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GSA SmartPay

Purchase

When paying for purchases of supplies, services, or construction, the GSA SmartPay solution provides your agency with numerous benefits including cost savings, discount programs, and refunds.  Find out more here! 

Account Holders/ AOs

Purchase Program Overview

What is a GSA SmartPay Purchase Account?

A purchase account is a type of payment solution, issued by a GSA SmartPay contractor bank, and used to pay for supplies or services procured at the direction of a Federal agency/ organization under official purchase authority. Purchase accounts may be established through any payment solution listed in the GSA SmartPay master contract.

The GSA SmartPay purchase program is the preferred method of payment for federal employees to make official Government purchases for supplies, goods, and services under the micro-purchase threshold.

  • The GSA SmartPay purchase accounts are both a procurement and payment mechanism for micro-purchases.
  • For purchases above the micro-purchase threshold, the GSA SmartPay purchase account may be used as an ordering and payment mechanism, but not a contracting mechanism.

Account holders can purchase any commercially available supply or service within their spending limits and not prohibited by either federal or agency-specific procurement regulations.

Purchases that are STRICTLY PROHIBITED include:

  • Long-term rental or lease of land or buildings
  • Travel or travel-related expenses (not including conference rooms, meeting spaces, and local transportation services)
  • Cash advances (unless permitted by your agency/ organization)

Use of the purchase account benefits the Government in many ways:

  • The GSA SmartPay accounts save the Government time, money and resources.
  • The GSA SmartPay purchase program provides the Government with financial and cash management control over low dollar value high volume procurements and can serve as a payment tool for larger transactions consistent with agency policy.
  • The Government saves money by making only one payment to the contractor bank rather than thousands of payments to individual merchants.
  • The Government improves the use of its resources by freeing up contracting personnel so they are able to focus on more complex activities that derive greater benefit from their expertise.
  • Merchants throughout the world accept the GSA SmartPay purchase account because they are familiar with commercial credit cards and they understand how to accept them.

As an account holder, you will have the flexibility to decide what to purchase, when to buy it, and from whom. You will also be able to monitor funds yourself.

The GSA SmartPay Account also benefits merchants because they are paid quickly for the supplies and services they provide.

 

What is a Centrally Billed Account vs an Individually Billed Account? Why is it important to know the difference?

Because the agency is invoiced for purchases and payments are made directly to the contractor banks by the Federal Government, all purchase accounts are considered Centrally Billed Accounts (CBAs). In contrast, Individually Billed Accounts (IBAs) are invoiced directly to the account holder and payment is the responsibility of the account holder, who is then reimbursed by the agency/ organization.

The distinction between CBA and IBA is important when determining state tax exemption. All GSA SmartPay CBAs should be exempt from state taxes. In addition, with a CBA, the Federal Government accepts liability for charges made by an authorized account holder, but is not liable for any unauthorized use. Unauthorized use means the use of an account by a person, other than the account holder, who does not have actual, implied or apparent authority for such use and from which the account holder receives no benefit. When the CBA has been used by an authorized account holder to make an unauthorized purchase, the Government is liable for the charge and the agency is responsible for taking appropriate action against the account holder.

Getting Started

New Applicants

New applicants should receive their GSA SmartPay purchase account from the contractor bank within 10-14 calendar days from the time the application is submitted by your A/OPC. Replacements for lost, stolen, broken, or otherwise unusable cards will be sent within 48 hours of the agency/organization request. In the case of an emergency, such as response to a natural disaster, threat to national security and military mobilization, the contractor bank will send the GSA SmartPay purchase account within 24 hours of the request.

Your GSA SmartPay Purchase Account is issued to YOU for official government business ONLY. The purchase account can NEVER be used for personal reasons. Do not share your account information with anyone - only you are authorized to use the account. This means that no family member or member of your staff, including your supervisor, may use your purchase account. Safeguard your purchase account information at all times. Unauthorized use of the account due to your failure to secure the account may result in disciplinary action.

Before Making Your Purchase

After receipt of your account the following steps should be taken:

  • Verify the accuracy of the account information (for example, your name and address).
  • Call the toll-free number provided by the contractor bank to confirm receipt and activate the account.
  • If you are given a physical card, sign the back of the card.
  • Review the account holder guide provided by the contractor bank.

Before using your purchase account, make sure you:

  • Plan your monthly purchases
  • Ensure availability of funds
  • Conduct market research
  • Select the best value
  • Seek state tax exemption
  • Talk to merchants

Making Purchases/Placing Orders

Making Purchases

It is important to understand the limits on purchase account use and to manage your purchases against those limits.
 

You are allowed to purchase any commercially available supply or service not prohibited by either Federal or agency-specific procurement regulations. To find out your agency specific procurement requirements regarding purchase amounts, receipt documentation and approvals contact your A/OPC or contracting officer. An approval may be required prior to purchase and may be needed in conjunction with a subsequent review of the purchase activity. If a purchase appears questionable, consult your A/OPC or contracting office.
 

There are a number of purchases that are STRICTLY PROHIBITED. The purchase account shall not be used for:

  • Long-term rental or lease of land or buildings
  • Travel or travel-related expenses (However, conference rooms, meeting spaces, local transportation services such as metro fare cards, subway tokens, and shuttle services can be properly acquired on a purchase account)
  • Cash advances (unless permitted by Agency/Organization)

 

Government-to-Government Transactions

Government-to-Government Transactions are payments between different agencies (inter-governmental) or within the same agency (intra-governmental). In most instances, these transactions are classified under Merchant Category Code 9399, Miscellaneous Government Services. 

Effective June 1, 2015 the Treasury Department lowered the maximum dollar amount allowed for intergovernmental transactions to $24,999 per day (not per single transaction). This change does not impact agency purchases from commercial vendors, either via open market or through GSA Advantage. It does apply to purchases from GSA Global Supply or GSA's retail stores, as well as purchases from Personal Property or GSA Fleet. A few notes to keep in mind:

  • Customers cannot divide transactions into smaller pieces to evade this limit. For example, a buyer cannot make two purchases of $15,000 each, because that total on a given day would exceed the $24,999 limit.
  • Transactions that exceed the limit will be denied by Vantiv, the contractor Treasury uses to manage transactions.
  • Treasury retains the option to lower the limit further at a later date. One goal is to reduce the fees government pays when it accepts the purchase account for large transactions.
Placing Orders

There are two basic types of transactions when placing your order: Card-present and card-not-present transactions.

