4-Appendix A PTB 12-1009.pdf
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- Solicitation number
- 2000004256
- Issued by
- Fairfax County, Virginia
About this file
This Procurement Technical Bulletin (PTB 12-1009) issued by the Fairfax County Department of Procurement and Material Management (DPMM) establishes comprehensive policies and procedures for the use of Procurement Cards (P-Cards) by Fairfax County employees and Commonwealth of Virginia agencies. The bulletin, effective November 6, 2023, provides guidance on P-Card management as an alternative to traditional purchase orders and petty cash, establishing this payment tool as the primary method for purchases within the county's FOCUS Marketplace. The document outlines three types of P-Cards: Department P-Cards (embossed with FCG and functional area names), Individual Named P-Cards (issued to specific employees), and Ghost P-Cards (account numbers embedded in FOCUS Marketplace and eVA platforms for electronic payment without physical cards). All P-Card users must complete mandatory training through the Employee U online learning platform and pass an embedded test before first use. The bulletin establishes that single purchase limits (SPL) are generally capped at $9,999 for standard P-Cards, with exceptions for special use P-Cards requiring written approval from the DPMM Director for higher limits, including eVA P-Cards with SPLs up to $99,999 and FOCUS Ghost P-Cards with higher limits restricted to approved Marketplace vendors.
The bulletin establishes strict control mechanisms and prohibited uses to prevent fraud and misuse, including prohibitions on cash advances, split transactions, personal purchases, and purchases from independent contractors. P-Card limits are controlled through Merchant Category Codes (MCCs) and Merchant Category Code Groups (MCCGs), with FC1 serving as the standard group excluding high-risk purchases such as cash, jewelry, massage parlors, and gambling establishments. Department P-Card Program Managers are required to establish Internal Control Procedures (ICPs) addressing separation of duties, P-Card security, and reconciliation processes. Monthly reconciliation to both bank records and FOCUS is mandatory, with departments required to maintain detailed transaction logs, receipts, and supporting documentation for a minimum of three years plus the current year. The DPMM Program Administrator retains authority to investigate violations, suspend or terminate P-Card privileges, and the bulletin establishes that fraudulent charges occurring in Fairfax County or made by county employees must be reported to the Fairfax County Police Department as criminal matters before replacement cards are issued. Emergency dispensation procedures allow temporary relaxation of P-Card restrictions during urgent mission-related activities with approval from the DPMM Deputy Director or Director.
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Procurement Technical Bulletin 12-1009
Appendix A
RFP200004256
PTB
12-1009
Effective Date
November 06, D
P
M
M
Procurement Technical Bulletin Procurement & Material Management
Use of the County Procurement Card
Purpose
The purpose of this PTB is to provide guidance for proper use and management of the county’s procurement card (P-Card) program and to establish a more efficient, cost-effective method of purchasing and paying for goods and services. The P-Card may be used as an alternative to Purchase Orders (POs), non-PO payments or petty cash, and is also the payment tool for purchases made within the county’s FOCUS Marketplace.
Policy
The Fairfax County P-Card policy applies to all employees of Fairfax County and the Commonwealth of Virginia agencies that are assigned a P-Card for the purchase of goods and/or services incurred on behalf of Fairfax County. Fairfax County is required to make all purchases in accordance with the Fairfax County Purchasing Resolution. The county P-Card is a tool that can be used to purchase goods and services with strict adherence to county policies and procedures to prevent fraud, waste, and abuse.
Definitions
• Agency (Department) P-Card Program Manager (P-Card PM): Appointed by the agency’s director. The P-Card PM is responsible for all aspects of the department’s P-Card program.
• Alternate P-Card PM: An individual who fulfills the P-Card PM duties in the absence of the primary P-Card PM.
• Bank/Card Issuer: Contracted bank issuing the corporate card and processes electronic transactions, authorizations, and billing.
• Billing Cycle: The time between two statement closing dates. Fairfax County’s corporate card billing cycle begins on the 28th of each month and ends on the
27th of the next month. This date is selected because of February and cannot be modified.
• Clickwrap: A clickwrap or clickthrough agreement is a prompt that offers individuals the opportunity to accept or decline a digitally mediated policy
(terms and conditions).
• Cardholder: Employees who have been issued a P-Card.
• Decline: A transaction that was not authorized by the bank or processor.
• Director’s Statement of Responsibility Form: A form, signed by each agency’s director to acknowledge responsibility for the department P-Card program.
• DOF: Department of Finance.
• DPMM: Department of Procurement and Material Management.
• Employee U (EU): An online county learning environment for training.
• Fairfax County Unified System (FOCUS): An online, interactive system that integrates procurement, finance, human resources, and business processes into a single unified system.
• Internal Control Protocol (ICP): An agency document that supplements this PTB by outlining their internal processes, policies, and delegated tasks.
• Merchant: The supplier of goods and/or services.
• Merchant Category Code: A four-digit number that defines the category or type of business a point of sale is registered under with the credit card processor.
