oversight

Cash Management: Benefits and Limitations of the Small Purchases Credit Card Program

Published by the Government Accountability Office on 1990-09-11.

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

                   United States General Accounting Office

GAO                Briefing Report to the Chairman,
                   Subcommittee on Treasury, Postal
                   Service, and General Government,
                   House Committee on Appropriations

September 1990
                   CASH
                   MANAGEMENT

                   Benefits and
                   Limitations of the
                   Small Purchases Credit
                   Card Program




GAO/AFMD-90-89BR
      I'nited States
aAO   (ieneral Aceountinft Offlce
      WaHhinttton, D.C. 20MH

      Accountlnit and Finiineial
      Manageinent Divialofl


      B-238531

      September 11,1990

      The Honorable Edward R. Roybal
      Chaitman, Subconmittee on Treasury,
        Postal Service, and General
        Government
      Committee on Appropriations
      House of Representatives

      Dear Mr, Chairman:

      In response to your request in House Report 101-170, dated
      July 25, 1989, that we study the difficulties surrounding
      the government's use of credit cards, we are providing the
      results of our review of the small purchases credit card
      program. This report covers the information we presented
      to your office in our May 10, 1990, briefing and, along
      with our earlier report entitled, Cash Management; Diners
      Club Business Travel Management Program Needs Improvement
      (GAO/AFMD-90-66, April 30, 1990), completes our work in
      response to your request.

      RESULTS IN BRIEF

      The small purchases credit card program can help agencies
      improve the efficiency of their purchasing and payment
      processes. However, the amount of any administrative
      savings that have resulted from the credit card program Is
      not known because most agencies have not conducted an
      analysis comparing the cost of using the credit card to the
      cost of other purchasing and payment methods.
      Although the small purchases credit card program includes
      internal controls that should prevent the credit card from
      being misused, four of the seven agencies in our review had
      some problems with the implementation of these controls.
      These agencies, however, are currently taking or planning
      corrective action to resolve the problems.
                                                       •i'^'-^v ,•::•;" y/z^fv^w^-m^"'^''''^




                 B-238531



                 BACKGROUND

                 The Depactnent of Commerce started using the small
                 purchases credit card under a pilot project in 1986. Under
                 the pilot project, the Colorado National Bank, through its
                 Bubsidiacy, the Rocky Hountain BankCard System (Rocky
                 Hountain), provided MasterCard credit cards to federal
                 agencies to make small purchases. Organizational entities
                 within 24 federal agencies participated in the pilot
                 project* In Harch 1989, the General Services
                 Administration (GSA), the central agency responsible for
                 managing govemmentwide contracts, awarded a contract to
                 Rocky Hountain for a govemmentwide program using VISA
                 credit cards for small purchases. For the most part,
                 agencies that participated in the Commerce pilot project
                 did not start using the GSA contract until after
                 September 29, 1989, when the Commerce pilot project
                 expired. From October 1989 through March 1990, agencies
                 spent $21 million under the GSA contract.

                 The small purchases credit card, also known as the
                 International Merchant purchase Authorization Card, has a
                 government seal and is embossed with the words, "US GOVT
                 TAX EXEMPT." parcicipating agencies assign the credit card
                 to selected personnel to make purchases such as office and
                 computer supplies and equipment for work at remote
                 locations. The credit card can be used for purchases up co
                 $25,000i but the average purchase with the credit card
                 during the first year of the GSA contract was $199.

                 The government does not pay vendors directly for purchases
                 made with the credit card. Instead, vendors get paid
                 through the credit card network generally within 48 hours
                 of a purchase, and agencies receive a consolidated bill
                 each month from Rocky Mountain. As of February 1990, 30
                 federal departments and agencies were participating in the
                 program under the GSA contract. Additional background
                 information on the small purchases credit card program is
                 contained in appendix I.

                 OBJECTIVES, SCOPE, AMD METHODOLOGY
                 We undertook this review in January 1989 to examine a new
                 cash management tool for purchasing and paying for small
                 items—the small purchases credit card. The objectives of
                 our review were to determine (1) the benefits, limitations,
                 and costs of the small purchases credit card program and



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           B-238531



           (2) whether agencies are implementing the internal controls
           established for the program*

           We selected seven agencies for our review to represent a
           range of sizes of small purchases credit card programs*
           Theae agencies were the Environmental Protection Agency;
           the Department of Houaing and Urban Development; the
           Department of the Treasury's Bureau of Alcohol, Tobacco,
           and Firearms and Internal Revenue Service; the Department
           of Health and Human Service's Social Security
           Administration; the Department of Transportation's Coast
           Guard Ninth District; and the 89th Military Airlift wing of
           the United States Air Force.

           We interviewed officials about their views of the program
           and reviewed agency internal guidance for the program,
           other relevant documents, and a sample of monthly
           cardholder statements. We conducted our work from
           January 1989 to July 1990. Our work was performed in
           accordance with generally accepted government auditing
           standards. The views of responsible agency officials were
           sought during the course of our work and are incorporated
           where appropriate. Additional details on our objectives,
           scope, and methodology are contained in appendix II,

           PROGRAM BENEFITS, LIMITATIONS, AND INTERNAL CONTROLS

           The agencies in our review were generally satisfied with
           the small purchases credit card program because it has
           enabled them to reduce the paperwork needed to make
           purchases and expedite the procurement process. The
           program also reduces the number of invoices agencies
           receive and must process for payment. However, some of
           these efficiency improvements can be offset by the time
           required by finance offices to obtain individual cardholder
           statements to use in verifying the agencies' consolidated
           credit card invoice.

           Agency officials we interviewed were generally dissatisfied
           with the administrative fee agencies must pay for using the
           small purchases credit card. This fee, however, will
           decline substantially as more agencies participate in the
           program and total government purchases with the card
           erceed $50 million. More details on the benefits and
           limitations of the program are included in appendix III.

           The Department of the Treasury instructs agencies to report
           the administrative savings that result from using cash




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B--238531



management initiatives, including the small purchases
credit card program. However, it has not instructed
agencies to conduct the type of analyses that would enable
them to develop reliable estimates of the savings from
using the credit card. As a result, agencies have reported
savings figures to Treasury that may be inaccurate. The
data on savings under the program are further discussed in
appendix IV.