 

Card Present Transactions means that you purchase an item in person using your GSA SmartPay charge card as payment. You physically choose your item in the shop and take the item to the sales clerk, identifying it as an OFFICIAL GOVERNMENT PURCHASE. All GSA SmartPay Purchase Accounts are centrally billed (CBA) and should be exempt from State taxes. However, there may be additional requirements in your state, such as a form or presenting a Federal ID.

 

When making a card present transaction, double check that:

  • You received an itemized receipt
  • Sales tax was not charged
  • You signed the receipt
  • You safeguard the receipt for reconciling your monthly invoice statement, and
  • You record the purchase in your purchase log.

Note: All purchase documentation should be kept for your records, in accordance with agency policies and NARA’s GRS 1.1

A Card-Not-Present Transaction is a transaction conducted without a physical card. Examples include purchase by phone, fax, or online.

When placing your order, make sure you:

  • Identify the purchase as an OFFICIAL GOVERNMENT PURCHASE so that it will be exempt from federal taxes and, if applicable exempt from state/ local taxes
  • Get a copy of the itemized receipt
  • Place the receipt in a safe place to use in reconciling your monthly invoice statement
  • Record the purchase in your purchase log
  • Verify that the item and price are correct upon arrival and if there is any discrepancy, call the merchant immediately

Do Not Pay List

In order to help eliminate waste, fraud, and abuse in federal programs, federal agencies should focus on preventing payment errors before they occur.  The Do Not Pay List consists of a list of databases containing information on a recipient’s eligibility to receive federal benefits payments or federal awards, such as grants and contracts. By checking these databases before making payments or awards, agencies can identify ineligible recipients and prevent certain improper payments from being made.

Below are a few resources for more information on the Do Not Pay List:

Benefits of Using Do Not Pay:

  • Helps agencies eliminate manual checking of databases maintained in multiple sites
  • Provides access to current, relevant data to help make a payment or eligibility decision.
  • Allows an agency a simple, streamlined way to comply with the “Do Not Pay” initiative, which requires all agencies to review key databases pre-award and pre-payment.
  • Detects and helps prevent erroneous payments.

Useful Websites:

  • Do Not Pay Portal – The Do Not Pay Business Center will provide automated tools, including a web-based single entry access portal, which federal agencies can use to gain access to an array of data sources to assist in determining whether an individual or company is eligible to receive federal payments or engage in federal contracts.
  • PaymentAccuracy.gov – As required by Executive Order 13520 dated November 20, 2009, Reducing Improper Payments, the U.S. Department of the Treasury, in coordination with the U.S. Department of Justice and Office of Management and Budget, established this website to create a centralized location to publish information about improper payments made to individuals, organizations, and contractors. This website also provides a centralized place where the public can report suspected incidents of fraud, waste, and abuse.

The Do Not Pay Portal Consists of Information Compiled from the Following Sources:

Excluded Party List System (EPLS)

  • Identifies parties excluded from receiving federal contracts, certain subcontracts, and certain types of federal financial and nonfinancial assistance and benefits; 
  • Verifies whether an individual that is receiving unemployment payments is still living, owes federal non-tax debt, and/or is recently employed;
  • Identifies providers, individuals, or vendors that are excluded from doing further business with the government or should be subject to more oversight based on past performance; 
  • Identifies keying errors that could cause the wrong entity to receive a payment; and  
  • Keeps the federal purchasing community aware of administrative and statutory exclusions across the entire government, suspected terrorists, and individuals barred from entering the United States. 

Death Master File (DMF)

  • Verifies whether an individual that is receiving unemployment payments is still living, owes federal non-tax debt, and/or is recently employed.

List of Excluded Individuals/Entities (LEIE)

  • Verifies whether an individual that is receiving unemployment payments is still living, owes federal non-tax debt, and/or is recently employed
  • Identifies providers, individuals, or vendors that are excluded from doing further business with the government or should be subject to more oversight based on past performance

Debt Check

  • Verifies whether an individual that is receiving unemployment payments is still living, owes federal non-tax debt, and/or is recently employed
  • Identifies vendors that owe federal non-tax debt and ensure vendors that owe debts are paid via the Treasury offset process instead of through a credit card.

The Work Number

  • Verifies whether an individual that is receiving unemployment payments is still living, owes federal non-tax debt, and/or is recently employed for agency programs that are means tested
  • Verifies the accuracy of income levels at the time of enrollment 

Central Contractor Registration (CCR)

  • Identifies providers, individuals, or vendors that are excluded from doing further business with the government or should be subject to more oversight based on past performance
  • During the payment process, ensures that the name associated with the DUNS is the name associated with that DUNS in CCR, thus preventing payment to the wrong entity
  • Identifies keying errors that could cause the wrong entity to receive a payment

Other Sources a Cardholder Can Use for Market Research:

  • Affirmative Proceeding Data
  • Dun & Bradstreet
  • Recovery.gov
  • Google Maps/Search Zip Code
  • Prison Address Source
  • Agency provided payment file
  • Agency provided payee list
  • FMS Payment Data
  • USASpending.gov
  • IPP Vendor Data
  • ASAP Grantee Data

FSSI

FSSI Office Supply Management

The Federal Strategic Sourcing Initiative for Office Supplies Third Generation (FSSI OS3) is GSA’s latest FSSI solution for office supplies. Strategic Sourcing leverages the purchasing power of the entire federal government, reducing costs of goods and services and allowing for better service. FSSI OS3 is a purchasing channel solution that helps federal customers achieve significant savings on their office supply purchases, while also supporting the nation’s small businesses. OS3 is expected to provide more than $90 million in annual savings captured through lower prices. The awards are the result of a collaborative team effort among customer agencies across the federal government. Under OS3 prices decrease as the collective purchases grow across the Federal Government.

Maintenance, Repair and Operations (MRO) Purchasing Solution, a Federal Strategic Sourcing Initiative (FSSI)

GSA has established Government Wide Blanket Purchase Agreements (BPA)s to sell  Maintenance, Repair & Operations products as a strategic sourcing solution. Average pricing is 12 percent lower than offered previously within the government marketplace.


Products are grouped into three categories in order to streamline offerings and ensure lower prices. These categories cover a wide range of hardware, tools, and paints and sealants products. By purchasing under this solution, customers can achieve socio-economic and green purchasing goals, while also achieving savings.  Customer agencies can place orders through GSA Advantage!, DoD EMALL or directly with the contractor using their GSA SmartPay payment solution.


The MRO website provides more information, including helpful documents for how to order plus a schedule for live training webinars: www.gsa.gov/fssimro


MRO can also be found on the Acquisition Gateway , built by GSA, to helps federal government buyers from all agencies access information from across the acquisition community.