• Merchant Category Code Group (MCCG): A list consisting of a group of category codes that may or may not be similar in their business nature.
• P-Card Transaction (Procurement) Log: A paper or electronic document used to record all purchases authorized and made using the P-Card to include the name of the P-Card user, date(s), vendor(s), business purpose, dollar amount and funding source (see attachment C).
• P-Card Change Form: A form used to request changes to a P-Card account (see attachment D).
• Purchase Order (PO): A document that is issued by a purchasing department requesting goods/services from vendor to include price and quantity.
• Point of Sale: The location where a retail transaction is completed.
• Program Administrator: The individual managing the Fairfax County procurement card program at the county level and establishes and enforces countywide P-
Card related policies and procedures.
• Purchasing Cards (P-Cards): A commercial procurement card used to make purchases to achieve greater cost efficiency, control, and convenience.
• Sales Tax Exemption: Free from an obligation to pay sales tax in Virginia using the P-Card on goods and/or services.
Software Purchases
Software purchases must have documentation that the purchase has been approved through the Technical Review Process and any terms and conditions were reviewed and approved by the DPMM Contracts Division.
Agreements, Terms and Conditions
Agencies do not have authority to agree to and sign agreements which include but are not limited to clickthrough and clickwraps with merchants without the review and approval of DPMM’s contracts division and the Office of the County Attorney. Please refer to PTB 12-1019 Exceptions to Competitive Procurement Requirements.
Due to an indemnification clause, agencies are prohibited from joining membership clubs where such agreements exist and require signature, (i.e., Costco/BJ’s Wholesale
Club and Sam’s Club).
Roles and Responsibilities
• Department P-Card Program Manager: Manages the day-to-day operations related to all P-Card activities and is ultimately responsible for managing the program. PM is the point of contact for their department and for DPMM in all P-
Card related matters. PM must ensure there are clear separation of duties amongst the various roles in managing the P-Card program.
• Alternate (Back-Up) P-Card Program Manager: Each agency is required to have an Alternate P-Card PM. The P-Card PM must ensure that the Alternate P-Card
PM is fully trained to assume the duties when the P-Card PM is unavailable.
• Cardholders: A trained employee who properly maintains and/or signs P-Card in and out and follows guidelines put forth in this PTB.
• P-Card Holder: The PM or designee must identify a P-Card holder for each P-
Card. The P-Card holder is responsible for the P-Card’s physical security and may be responsible for more than one P-Card. If operational requirements necessitate more than one P-Card holder for any given P-Card, the department should establish internal controls for tracking card responsibility, where one P-
Card holder remains responsible for the P-Card until relieved by another P-Card holder.
• Reconciler: Reconcilers are departmental staff who may be assigned one or more of the following tasks: review procurement card logs, generate and review reports using the bank’s online reporting tool, review charges in FOCUS, transfer charges to other cost centers using FOCUS, review monthly bank statements, and approve each monthly reconciliation package with all relevant documentation. When multiple reconcilers are identified, all job tasks should be articulated in the department’s ICP.
P-Card Program Eligibility
Unless otherwise specified, the DPMM Director delegates authority to use the P-Card program to all county departments (agencies). Directors of newly created agencies who wish to have a P-Card program must send a request to the DPMM Program
Administrator. The agency director must name the employee who will serve as the department P-Card PM and must sign the “Using Department Director’s Statement of
Responsibility” form (attachment B). The DPMM Program Administrator will work with the new P-Card PM to ensure that all required tasks are completed prior to program implementation. This includes creating an ICP, completion of mandatory training and ordering of new P-Cards.
To participate in the P-Card program, the department must have an active P-Card PM. If the P-Card PM vacates the role, the agency will name either a permanent or temporary
P-Card PM. Failure to have an active P-Card PM may result in a temporary suspension of the department’s P-Cards. If the director leaves the department, the P-Card PM shall ensure that the new director completes an electronic Director’s Statement of
Responsibility form and forward the original to the DPMM Program Administrator at
DPMMPCARD@fairfaxcounty.gov.
The DPMM P-Card Administrator may terminate or suspend a department’s P-Card program temporarily or permanently based upon non-compliance with procurement policies and procedures. The DPMM Administrator is authorized to suspend or close P-
Cards, as necessary.
Internal Control Procedures (ICP)
For each P-Card program, the department must establish and adhere to its own ICP that governs P-Card security, processes, use, and accounting. Development and content of the ICP is delegated to the department, but it may not conflict with this PTB. The P-Card
PM must submit the ICP (both new and revised versions) to the DPMM Program
Administrator for review and approval after the new PTB has been revised. The DPMM
Program Administrator can assist departments with the development of new and/or revised ICPs.