Four of the seven agencies in our review had various
weaknesses in their implementation of the internal controls
over the small purchases credit card program. For example,
our review showed that, as of December 1989, the Internal
Revenue Service (IRS) headquarters did not have adequate
internal controls over $392,000 (94 percent) of the
$418,000 in credit card purchases raade during fiscal years
1988 and 1989. At IRS, we found that (1) cardholders did
not routinely verify their monthly credit card statements
and document their purchases with receipts and
(2) approving officials did not routinely review the
cardholders* statements. When these internal control
procedures are not followed, an agency has no assurance
that its cardholders' purchases were for authorized
purposes or that it received the iteras on its credit card
invoice. Internal control problems at the other three
agencies included missing documentation of purchases by
cardholders and lack of approving otticial review of
statements. These agencies are currently taking or
planning corrective actions to resolve the problems.
Appendix V contains additional details on the internal
control problems we identified.

RECOMMENDATION

In order to accurately assess the savings associated with
using the small purchases credit card prograia, we reoommend
that the Secretary of the Treasury revise the instructions
to agencies for reporting savings from the small purchases
credit card program. These instructions should require
that agencies calculate their savings estimates based on
their costs for using the small purchases credit card
versus other procurement and payment methods, covering the
entire procurement and payment process.



Aa agreed with your office, unless you publicly announce
its contents earlier, we plan no further distribution of
B-238531


this report until 10 days from the date of this letter. At
that time we will send copies to the Director of the Office
of Management and Budget, the Secretary of the Treasury,
the Administrator of the General Services Administration,
and the heads of the agencies where we conducted our work.
We will also make copies available to others upon request.
Please contact me at (202) 275-9454 if you or your staff
have any questions. Major contributors to this briefing
report are listed in appendix VI.

Sincerely yours.




            naneial~Management
  Systems and Audit Oversight
                                                      I. miw




                          C o n t e n t s

                                                               Page
LETTER                                                           1
APPENDIXES

      I      BACKGROUND                                          8
  II         OBJECTIVES, SCOPE, AND METHODOLOGV                14
 III         PROGRAM BENEFITS AND LIHITATIONS                  20
  IV         RELIABLE ANALYSES OF PROGRAM SAVINGS
               UNAVAILABLE                                     26
      V      INTERNAL CONTROL PROBLEMS                         30
  VI         MAJOR CONTRIBUTORS TO THIS REPORT                 36

TABLES

  1.1        Administrative Fees Under the GSA Contract
               as of March 4, 1990                             12
 II.1        Monthly Cardholder Statements Reviewed            17

                          ABBREVIATIONS

ATF             Bureau of Alcohol, Tobacco, and Firearms
EPA             Environmental Protection Agency
GAO             General Accounting Office
GSA             General Services Administration
HUD             Department of Housing and Urban Development
IRS             Internal Revenue Service
SSA             Social Security Adrainistration
                         ',,!^v'','i;!^"jifM''"i'K..-Mii!4.jfiia,;i.!^!!fwy»'^iiw^^^




          BLANK   PAGE


                    7



^^
^

     mm
APPENDIX I                                               APPENDIX I




                            BACKGROUND



PBOGRAH STARTBD A8 COMHBRCB PILOT PROJECT AND IS NOW UNDER GSA
GOVBRMHBNTVIDB CONTRACT



PBOGRAH OSES ZHTBRNATIONALLT RBCOGNIZED CRBDIT CARD FOR PURCHASES
UP TO $25^000 INSTEAD Ot TRADITIOHAL GOVERNHENT PURCHASING NETHODS



GOVERNHBNT RBIHBURSES CONTRACTOR BANK FOR CREDIT CARD PORCHASSS


CONTRACTOR BANK CHARGES GOVERIMENT AN ADMINISTRATIVE FEB FOR
CRBDIT CARD SERVICES
APPENDIX I                                               APPENDIX I


                               BACKGROUND

     In 1986, the Department of Commerce started a pilot project
using an internationally recognized credit card to make small
purchases. It contracted with the Colorado National Bank for
credit card services provided through the bank's subsidiary, the
Rocky Mountain BankCard System (Rocky Mountain). Organizational
entities within 24 federal agencies participated in the Commerce
pilot project, which expired in September 1989.

     The current small purchases credit card program is
administered by the General Services Administration (GSA), the
central agency responsible for managing govemmentwide contracts.
The GSA contract with Rocky Mountain for the govemmentwide prograra
took effect on March 4, 1989. GSA issued a Federal Supply Schedule
on the Govemmentwide Commercial Credit Card Service, which
includes the requirements for using the GSA contract and provides
agencies guidance on implementing the program. The GSA small
purchases'credit card program is similar to the Commerce pilot
project, except GSA uses a VISA credit card, and Commerce used a
MasterCard. In addition, the GSA program uses a different method
to pay Rocky Mountain and charges agencies a different type of fee
than was used under the Commerce pilot project.

PURCHASING UNDER THE PROGRAM
     Agencies provide the small purchases credit card to employees
who need a simplified method of making small purchases. For
example, the Bureau of Alcohol, Tobacco, and Firearms gives cards
to agents conducting surveillance to pay for car repairs and
photographic supplies; the Coast Guard gives cards to its personnel
to purchase tools and parts for their boats; and HOD gives cards to
employees to purchase office supplies. Each credit card is
assigned to a cardholder, who is the only person authorized to use
the card. The credit card replaces traditional purchasing and
payment methods, such as cash from an imprest fund,^ the standard
form 44,2 and the purchase order.


lAn imprest fund is a cash fund with an authorized cashier
 responsible for receiving monies and making small cash
 disbursements.




 the federal agency.
        AI:»PENDIX I                                             APPENDIX I



             Agencies can use the small purchases credit card for
        purchases of $25,000 or less, which is the amount defined as a
        small purchase in the Federal Acquisition Regulation (48 C.F.R.
        13.101 (1989). However, agencies routinely use the card for
        purchases well below $25,000. The average purchase with the
        credit card during the first year of the GSA contract was $199.
        From October 1989, after the Commerce pilot project expired,
        through March 1990, agencies spent about $21 million with the
        credit card.

              Cardholders have limits on the amount they can spend with the
        credit card and the types of vendors they can use. The agencies
        covered by our review, except the Air Force's 89th Military Airlift
        Wing, generally limit the amount cardholders can spend on any
        single purchase to $1,000 or less, unless the cardholder works in a
        procurement office. In addition, agencies limit the amount all
        cardholders in an office can spend during a month. They also
        determine the types of vendors cardholders can use, such as
        hardwai'e stores and business services. Cardholders are generally
        prohibited from using the amall purchases credit card at airlines,
        restaurants, and hotels because the small purchases credit card
        program is not intended to compete with the Diners Club credit card
        program for employee travel.