After Purchasing

Inspection and Acceptance

Account holders, when possible, should use a third party to document independent inspection and acceptance of supplies and services they order or obtain in person. This simply means having another government employee sign off on the receipt or other purchase documentation verifying that the supplies/services were inspected and accepted. In some cases, such as when making an emergency purchase or when no other government employee is available, independent inspection and acceptance may be impossible. If that is the case, the account holder must document that independent inspection and acceptance was not possible and why.

 

Inspect each product to verify that it is in good condition with no visible damage or defects and the items meet the requirements of the purchase (color, size, quantity, etc.). Account holders should also verify that the purchase documentation (receipts, packing lists, shipping documents, etc.) matches what is provided by the merchant and that all requirements of the purchase are fulfilled. For services, verify that the work done is satisfactory. If upon inspection, all terms of the order as described above are fulfilled, the products or services may be accepted.

 

In the event the items purchased are defective, damaged, or otherwise do not comply with the account holder’s order, the account holder shall attempt to resolve these issues as soon as possible directly with the merchant. Similarly, if services provided are not satisfactory, the account holder shall address deficiencies immediately and directly with the merchant and prior to payment, if possible.

 

Disputes

If the payment has already been made on the GSA SmartPay purchase account and the merchant has failed to resolve issues satisfactorily, the account holder should dispute the transaction with the contractor bank as soon as possible. According to the GSA SmartPay Master Contract, the account holder is responsible for notifying the contractor bank of any items in dispute and shall have 90 calendar days from the transaction date to initiate a dispute, unless otherwise specified by the agency/organization.

 

Note: Account holders who fail to timely dispute erroneous or incorrect purchases may become personally liable for that purchase.

Sensitive Property

Because GSA SmartPay purchase accounts are frequently used to obtain sensitive items, an accurate property tracking system should be in place. Sensitive property includes items that are susceptible to loss, misuse or theft, such as mobile phones, laptops, monitors and printers.

Accountability for Items Purchased

Each year, agencies acquire billions of dollars of property with GSA SmartPay purchase accounts. This means that the account holder’s responsibilities do not end when an item they purchased is inspected and accepted. The purchased item must be properly accounted for in accordance with applicable federal and agency policies and regulations.

 

Supplies and services purchased with a GSA SmartPay purchase account are for official use only. For example, an iPad purchased to view podcasts of work-related presentations and lectures should not also be used to store personal music and photos, nor should it be engraved with the user’s name. At any time, property could be taken back by the issuing activity or program and re-issued to another person within that program.

 

Check with your agency policy on governing accountability for sensitive property. Account holders shall ensure applicable Federal and agency accountability procedures are followed for property for which they are responsible. This activity includes providing information to agency/organization property officers and/or systems on items purchased, excluding consumables.

 

If the account holder is purchasing an item for another government employee, that employee is the user of that property and is therefore responsible for ensuring the proper accounting of that property. However, account holders should ensure they have documentation in their file demonstrating that the property acquired was delivered to another party and is no longer their responsibility.

 

Account holders must be familiar with and comply with their organization’s policies regarding property management. This includes coordinating with your servicing property officer and appropriate custodians to ensure that all sensitive and otherwise accountable property is recorded in the applicable property tracking system, consistent with your agency’s policies and procedures. Account holders shall also familiarize themselves with agency policies for reporting property they acquired with a GSA SmartPay account that is missing, stolen or damaged after the initial receipt process.

Order Cancellation

If you need to cancel an order, immediately contact the merchant. Immediately contacting the merchant allows you to cancel before the item has been shipped. If the merchant has already processed the transaction, a credit should be issued. If the merchant has not processed the transaction, simply cancel the order. Special order items may include a restocking charge.

Returning a Purchase

Return policies can vary by merchant. Merchants are responsible for establishing their own return and adjustment policies with their customers. If the return policy is unclear when making a purchase, please ask the merchant for clarification to avoid future misunderstandings. Merchants are required to disclose their return policies to the customer before the completion of a transaction.

 

Obtaining Redress

By accepting the GSA SmartPay purchase account as payment, merchants agree to refund or replace any defective items. The first step to obtaining redress is to work with the merchant on a resolution. This is usually a refund or replacement of the defective item. If the merchant refuses to issue a credit voucher, you must dispute the transaction through the issuing contractor bank.

 

Obtaining Sales Receipt Copies

Obtain and save a copy of your sales receipts. You need a copy of a sales receipt in order to verify the purchase when reconciling your statement. If you misplaced the sales receipt and need a copy to verify an item on your statement, contact the merchant directly. If getting a reprinted receipt isn’t an option, contact your contractor bank to send you a copy.

 

What happens if you make a purchase that was not approved?

If it has been determined that the item cannot be returned, the Government must pay for the purchase and recoup the amount of the purchase from YOU! That is why it is important to fully understand what can and cannot be purchased with the GSA SmartPay purchase account, and ensure that your Approving Official is aware in advance of what you are purchasing.

Billing and Payment

Reconciling Your Purchase Account Statement

You will receive a statement notification, either electronically or through the mail, from the contractor bank once a month for your GSA SmartPay purchase account. The statement is mailed directly to your business address unless the agency is using the service provider’s Electronic Access System (EAS).

When you receive your monthly statement:

  • Identify and annotate any erroneous charges and work with the merchants and the issuing bank contractor on a resolution.
  • Review and reconcile your statement within the timeframes required by your agency (usually 3 to 5 days). Reconciling your statement includes reviewing receipts, citing proper accounting codes, documenting disputed items, and completing any other documentation required by your agency.
  • Forward your statement to your Approving Official and the appropriate Payment/Finance office for payment.

 

Reconciling a Credit

On occasion your statement will show a credit for a transaction that took place in a prior billing period. An example would be a credit for a returned item. When you get a credit several months after the original purchase, reconcile back to the original purchase documentation and note that the credit was received.

Questionable Charges

As an account holder, you are responsible for reviewing all charges on your statement. One of the first signs of fraud is at least one “mystery expense” showing up on your statement. Verify your statement by:

  • Looking for transactions or account withdrawals you do not recall making; and
  • Checking for unknown vendors.

 

If you do notice a questionable charge, act promptly so that you will have the necessary information before payment is due.