The ICP must address separation of duties, in accordance with PM 12-14 Separation of
Duties. At a minimum, the employee (by job title) who handles the following tasks must be identified: P-Card PM, Alternate P-Card PM or back-up, P-Card holder(s), purchase mailto:DPMMPCARD@fairfaxcounty.gov approver(s), reconcilers, approval of monthly reconciliation packages, training, and
Employee U record for P-Card tests. Procedures for obtaining, safeguarding, and returning P-Cards must also be addressed.
The P-Card PM must maintain a list of all general use P-Cards that includes, at a minimum:
• The last four (4) digits of the P-Card account number.
• P-Card name.
• P-Card control limits.
• P-Card holder and its P-Card location(s).
Ghost P-Cards are not physically stored in the department. However, using the bank’s online reporting tool, the P-Card PM shall maintain a list of:
• P-Card names.
• Last four (4) digits of the P-Card account number.
P-Card PMs are reminded to safeguard these lists so they cannot be easily accessed by way of an electronic password or under lock and key as it contains sensitive information.
P-Card Training
All P-Card PMs are required to attend the program manager training, which is provided by the DPMM Program Administrator. The training includes a detailed discussion of the procedures necessary to obtain, use, and properly account for the department’s P-
Cards’. If requested, DPMM will also provide training to Alternate P-Card PMs and other key staff with P-Card duties.
PM’s must ensure that all new P-Card users and those who have P-Card program duties complete the online course called Introduction to Procurement Card for P-Card Users located in Employee U.
The cardholder must complete the training and pass the embedded test prior to using the P-Card for the first time. They must then submit a copy of the certification to their supervisor or designee. For audit purposes their test will remain in Employee U account throughout their employment with Fairfax County Government.
You will only get notified automatically when your staff enrolls for the P-Card User training in Employee U. However, you can track the training progress by logging into
Employee U, navigating to ‘Manage’ (which is in the blue banner at the top of the page) and then clicking on ‘Team’. This will allow you to see the EU training completion status of your staff.
DPMM highly recommends all existing P-Card holders take the new training within
Employee U.
Ordering Different Types of P-Cards
There are three (3) types of P-Cards.
• Department P-Cards: The first line is embossed with FCG (Fairfax County
Government). The name of a work group or functional area is embossed on the second line of the P-Card; for example, “Administration” or “Lab
Supplies.” P-Card should have a unique name within any given department.
Department P-Cards are easy to share within a work group, reducing the quantity of P-Cards required.
• Individual (Named) P-Cards: DPMM encourages the use of a P-Card issued in an individual’s name instead of a department name when it will be used primarily by one employee. Although individual P-Cards may occasionally be shared when placing telephone or Internet orders, they should not be used to make purchases at retail locations.
• Ghost P-Card (No physical card): A P-Card account number that has been embedded within their respective platform for the use in the FOCUS
Marketplace and eVA. Account numbers are invisible to shoppers and are electronically captured during checkout. Ghost P-Cards are used as the payment tool for all Marketplace orders.
To request a new P-Card, agency PM or designee must complete and submit a P-Card application form through links which can be found on the DPMM SharePoint site.
In addition to completing the application form, the agency must also identify the default cost assignment (i.e., FOCUS fund code, cost center, and general ledger accounts) where the P-Card transactions will post. If P-Card expenditures will affect more than one general ledger account, the department should assign clearing account general ledger
544540 to the P-Card. Departments are required to select a combination of cost assignments that are valid, active, and have sufficient funding budgeted in FOCUS.
During the application process, the cardholder must provide their personal home address if it’s for an individual P-Card. This will not affect their credit score, but it is a requirement from the bank to check the name against the Office of Foreign Asset
Control.
The DPMM Program Administrator reviews the application, fills out the necessary data and submits the application. The bank receives the application for processing, creates a card number and a new card batches overnight. The bank mails the new P-Card directly to the card holder’s address on file. Applications can be sent to the DPMM
Administrator address in extreme circumstances. Please work with your administrator to work out the details. When the P-Card arrives please email the DPMM P-Card email box at DPMMPcard@fairfaxcounty.gov to request the P-Card be activated.
All P-Cards are imprinted with the Fairfax County seal and the Virginia sales tax
“exemption” number with embedded chip technology.
Card Characteristics and Control Limits
The County P-Cards have built-in P-Card limits that include maximum dollar amount allowed for a single purchase limit (SPL), maximum dollar amount allowed per monthly cycle known as a cycle spending limit (CSL), maximum quantity of authorizations allowed per day, and maximum quantity of transactions allowed per monthly cycle.
Generally, County policy restricts the single purchase limit to a maximum of $9,999.
Policy does not establish maximums for other limits, as discussed below. However, all limits must be supported by the P-Card’s business requirements. P-Card limits provide an important safeguard against fraud and misuse. It is important that P-Card limits are set as close as possible to anticipated use. DPMM can work with the department to determine appropriate limits.
Based on anticipated use, total number of P-Cards, budget constraints, and any other relevant factors, the department must determine P-Card limits for each P-Card. Limits may be set at different levels for each P-Card.