             For purchases over specified amounts, which vary by vendor,
        thc vendor is required tc obtain uuthorizaticn fror;^ the credit
        card network, which electronically connects vendors, banks, and
        the VISA credit card organization. To obtain authorization for
        the purchase, the vendor either calls the network or passes the
        card through a device that is electronically connected to the
        network. If the purchase is above the cardholder's limits or the
        vendor is not one of the types authorized for use by the
        cardholder, the vendor will not receive authorization for the
        sale.

        PAYMENTS UNDER THE PROGRAM
             Vendors who accept the credit card as a source of payment do
        not have to send invoices to the federal agency making the
        purchase. Instead, according to a Rocky Mountain official, they
        can generally get cash reimbursement for the sale from their banks
        within 48 hours. The vendors' banks are reimbursed by the credit
        card corapany, which, in turn, is reimbursed by Rocky Mountain.
        Rocky Mountain must then get reimbursed by the government.




                                       10
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APPENDIX I                                                                APPENDIX I


     Under the Commerce pilot project. Treasury reimbursed Rocky
Mountain through a letter of credit, Which enabled Rocky Hountain
to get payments on a daily basis for the government's credit card
charges. However, under the letter of credit. Rocky Hountain was
paid before agendas received and verified the accuracy of their
cradit card invoices. In order for agencies to verify the
accuracy of their credit card invoices before making payment, the
GSA contract did not use a letter of credit to pay Rocky Mountain*
Instead, under the GSA contract. Rocky Hountain sends an invoice to
each agency at the end of a billing period, and the agency must
make payment in accordance with the Prompt Payment Act of 1982, as
amended (31 U.S.C. Chapter 39). The act generally requires that
agencies pay an interest penalty if they do not make paynent
within 30 days after receiving an invoice. The GSA contract
estimates that it will take approximately 55.5 days from the time
Rocky Mountain makes payments for credit card purchases to the time
federal agencies receive and pay their invoices.

FEES FOR USING THB CREDIT CARD

     Commerce charged agencies an annual fee for each credit car"*
under the pilot project. This fee, which was initially $50 and
later reduced to $25, primarily covered Commerce's costs for
administering the program. Under the GSA contract, agencies no
longer pay annual credit card fees. Instead, they pay a f e e —
called the administrative fee—which is a percentage ot all
purchases made with the credit card.

     The administrative fee for the first year of the GSA contract
(March 4, 1989, through March 3, 1990) was 2.356 percent. Of this
fee, 61.5 percent covered Rocky Mountain's cost of funds^ for the
estimated 55*5 days it finances credit card purchases. In
addition, the administrative fee provides a profit margin for Rocky
Mountain and covers its administrative expenses, such as those for
preparing management information reports to agencies. The
administrative fee declined to 1.876 percent in March 1990, the
beginning of the second contract year, it will decline further
when the government's total purchases with the card exceed certain
dollar levels. For the first 2 contract years, total government
purchases will be calculated by adding together the purchases made
during both years. However, for the remaining 3 years of the
contract, only total purchases within each contract year will be


^The cost of funds is the interest paid to boirow the funds or the
 income that could have been earned by using the funds for an
 alternative investment.
                                 11
                                                                          •mpvii'vittMni




           APPENDIX I                                                APPENDIX I


           used to determine the administrative fee. The fee that is reached
           by the end of a contract year carries over to the next contract
           year and remains in effect until the next level is reached. (See
           table 1.1.)

           Table 1.1;   Administrative Fees Onder the GSA Contract as of
                        March 4, 1990
                        Total qovernment purchases        Administrative feea,b
                          (Dollars in millions)                (Percent)
                                 $      50                        1.143
                                        75                        1.036
                                       100                         .887
                                       150                         .779
                                       200                         .676
                                       250                         .629
                                       500                         .528
                                     1,000                         .512
           aThe administrative fees are adjusted at the beginning and middle
            of the contract year according to a formula in the contract. The
            formula is based on changes in the federal funds rate (which is
            the GSA contract's basis for calculating Rocky Mountain's cost of
            funds) and the income Rocky Mountain receives from fees that
            vendors pay under the program.

           bAgencies that receive their monthly reports and invoices
            electronically, instead of through the mail, are charged an
            administrative fee .094 less than those listed above. For
            example, instead of paying 1.143 percent, those agencies would
            pay 1.049 percent.

                After a new level with a lower administrative fee is reached.
           Rocky Mountain will refund the agencies involved in the program the
           difference between what they paid under the previous fee and what
           they would have paid if the new fee had been in place during the
           year. This refund will cover purchases made from the beginning of
           the contract year to the point the new fee is reached. The refund
           will be calculated and paid at the end of the contract year.




                                             12




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                 APPENDIX I                                APPENDIX I




                              BLANK PAGB
                                    13




••'-'.'•'.•?..
APPENDIX II                                           APPENDIX II




                 OBJBCTIVBS, SCOPE, AND METHODOLOG»



(fflJECTIVES OF OOR REVIEV HERE TO


        DETERMINE THB BENEFITS, LINITATICHS, AND COSTS OF THB SHALL
        PORCHASES CRBDIT CARD PROGRAH


        ASSESS AGBNCIBS* INPLEHBNTATION OP THB INTERNAL CONTROLS
        ESTABLISHED FOR THB PROGRAH



SELECTED 7 AGBNCIBS TO RBPBESBNT A RANGE OP SIZES OP CRBDIT CARD
PROGRAMS


iMTEkVlBWBD OFFICIALS TO GBT THEIR VIEWS ON PROGRAM BENEFITS AND
LIMITATIONS


<»TAINED AVAILABLE DATA ON THB COST OP USING THE CREDIT CARD
VERSUS OTHER PROCURBHBNT AMD PAYMENT METHODS

REVIEWED A SAMPLE OF HONTHLY CARDHOLDER STATEMENTS ONDER COMHBRCB
PILOT PROGRAM AND GSA CONTRACT




                                 14
APPENDIX II                                           APPENDIX II



                OBJECTIVES, SCOPE, AWD METHODOLOGY

     The objectives of our review were (1) to determine the
benefits, limitations, and costs of the small purchases credit card
program and (2) to assess agencies' implementation of the internal
controls established for the program.

