APC Questions/Answers
for
GSA CONFERENCE 2012
1 August
Nashville, Tennessee
DON CONSOLIDATED CARD PROGRAM MANAGEMENT DIVISION (CCPMD)
Session Objective
To provide answers to questions regarding
the DON Purchase Card Program received
from APCs.
2
Approach
Grouped the Q&As according to the lay-out
of the new NAVSUPINST 4200.99B and
answered them as simply as possible.
3
Question
Roles and Responsibilities
Who is the proper Appointing Authority?
4
Answer
Roles and Responsibilities
The Head of Activity (HA) or their designee is
the proper Appointing Authority for each
Agency.
5
Question
Roles and Responsibilities
Must appointments be redone when the
Appointing Official that signed it leaves?
6
Answer
Roles and Responsibilities
Change of Appointing Official does not require that a
new appointment document (i.e. DD 577, Letter of
Delegation, Letter of Appointment) be issued.
The only time an appointment document must be
redone is when the authority changes.
For example, if a CH‟s authority is going to be changed
to include using their card to pay for training authorized
using a SF-182, then their letter of delegation should be
reissued. Similarly, if an AO/CO receives authority to
certify purchases for an activity that‟s different from the
one on their current DD 577, a new DD 577 should be
made to reflect the new authority.
7
Question
Roles and Responsibilities
When a GCPC participant leaves the program,
is there a requirement for Section IV of the DD
577 to be completed?
8
Answer
Roles and Responsibilities
Yes. All DD 577 appointments must be terminated by
completing Section IV of a copy of the original DD 577.
Approving Official/Certifying Officials: The A/OPC must
notify DFAS that the appointment has been terminated by
mailing the DD 577 to DFAS and putting a copy of the DD
577 in the AO/CO‟s personal file. If the AO/CO is not
available to initial the termination, indicate N/A in box 19.
Cardholders: The A/OPC DOES NOT need to notify DFAS,
but must put the completed DD 577 in the CH‟s personal
file.
9
Question
Roles and Responsibilities
If an employee is nominated to become a CH
and the employee was a poor AO, can the
A/OPC refuse to accept the nomination?
10
Answer
Roles and Responsibilities
Supervisors are responsible for nominating
trustworthy and competent personnel to fill
GCPC program positions.
Supervisors are responsible for taking
disciplinary action when poor performance is
demonstrated.
The A/OPC should work to develop a good
relationship with supervisors and managers and
inform them of any performance problems with
personnel the supervisor nominates.
11
Question
Roles and Responsibilities
How are the below forms used?
Letter of Delegation
Appointment Letter
DD 577
12
Answer
Roles and Responsibilities
Letter of Delegation (LOD) – Involves Contract
Authority. Only A/OPCs and CHs are issued
contract authority.
A/OPC LOD - Delegates the authority to manage the
GCPC program and issue Letters of Delegation to
CHs .
CH LOD – Delegates authority to commit the
government using the GCPC. Should include limits
to what can be purchased and amount. Documents
pecuniary liability, has DD 577 attached.
13
Answer
Roles and Responsibilities
Appointment Letter – Used to appoint an AO/CO.
Indicates duties and limits. Documents
pecuniary liability, has DD 577 attached.
DD 577 – Form serves two purposes. Attached
to AO/CO Appointment Letter and CH LOD.
1) Notify DFAS of appointment to certify invoices for
payment, contains signature specimen (AO/CO
only)
2) Appointment and acceptance of pecuniary liability
AO/CO and CH
14
Question
Roles and Responsibilities
Does a AO/CO really need to submit a DD 577
with a wet signature if they do not manually
certify vouchers?
15
Answer
Roles and Responsibilities
Yes, the original DD 577 with a handwritten
signature of the AO/CO is required to be on file
at DFAS. It is required whether using manual
or electronic certification.
A manual certification may be needed to
correct a billing account error and a signature
must be on file at DFAS.
16
Question
GCPC Program Management
What if an AO refuses to provide their
SSN for DD 577?
17
Answer
GCPC Program Management
If an AO refuses to provide their SSN, DFAS
could refuse to make a payment and the
command could take disciplinary action.
18
Question
Roles and Responsibilities
Why does the DD Form 577 require a
complete SSN?
