchase Cardholder Training. EEOC could not provide us documentation evidencing the
completion of training for any of the cardholders selected.

For existing accounts we inquired with EEOC on how the refresher course training is tracked and
how they demonstrate the control over refresher course training is operating effectively. EEOC
provided us two memoranda from the OCFO to all non-responders, the first was dated March 5,
2012 requesting the training to be completed by April 2, 2012, and the second was dated October
11, 2012 requesting the training to be completed by November 10, 2012. The three-year
refresher course was originally to be completed during February and March of 2012. As of
November 7, 2012 of the 618 cardholders, 210 (34%) had not completed training.

       Finding No.4 – Non-compliance with account creation policies and procedures.

We tested the statistic sample of 28 cards activated in FY 2011 and FY 2012 for compliance with
cardholder account activation requirements indentified in EEOC SOPs CSD-704 and 705. Per
the SOPs, the activation packet should contain: the Citibank Government Purchase Card Setup
Form (Cardholder Application), certification of completion of GSA SmartPay Purchase
Cardholder Training, the Account Setup Form Completed by the Credit Card Purchase Manager,
the signed Delegation of Authority memorandum, and the signed Employee Acknowledgement
Form. Additionally, we requested and obtained a listing of the purchase authority delegated to
each of the cardholders in the sample to determine if the levels of credit are in line with EEOC
position and policies.

We found a significant lack of documentation to evidence the application packet policies and
procedures had been performed. Of the 28 samples, EEOC was unable to provide us any
documentation for 18 of the cardholders. EEOC was able to provide copies of the Cardholder
Application for the remaining 10 cardholders tested, however no other documentation was
provided for these 10 cardholders. We did not find any exceptions in the appropriateness of level
of credit for each cardholder.



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                                          Prepared by Harper, Rains, Knight & Company, P.A.
                     For Equal Employment Opportunity Commission-Office of Inspector General

       Finding No.5 – Lack of sufficient documentation evidencing transaction approval
       requirements.

We selected a statistical sample of 72 charge card transactions from FY 2011 and 2012. We
identified 46 instances of missing documentation to evidence the approval of an Authorizing
Official (AO) and 51 instances of missing evidence to support the availability of funds prior to
purchase.

       Finding No.6 – Lack of documentation to support a purchase card transaction.

We selected a statistical sample of 72 purchase and travel card transactions, consisting of 61
purchase card transactions and eleven travel card transactions. EEOC was not able to provide
any support for 17 of the purchase card transactions. These 17 purchase card transactions totaled
to $263,466.89 of the $510,688.12 sampled dollars.

       Finding No.7 – Non-compliance with cardholder account closure policies and
       procedures.

For account closures, we selected a statistical sample of 24 closures during FY 2011 and 2012.
EEOC was unable to provide documentation to evidence the controls over account closure for 17
of the accounts in our sample. EEOC was able to provide complete documentation the remaining
7 accounts.

In addition, we performed an analytical review of closed accounts to determine if there was any
charge card activity after the account was closed. We identified one account that was reported
closed as of June 26, 2012 where a cash advance in the amount of $1,875.75 and an associated
fee for $42.20 was recorded on August 2, 2012.

       Finding No.8 – Lack of monitoring controls in place over Merchant Category
       Codes (MCC).

We found that EEOC relies heavily on the Citibank standard Federal government MCC codes as
a primary control over the identification and prevention of fraud, waste, abuse, and misuse;
however, we found that EEOC does not regularly monitor the use of MCC nor has EEOC created
an agency-specific list to prevent improper purchases relevant to EEOC. We identified nine
allowable MCC codes ranging from Barber and Beauty Shops (MCC 7230) to Medical Services
Health Practitioners – Not Elsewhere Classified (MCC 8099), that have the potential for being
improper in the normal business activities of EEOC.

       Finding No.9 – Lack of monitoring controls in place over monthly spending
       limits.