     To determine the reguirements for the program and how the
program is intended to operate, we reviewed federal requirements
for small purchases, agency internal guidance and other documents
on the small purchases credit card program, and the Federal Supply
Schedule on the Govemmentwide Coramercial Credit Card Service. To
obtain background information on the Commerce pilot project, the
GSA program, and the contracts with Rocky Mountain, we reviewed the
contracts and Commerce reports on the results of the pilot project
and interviewed officials at Commerce, GSA, the Office of
Management and Budget, Treasury, and Rocky Mountain. To learn
about requirfeiTients to cake credit card purchases from small
businesses, we reviewed the laws and regulations establishing the
requirements and interviewed officials at the Small Business
Administration.

     We selected agencies for our review to represent a range of
sizes of small purchases credit card programs under the Commerce
pilot project. Three of the agencies we selected for review—the
Department of the Treasury's bureau ot Aicobol, Tobacco, and
Firearms (ATF); the Department of Transportation's Coast Guard
Ninth District; and the Department of Health and Human Services'
Social Security Administration (SSA)--had over 350 cardholders
each and were among the agencies with the most cardholders. Three
other agencies—the Environmental Protection Agency (EPA), the
Department of Housing and Urban Development's (HUD) headquarters,
and the Air Force 89th Military Airlift Wing—had between 50 and
350 cardholders, while the Department of the Treasury's Internal
Revenue Service's headquarters had less than 50 cardholders.
     At these agencies, we interviewed officials involved in
managing and implementing the program, such as procurement,
finance, and approving officials, and cardholders to obtain their
views on the benefits and limitations of the small purchases credit
card program.
     In our analysis of whether agencies were following the
internal controls established for the program, we reviewed a sample
of cardholder statements to determine if (1) cardholders were
adequately documenting their purchases and (2) the purchases were
properly reviewed by an approving official. Most of our review was
conducted while agencies were participating in the Commerce pilot
                               15
                                                   ^T-^^




APPENDIX It                                            APPENDIX II



project, and, for all agencies, we reviewed the most recent month
of activity at the time of our review. Also, for some agencies, we
reviewed additional months of activity. To determine if switching
to the GSA contract affected agencies' internal controls over the
program, we reviewed some agencies' first month of activity under
the GSA contract. We were unable to review a sample of cardholder
statements at IRS headquarters because, at the time of our work,
few cardholders had reviewed and submitted their statements as
required by IRS guidelines. In addition to reviewing 2 months of
cardholder statements at SSA headquarters, we reviewed the
documentation of statements for SSA cardholders in one regional
area for fiscal year 1989. We did this because SSA does not
require cardholders to send their documentation of purchases to
headquarters. Table II.1 shows the number of months for which we
reviewed statements at each agency, the number of statements in the
sample, and the total charges on the statements we reviewed.




                               16
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                          APPENDIX I I                                                                                APPENDIX I I



                          Table I I . 1 :          Monthly C a r d h o l d e r S t a t e m e n t s Reviewed

                                                                                                       Nonber of                         Dollar
                                                               Number of monttis reviewed              statements                        value
                                                             Under Oommerce         Under Q5A

                          Envlronnental
                           Protection
                           Agency                                                                             214                     $132, U 8
                          Department of
                           Housing and Urban
                           Developnnent
                           headquarters                                                                     213                          251,941

                          Coast Guard,
                           Ninth D i s t r i c t                                          oa                164                            38,109

                          Bureau of
                           Alcohol, Tobacco,
                           and Fi reaons                                                                       63                          12,969

                          Social Security
                           Administration                                                                      50                            5,684

                          Air Fbrce 89th
                           Military
                           A i r l i f t Wing                                            Ob                    27                          88,146

                          SThe Coast Guard Ninth D i s t r i c t was making organizational changes in the
                           program that would have affected the r e s u l t s of our work covering the f i r s t
                           month under the GSA contract; therefore, we excluded i t from our sample.
                          bzhe Air fbrce 89th Military A i r l i f t Wing planned to s t a r t using a c r e d i t card
                           designed for aviation and did not participate in the small purchases c r e d i t
                           card program under the GSA contract.

                                    To s u p p l e m e n t o u r d e t a i l e d a n a l y s i s of t h e a g e n c i e s i n our
                          r e v i e w , we a l s o o b t a i n e d t h e views of o f f i c i a l s a t t h e D e p a r t m e n t s
                          of t h e Navy and I n t e r i o r and t h e Department of A g r i c u l t u r e , b e c a u s e
                          t h e s e a g e n c i e s a c c o u n t f o r 44 p e r c e n t of t h e d o l l a r s s p e n t u n d e r
                          t h e GSA c o n t r a c t from A p r i l 1989 t h r o u g h March 1990.
                                   To d e t e r m i n e t h e s a v i n g s t h a t r e s u l t from u s i n g t h e c r e d i t
                          c a r d , we o b t a i n e d T r e a s u r y documents on s a v i n g s r e p o r t e d by
                          a g e n c i e s p a r t i c i p a t i n g i n t h e p r o g r a m . A l s o , from Commerce and
                                                                              17


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             ^^^^^'^^"-
                                                             -HI I'lPfWIll-i^lW   H V ^




      APPENDIX II                                           APPENDIX II



      entities within the Navy and Interior, we obtained analyses of the
      cost of using other procurement and payment methods versus the cost
      of using the small purchases credit card; however, we did not
      assess the accuracy and validity of the cost analyses performed by
      agencies. In addition, we assessed whether the arrangement under
      the GSA contract of including the cost of funds in the
      administrative fee is cost-effective from a govemmentwide
      perspective* To do this, we compared the cost of different levels
      of administrative fees to the government's cost of funds for making
      immediate payment to Rocky Mountain.

           The views of responsible agency officials were sought during
      the course of our work and are incorporated where appropriate.