19
Answer
Roles and Responsibilities
Per FMR Volume 5, Chapter 33, you must
include the appointee‟s full Social Security
number on the DD 577 to enforce pecuniary
liability if needed.
20
Question
Roles and Responsibilities
How is authority to use the GCPC above
the micro purchase threshold delegated?
21
Answer
Roles and Responsibilities
A/OPCs can use a Letter of Delegation to provide
authority for a CH to:
1) Acquire commercial training up to $25,000
2) Acquire reproduction/printing services less than
$50,000 from DLA Document Services
3) As a method of payment for contract
actions/orders placed by a warranted Contracting
Officer or Ordering Officer
Any other authority to use the GCPC above the
micro purchase threshold must be provided by
SF-1402 issued per HCA procedures.
22
Question
GCPC Program Management
What are the rules governing a foreign
national performing GCPC program duties?
23
Answer
GCPC Program Management
Currently the Financial Management Regulation
(Volume 5, Chapter 33) prohibits Indirect Hire
Foreign Nationals from performing CH, AO or
APC duties.
This prohibition is being reviewed by the OSD
General Counsel (GC).
Until the OSD GC rules, the DON policy will
allow Indirect Hire Foreign National to perform
CH, AO/CO or A/OPC duties.
24
Question
GCPC Program Management
With the recent emphasis on audit readiness, will
there be any changes to how the purchase card
program is currently managed?
25
Answer
GCPC Program Management
No change to GCPC Program Management
Policy is anticipated.
Reason for new emphasis on audit readiness
is to validate the DON and DOD Financial
Statement.
The impact to GCPC program is uncertain.
Check with your comptroller before
destroying any GCPC supporting
documentation.
26
Question
GCPC Program Management
What is the connection between the Financial
Improvement and Audit Readiness (FIAR) and
the Government Purchase Card Program?
27
Answer
GCPC Program Management
The Purchase Card Program is intended to
simplify small purchase methods, minimize
paperwork and streamline payment processes.
FIAR is an audit of financial processes.
Making payments using the GPC is considered
a financial process.
28
Question
GCPC Program Management
With the FIAR being put in place, is this going
to take the responsibility out of the hands of the
AO/CO or A/OPC, since the Command will not
be doing the scanning of documentation?
29
Answer
GCPC Program Management
No, the AO/CO is still responsible for
maintaining the original supporting
documentation for six years and three months
(10 years for Foreign Military Sales funding).
Before destroying any GCPC supporting
documentation the AO/CO should check with
their local comptroller.
30
Question
GCPC Program Management
Where can I get training on Citi systems?
31
Answer
GCPC Program Management
Citi recently introduced a new self service
training module accessible from CitiManager.
Training on CitiManager, CCMS, CCRS and PAT is
available using CITI Commercial Card Learning and
System Support (CLASS) from the Web Tools menu.
Citi always welcomes input from experienced
users to improve training offered from CLASS.
Suggest you visit the Citi computer lab or
attend a CitiManager training session while at
the conference.
32
Question
GCPC Program Management
Can you walk through the process for updating
accounts with new fiscal year Lines of
Accounting?
33
Answer
GCPC Program Management
The process is as follows:
1
2
3
4
LOAs are downloaded from CCMS and updated
with new FY information in the BFYEFY and Cost
Code segments.
Updated LOAs are disseminated via HL3 A/OPCs
to HL5 A/OPCs for local Comptroller
review/correction and return to CCPMD.
LOAs are validated in CCMS and bad LOAs
returned to HL5 A/OPCs for correction.
LOAs applied to accounts.
34
Answer (Cont‟d)
GCPC Program Management
This year Citibank is automating the Fiscal Year
Rollover within CCMS. Within CCMS, FY
information will be automatically updated in
existing LOAs and then validated.
CCPMD will provide additional guidance
regarding HL 5 A/OPC responsibilities via PCAN.
Recommend that you attend the Citibank
training session on Thursday, August 2 from
8:00 – 9:10 in the Delta Mezzanine Bayou E
Room to see an overview of this new process.
35
Question
GCPC Program Management
Why do Convenience Checks need to be bulk
funded?