  1. Contact the merchant for clarification on the charge. If you need help identifying the merchant, call the contractor bank's customer service number. If the charge is erroneous, generally the merchant will reverse it, and it will appear as a credit on your next statement. Be sure to follow up and make sure the credit was posted to your account and deduct the credited amount from your payment. If the credit is not posted in a reasonable amount of time, dispute the charge with the bank. If the merchant says it is a legitimate charge to your account, ask for proof, such as a signed receipt. If, after receiving the additional information from the merchant, you do not agree that it is a legitimate charge, dispute the charge with the bank.
  2. A dispute is a disagreement between the account holder and the merchant with respect to a transaction. You, the account holder, are responsible for notifying the contractor bank of any items in dispute and shall have 90 calendar days from the transaction date to initiate a dispute, unless otherwise specified by the agency/organization.
    • Disputable charges include double billings and charges to your account that belong to another account.
    • Non-disputable charges include sales tax and shipping. 
  3. Payment of the undisputed charges must be made by the payment due date. Once you have submitted the dispute to the bank, delinquency of the disputed amount will be held in abeyance until the matter is resolved.

 

Note: You relinquish your right to recover a disputed amount if you do not dispute it before 90 calendar days from the transaction date.

Green Purchasing

Sustainable Acquisition or Green Purchasing refers to the procurement of products and services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose.

 

Benefits to using your purchase account to buy green products are that you help your agency to perform its mission while:

  • Saving money,
  • Enhancing energy security,
  • Protecting public health,
  • Promoting environmental stewardship,
  • Reducing greenhouse gas emissions, and
  • Fostering markets for sustainable technologies, materials, products and services.

 

In addition, regulations require federal buyers to purchase products with specific environmental or energy attributes and services under which those products will be used or supplied.

 

As an account holder, you can implement several environmentally friendly best practices to reduce your carbon footprint including:

  • Eliminating the use of paper by signing up for online or paperless statements and payments
  • Reduce the need to copy and print by taking advantage of online reporting.  If you do need to print, use recycled paper and ink cartridges. 
  • Reduce the use of convenience checks.
  • Request a GSA SmartPay charge card that is made from recycled or environmentally friendly materials.   
  • When shopping, use your GSA SmartPay account to purchase environmentally friendly or recycled products.  Use the GSA Advantage! Environmental Aisle to procure green products and services to maximum extent practicable. 
  • Inquire about any green purchasing training offered at your agency.

Account Holder Responsibilities

The account holder, or also known as cardholder, is the individual or agency/organization component designated by an agency/organization to receive an account to purchase supplies and services for Government use. The account holder is responsible for:

  • Securing the account;
  • Maintaining records relating to all transactions;
  • Using the account ethically and appropriately;
  • Performing market research;
  • Observing all dollar limits on purchases;
  • Complying with green purchasing requirements; and
  • Reconciling and documenting transactions.

You, as the account holder are the Government's legal agent for each purchase made with the purchase account, thus legally responsible and accountable for each transaction. You are responsible for complying with all applicable regulations and procedures of your agency.

For more information on Account Holder Responsibilities, download Helpful Hints for Purchase Account Use.

Reporting an Account Lost or Stolen

Report a lost or stolen purchase account promptly to:

  • The contractor bank;
  • Your program coordinator (A/OPC); and
  • Your supervisor.

Once an account has been reported as lost or stolen, the contractor bank immediately blocks that account from further usage and a new account number will be issued to the account holder.

 

Reporting the account as stolen does not relieve the account holder or the Government of payment for any transactions that were made by the account holder prior to reporting it stolen. If you do not recognize a transaction appearing on your statement, you are responsible for notifying the contractor bank within 90 calendar days from the transaction date to initiate a dispute, unless otherwise specified by the agency/organization. This notification of transaction dispute may occur via the electronic access system, by telephone, or other electronic means (e.g. email).

 

Note: You relinquish your right to recover a disputed amount after 90 calendar days from the date that the transaction was processed. It is your responsibility to dispute questionable charges. If you don’t, you will be held personally liable for the amount of the questionable charge.

Common Questions

Click here for commonly asked questions.

Program Coordinators

The GSA SmartPay purchase program provides payment solutions to federal government employees for official government purchases.  In order to be successful in managing your purchase program, you will need to have a clear understanding of how the GSA SmartPay program works, actively participate in meetings and training conferences, communicate relevant information to account holders, and be familiar with agency/ organization specific policies and procedures.

Purchase Program Overview

What is the GSA SmartPay Purchase Account?

A purchase account is a type of payment solution, issued by a GSA SmartPay contractor bank, and used to pay for supplies or services procured at the direction of a Federal agency/ organization under official purchase authority. Purchase accounts may be established through any payment solution listed in the GSA SmartPay master contract.

The GSA SmartPay purchase program is the preferred method of payment for federal employees to make official Government purchases for supplies, goods, and services under the micro-purchase threshold.

  • The GSA SmartPay purchase accounts are both a procurement and payment mechanism for micro-purchases.
  • For purchases above the micro-purchase threshold, the GSA SmartPay purchase account may be used as an ordering and payment mechanism, but not a contracting mechanism.

Account holders can purchase any commercially available supply or service within their spending limits and not prohibited by either federal or agency-specific procurement regulations.

Purchases that are STRICTLY PROHIBITED include:

  • Long-term rental or lease of land or buildings
  • Travel or travel-related expenses (not including conference rooms, meeting spaces, and local transportation services)
  • Cash advances (unless permitted by your agency/ organization)
What is a Centrally Billed Account vs an Individually Billed Account? Why is it important to know the difference?

Because the agency is invoiced for purchases and payments are made directly to the contractor banks by the Federal Government, all purchase accounts are considered Centrally Billed Accounts (CBAs). In contrast, Individually Billed Accounts (IBAs) are invoiced directly to the account holder and payment is the responsibility of the account holder, who is then reimbursed by the agency/ organization.

The distinction between CBA and IBA is important when determining state tax exemption. All GSA SmartPay CBAs should be exempt from state taxes. In addition, with a CBA, the Federal Government accepts liability for charges made by an authorized account holder, but is not liable for any unauthorized use. Unauthorized use means the use of an account by a person, other than the account holder, who does not have actual, implied or apparent authority for such use and from which the account holder receives no benefit. When the CBA has been used by an authorized account holder to make an unauthorized purchase, the Government is liable for the charge and the agency is responsible for taking appropriate action against the account holder.