                                     18



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APPENDIX II                                                                        APPENDIX II




              BLANK PAGE
                     19
APPENDIX III                                           APPENDIX III




                  PBOGRAH BENEFITS AND LIHITATIONS


CREDIT CARD BENEFITS INCLUDE


     —   PAPERWORK RBDOCTION


     —   PRONPT RECEIPT OF ITBNS

     —   REDUCED NUMBER QP INVOICES


    —    RBDDCED VENDOR INQUIRIES ABOUT PAYMENTS



CRSDIT CAKD LISITATICSS XHCLUDE


    —    TIHB REQUIRED BY FINANCE OFFICE TO VERIFY AGENCY INVOICE


    —    ADHINISTRATIVB FBB


    —    DIFFICULTIES IDENTIFYING SHALL BUSINESSES




                                   20
          APPENDIX III                                          APPENDIX III


                             PROGRAM BENEFITS AND LIMITATIONS

               The small purchases credit card program offers several
          benefits to agencies, such as reducing the paperwork needed to make
          a purchase and reducing the number of Invoices agencies receive.
          However, the overall benefits from the program are limited by
          factors such as the time-consuming nature of verifying the agency's
          credit card invoice and the requirement to pay an administrative
          fee for using the credit card.

          PROGRAM BENEFITS

               The small purchases credit card program can help improve
          purchasing and payment efficiency and reduce the cash requirements
          of imprest funds.

          Oredit Card Improves Putchasing efficiency
               Cardholders and officials who manage the small purchases card
          programs at EPA, HUD, the Coast Guard, ATF, and SSA told us that
          the credit card requires less paperwork than other purchasing
          methods. For example, with the small purchases credit card, a
          cardholder does not have to complete a requisition form requesting
          that the procurement office purchase office supplies. Instead, the
          cardholder can buy supplies directly from an oftice supply sLote.
          Also, the cardholder does not need to go to an imprest fund
          cashier, which eliminates the need to complete a form requesting
          Imprest fund monies.

               Officials at E^A, HUD, the Coast Guard, and ATF stated that
          the card reduces the amount of time required to obtain an item
          because cardholders can make purchases themselves, instead of
          waiting for the procurement office to make the purchase or for
          procurement forms to be approved. Also, officials at EPA and HUD
          told us that by letting program officials make their own small
          purchases, the procurement office can concentrate its efforts on
          complex, higher priced purchases.
               In addition, officials at EPA, ATF, HUD, IRS, and the Coast
          Guard informed us that using the small purchases credit card makes
          it easier to find vendors who will do business with the federal
          government. For example, officials said that, in the past, some
          vendors would not accept purchase orders or standard form 44s
          because the government took too long to make payment. However,
          they said that the vendors like the small purchases credit card,
          which, according to a Rocky Mountain official, generally enables


                                          21




Mi kia-
          APPENDIX III                                           APPENDIX III



          the vendors to receive payment from their banks within 48 hours of
          the purchase.

          Credit Card Can Improve Payment Process

               The small purchases credit card enables agencies to reduce the
          number of invoices their finance offices receive from vendors and
          must process for payment. This occurs because under the small
          purchases credit card program, the agencies do not make individual
          payments to vendors. Instead, vendors are paid through the credit
          card network, and agencies pay Rocky Mountain based on a
          consolidated monthly invoice of all credit card purchases.
          Reducing the number of invoices agencies must pay saves Treasury
          the $.30 in processing and mailing costs for the check issued to
          pay each invoice.

                Making fewer individual payments to vendors can also help
          agencies avoid problems that result from receiving meiny invoices,
          such as iate payments and inquiries from vendors. For example, a
          finance office official at the Coast Guard Ninth District
          attributed the District's use of the small purchases credit card
          with reducing the number of late payments it made from 200 in
          fiscal year 1987 to 10 in fiscal year 1989. Also, officials at
          ATF, the Coast Guard Ninth District, and EPA said that usinq the
          card had greatly reduced the number of inquiries vendors make to
          etgency finance offices anout invoice payment. Officials sai^i that
          responding to these inquiries can be extremely time-consuming;
          therefore, reducing the number of these inquiries can improve "^e
          finance offices' overall efficiency.

          Crsdit Card Reduces Imprest Funds
               The small purchases credit card enables agencies to reduce
          the use of imprest funds for small purchases, thereby reducing the
          amount of cash that needs to be held in these funds. Reducing the
          size of imprest funds improves Treasury's cash flow and gives it a
          higher cash reserve on which to earn interest. Specifically,
          Treasury is able to invest the unneeded cash in special bank
          accounts that earn interest and to delay borrowing funds from the
          public, thus reducing interest on borrowed funds*
               According to a December 1989 Department of Commerce report on
          its experiences under the pilot project. Commerce's imprest funds
          decreased 40 percent in fiscal year 1988, when it began using the
          small purchases credit card extensively. Based on this decrease.
          Commerce estimated the government saved $91,000 in interest during
          fiscal year 1988. In addition, an analysis done by the Navy's
          Haval Weapons Center at China Lake found that the Center's imprest

                                          22




UiuUtf.
APPENDIX III                                          APPENDIX III



fund used $20,000 less in the month of September 1989 than it used
in September 1988, when its small purchases credit card program was
just beginning.
PROGRAM LIMITATIONS

     The limitations of the small purchases credit card include the
amount of time that agencies spend verifying their credit card
invoices and the cost of the administrative fee for using the
credit card. In addition, not all vendors accept the credit card,
and, as with other small purchase methods, those making purchases
with the credit card may have difficulty complying with the
requirement to make purchases from small businesses.

Verifying Agency Invoices Is Time-Con sum inci

     Efficiency improvements that result from receiving fewer
invoices can be offset by the amount of time the finance office
spends verifying monthly credit card invoices. To verify its
agency's consolidated monthly invoice, a finance office must
receive statements from each cardholder that have been reviewed by
the cardholder and approving official. The finance offices at EPA
and ATF had difficulties getting statements from all their
cardholders and had to spend time contacting the cardholders to
obtain the stateraents. Officials at the EPA and A T F finance
offices stated that the signiticant amount ot i.ime LIICIL offlccc
spend contacting cardholders is a disadvantage of the credit card
program.

Agencies Dissatisfied With
tne Administrative Fee
     Our review found that agency officials wete generally
dissatisfied with the administrative fee agencies must pay to use
the credit card. Agency officials stated that the federal
government should not have to pay an administrative fee because
Rocky Mountain already earns income from fees vendors pay on
purchases made with a VISA card. However, Rocky Mountain and GSA
officials stated that Rocky Mountain's income from vendors' fees--
called the interchange fee—currently does not cover Rocky
Mountain's costs for the program. The interchange fee is shared
among the vendor's bank, the VISA network, and Rocky Mountain. In
1989, Rocky Mountain's interchange fee income from the small
purchases credit card was 1.37 percent of all government purchases
with the card.