36
Answer
GCPC Program Management
The last update to the Financial Management
Regulation (FMR) removed this requirement so
Convenience Checks no longer need to be
bulk funded.
37
Question
GCPC Program Management
The FPDS Reporting system is user UN-friendly
and asks for too much information that seems
redundant with data maintained by Citi.
Untrained personnel are inputting data they
don‟t understand. FPDS training is lacking, and
it‟s difficult to use.
Is there a plan to simplify the use of FPDS?
38
Answer
GCPC Program Management
FPDS was designed to be used by trained Contracting
Officers to capture, report and analyze contract actions.
Only CHs authorized by SF-1402 should be performing
contract actions that must be input into FDPS.
How to use FPDS should be part of training for being
issued an SF-1402.
Each Command has an FPDS subject matter expert to
answer FPDS questions or make suggestions to improve
FPDS.
Try: https://www.fpds.gov/fpdsng_cms/index.php/training
39
Question
GCPC Program Management
If we have a single instruction governing the
GPC program, should we now think about
establishing a standard IOP?
40
Answer
GCPC Program Management
NAVSUPINST 4200.99B provides high level
overarching GCPC policy to allow
Commanders the flexibility to develop
operational procedures aligned to their
specific mission.
A “standard” Internal Operating Procedure
would not address the unique mission
requirements of each activity.
41
Question
GCPC Program Management
Since reviewing and advising on acquisition
policy is a major part of the job, is there any
thought to requiring all A/OPCs to be in the
DAWIA corps?
42
Answer
GCPC Program Management
There is no plan to require GCPC A/OPC
positions to be part of the DAWIA corps.
There are specific personnel policies that
govern the establishment and filling of DAWIA
positions.
If an Activity wants to require their A/OPCs to be
DAWIA certified, they should discuss this with
their Command Personnel policy experts.
43
Question
Using the GCPC
What are “terms and conditions”?
44
Answer
Using the GCPC
Terms and conditions (T&Cs) are those special
requirements that apply to a purchase, and
because they are special requirements should
be stipulated in a contracting document.
T&C can be required by the Government or the
Vendor.
Government T&Cs include specification,
inspections, etc.
Vendor T&Cs include additional payments,
restrictions, penalties, etc.
45
Answer (Cont‟d)
Using the GCPC
CHs should not sign vendor T&C. Ask the
vendor to waive their T&Cs or look for another
vendor.
Commercial products delivered with written
T&C that are not signed are OK.
Check with your local contracting office if you
have questions regarding T&Cs.
46
Question
Using the GCPC
What can a SF-182 be used for?
Can it be used to reserve a space for a nontraining meeting?
47
Answer
Using the GCPC
When used with the GCPC, a properly completed
SF 182 authorizes payment of approved training
expenses under the following conditions:
 Must be a single training event not to exceed $25K
 Must be a fixed price event
 Must be commercial off-the shelf w/no modification
resulting in extra cost to the government
The SF-182 is not used to purchase general
supplies, training equipment, or non-training
services. Therefore, it is not used to reserve
space for a training or non-training event.
48
Answer (Cont‟d)
Roles and Responsibilities
The SF 182 is also used for requesting,
approving, and for attendance at meetings,
conferences, seminars, and symposia where the
primary purpose is to train an employee to meet
a performance improvement related need.
49
Question
Using the GCPC
When purchasing training, is it necessary for
the purchase cardholder to update the
purchase log after it has been submitted for
approval to show that a course was received?
50
Answer
Using the GCPC
The purpose of the purchase log is to reconcile
the bank statement with what the CH purchased.
Many times training is purchased prior to the
student attending the course. In this case the
training could be paid using „pay and confirm‟
procedures.
Like any purchase, receipt of training should be
documented; procedures for documenting
completion of training can be included in the
Activity IOP.
51
Question
Using the GCPC
What is the policy for using the purchase card
to pay for tuition fees or conference fee
associated with official TAD/TDY trips.
52
Answer
Using the GCPC
The common element between Tuition and
Conference Fees are they both usually need to be
paid in advance.
Tuition fees should be authorized using an SF-182
and paid for using the GCPC.
Conference fees may also be authorized using SF
182 and are usually paid for using the GCPC.