What are some of the innovative solutions offered under GSA SmartPay 3?

ePayables:

A solution that replaces the accounts payables process such that electronic transactions take place directly between the Government and the supplier. ePayables solutions are typically used with merchants who are either:

  • Traditionally paid by convenience check or EFT or
  • Merchants who do not accept charge card payments (e.g., utility companies)
Mobile Application:

The ability to access EAS, pay invoices, receive text/email alerts, and view statement and payment information over a mobile device. Your contractor bank provides mobile application capabilities, upon request, at no additional cost. Mobile application capabilities include:

  • the ability to access EAS,
  • pay invoices,
  • receive text/email alerts and
  • view statement and payment information over a mobile device.
Mobile Payments:

The ability to make payments via mobile device at the point-of-sale. Your contractor bank provides the ability for account holders to make secure payments using a mobile device at the point-of-sale.

Net Billing:

The process of ensuring that merchant discounts or refunds offered are deducted at the point-of-sale and guaranteeing such discount arrangements. For example, the contractor bank ensures that discount information is identified on the invoice and passed to the agency/organization, when available. If Mark purchased a toner cartridge for $100 and the merchant offers a Government discount of $4.00 to the agency/organization based on existing agreements, the contractor bank shall net bill only $96 for the transaction.

Single-Use Account (SUAs):

SUA payment solutions leverage a single virtual account number for each payment. The limit on each account is set to the specific payment amount. Internal controls such as MCC blocks, spend limits, timeframes, and account expiration dates can be used for increased control. Agencies also have the ability to append accounting data for seamless reconciliation. Examples of use include payment invoice and contract payments, which help to ensure that merchants are not able to charge more than approved amounts. Benefits to SUAs include:

  • Accounts can be activated in real time
  • Controls can be placed on account allowing for increased oversight of spend
  • Disposable; one-time use account numbers reduce the risk of fraud
  • Seamless reconciliation, and
  • Reduces the necessity for using convenience checks
Tokenization:

Tokenization is the use of a secure, unique “token” in place of a 16-digit account number to provide extra security for transactions.

Virtual Cards:

The Contractor shall provide virtual accounts that may be used during a limited time, for a limited amount and possibly for a specific vendor.

Declining Balance Cards:

Declining Balance Cards can be applied for a specific purpose, a finite balance, or for a specified time period. Credit limits can either be reset as needed or the card becomes inactive once the balance is used. These accounts can be easily loaded and distributed to employees in case of emergency or disaster situations. Benefits may include:

  • Financial flexibility and security,
  • Reduction of agency/organization administrative fees,
  • A flexible option for applicants who cannot be issued a traditional account, and
  • Safe and excellent alternative to cash and paper checks.
Ghost Cards:

Ghost Cards are for agencies who frequently do business with one vendor and have recurring payments. An account number can be assigned to the vendor and authorized agency personnel transactions occur without having to use multiple cards or accounts. Many agencies use this product for purchases such as airline tickets. Benefits may include:

  • Reduced number of open accounts (payment processing and oversight easier)
  • Allows for multiple users
  • Allows for a high level of control
  • Reduces the risk of lost or stolen cards

Program Coordinator Responsibilities

What are my responsibilities as a Program Coordinator?

As an A/OPC for your agency/organization, you serve as the liaison between your agency/organization, the contractor bank, the account holder, and the GSA Contracting Office.  Your role is essential to efficiently and effectively managing the purchase program.

The following list identifies specific A/OPC responsibilities. You may be required to assume some or all of the following responsibilities:

  • Maintain an up-to-date list of account names, account numbers, addresses, emails, telephone numbers, etc., of all current account holders and accounts.
  • Provide to the contractor bank any changes in your agency's organizational structure that may affect invoice/report distribution.
  • Review and evaluate the contractor's technical and administrative task order performance and compliance.
  • Resolve technical and operational problems between the contractor and account holders as required.
  • Take appropriate action regarding delinquent accounts and report to internal investigative units and the GSA Contracting Officer any observed violations of applicable executive orders, laws or regulations.
  • Participate in the annual GSA SmartPay Training Forum and train account holders.
  • Ensure account holders use their account correctly.
  • Monitor account activity and manage delinquencies.
  • Ensure that appropriate steps are taken to mitigate suspension or cancellation actions.
  • Develop agency program procedures and policies as necessary.
  • Keep the lines of communication open with all key program participants.

Communication is key to an effective purchase program is to ensure that all program participants, including senior management/leadership, are aware of what is going on in the program. Keep in touch with your agency/organization's purchase program participants by networking, asking questions, and sharing or distributing agency/organization policy changes, program information, and/or other purchase account information.

As an A/OPC, you should try to establish relationships with the account holders and AO within your span of control. The better you understand why and how the purchase account will be used, the more effective you can be in managing the program.

How are new accounts set up?

As an A/OPC, you are responsible for setting up and maintaining all accounts. There are three documents you should have for each account holder prior to setting up a new account:

  1. Delegation of Procurement Authority (DPA): You should have a legible copy of the Delegation of Procurement Authority for each prospective account holder prior to creating an account. Your agency/organization policy will dictate what the contents of the DPA should be and who has authority to issue it. FAR 1.603-3(b) states: "Agency heads are encouraged to delegate micro-purchase authority to individuals who are employees of an executive agency or members of the Armed Forces of the United States who will be using the supplies or services being purchased.” Individuals shall be appointed in writing in accordance with agency procedures.
  2. Training Certification: Each account holder must complete training prior to appointment and must take refresher training at a minimum of every 3 years. Account holders should understand their responsibilities and duties associated with having a GSA SmartPay purchase account. In addition, you must ensure that the account holder is in compliance with specific agency policy regarding account holder training.
  3. Account Setup Form: Each prospective account holder must complete and submit an accurate account setup request. Account setup forms are located in your official contractor bank A/OPC guide or from the contractor bank's website or EAS.

Once you are in receipt of the DPA, the training certificate, and the completed account setup form, you will review and approve/disapprove the request.

Note: Be aware and follow any additional agency specific requirements in setting up accounts.

If you approve a request, you will then contact your contractor bank to issue the account to the account holder. Completed account forms can be sent to the bank by EAS, email, fax, or mail. In cases where there is an emergency, an A/OPC can give verbal directions to the bank to move forward with setting up an account, followed by electronic/written confirmation to the bank within 3 business days.

You will create an account for the new account holder in the bank's EAS. At the time of account setup, you will set authorization controls. You can change authorization controls at any time in case you determine that some are too restrictive (or not restrictive enough). Use authorization controls as a tool to prevent fraud and misuse. Here are some typical authorization controls:

  • Single purchase limit , or the dollar limit for an individual transaction.
  • Monthly purchase limit, or the cumulative dollar limit for purchases in one month. The monthly purchase limit may be set to any dollar amount equal to or greater than the single purchase limit.
  • The number of transactions limit
  • Merchant category codes (MCC) restrictions. Note: An MCC is a four-digit code used to identify the type of business a merchant conducts (gas stations, restaurant, airlines, etc).
How are accounts closed/terminated and what are the recommended exit procedures?