Exceptions:
• Special Use P-Cards: If there is a business need for a P-Card to have a higher SPL, the department may request a special use P-Card. The request must be made in writing by the agency Director to the DPMM
Director. The request should detail the business need, identify the higher
P-Cards limits being requested, and the name that will appear on the P-
Card. Most special use P-Cards are associated with vendors who have
County contracts. Use of these P-Cards is limited to the business purpose and parameters as approved by the DPMM Director. The department shall maintain an electronic copy of the memo requesting the special use mailto:DPMMPcard@fairfaxcounty.gov
P-Card as well as an electronic copy of the approval from the DPMM
Director.
• eVA P-Cards: Departments who solicit and/or shop in the Commonwealth of Virginia’s electronic procurement portal called eVA will have an eVA ghost card that is used to make payment to the vendor. The department may have more than one P-Cards with an SPL of up to $99,999. The ghost card account number is embedded in eVA and is invisible to the shopper.
• FOCUS Ghost P-Cards: FOCUS Ghost P-Cards are P-Card account numbers
(no physical card) that are embedded in FOCUS and are used as a payment tool for Marketplace PO’s. Each Marketplace shopper/agency has a ghost P-Card account number that is associated with their user profile. Ghost P-Cards have higher P-Card limits; however, P-Card transactions are limited to MCCs that are associated with Marketplace vendors. The department must assign either the P-Card PM or another departmental point of contact to oversee the Marketplace program.
Reference PTB 12-1008 Online Procurement Using the FOCUS
Marketplace for additional information.
As referenced above, County P-Cards have built-in control limits. Below are the different types of limits.
• Cycle Spending Limit (CSL): The maximum dollar limit of total purchases allowed for the monthly cycle. This limit should be set at an amount slightly above anticipated or estimated monthly spend.
• Monthly Transaction Limit: The maximum quantity of P-Card transactions allowed per cycle. This number should be slightly greater than the maximum number of transactions anticipated per cycle.
• Daily Transaction Limit: The maximum quantity of P-Card transactions allowed per day. This number should be slightly greater than the maximum number of transactions anticipated per day.
• Single Transaction Limit: Each P-Card will have an established single transaction limit determined by the department Program Manager, generally set at $2,500. The maximum single transaction limit can be up to $9,999 with supporting documentation. Transactions above the card’s single transaction limit will be automatically declined at point of sale. If a purchase exceeds the single transaction limit amount, an electronic
Change Request Form (attachment D) must be completed by the agency
PM and sent to the DPMM inbox with a copy of the invoice and the requested temporary increase amount for review and approval.
The P-Card Change Request Form should be used to request various changes to the P- Card to include but are not limited to P-Card activations, monthly credit limit changes, transaction limit changes, single transaction limit changes, password reset etc.
Fairfax County reserves the right to block or prohibit the use of goods and services.
Merchant category codes (MCC) are used to classify a business by the type of goods and/or services provided. A request to unblock a MCC must be approved by the Program Administrator.
Certain types of purchases/merchants may be blocked, such as cash, jewelry, massage parlors, gambling, and other high-risk areas.
Transactions to one of the blocked MCCs will be automatically declined at point of sale.
It is the cardholder’s responsibility to know the P-Card’s allowable/prohibited uses list to determine acceptable use for their P-Card program (attachment A).
There are four main categories of MCCG schemes designed for County use:
▪ FC1: This group excludes purchases from vendor groups listed on
Attachment A. Purchases up to a maximum of $9,999 may be made from all other authorized vendors, including most travel vendors. For most P-
Cards, FC1 is the County standard MCCG.
▪ FC6: This group is the same as FC1 above, except those purchases for airfare in MCC categories 3000 to 3299 are allowed, up to $9,999.
▪ Custom Groups: If supported by a business need, DPMM will work with the P-Card PM to develop a custom MCCG. Many of the special use P-
Cards with high SPLs are set up with custom MCCGs to mitigate risk.
▪ FOCUS MKT Include: This MCCG is specific to FOCUS ghost P-Cards and includes only those approved MCCs for county contracted vendors that participate in the FOCUS Marketplace.
Use of P-Cards
Cardholders may complete legitimate business transactions using various methods such as retail point of sales, telephone and/or internet platforms including electronic ordering in eVA, FOCUS Marketplace and vendors who have e-commerce.
Permitted use of P-Cards include but are not limited to the following:
• Business Travel Expenses: This includes services such as airfare, lodging, car rental, taxis, Uber/Lyft, etc. Refer to Department of Finance (DOF) PM 06-03
Travel Policies & Procedures for additional information.
• County Contracted Goods and Services: Purchases of goods and services from county contracts with verified contract pricing.
• Capital Items (Accountable Equipment): Department may use the P-Card to purchase accountable equipment if it’s in the department’s approved budget. Upon receipt of the accountable equipment, the department must report the items to DPMM using an Inventory Maintenance Report (IMR01).