Conference fees may be placed on the travel card,
ONLY when feasible (low cost or at conference).
53
Question
Using the GCPC
Why are CHs required to „screen‟ or check
FAR Part 8 Mandatory Sources?
54
Answer
Using the GCPC
FAR 13.201 states the requirements in Part 8
(Required Sources of Supplies and Services)
apply to purchases at or below the micropurchase threshold.
55
Question
Using the GCPC
How should a CH ensure compliance with
requirement of FAR Part 8 ?
56
Answer
Using the GCPC
The easiest way to comply with FAR Part 8
requirements is to make purchases using a
Government online purchasing system like DOD
EMALL, GSA Advantage or VA.Gov.
These systems provide information to help the
CH comply with FAR Part 8 and other
procurement requirements like Strategic
Sourcing, Green Procurement and supporting
Small Business.
57
Question
Using the GCPC
What steps should a CH consider when getting
ready to make a buy?
58
Answer
Using the GCPC
1. Ensure funding is available.
2. Check the requirement.




Approved by authorized individual
Item description and need date
Not available from the „supply system‟
Strategic sourcing item? Office Supplies,
Incidental Janitorial Supplies, Furniture,
Wireless Services,
3. Use online purchasing system to check
required sources.
4. Make the purchase.
59
Question
Using the GCPC
How can I find out if I am allowed to buy
something with the GCPC?
60
Answer
Using the GCPC
Check GCPC policy for prohibited items
Check CCPMD website FAQs
Check GCPC Desk Guides
Apply the Necessary Expense Rule
Search GAO „Red Book‟
Seek advice from local experts
Contracting Office
Comptroller
Legal Office
HA makes decision based on advice
Document decision and advice
61
Question
Using the GCPC
How should I handle iPad Buys?
62
Answer
Using the GCPC
Buying IPADs and similar devices present several risks,
such as property accountability, security and recurring
payments. These purchases will most likely be the
target of any audit.
The Chief of Naval Operations recently released
guidance for purchasing Information Technology (IT)
products, supplies, and services that requires
Command CIO approval of non-weapon or non-C4ISR
system IT related purchases under $500K.
While not Purchase Card policy, CHs need to be aware
of this new IT Procurement Policy when purchase IT
equipment, supplies, and services.
63
Question
Using the GCPC
What controls are in place for deleting
downloadable apps that are not needed by the
next user?
64
Answer
Using the GCPC
Each Activity should develop its own procedures for use,
tracking, and disposal of these devices.
 Procedures should be placed in the Agency‟s IOP.
 Devices and Apps should only be purchased if
necessary for mission accomplishment. “Necessary
Expense Rule” applies.
 Apps should only be deleted if the mission changes.
The purchase should be centered around the
mission, not the person.
65
Question
Using the GCPC
What is the policy for purchasing command
coins?
66
Answer
Using the GCPC
Command Coins may be purchased using
appropriated funds.
 As an AWARD to recognize individual
outstanding performance that contributes
to a command's efficiency and
effectiveness
 Should be limited in number, accounted
for in a logbook, and NOT personalized
with the CO name.
67
Answer (Cont‟d)
Using the GCPC
Command Coins may be purchased using
appropriated funds as RECOGNITION for
military recruitment or retention.
 Each coin shall be of nominal value (less than $50
per item).
 Used to recognize and commemorate their service
 Document justification for the basis for the
recognition
 Can be presented to members of the armed forces
and their families, and other individuals recognized
as providing support that substantially facilitates
their service in the armed forces
68
Answer (Cont‟d)
Using the GCPC
Command Coins may be purchased using ORF
funds.
 Mementos to foreign dignitaries or other
prominent citizens NTE $335 (command coin
NTE $50)
 Mementos to prominent visiting DoD/DoN
officials NTE $40
69
Question
Using the GCPC
Why do some EMALL venders require minimum
purchases which sometimes are more than we
need?
70
Answer
Using the GCPC
One of the benefits to using EMALL is strategic
sourcing which allows Navy to negotiate better
pricing. Some vendors have minimum ordering
requirements to help control prices. Small orders
drive up unit costs and without the minimums the
vendor would not be able to provide the items at
the contracted price. Remember these minimums
are order specific not item specific. Office
Supplies are rarely emergent where an order can‟t
be "saved" until more items are required and the
minimum is met.