There are four steps to closing or terminating an account, as follows:

  1. Immediately notify the bank when an account holder leaves the agency/ organization, is terminated from employment, or no longer requires a purchase account.
  2. Follow the account close out procedures from your contractor bank.
  3. Instruct the account holder to destroy/dispose of the card by cutting it into pieces.
  4. Review the master file/ account holder listing to ensure the account is closed.
What is my responsibility in the suspension/ cancellation of a purchase account?

As the A/OPC you have the discretion to initiate suspension and/or cancellation procedures for any account; however, you must document the reason for cancellation and/or suspension.

Suspension is the process by which an account is deactivated due to delinquency or multiple pre-suspension actions. An account is considered past due if payment for undisputed principal amounts has not been received within 45 calendar days from the billing date.

The contractor bank may suspend an account when the account becomes delinquent. Once payment of the undisputed principal amount and Prompt Payment Act Interest is received, the bank is required to reinstate suspended account.

An account can be canceled if an undisputed balance remains unpaid for the prescribed number of calendar days after the date of the statement of account on which the charge first appeared. An account may also be canceled for numerous suspensions.

Can I, as an A/OPC, suspend or cancel an account? Yes. A reason must be documented for suspension or cancellation. Accounts may be cancelled through your bank’s electronic access system or through the bank’s customer service office.

 

The following chart may be used as a guide for determining the status of an account.

Calendar Days Past the Payment Due Date Account Status/Action
45 Days Past Due Pre-Suspension
61 Days Past Due Suspension/Pre-Cancellation
126 Days Past Due Cancellation
180 Days Past Due Charge Off/Write Off

*Please refer to your agency policy for specific delinquency stages.

(For more details on Suspension/ Cancellation Procedures, see the GSA SmartPay 3 Master Contract, Section C.3.3.11 Suspension Procedures and Section C.3.3.12 Cancellation Procedures)

 

The bank is required to automatically reinstate suspended accounts upon payment of the undisputed principal amount unless otherwise specified by you. You may also notify the bank of any mission-related, extenuating circumstances for which the account should not be suspended within the notification timeframes mentioned previously. Once an account has been cancelled, the contractor bank is under no obligation to reinstate the account.

Refunds

The Federal Government saves on processing costs and generates revenue through volume refunds.  The amount of refund your agency receives is calculated during task order negotiation.

Agencies must verify their own refunds.  You can do this by comparing the base points in the task order with the quarterly refund report received from your bank.  If you need a copy of the quarterly report, contact your point of contact at the bank.  With GSA SmartPay, split disbursement will allow agencies to receive productivity and sales refunds for IBA accounts in addition to CBA accounts.

Click here for more information on refunds.  

Reporting Tools

How do I access reports related to the GSA SmartPay purchase program?

Program Coordinators have a number of reporting tools that enable you to manage your purchase program effectively through your contractor bank's Electronic Access System (EAS). To access reports, contact your bank representative to obtain a User ID and password.

Each bank has a slightly different suite of reports available, so review the contractor bank's A/OPC guide or get online to learn about the specific reports offered. Most electronic reports are updated within two to three days after a transaction. However, some reports are only updated at the end of the billing cycle.

Program coordinators will also have access through the EAS to monitor account holder transactions at any time. By searching by account holder name, account number or SSN, you can track account holder transactions (e.g., transactions, payments, disputes), as well as view account holder monthly statements. You may also contact the bank’s customer service at any time to request information on a specific account.

Note: See the GSA SmartPay 3 Master Contract, Section C.7.1 Electronic Access System for a full list of the EAS requirements.

Which reports provide general account information?

The Account Activity Report consists of summary totals for the reporting period, the FY to-date, categorized by account and agency/organization. This report is used by the A/OPCs to obtain and manipulate program data. It includes

  • Complete account activity, both active and inactive,
  • An agency/organization hierarchy roll-up section,
  • Current and past FY account activity,
  • Segregates charges and credits by individual or agency/organization accounts with current period totals of the data elements identified, and
  • Merchant information such as name, address, and MCC (as applicable).

The Account Change Report lists any changes made to the master file information and identifies what and when elements were changed. This report is generally used by A/OPCs to manage programmatic data as well as to flag/verify changes.

The Current Accounts Report shows all accounts in alphabetical order and includes all information necessary to identify and contact the account holder. This report is generally used by A/OPCs as an easy reference for account holder identification.

The Exception Report identifies high risk transactions such as lost, stolen, invalid or cancelled accounts, declined transactions and unusual spending activity, and details such transaction activity. This report includes current and past due balances. It is generally used by A/OPCs and the Designated Billing Office (DBO) to monitor account holder activity, track misuse and/or identify training needs of an account holder.

The Master File Report contains master file information on all accounts (e.g., account number, cardholder information, account expiration date, etc.).

The Renewal Report lists accounts due to expire and identifies account name, account number, expiration date, and any other information required to determine renewal status. This report is generally used by the A/OPC to flag expiring accounts.

Which reports are available on transactions, payments, and disputes?

The Detailed Electronic Transaction File lists each account holder’s detailed transactions for the reporting period and contains all transaction data. This file is used by the agency/ organization in processing transactions through their financial systems and for reporting purposes.

The Invoice Status Report identifies payment status on each outstanding invoice and includes all transaction data, including the original invoice number and other references required to identify the charge. This report is generally used by the DBO to manage payments and disputes.

The Transaction Dispute Report lists all outstanding and resolved transaction disputes and includes all information necessary to identify, track, balance, and obtain status on the dispute from the original charge through resolution. It is generally used by the Transaction Dispute Office (TDO) to manage disputes.

Which reports provide information on account delinquency?

The Pre-suspension/Pre-cancellation Report lists accounts eligible for suspension or cancellation as defined in the Master Contract, Section C.3.3.11 Suspension Procedures and C.3.3.12 Cancellation Procedures. It identifies account name, account number, status, balance past due, number of days past due, and interest penalty for CBAs.

The Suspension/Cancellation Report lists accounts that have been suspended or canceled as defined in the Master Contract, Section C.3.3.11 Suspension Procedures and C.3.3.12 Cancellation Procedures. It identifies account name, account number, status (suspended or canceled), date of status, balance past due, number of days past due, and interest penalty.

The Delinquency Report lists account status for each 30-120+ day time frame (e.g., 30, 60, 90, 120 or more days).