Please refer to PTB 12-2001 Accountable Equipment and PTB 12-1001 Online
Procurement Using eVA for additional information.
• Non-Purchase Order (PO) Goods and Services: Certain types of purchases, such as capital construction and professional services, made through a competitive procurement process. In instances where a vendor will accept payment with a P-Card, the county P-Card is an acceptable form of payment.
• Technical Review Items: Departments may use their P-Cards to purchase technical review items if they have prior written approval from the technical review department. Further information on technical review may be found in
Technical Review of Purchase Requisitions PM 12-04. Exceptions include goods and services that are ordered in the FOCUS Marketplace – they will automatically route for approval to the technical review department.
• Gift Cards: An allowable purchase expense when purchased for clients and residents. The purchase of gift cards must be tracked using the P-Card log. If gift cards are purchased for County employees as an award, the value of the card must not exceed $50.00 AND must be reported to DHR so the amount can be taxed appropriately as required by the Internal Revenue Service. The
P-Card log must include who received the gift cards. See Personnel/Payroll
Administration Policies and Procedures Memo 18.
Prohibited use of P-Cards include but are not limited to the following:
• Cash Advances: Withdrawal from a financial institution or ATM.
• Split Transactions: Splitting a single purchase into multiple transactions to achieve a smaller total amount to circumvent the single transaction limit is prohibited.
• Rewards: Using and benefiting from a personal membership reward account while completing a county business transaction is prohibited unless there’s a savings recognized by the County.
• Personal Purchases: No personal purchases to include but are not limited to gifts and floral arrangements for weddings, baby shower and/or funerals for employees.
• Purchases by Non-Employees: Only County payroll employees and Virginia
State employees are authorized to make P-Card purchases.
• Services Provided by Independent Contractors: These are tax form 1099 reportable vendors and are subject to technical review by the Department of
Human Resources.
• Inventory Items: Stocked items that are replenished through the FOCUS
Inventory Management (IM) process.
• Travel Expenses: Purchases not permitted include but are not limited to paying for an additional baggage (without documented supervisor approval), upgrading airfare class, upgrading hotel rooms, incidentals to include internet fees not related to business, non-business phone calls, newspapers, on-demand TV/movies, and food/beverage bars. These expenses must be charged to your own personal credit card.
• Restricted Merchant Category Code Group (MCCG): County P-Cards have certain restrictions programmed in to reduce the risk of fraud and improper purchases. Please refer to attachment A for a list of categories that are restricted.
Procedures for P-Card Use
• P-Card Security: Individual P-Cards should be safely stored while department
P-Cards should be kept in a locked location while not in use. Access to the location should be limited to those individuals who require access to the P-
Card. An individual who has possession of a P-Card should exercise reasonable care when carrying the card.
• Funding: General use P-Card purchases do not follow the traditional encumbrance process of a PO, departments must devise a method to ensure that adequate funds are available before each purchase is made. For ghost
P-Cards, funds are encumbered at the time that the FOCUS Marketplace PO is approved within FOCUS.
• Purchase Approval: The department shall follow their own ICP to ensure that each purchase is properly authorized.
• P-Card Transaction Log: For general use P-Cards, the department shall maintain a log that records purchases as they occur and tracks who is in possession of P-Cards. Departments may use a manual or an electronic log to record both debit and credit transactions. Entries must be current so that they provide up-to-date information on funds expended and should identify the P-Card user. Department staff may use the example in this PTB, attachment C, as a guide when developing a P-Card transaction log.
Departments should ensure that it contains all the elements as shown in attachment C.
• Marketplace POs: For Marketplace POs that are paid via ghost P-Cards, department staff may use PO documents or a P-Card transaction log as a tool to track spending to ensure that the P-Card has sufficient credit availability for the monthly billing cycle. Ghost P-Cards are account numbers only (no physical card), tracking possession of the card is not a requirement.
• Purchases at Retail Locations: P-Card users should present their County ID prior to the completion of their transaction when making a purchase in person to ensure no Virginia sales tax is added. Be sure to obtain and submit receipt(s) to your agency for documentation.
• Sales Tax Exemption: Most county purchases are exempt from Virginia state sales tax. When making a P-Card purchase, users should inform the vendor of the county tax exempt status and examine the receipt to verify sales tax was not charged. The county’s “exempt number” is printed on the upper left-hand corner on the front of each P-Card. The Commonwealth of Virginia permits local governments hosting meals and catering events to be exempt from paying sales tax if the event is NOT for employees. The county is not exempt from sales tax imposed by other states on goods and services purchased outside of Virginia.
Updating P-Cards
If the department wishes to change any aspect of a P-Card, such as default account assignment (Cost Center, General Ledger, Fund , Grant) or P-Card limits, the P-Card PM or designee must submit the requested changes to the DPMM Administrator via email to DPMMPcard@fairfaxcounty.gov. The DPMM Program Administrator will review and approve the changes and notify the department when the changes are in place.