     In addition. Rocky Mountain and GSA officials told us that the
administrative fee is necessary because Rocky Mountain cannot
                                 23
               APPENDIX III                                          APPENDIX III



               charge the federal government the amount of interest on late
               payraents that it charges private sector cardholders. For example.
               Rocky Mountain currently charges private sector cardholders an 18.6
               percent annual interest rate; federal agencies pay a significantly
               lower interest rate, which is calculated by Treasury pursuant to
               the Prompt Payment Act. For the last 6 months of 1989, this ra<o
               was 9.125 percent annually.

                    As discussed in appendix I, a portion of the administrative
               fee covers Rocky Mountain's cost of funds for making payments fcr
               credit card purchases approximately 55.5 days before it receives
               reimbursement. This cost of funds was not included in the annual
               credit card fees agencies paid under the Commerce pilot project;
               however, by paying Rocky Mountain daily for credit card purchases,
               the government lost the interest it could nave earned if it had
               delayed payraent. According to a GSA official, now that the cost of
               funds is covered through the administrative fee, some agencies
               perceive the fee as b«»ing too high.
                    To determine whether the current arrangement of including the
               cost of funds in the administrative fee is cost-effective from a
               govemmentwide perspective, we compared the current administrative
               fee to the amount of interest the government would lose by making
               daily payments to Rocky Mountain. Our analysis showed that,
               h&canse the administrative fee will decline when total government
               purchases reach certain dollar levels (as shown in table i.l),
               paying the administrative fee will eventually be more cost-
               effective than making daily payments to Rocky Mountain.
               Specifically, we converted the interest rate applicable to the
               government's investments to a rate comparable to the credit card's
               administrative fee.* We concluded that the interest the government
               would lose by making daily payments to Rocky Mountain is equivalent
               to a 1.229 percent administrative fee. This is greater than the
               1.143 percent administrative fee agencies will pay when total
               government purchases with the credit card exceed $50 million.




               *For this conversion, we (1) used the federal funds rate (which is
                the basis for calculating the cost of funds portion of tbe GSA
                contract's administrative fee) minus .25 percent to approximate
                the intetest rate for the government's investments and
                (2) converted it from an annual rate to a rate applicable to a
                55.5 day period, which is the period of time credit card purchases
                are financed as estimated by the GSA contract.

                                              24
^




    •t-^ti--
APPENDIX III                                          APPENDIX III



Some Vendors Do Not Accept Credit Cards

     Although the credit card generally makes it easier to find
retail vendors from which to make purchases, officials at HUD,
IRS, the Coast Guard, and SSA mentioned that some vendors, such as
some wholesalers and office equipment repair shops, do not accept
credit cards. Also, agencies such as IRS and SSA which
frequently purchase information from banks to determine an
individual's financial status are unable to use the small
purchases credit card to purchase the information because the
banks do not accept credit cards for payraent.

     Rocky Hountain officials stated that they are making efforts
to get more vendors to accept the credit card. They stated that
they ask federal agencies to give them the names of vendors that
do not accept the credit card, so that they can contact the
vendors and arrange for them to accept the credit card.

Cardholders May Have Difficulties
Identifying Small Businesses
     The Small Business Investment Act of 1956, as amended,
generally requires that agencies make small purchases from small
businesses, when available (15 U.S.C. 644(j) (1988)). However, due
to the complexity of the definition of a small business,
cardholders may nave difficulty identifying small businesses from
which to make purchases. According to a Small Business
Administration official, the definition, contained in a 15-page
table in the Code of Federal Regulations (13 C.F.R. 121.601
(1990)), probably Is not understood by cardholders. Agency
officials told us that their primary guidance on how to identify
small businesses for those who make small purchases, including
credit cardholders, is to ask someone at the business whether it is
small or large. Small Business Administration officials told us
that salespeople should not be expected to know whether the
business they work for qualifies as a small business under federal
regulations. Therefore, those who use the small purchases credit
card, as well as those who use other procurement methods, may have
difficulty identifying small businesses and complying with the
requirement to purchase from those businesses.




                               25
     APPENDIX IV                                             APPENDIX IV




              RBLIABLE ANALYSES OP PBOGBAM SAVINGS DNAVAILABLB


     LIMITED ANALYSES BY 3 AGENCIES INDICATE THE CREDIT CAKD CAH SAVE
     HONEY


     TREASURY ESTIMATES OP SAVINGS PROM THE CREDIT CARD MAY BE
     INACCURATE


     AGENCIES SHOULD ANALYZE HOW CREDIT CARD COSTS CCMPARB WITH COSTS
     OP OTHER PURCHASING AHD PARENT HETHODS




                                    26
';
             APPENDIX IV                                                  APPENDIX IV


                       RELIABLE ANALYSES OF PROGRAM SAVINGS UNAVAILABLE

                  Although the agencies included in our review believe that
             using the small purchases credit card improves efficiency, most had
             not analyzed how the cost of using the credit card compares with
             the cost of using other purchasing and payment methods. However,
             three organizations, including the Department of Commerce, have
             conducted such analyses. The Department of the Treasury, in its
             efforts to monitor agencies' progress in using cash management
             initiatives, has been collecting data from agencies on operational
             savings that result from using the credit card. However, the data
             may be inaccurate because agencies have not conducted the type of
             analyses needed to make reliable estimates of savings.

             LIMITED AGENCY .ANALYSES
             INDICATE THE CREDIT CARD
             CAN SAVE MONEY

                  The Department of Commerce and components in the Navy and
             Interior have analyzed the cost of using the small purchases
             credit card compared to other procurement and payment methods. As
             mentioned in appendix I, we did not verify the accuracy and
             validity of these analyses. The analyses resulted in varying cost
             figures, but all showed that allowing program officials to make
             their own purchases wi th the cieult caru wa:» It^^ss t±xpt:im ive tiian
             other methods.
                  The Department of Commerce's analysis found that the small
             purchases credit card is more cost-effective to use than three
             traditional methods of making purchases and payments--the purchase
             order, the standard form 44, and cash from an imprest fund. The
             analysis was based on procurement and finance office officials'
             judgment of the amount of staff time spent requesting a
             procurement, completing required forms, receiving deliveries or
             picking up purchases, and certifying the bill for payment. The
             analysis was also based on the assumption that the credit cards
             were being used by program officials who did not have to complete a
             requisition form for a credit card purchase. The Commerce analysis
             results were that a purchase with the credit card costs $16 to
             process, while a purchase order costs $44 to process, and imprest
             fund and standard form 44 purchases cost $26 and $22, respectively.
             Department of Commerce officials said this analysis only applies
             to Commerce and does not necessarily apply to other agencies,
             because it is based on Commerce's procedures, which probably differ
             from those used by other agencies. The primary reason that less
             staff time is needed to make and pay for a purchase with the card
             than for other methods is that forras, such as requisition forms,
                                               27




i^ip'-v^/!
     APPENDIX IV                                                    APPENDIX IV


     standard forra 44s, or imprest fund vouchers, do not have to be
     completed before making a card purchase.