We identified three instances of cardholders exceeding the monthly spending limit established by
EEOC. In July and September of 2011, one cardholder had monthly activity of $27,184.82 and
$59,146.46, respectively. In March of 2012, another cardholder had monthly activity of
$25,523.47. Both cardholders have monthly limits if $25,000.

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                                          Prepared by Harper, Rains, Knight & Company, P.A.
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Objective 3 — To determine if the EEOC’s purchase card/convenience check program is
              operating in compliance with laws and regulations.

OMB A-123, Appendix B Improving the Management of Government Charge Card Programs,
section 4.3 describes the responsibilities of management over the agency’s charge card program:

“The general responsibilities of charge card managers in implementing risk management
controls, policies and practices are:

   •   Implementing the appropriate controls to ensure compliance with Federal laws, Federal
       and agency regulations, and for monitoring program effectiveness;
   •   Ensuring that any risk management polices and practices established in the agency’s
       charge card management plan are carried out effectively and that the charge card
       management plan is updated with enhanced risk management policies and practices, as
       applicable.”

As reported under Objective 1, EEOC has implemented appropriate controls to ensure
compliance with Federal laws as well as Federal and agency regulations. However, we did
identify issues with the timeliness of updates to the SOPs. Our testing of operating effectiveness
reported in Objective 2, identified deficiencies in EEOC’s ability to provide oversight on the
effectiveness of these programs and to ensure policies and practices established in its charge card
SOPs are monitored and violations addressed.

Based on the findings identified above, EEOC’s purchase card/convenience check program is not
operating in compliance with OMB A-123, Appendix B established under the authority of 31
U.S.C. 1111, Executive Order 11541, the Chief Financial Officers Act of 1990 (P.L. 101-576)
and the Office of Federal Procurement Policy Act (41 U.S.C. Chapter 7).

Recommendations

We recommend that the Chief Financial Officer of the U.S. Equal Employment Opportunity
Commission:

1) Perform further analysis on its government charge card operations to identify all of the
   controls that should be implemented per OMB directives. This would include the
   identification of procedures performed utilizing the new accounting system (FCS) as well as
   current duties of personnel interacting with the system. Specifically, EEOC should:

   •   Meet with all process lead personnel to determine what controls are or should be in place
       to ensure that fraud, waste, abuse and misuse are not present in the charge card program;
   •   Identify all requirements in OMB Circular A-123, Appendix B and determine the
       procedures necessary to comply with the requirements; and
   •   Ensure policies and procedures are reviewed on an annual basis or more frequently if
       substantial changes have occurred in EEOC’s systems or laws and regulations have been
       issued to ensure that policies and procedures are appropriate for the current environment.
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2) Develop a system to either 1) identify and track all of its charge card activity, including open
   accounts, closed accounts, cardholder approver levels, and cardholder training; or 2) perform
   an evaluation of its service providers controls over the charge card program to ensure that
   controls are appropriate and operating effectively. Additionally, EEOC should monitor all of
   its controls, whether performed at EEOC or at a service provider at least annually to ensure
   that the controls remain adequate and continue to operate effectively.

3) Develop policies and procedures to identify and track all cardholder-required training.
   Documentation should be maintained following NARA requirements for cardholders who
   have successfully completed training requirements. For cardholders who have not
   successfully completed training requirements, EEOC should document notification(s) of the
   required training and all corrective actions taken against the cardholder, until the successful
   completion of training can be demonstrated.

4) Further develop its controls over the retention of application documents for charge card
   accounts. The Purchase Card Program Manager should maintain the documentation
   identified above for all account applications electronically or in hard copy. The policy or
   procedure should establish an appropriate period of time for retention of records.

5) Monitor its controls over transaction approval, whether performed at EEOC or at a service
   provider, at least annually to ensure that the controls remain adequate and continue to operate
   effectively.

6) Implement policies and procedures over record retention for purchase and travel card
   transactions. EEOC should monitor these controls at least annually to ensure that the controls
   remain adequate and continue to operate effectively.