P-Card Closure
If a department wishes to close a P-Card (i.e., no longer required or P-Card user leaves the department), the P-Card PM must submit a request to the DPMM Administrator via email to DPMMPcard@fairfaxcounty.gov with the name and the last four digits of the P-
Card. The P-Card PM must ensure that the P-Card is shredded.
Lost and Stolen P-Cards
Lost or stolen P-Cards must be reported to the DPMM P-Card Administrator immediately by emailing the P-Card email box at: DPMMPcard@fairfaxcounty.gov. All department P-Card users should be trained on the proper procedures for reporting a lost or stolen card, including how to proceed when the P-Card PM or DPMM Program
Administrator is not available at the time the loss is discovered. The DPMM Program
Administrator will review the email and reach out with any questions and then obtain a new replacement P-Card from the County’s contracting bank.
Fraud and Misuse
Each department is responsible for actively monitoring their P-Cards from fraud and misuse. Fraud prevention efforts may further be enhanced by when the below controls are followed:
• Limit P-Card Access: Maintain P-Cards in a locked location when not in use and limit access to provide greater security.
• Protect P-Card Information: Protect all P-Card information such as the P-Card name, account number, and expiration date. File reports that contain P-Card numbers in locked file cabinet. Shred documents when disposing of P-Card reports or other paperwork. Ensure security of P-Card documentation that is maintained electronically.
• Perform Weekly Reviews: Performing weekly reviews of all P-Card activity will reveal transactions that look suspicious or that do not appear to belong to the department.
mailto:DPMMPcard@fairfaxcounty.gov
• Establish Reasonable P-Card Limits: Establish reasonable spending and transaction limits. This will limit risk in the event the P-Card or the account number is compromised.
• Adequate Separation of Duties: No one person should have multiple roles that may cause a conflict of interest. No person should initiate a transaction, execute a transaction, and then approve the transaction.
If fraud or misuse is suspected or confirmed, the P-Card PM or designee shall take the following steps:
• If it appears that an unauthorized charge (or attempted charge) has been made, the PM should contact DPMM immediately at
DPMMPCARD@fairfaxcounty.gov providing the specific transaction details in question. The DPMM Administrator will work with the bank to close and reissue the card.
• Do not file an online “dispute” in cases of fraud. Dispute is a disagreement between a county department and a legitimate vendor regarding an authorized purchase (see Dispute section for further information).
• If there is a suspicion of fraud or misuse by a county employee, the P-Card
PM should contact the Internal Audit Office for assistance. Depending on the circumstances, the department may want to mitigate risk by requesting
DPMM to place the P-Card on a temporary hold or requesting that the P-Card be closed permanently. Should a county employee make fraudulent charges or misuse the P-Card, the county will seek reimbursement from the employee.
• If the fraudulent incident occurred in Fairfax County or if the fraudulent charge was made by a Fairfax County employee, the matter is considered a violation of law and the department is required to file a police report with the Fairfax County Police Department (FCPD) so that it can be investigated as a criminal matter. The case number must be submitted to DPMM before a replacement P-Card will be released to the P-Card PM. If the fraud occurred outside of the County (i.e., Internet hacking or counterfeit P-Card), the department may optionally file a police report with FCPD; however, depending on the circumstances, FCPD may not be able to investigate a crime that occurred outside of the County’s jurisdiction.
• If a fraudulent charge posts to the P-Card account, the P-Card PM and DPMM
Program Administrator shall make every effort to obtain a credit from the bank.
mailto:DPMMPCARD@fairfaxcounty.gov
Disputes
A dispute is defined as an instance when a vendor has incorrectly charged a P-Card.
Examples include charging the P-Card twice, charging the wrong price, charging sales tax when it’s supposed to be exempt, or adding a shipping fee when it was promised to be free. A dispute is usually NOT fraud; it is usually a disagreement between the county and the vendor.
The department is responsible for pursuing credit adjustments for any items that are incorrectly billed by the vendor. The department should first request an adjustment from the vendor, documenting all oral and written correspondence. If that is unsuccessful, the P-Card PM or designee should file a dispute with the bank. The P-Card
PM may contact the DPMM Administrator for guidance on the subject.
Disputed charges must be reported to the bank within 60 days of the P-Card posting date, using the bank’s online reporting tool. The bank will issue a temporary credit adjustment on the P-Card account until the investigation is complete. Depending on the outcome of the investigation, the credit may become permanent or be reversed. If it’s beyond the 60-day period, the bank has no obligation to review the dispute.
Procedures for Reconciliation
The contracted bank provides P-Card management software which is an online reporting platform that enables department staff to create a variety of program related reports.
DPMM will coordinate software access and training with P-Card PMs.
• Weekly Transaction Detail Report: Each week designated department staff are required to prepare the P-Card transaction detail reports showing all transactions from the prior week for both general use P-Cards and ghost P-
Cards. They must review the reports in a timely manner. Prompt review is vital to detection of erroneous and/or fraudulent charges.