          The Department of the Interior's Geological Survey did an
     analysis that covered the same type of expenses as Commerce's
     analysis and found that it spends from $166 to $245 to process a
     purchase order and $18 to process a credit card purchase. The
     Naval Weapons Center at China Lake also did an analysis that
     compared the average cost of processing a purchase made by the
     procurement office using methods other than the credit card with
     the cost of having officials make their own purchases with the
     credit card. This analysis showed that a purchase with the credit
     card costs $98 compared to $154 for a purchase by the procurement
     office.

     TREASURY ESTIMATES ON SAVINGS FROH
     THE CREDIT CARD MAY BE INACCURATE
          Agencies using the small purchases credit card are instructed
     to report savings that result from the program to Treasury. For
     fiscal year 1989, 13 agencies reported savings of $1,659,616 frora
     using the small purchases credit card. However, we believe this
     figure may be inaccurate because, according to a Treasury
     official, agencies generally based their savings figures on the
     results of Commerce's analysis, which do not necessarily apply to
     agencies other than Commerce. In addicion, not all ^ g ^ r i c i s s using
     the credit card have yet reported savings to Treasury.

          Treasury's Instructions to agencies for reporting savings from
     the credit card program did not require them to conduct their own
     analyses of the cost of using the credit card compared to other
     procurement and payment methods. Instead, Treasury provided the
     results of Commerce's analysis as a guideline, and, according to a
     Treasury official, agencies generally used these results as the
     basis for calculating their savings under the program. These data
     may not be reliable because Commerce's analysis is based on the
     cost of Commerce's own internal operations, which could differ from
     the costs associated with the same operations of other agencies.
     As we discussed above. Interior's Geological Survey and the China
     Lake Naval Supply Center, which performed their own analyses, had
     results that differed significantly frora those of Commerce.

          We believe that to obtain reliable estimates of cost savings
     from this program, agencies must conduct their own analyses
     comparing the cost of using the sraall purchases credit card with
     other procurement and payment methods. Without these comparative
     analyses. Treasury will not have meaningful statistics with which
     to assess the costs and benefits of the small purchases credit
                                        28




im
     APPENDIX IV                                             APPENDIX IV



     card program versus other procurement and payment methods. Such
     analyses can also be useful to the Office of Management and Budget
     and GSA in determining the effectiveness of the credit card
     program.

     RECOMMENDATION
          We recommend that the Secretary of the Treasury revise the
     instructions to agencies for reporting savings from the small
     purchases credit card program. These instructions should require
     that agencies calculate their savings estimates based on their
     costs for using the small purchases credit card versus other
     procurement and payment methods, covering the entire procurement
     and payment process.




                                    29



3>
                                                                           ^^^^m^mmi




                          APPENDIX V                                                   APPENDIX V




                                               INTERNAL CONTROL PROBLEMS



                          4 OP 7 AGENCIES BBVIBNBD BAD SOME INTERNAL CONTROL PB<»LBHS



                              —   POBCHASES AT IRS BBADQUARTERS WERE NOT ROUTINELY DOCDHENTED
                                  OR RBVIBHBD


                                  PDBCBASBS AT SPA AND HOD WERE HISSING DOCUMENTATION


                                  STATEMENTS NOT REVIBNBD BY DESIGNATED APPROVING OFFICIALS
                                  AT EPA, ATP, AND HOD


                              —   CARDS USED BY NONCARDHOLDERS AT HUD




                                                         30




k
i * ' ' ^ ' ' . •   ••.
APPENDIX V                                               APPENDIX V


                     INTERNAL CONTROL PROBLEMS


     Policies and procedures have been issued prescribing internal
controls for the small purchases credit card program that should
prevent cardholders from using the card for unauthorized purposes.
However, we found weaknesses in the implementation of these
controls at four of the seven agencies in our review—IRS, HUD,
EPA, and ATF« Specifically, we found instances of inadequate
documentation of purchases by cardholders, lack of approving
official review of cardholder statements, and noncardholder use of
the card. We generally did not find any significant problems in
these areas at the £k>cial Security Administration, the Coast Guard
Ninth Dis'-rict, or the 89th Military Airlift Wing.

     The agencies in our review are making or planning corrective
action to ensure that their internal control procedures are
followed. Therefore, we are not making specific recommendations
tc these agencies. We advised internal audit staff at these
agencies of the problems we identified. IHS Internal audit staff
have been conducting a review of the small purchases credit card
program, and we suggested that other agencies* internal audit
staffs monitor their agencies' efforts to correct the problems we
identified.
TwygDMyr COHTJROLS OVER CARD TURCHASSS

     The small purchases credit card program has two primary
internal controls to ensure that the credit card is only used for
authorized purposes and that agencies only pay for items they have
received. These controls are (1) cardholders are to review
monthly statements of their charges and attach receipts showing
what was purchased and (2) approving officials are to review the
cardholders' statements and receipts to ensure that the purchases
were for authorized purposes. After the approving officials
review the statements, they send them to the finance office to use
in verifying the agency's credit card invoice.

     These internal controls over the small purchases credit card
program were developeo under the Commerce pilot project and were
included in agencies' Internal guidance on the program. The
Federal Supply Schedule on the Govemmentwide Commercial Credit
Card Service under the GSA contract also provides guidance to
agencies on the controls over the program.




                                31
               APPENDIX V                                               APPENDIX V


               PURCHASES NOT DOCUMENTED OR
               ftEvlfiwgP AT IRS HEADQUARTERS
                    Our review at IRS headquarters disclosed that IRS cardholders,
               who were purchasing agents in the procurement office, were not
               implementing the Internal controls over the small purchases credit
               card program. Specifically, as of December 1989, cardholders had
               not submitted statements to the IRS finance office for
               approximately $392,000, or 94 percent, of the $418,000 in purchases
               they made with the card during fiscal years 1988 and 1989. Because
               the finance office did not receive these statements, IRS had no
               assurance that the purchases were received by the agency or were
               for authorized purposes. An official from IRS' office of internal
               audit told us that that office conducted a review of the small
               purchases credit card program at IRS and also identified this
               problem.