7) Improve its controls over the closure of charge card accounts. The Purchase Card Program
   Manager should maintain documentation of all account closures electronically or in hard
   copy. Documentation should include evidence of the name of the DRM or A/OPC who
   received the employee’s charge card, the date the card was turned into the DRM or A/OPC ,
   the date the card was physically destroyed, and the date that account closure was confirmed
   by the Charge Card Vendor.

8) Develop and implement policies and procedures to require reviews of total cardholder
   activity to ensure compliance with monthly spending authority for all cardholders.
   Documentation of authority to exceed cardholders spending limits should be maintained by
   management. Penalties for exceeding authorized spending limits should be established and
   enforced.

9) Develop additional monitoring controls as a best practice. The Office of Management and
   Budget does not currently require these controls. EEOC should consider developing and
   implementing policies and procedures to use data mining to monitor charge cardholder
   activity. Data mining should target the nature and frequency of purchases and fees. Effective

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                                         Prepared by Harper, Rains, Knight & Company, P.A.
                    For Equal Employment Opportunity Commission-Office of Inspector General

   use of data mining techniques can help to prevent and identify improper purchases,
   unnecessary fees, split transactions, and progress of refund requests. This control would
   improve the agency’s ability to prevent and detect improper or unnecessary charges.

10) Consider supplementing the listing of disallowed merchant category codes used by its charge
    card vendor with additional disallowed codes based on EEOC’s policies on purchases and
    travel expenses.

We appreciate the cooperation and courtesies that EEOC personnel extended to us during this
audit.




Harper, Rains, Knight & Company, P.A.




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Appendices




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                                                                                     Appendix A

Background

A U.S. government purchase card is an internationally accepted credit card issued by individual
contractors and available to personnel in all federal agencies under a single General Services
Administration (GSA) contract. The purpose of Charge Card Programs is to minimize the
paperwork needed to make purchases with proper authorization.

Effective Charge Card Programs depend on the users having been properly trained to manage
their card use. Treasury Financial Manual, Vol.1, Part 4, Section 4525, requires each agency to
have its own internal procedures for using purchase cards, so cardholders must be made aware of
the applicable laws, regulations, and procedures developed by their agency. Management’s
understanding of internal controls is essential in ensuring accountability at all levels of charge
card use.

Charge cards allow the same individual to order, pay for, and receive goods and services.
Purchase and travel cards are at a high risk for misuse, fraud, waste, and abuse. Accordingly, if
the internal controls governing the Equal Employment Opportunity Commission’s (EEOC)
purchase and travel card programs are not sufficient, properly designed, and fully implemented,
EEOC will not be able to detect and prevent fraudulent purchases or other improper use of the
cards.

The Office of the Chief Financial Officer (OCFO) at EEOC has responsibility for overall
management of the commercial purchase card program. The OCFO has established policies and
procedures relating to the program which are contained in the EEOC’s Government-wide Travel
Card and Government Commercial Purchase Card programs standard operating procedures
(SOPs). Included in the user’s guide are responsibilities for individuals and EEOC offices,
guidance on authorized use of the purchase card, purchase limits, reconciliation and payments
and training requirements for those involved with the use of the agency’s purchase card.

Key roles within the EEOC’s purchase card program include the Charge Card Program Manager
(CCPM), Agency /Organization (A/OPC) Program Coordinator, Approving Officials (AO), and
Cardholders. The CCPM is responsible for the day to day oversight and administration of
purchase card operations within the agency. This includes establishing new purchase card
accounts, closing accounts, and increasing or decreasing purchase limits and monitoring
merchant category restrictions. AOs are usually the office director or supervisor designated to
approve purchase card transactions, monitor purchase card activity in an organization, and certify
the invoice for payment for the purchase card services. Each cardholder is assigned an approving
official who will review cardholder transactions to ensure that the purchases are valid and
allowable. Purchase cards reflect the cardholder’s name and may only be used by the named
employee. Cardholders may purchase supplies and services within their delegated procurement
authority. The purchase charge card is the primary method for making purchases valued up to
$3,000 for supplies, $2,500 or less for services and $2,000 for construction.