71
Question
Using the GCPC
Our providers are very passionate about getting
the community involved in their healthcare.
What is the policy on "give-away" items for
health fairs, patient safety, etc.?
72
Answer
Using the GCPC
Activities frequently want to use gifts to attract attention to
their Activity‟s mission or to specific programs. For
example, gifts are often used as recruiting tools or to
inform individuals about an Activity‟s program.
The general rule is Appropriated funds may not be used for
personal gifts, unless there is specific statutory authority.
Because a necessary expense analysis is case specific, it
is impossible to draw a rational line identifying the gift
items that are acceptable and those that are not. It is
important that anyone confronting a "gift" issue scrutinize
the case law carefully to appreciate distinctions that may
not be apparent at first. This is why we recommend getting
your legal office involved.
73
Question
Using the GCPC
Instead of paying for something I‟ve yet to
receive, wouldn‟t it be better to simply roll it to
the next billing cycle?
Is there a plan to modify pay & confirm to
alleviate confusion?
74
Answer
Using the GCPC
The GCPC program uses industry charge
card business rules; any change to these
business rules would be cost prohibited.
To avoid having to use Pay & Confirm
procedures a CH can take the following steps:
 Buy EARLY in the billing cycle
 Ensure items are available for deliver when
ordering
 Confirm anticipated receipt date
75
Question
Using the GCPC
Given the increased emphasis and review on
conferences, are there any additional
requirements for GPC payments for
conferences below the micro purchase level?
76
Answer
Using the GCPC
The recent attention to conferences focuses on
approving the hosting and attendance of
conferences, NOT paying for conferences.
However, a CH should ensure any conference
fee they are asked to pay is approved by the
conference attendee‟s supervisor.
77
Question
Using the GCPC
Will there be a strategic sourcing initiative
(contract) for IT equipment?
78
Answer
Using the GCPC
The DON Strategic Sourcing Team does not expect a
single IT contract will be awarded.
CNO message 152325Z NOV 11 requires acquisitions of
non-weapon or non-C4ISR system related IT materiel
and support services above $500K to be processed
through SPAWAR.
Non-weapon or non-C4ISR system IT acquisitions below
$500K must be approved per Command CIO procedures.
CHs should not procure any ensure IT requirements
have been approved by their Command CIO.
79
Question
Using the GCPC
Due to the requirement to maintain all
documentation indefinitely for audit readiness
purposes, can we start scanning documents
over 7 years old and maintain them
electronically in order to save space?
80
Answer
Using the GCPC
NAVSUPINST 4200.99B allows for scanning
and electronic storage of supporting
documentation if procedures are in place to
ensure the scanned image is an accurate
representation of the original document and
the storage system is centrally managed with
a backup system.
Scanning and electronic storage procedures
that meet the above requirements should be
documented in the Activity IOP.
81
Question
Using the GCPC
DoD EMALL surcharge. Does the surcharge
ONLY apply to office supplies?
82
Answer
Using the GCPC
No – The surcharge applies to ALL DLA stock numbered
items not just office supplies or EMALL.
The surcharge reimburses the Stock Fund for expenses
in managing the item and is a long established process
for funds management in the supply system.
There is NO surcharge when shopping in the Navy
Contracts corridor.
83
Question
Using the GCPC
If CH‟s go outside the Navy Contracts
corridors, will they be required to justify the
use of other corridors regardless if what is
being purchased is an office supply or not?
84
Answer
Using the GCPC
No justification is needed to use “All DOD
EMALL” for office supplies not found in the
Navy Contracts corridor.
Navy policy for acquisition of office supplies is
to use the base supply stores (ServMarts) or
vendors in the Navy Contracts Corridor of
EMALL.
If using EMALL, only if the office supply product
cannot be located from the Navy Contracts
Corridor should the search be expanded to “ALL
DOD EMALL”.
85
Question
Using the GCPC
If an office supply item is not found within the
Navy Contracts corridor, will CH‟s be required
to use a local ServMart first (to avoid the
surcharge) prior to using any of the other
corridors?