The Write-off Report lists the amount of the write-off and date written off. This report is used by the agency/organization to identify problem areas to better manage delinquencies, to analyze and project programmatic data for the future, and to verify and balance delinquent data in contract reports.

Exception Reports identifies high risk transactions, as defined by the agency/organization, such as declined authorizations, Merchant Category Code (MCC) reports for questionable expenditures, ATM withdrawals, high volume accounts, etc.

Which reports provide statistical or summary information?

The 1057 Report contains summary merchant demographic information (minority, women-owned business, etc.) on a quarterly and cumulative fiscal year basis. It includes the amount of purchase, merchant name, merchant address, merchant demographic information, North American Industrial Classification System (NAICS) code and size standard. This report is generally used by the agency/organization in fulfilling its small business and small disadvantaged business goals.

The 1099 Report shows that in accordance with Section 6050W of the Housing Assistance Tax Act of 2008 Information Reporting for Payments Made in Settlement of Payment Card and Third Party Network Transactions, the Contractor bank is responsible for reporting payment card transaction information through a 1099-K Merchant Card and Third Party Payments form to the IRS. Reporting shall include all payment card transactions at all dollar thresholds. The Contractor shall provide agencies/organizations with documentation confirming the completion of the 1099 Report Information. Contractors are not required to complete 1099 reporting on convenience check information. For further information see https://www.irs.gov/pub/irs-pdf/i1099k.pdf.

The Payment Performance and Refund Report lists the payment performance (average payment time) and any refunds paid to the agency/organization level. It includes total net charge volume, payment performance, refund amount, payment method and transaction type (e.g., ePayables, large ticket items). This report is used by the agency/organization to analyze payment performance and refunds as well as for audit purposes. This report includes daily accrual figures and the percentage of potential refunds earned by the agency/ organization along with an explanation of how this figure was derived.

The Statistical Summary Report provides program summary information such as dollar volume, ATM volume, number of transactions, active account holders, total accounts, new accounts, miscellaneous fees, transaction type (e.g. convenience check, ATM, large ticket) and identification of fees (e.g., fees for customized services, fees for convenience checks, fees for value-added product and service offerings) on a current and FY basis.

The Summary Quarterly Merchant Report lists, by FY Quarter, summary spending information by merchant category codes (MCCs) and Product Number/Code. It reports MCC description, number of transactions per MCC, total dollar amount per MCC, and average dollar amount per MCC. This report is used by the agency/organization to summarize supplier categories where the agency/organization dollars are spent, and trend analysis. This report shall also show which MCCs are listed in each template.

The Summary Quarterly Purchase Report provides a summary of purchases under the micro-purchase threshold as described in FAR Part 2.101 Definitions. It also provides a summary of purchases over the micro-purchase threshold. It includes number of transactions, the dollar volume and comparative percentages for the current reporting period and FY activity.

OMB Report: This report provides transaction data required by Chapter 5 – Performance Metrics and Data Requirements of OMB Circular A-123, Appendix B. This report shall include a program type identifier (e.g., Purchase, Travel, Fleet, Integrated). Examples of this transaction data includes, but is not limited to, number of cards, and number of active accounts.

Summary Quarterly Merchant Analysis Report: This report lists, by FY, a detailed quarterly and cumulative summary of the top 100 merchants, by individual merchant, city, state, and service type, in total dollars and total number of transactions. This report is used by the agency/organization to negotiate better discounts with merchants and trend analysis. 

Summary Quarterly Merchant Ranking Report: This report lists, by FY, a quarterly and comparative summary by name and type of merchant, ranking the major merchants and their dollar charges, along with a percentage breakdown of totals and changes from the previous quarter as well as the same quarter of the previous year, if applicable. This report is used by the agency/organization for market and trend analysis.

What are my responsibilities for printing and storing reports?

You should save copies of all electronic reports you generate, particularly statistical or summary reports. Due to the volume of information available, the bank will furnish information for a limited period of time (generally, 18 months or less) before archiving the data. Reports containing sensitive information (e.g., account numbers, account holder information, etc.) should be maintained in a secure location. Review and follow your agency/ organization policy for instructions on printing and safeguarding reports.

What are Ad Hoc Reports?

Ad Hoc Reports provide the ability for GSA and the agency/organization community to access all data elements of the AO, account holder, and transaction records at any time by allowing GSA and/or agencies/organizations to create reports in html, Excel, text (ASCII) formats, and/or others as defined by the agency/organization at the task order level. The contractor bank provides the capability for GSA to utilize the ad-hoc reporting functionality of the EAS Systems for any additional future reporting needs that are not listed.

FSSI

FSSI Office Supply Management

The Federal Strategic Sourcing Initiative for Office Supplies Third Generation (FSSI OS3) is GSA’s latest FSSI solution for office supplies. Strategic Sourcing leverages the purchasing power of the entire federal government, reducing costs of goods and services and allowing for better service. FSSI OS3 is a purchasing channel solution that helps federal customers achieve significant savings on their office supply purchases, while also supporting the nation’s small businesses. Designated as a Governmentwide Category Management “Best-in-Class” vehicle, OS3 continues to generate significant spend and savings. Customer agencies can expect an average savings rate of 15% when they order through the OS3 contract vehicle 

Additional benefits include:

  • Capturing economies of scale;
  • Consolidating orders with the new delivery order discounts feature and save as discounts are triggered on individual orders;
  • Ensuring compliance with applicable regulations to include the AbilityOne Program, sustainable purchasing requirements and the Trade Agreement Act;
  • Fostering markets for sustainable technologies and environmentally preferable products;
  • Simplifying data collection and enhancing transparency by enabling agencies to better manage expenditures and measure cost-savings;
  • Aligning purchasing with existing agency procurement practices;
  • Enabling achievement of socioeconomic goals;
  • Providing ease of ordering; and
  • Providing point of sale compliance, ensuring that purchase card users automatically receive the FSSI price.

Visit the GSA.GOV OS3 page for more information and FSSI Performance Dashboard on the D2D portal to see current sales and savings.

FSSI Maintenance, Repair and Operations (MRO) Purchasing Solution

The Maintenance, Repair & Operations Supplies (MRO) purchasing strategic sourcing solution was established to save time and money, with goals to:

  • Offer uniform prices;
  • Measure total cost savings;
  • Capture transactional data to aid in managing agency MRO spend;
  • Reach socio-economic goals;
  • Drive regulatory compliance including AbilityOne and Trade Agreements Act; and
  • Provide sustainable solutions.