                    According to an IRS official, the problem occurred because
               purchasing agents in the fiocurement office ordinarily arc not
               required to verify receipt of the items they purchase and,
               therefore, did not follow this requirement for purchases made with
               the small purchases credit card. IRS has made an effort to
               resolve this problem by appointing an official to monitor the
               program, ensure that cardholders submit their old statements and
               documentation for the purchases, and provide clear Instructions to
               caruuolueis on procedures for the prcgrciru.
               MISSING DOCUMENTATION OF
               PURCHASES AT HUD AND EPA
                    At HUD and EPA, about a quarter of the statements we reviewed
               from the Commerce pilot project were submitted to the agencies'
               finance offices without receipts for the purchases. The receipts
               or other documentation, such as packing slips from items received
               through the mail, are needed to document that the items purchased
               were received and were for authorized purposes. At HUD, 27 percent
               of the 173 monthly cardholder statements we reviewed from the
               Commerce pilot project were missing sales receipts for purchases
               totaling approximately $27,500- In addition, 29 percent of the 174
               statements we reviewed at EPA frora the Commerce pilot project did
               not have receipts for purchases of at least $29,600. A HUD
               official stated that the receipts may be missing because (1) the
               cardholders are not attaching them to the statements, (2) approving
               officials are not ensuring that cardholders attach them, and (3)
               some vendors do not provide receipts. EPA oiificials stated that
               aome cardholders may not attach receipts because they do not



ty                                              32



W'-'.
     '.i^.-^
                                                          •pm   mmm




      APPENDIX V                                                      APPENDIX V



      understand the requirement to do so and that for some purchases,
      especially those made over the telephone, vendors may not provide
      receipts.
           At EPA, tho documentation of purchases improved under the GSA
      contract. Of the 40 statements we reviewed at EPA for the first
      month under the GSA contract, 15 percent were missing receipts for
      purchases. An EPA official who oversees the small purchases credit
      card program attributed the improvement to BPA's monitoring of card
      purchases and sending memorandums to cardholders reminding them of
      the program's requirements.

           Although the documentation of purchases at HUD did not improve
      under the GSA contract, HUD officials stated that they will be
      issuing additional guidance to cardholders and holding training
      sessions to help ensure that cardholders follow the credit card
      program's procedures.

      STATEMENTS NOT RSVIEWSD BY
      DE^lflriATEb AP&ft6vli*d OTFTglALS
             The review of monthly cardholder statements by the approving
      official is an essential control to ensure that credit card
      purchases are for official purposes. The approving official needs
      to be aware of the requirements for credit card use and for
      *inf»njngntinc; purchasss and shculd be able tc detect rriisuse of the
          "" However, we found the following:
      card.
              At EPA, 7 percent of the 174 st atements we reviewed from
              the Commerce pilot project were accepted by the finance
              office with no approving offici al signature. According to
              an EPA official Involved in the sraall purchases credit
              card program, EPA managers trav el frequently, and,
              therefore, the approving offici als may not have been
              available to sign the statement s. In its operations under
              the GSA contract, EPA's finance office returns all monthly
              statements to the cardholder if the approving official's
              signature is missing.
              Twenty-seven percent of the 63 statements we examined at
              ATF's finance office and 15 percent of the 213 statements
              at HUD's finance office were approved by someone other
              than the designated approving official. Officials at ATF
              said the approving officials may have been too busy or not
              available to review the stateraents. Consequently, someone
              else was designated to perform the review, but the agency
              did not have a system for verifying that these people were
              authorized to perform the approving officials' review. An

                                           33
e-.
APPE.NDIX V                                              APPENDIX V


        ATF official stated that, in the future, ATF will require a
        written explanation whenever someone other than the
        designated approving official approves a cardholder
        statement. Also, HUD officials said that during the period
        covered by our review, HUD was undergoing a change in
        administration and many of the managers were on an acting
        basis; therefore, the credit card files had not been
        changed to show the individuals currently authorized to
        serve as approving officials. According to a HUD official,
        to address this problem, the HUD finance office will keep a
        file of officials who are authorized to review cardholder
        statements for the approving official.

CARDS USED BY NONCARDHOLDERS AT HUD

     The cardholder's knowledge of credit card purchases and
verification of the monthly statement is a key element in the
internal controls over the card. The federal government is only
liable for purchases made by authOLized caLdholdeiS. However, the
practice of loaning cards could result in instances of fraud.
     Out of the 213 statements we reviewed at HUD, we found
8 instances of noncardholders using the small purchases credit card
to make purchases which appeared to be for authorized purposts.
In these instances, noncardholders had signed the credit card
receipts attached to tht- mOuLhly stiateuients. However, because
27 percent of the statements we reviewed at HUD were missing
receipts, we were unable to determine the extent to which
noncardholders used the credit card. A HUD official involved in
the program stated that cardholders should not allow others to use
their cards but that some cardholders view the card as an office
card and not an individual card. Also, a HUD cardholder told us
that he allows a co-worker to use his card if he does not have the
time to make the purchase himself. A HUD official stated that HUD
will provide additional guidance to cardholders and hold a training
class that emphasizes that cardholders should not allow others to
use their cards.




                               34
                                      •••'fwr'-'n :-.'?7g:>-'jf.'.^7''?TrTC   '^•.r-t,!^.;^.^,'^,^-^^   m i ^ V   iiii,iiii!«iiii,pi




            APPENDIX V                                                                  APPENDIX V




                         BLANK PAGE

                                 35
Mr



     ^2i^
APPENDIX VI                                            APPENDIX VI


                 MAJOR CONTRIBUTORS TO THIS REPORT

ACCOUNTING AND FINANCIAL MANAGEMENT DIVISION. WASHINGTON, D.C.
Robert A. Pewanick, Senior Assistant Director
Helen Lew, Assistant Director
Kathleen Peyman, Evaluator-in-Charge
Tracy E. Ferrell, Accountant
Kent L* Eby, Accountant


DETROIT REGIONAL OFFICE

Robert F. Stephens, Regional Assignment Manager
Gerald H. Springborn, Evaluator
Allen R. Walter, Evaluator




(901492)



                               36