P-Card reconciliation is the process of verifying the accuracy of all posted P-Card transactions, both debits and credits. Department staff must perform two reconciliations, to bank records and to FOCUS:
• Reconciliation to Bank Records: At a minimum, on a weekly basis, the department is required to use the bank’s transactions detail reports to reconcile charges for both general use P-Card transactions and ghost P-Card transactions. Departments should review the reports, looking for any abnormalities. Any charges that are not recognized or appear to be fraudulent should be addressed immediately. Monthly billing statements should be filed with the monthly reconciliation package.
o For general use P-Cards, the department must reconcile the bank’s report to the purchase log, original/electronic receipts, and any other pertinent documentation to verify that all charges are proper and that the correct amounts have been charged.
o For FOCUS P-Cards, the department must reconcile the bank’s report to FOCUS Marketplace PO documentation, including packing lists or other receipt documentation to verify that all charges are proper and that the correct amounts have been charged.
• Reconciliation to FOCUS: Each department must ensure that all P-Card transactions are properly posted in FOCUS monthly, at a minimum.
Departments can use the bank’s transaction details reports, logs, receipts, and FOCUS Marketplace PO documentation as reconciliation tools.
o The department must verify that each order is posted in FOCUS. Each general use P-Card transaction will post to FOCUS as one entry for the total amount of the order (debit or credit). If the general use P-Card transactions post to a clearing account (i.e., GL 544540 Credit Card
Expense), the department must move those charges both debits and credits to the appropriate expenditure account monthly, at a minimum.
o Each FOCUS Marketplace PO line item generates an electronic invoice and receiving report at the time the bank’s billing file is uploaded to
FOCUS. DPMM permits the departments to reconcile these charges in two different ways. Departments with a small volume of orders may wish to reconcile each PO line in FOCUS. Departments with a large volume of orders may wish to reconcile by exception, in which case they can use open FOCUS PO reports to identify lines that may have not posted properly. For assistance with Marketplace PO lines that may have not posted properly, contact DPMM. Most FOCUS transactions post directly to the account assignment that is identified at the time that the Marketplace PO is entered and therefore do not need to be moved from a clearing account.
Following review, the reconciler(s) is required to sign (email, DocuSign or FOXIT) physically or electronically and date all reconciliation documentation to include but are not limited to the bank’s transaction detail reports, monthly bank statements if applicable, journal entry workbooks, etc., to document that the reconciliation was performed in a timely manner and to establish that an adequate separation of duties exists. Email exchanges are acceptable documentation for reconciliation.
Policy discourages the reconciler from being a P-Card user; however, if the reconciler uses the P-Card, the reconciliation must be reviewed by another staff member, preferably a supervisor. The reviewer must sign (electronically or physically) and date the reconciliation.
Emergency Dispensation of P-Cards
Agencies may experience an urgent need to have their P-Card(s) restrictions loosen to accommodate mission-related purchases that otherwise are not permitted due to either
MCC restrictions and/or P-Card control limits.
Emergency events may include but are not limited to the deployment of the Fairfax
County Urban Search and Rescue teams, inclement weather, and law enforcement personnel on business travel.
To initiate the emergency dispensation of the P-Cards, agencies are required to reach out to the DPMM P-Card Administrator via email to
DPMMPCARD@FAIRFAXCOUNTY.GOV providing justification and/or documentation for the request, the duration of this dispensation and the name and last four digits of the P-
Cards affected.
The DPMM Administrator will then review the request and reach out to the Deputy
Director of DPMM with a recommendation for final approval. If the Deputy Director is unavailable, then the Director of DPMM should be contacted.
In the event both the Deputy Director and Director of DPMM are unavailable, the
DPMM Administrator will use its discretion on granting the emergency dispensation while documenting the process and actions taken.
Once the emergency has passed, the DPMM Administrator will revert all affected P-
Cards back to their original restrictions and limits.
mailto:DPMMPCARD@FAIRFAXCOUNTY.GOV
Receipts
Department staff shall retain paper or electronic detailed vendor receipts and invoices for each transaction. Receipts should show all details pertinent to the transaction, including date of purchase, vendor name and location, item(s) purchased with corresponding description(s) and price(s), and total amount paid. The business purpose of the goods or services should be clearly documented if it is not readily apparent (i.e.
refreshments for annual vendor forum.) For goods that are delivered with packing slip, the packing slip should be signed, dated and retained as evidence that the goods have been received. All receipt documentation should be filed with the appropriate bank record (monthly statement or weekly transaction detail report) and retained by the department.
If a receipt/packing slip is unavailable, the department may use an alternate receipt, such as an Internet screen print, a scanned receipt, or order confirmation. The receipt should contain the same level of detail required for an original receipt.
If a photocopied receipt is retained instead of an original, the record should provide a short explanation as to why the electronic receipt was unavailable.