86
Answer
Using the GCPC
DON Office Supply Policy does not prioritize
between EMALL and SERVMART, both are
authorized sources of supply for office
supplies. Shopping in the Navy Contracts
Corridor will avoid any surcharge.
Only if the office supply product cannot be
located from the Navy Contracts Corridor
should the search be expanded to “ALL DOD
EMALL”.
87
Question
Using the GCPC
Who has the waiver authority for the furniture
procurement policy?
This is a big impact on cost and time
consuming to an OCONUS command.
88
Answer
Using the GCPC
Exceptions to this policy must be made on a
case by case basis at a level no lower than the
Chief of the Contracting Office.
The furniture BPAs achieve an initial discount
and reduce use of redundant vehicles. These
BPAs were competitively awarded against
Federal Supply Schedules and to the Federal
Prison Industries as part of Spiral II of the Navy's
Strategic Sourcing Initiative for Furniture.
89
Question
Using the GCPC
I am not clear on the prioritized order of
purchases between GSA and open market to
card holders under 3K.
Please clarify.
90
Answer
Using the GCPC
GSA provides access to supplies and
services from two online systems
1. GSA Global Supply provides online shopping for GSA
Stock Program and Special Order Items. This is a
working capital program and fees are added to orders.
This falls into the category of Wholesale Supply
Sources.
2. GSA Advantage provides online shopping for items
available from GSA Multiple Award Contractors. Fees
are included in the schedule price of the contracts.
This falls into the category of Optional FSS.
91
Answer (Continued)
Using the GCPC
NAVSUPINST 4200.99B authorizes use of
commercial sources if:
 the item is not available from Government online
systems, or
 is not available to meet the required need date, or
 can be acquired at a lower cost - REQUIRES AO
pre-approval.
EXCEPTION: Items on the AbilityOne
Procurement List MUST be purchased if
available in time to meet requirement,
REGARDLESS of cost.
92
Question
Using the GCPC
What is the possibility of increasing the
micro purchase level from $3,000?
93
Answer
Using the GCPC
Increasing the micro purchase threshold is
currently being discussed at the highest levels
of the Department of Defense.
The DOD Comptroller suggested an increase,
but the Director of Procurement and Acquisition
Policy was concerned this might lead to
additional misuse, so a study was done to
determine the impact of raising the micro
purchase threshold.
DON CCPMD will keep HL3 A/OPC informed of
the status of the study.
94
Question
Using the GCPC
What is the definition of a split buy? Be
specific .
95
Answer
Using the GCPC
Split Purchases are simply the “intentional” breakdown
of a single requirement into separate purchases merely
to get around the micro-purchase threshold.
Split Requirements are the “intentional” breakdown of
a single requirement into separate purchase requests to
get around the micro-purchase threshold.
The "requirement" is the description of what is needed
and when it is needed.
96
Question
GCPC Program Oversight
Can there be an enterprise consolidated report
built that can be generated at the enterprise
level for consolidation of the information for
the Semi Annual Review?
97
Answer
GCPC Program Oversight
Many improvements have been made to the semi
annual reporting process since it was introduced
in 2003.
The majority of the information required for the
semi annual review is contained in the PAT CO
Management Report.
However, there are some internal controls/
weakness that are not reviewed within PAT, like
findings from audits, that have to manually be
reported.
98
Question
GCPC Program Oversight
What‟s considered a weakness in the Semi
Annual Review?
99
Answer
GCPC Program Oversight
Weaknesses in the Semi Annual Review
include anything that indicates a lack of
internal controls, policy compliance,
absence of oversight, or anything that
indicates the GCPCs are being used for
other than their intended purpose.
100
Question
GCPC Program Oversight
Why are the Level 5 A/OPC and the AO/CO not
notified by email when transaction(s) are added
by a higher level A/OPC in PAT?
101
Answer
GCPC Program Oversight
Whenever a transaction is added in PAT, the system
sends an email to the AO.
PAT uses the email address in CCMS of the AO that
performed the last review.
APCs can use the „Manage Contracts‟ function of
CCMS to change an erroneous AO email address.
PAT will be changed to provide email notification to the
HL5 APC whenever a higher level APC adds a
transaction.
102
Question
Are there any other questions someone
would like to ask?
Raise your hand and someone will give
you a microphone.
103