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Convenience checks are payment instruments drawn on the purchase card account. Convenience
checks may be written only to vendors who do not accept the purchase charge card, for
emergency incident response, and for other Commission approved purposes that comply with
Public Law 104-134, the Debt Collection Improvement Act of 1996.




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                                          Prepared by Harper, Rains, Knight & Company, P.A.
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                                                                                    Appendix B
Objective, Scope, Methodology, and Criteria

Objective
The audit objectives were as follows:

(1) To determine whether internal controls are in place to detect and prevent fraud, waste, abuse
    and misuse in the EEOC’s purchase card program.

(2) To evaluate the effectiveness of the processes and procedures over EEOC’s purchase card
    program. Specifically, determine if procedures for issuing purchase cards/convenience
    checks, monitoring the use of the purchase cards/convenience checks, and providing training
    to employees having responsibilities for purchase cards/convenience checks are adequate.

(3) To determine if the EEOC’s purchase card/convenience check program is operating in
    compliance with laws and regulations.

Scope
The scope of this audit covered testing of purchase card program transactions covering the fiscal
years (FY 2011-FY 2012). The audit was conducted in accordance with generally accepted
government auditing standards: the audit was planned to obtain sufficient, appropriate, evidence
to provide a reasonable basis for findings and conclusions based on the objectives.

Our performance audit was not designed to, and we did not, perform a financial audit of the
amounts obligated or expended by EEOC.

We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for findings and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.

Methodology
We conducted interviews and process walkthroughs with officials at EEOC’s Central Services
Division (CSD) within the OCFO organization, to understand the internal controls, processes,
systems, and procedures used to manage the agency’s charge card program. Our consideration of
internal controls relevant to our audit objectives would not necessarily disclose all matters that
might be significant deficiencies. Because of inherent limitations in internal controls,
noncompliance may nevertheless occur and not be detected.

We selected statistical samples of the agencies controls over the issuance of purchase and travel
accounts and closing of cardholder accounts at separation. Sample items were tested for
compliance with EEOC policies and procedures as well as compliance with the requirements of
OMB Circular A-123, Appendix B.


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                                          Prepared by Harper, Rains, Knight & Company, P.A.
                     For Equal Employment Opportunity Commission-Office of Inspector General

We selected a statistical sample of purchase and travel card transactions during FY 2011 and
2012. Testing performed over the sample included verification of: transaction support, transaction
approval, allowable MCC codes, evidence to support amounts were available prior to purchase,
appropriate purchases for government use, dispute of unauthorized charges, purchases were from
the required sources of supply and service, cardholder not splitting purchases, and balances paid
timely. Based upon these tests and assessments, we concluded the data was sufficiently reliable to
be used in meeting the objectives.

Criteria

We used the following to perform the audit:

•   GAO Government Auditing Standards, 2011 Revision
           o Chapter 7: Field Work Standards for Performance Audits
           o Chapter 8: Reporting Standards for Performance Audits
•   GAO Standards for Internal Control in the Federal Government, November 1999
•   OMB Circular A-123, Appendix B Improving the Management of Government Charge Card
    Programs, Revised January 15, 2009
•   Treasury Financial Manual, Vol.1, Part 4, Section 4525
•   31 U.S.C. §§ 3321, 3322, 3327, 3335, 3901
•   Public Law 112-194 “Government Charge Card Abuse Prevention Act of 2012”




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                                                                            Appendix C
Acronyms and Abbreviations

A/OPC          Agency/Organization Purchase Manager

CCPM           Charge Card Purchase Manager

CPA            Certified Public Accountant

CSD            Central Services Division

EEOC           Equal Employment Opportunity Commission

FY             Fiscal Year

GAGAS          Generally Accepted Government Auditing Standards

GAO            U.S. Government Accountability Office

GSA            General Services Administration

MCC            Merchant Category Code

OCFO           Office of Chief Financial Officer

OIG            Office of Inspector General

OMB            Office of Management and Budget

P.A.           Professional Association

U.S.C.         United States Code




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                                                                            Appendix D
Equal Employment Opportunity Commission Response




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