If, for any reason, an original, alternate, electronic, or photocopied receipt is unavailable, a memorandum providing the purchase details and reason why a receipt is not available must be included with the appropriate monthly statement or weekly transaction detail report.
Both photocopied receipts and documentation in lieu of missing receipts must be signed and dated by the P-Card PM or designee. If the purchase was made by the P-Card PM, another staff member must sign and date the receipt to maintain an adequate separation of duties. Email exchanges are acceptable signatures.
Violations and Consequences
The P-Card Program Administrator has the authority to investigate and determine whether a violation of procurement policy has occurred, and to recommend actions that may be taken because of such determinations. DPMM will consider the facts and circumstances of each incident, and will act appropriately, and as permitted by applicable law and/or policy. Human error and extraordinary circumstances may be taken into consideration when investigating any violation of policy.
Policy violations include but are not limited to purchasing of items for personal use, purchasing items defined as prohibited and splitting transactions as discussed in prior sections.
DPMM retains the right to terminate the card holder’s privileges upon violation and user must retake P-Card training in Employee U to regain access to the P-Card.
Compliance Reviews
The P-Card program is subject to review by DPMM, DOF, and the county’s external auditors. In addition, business process audits will be conducted on a cyclical basis by the
Internal Audit Office.
The department must retain all records to include P-Card reconciliation documentation for a minimum of three years plus the current year in accordance with VA Public
Records Act for retention of books, accounts, and records § 6.2-1916.
Referenced Documents
Documents referenced in this PTB can be located on the DPMM and DOF SharePoint site.
• PM 12-1010 Technical Review of Purchase Requisitions.
• PM 12-14 Separation of Duties.
• PTB 12-1001 Online Procurement Using eVA Marketplace.
• PTB 12-2001 Accountable Equipment.
• PTB 12-1008 Online Procurement Using the FOCUS
• PTB 12-1019 Exceptions to Competitive Procurement Requirements.
• PM 06-03 DOF Travel Policy.
Revision Control
Supersedes PTB 12-1009 Use of The County Procurement Card, dated 11/18/2016.
APPROVED BY:
2023 November 6 | 07:23:57
Lee Ann Pender, CPPB Date
Director/County Purchasing Agent
Attachment A
Fairfax County P-Card Merchant Category Code (MCC) Restrictions
MCC Groups (MCCG)
Updated 10/01/2016
MCCG Name
MCC #
MCC Description
Include
Exclude
Single Trans Max.
$Limitation*
FC1
3000-3299 4511 & 4582
All Airlines
X
Wire Transfer, Money Orders
Duty Free Stores
Furriers and Fur Shops
Wig and Toupee Shops
Bars, Cocktail Lounges, Taverns - Drinking Places
5921 Package Stores
X 0
5933 Pawn Shops
5972 Stamp and Coin Shops
6000-6999 Financial and Related Institutions
7230 Beauty Salons
7273 Dating and Escort Services
7297 Massage Parlors
7298 Health and Beauty Spas
7932 Billiard / Pool Establishments
Betting (Lottery, Off-Track, Racetrack, etc.)
9223 Bail and Bond Payment
All other MCCs X
$ 2,500.00 *
$99,999.00**
FC6
Wire Transfer, Money Orders
(Airlines Allowed)
Duty Free Stores
Furriers and Fur Shops
Wig and Toupee Shops
Bars, Cocktail Lounges, Taverns - Drinking Places
5921 Package Stores
5933 Pawn Shops
5972 Stamp and Coin Shops
6000-6999 Financial and Related Institutions
7230 Beauty Salons
7273 Dating and Escort Services
7297 Massage Parlors
7298 Health and Beauty Spas
7932 Billiard / Pool Establishments
Betting (Lottery, Off-Track, Racetrack, etc.)
Bail and Bond Payment
All other MCCs X $ 2,500.00 *
* Maximum single transaction limitation. This figure may be set lower by department request. ** eVA P-Cards may be set at a maximum SPL of $99,999.00Note: FC1 and FC6 MCC Groups are the standard groups for P-Cards. Special use cards generally have a Custom named group with restrictions that are specific to the P-Card itself. When appropriate, DPMM will work with the department to set up a special MCCG.
Attachment A (continued)
Fairfax County P-Card Merchant Category Codes (MCC)
FOCUS Marketplace P-Card Purchase Restrictions (Exclude) Company #15678
Updated 10/1/2016 (FOCUSMKT Include)
MCCG
Name
Custom/
Standard
MCC #
MCC Description
Include
Exclude
Single Trans
$Limitation*
FOCUSMKT Custom 5045 Computer, peripherals, software X $15,000
5065 Electrical parts & equipment X $15,000
5111 Office supplies, paper, etc. X $15,000
Dec 2015 5943 Office & school supplies, etc. X $15,000
XXXX For future MCC X
Attachment B
Attachment B (Sample)
Attachment C
Attachment D:
File details come from the government source that posted it. Updated .