As strategic sourcing is evolving to Category Management, the acquisition approaches that have generated solutions are coming together in the categories that allow government purchasers to get a view of all possible solutions for a streamlined way to obtain products. In partnership with numerous federal agencies, both military and civilian, GSA has established multiple Blanket Purchase Agreements (BPAs) to address the significant MRO spend volume. Awarded contractors meet socioeconomic factors such as Women Owned Small Business, Service Disabled Veteran Owned Small Business, and Small Disadvantaged Business.

Agencies can order products and access pricing through GSA Advantage!®, FedMall, or contractor-operated websites.

Visit GSA.GOV FSSI MRO for more information and assistance from the MRO team

FSSI Janitorial and Sanitation Supplies

A “Best-in-Class” solution, the Janitorial and Sanitation (JanSan) Purchase Channel has been running since October 2015. GSA has 18 blanket purchase agreements (BPA) for this strategic sourcing solution. It is designed to help federal agencies purchase Janitorial and Sanitation supplies at significant cost avoidance—prices that are at least 26 percent lower than standard government pricing. Consolidating purchasing under programs such as these saves taxpayer dollars and drives necessary spending to our small business partners. This makes a real and positive impact for government agency budgets and improves the bottom line for selected small businesses and suppliers.

Federal agencies may place orders directly with JanSan Purchase Channel contractors and receive blanket purchase agreement (BPA) pricing.

All BPA holders are available in GSA Advantage!®. It is easy to find specific products by searching directly for JanSan products

Visit GSA.GOV FSSI JanSan for more information including a guide to online store information.

Bank Contact Information

In order to effectively manage the GSA SmartPay purchase program for your agency/organization, it is important to know your contractor bank’s information. It will be helpful to get to know your bank's Customer Service Representatives/ Account Managers. They can provide a wealth of information and are ready and able to answer questions to help you manage your program. Many of your responsibilities as an A/OPC involve a working relationship with the contractor bank.

Here is a listing of the contractor bank's websites and phone numbers. Ask questions and get involved - they are available to give you the technical assistance you need.

Citibank:

U.S. Bank:

Risk Mitigation

How do I minimize the risk of misuse/ fraud in my program?

The most important thing you can do is to be aware of what activity is occurring on the accounts under your purview. Do not be afraid to ask account holders questions if you identify unusual or suspicious transactions or behavior.

GSA SmartPay Purchase Account Misuse/ Abuse can take many different forms, but here are some of the most common examples:

  • Purchases exceed the account holder's authorized limit. Account holders may be limited to a specific spending limit per transaction, per day, or per monthly billing cycle.
  • Purchases for which no funding is available. Federal law requires that funds must be available before any government purchase is made. It is up to the account holder to ensure that the funds are available prior to making any transaction.
  • The account holder allows other people to use his/her purchase account. Account holders must take steps to ensure the security of their account. This means the purchase account must be used only by the account holder and only for official government business. If the account holder allows others to use the purchase account, the account holder will be held personally liable to the Government for any unauthorized transactions.
  • Split Transactions. The FAR limits the dollar threshold for micro-purchases. Any purchase that, as a whole, would exceed the micro-purchase limit but is separated into smaller transactions in order to avoid the micro-purchase limit is considered to be a split transaction.
  • Products or services that do not meet the government's requirements. Account holders must use discretion when making purchases to ensure that they meet the government's requirements. Due to the wide array of products and services available, there may be occasions when account holders may be requested or tempted to buy luxury or deluxe versions of products and services that exceed the government's actual requirements. For instance, it would be questionable for an account holder to buy a $500 designer fountain pen when there are many quality fountain pens available for $50 or less.
  • Purchases for personal consumption. All purchases must be for official government use only. Thus, any purchase made that is for the account holder's personal use rather than for official government purposes is considered to be misuse. For example, an account holder who uses the purchase account to buy himself lunch because he had no cash available that day is misusing the purchase account.
  • Purchases that are not authorized by the agency/organization. Your agency/organization may have additional limits on the use of the purchase account, such as limiting certain categories or types of products or services.

Consequences for misuse/abuse may include:

  • Reprimand;
  • Purchase account cancellation;
  • Counseling;
  • Suspension of employment;
  • Termination of employment; and
  • Criminal prosecution.

Note: Some agencies have agency-specific penalties and consequences for misuse/abuse of the purchase account.

What is fraud?

Fraud is a deception deliberately practiced with the motive of securing unfair or unlawful gain. Fraud can be an attempt to cheat the Federal Government and corrupt its agents by using GSA SmartPay payment solutions for transactions not part of official government business. Like any deception, fraud has its fair share of victims.

Some of the different types of fraud include:

  • Counterfeit Accounts — To make fake cards, criminals use the newest technology to “skim” information contained on magnetic stripes of cards, and also to pass security features (such as holograms).
  • Lost or Stolen Accounts — Often physical cards are stolen from a workplace, gym or unattended vehicle.
  • Card Not Present (CNP) Fraud — Internet fraud occurs whenever account information is stolen and used to make online purchases. Usually, a merchant will ask for the CVC code (located on the back of the card itself) to help prevent this type of fraud.
  • Phishing — Phishing occurs whenever an account holder receives a fake email directing him or her to enter sensitive personal information on a phony website. The false website enables the criminal to steal information from the account holder.
  • Non-Receipt Fraud — This occurs whenever new or replacement cards are mailed and then stolen while in transit.
  • Identity Theft Fraud — Whenever a criminal applies for an account using another person’s identity and information

As a program coordinator, you must inform your account holders to:

  • Be alert to the indicators of fraud (including false charges/ transactions, mischarging, bribes, gratuities, and kickbacks)
  • Report suspected fraud immediately through the proper channels at your agency (AO, A/OPC, Financial Officer, Office of the Inspector General or Office of Special Investigations)

Note: Any intentional use of the GSA SmartPay purchase account for other than official government business is considered an attempt to commit fraud against the U.S. Government and may be cause for disciplinary actions. The account holder is held personally liable to the Government for the amount of any non-Government transaction. Under 18 U.S.C. 287, misuse of the purchase account could result in fines or imprisonment or both. Military members who misuse the purchase account may be subject to court martial under 10 U.S.C. 932, UCMJ Art. 132.

What should I do if I suspect misuse or fraud?

A key responsibility for most program coordinators is to detect and report suspected misuse. If a situation occurs where you must report suspected misuse, make sure you have all the information necessary to assist with a formal inquiry or investigation. Contact the account holder to obtain any information that could explain questionable charges. If the account holder provides documentation or an explanation regarding the charges and you still have questions or concerns about it, compile all the information (e.g., statement, exception report, documented contacts between you and the account holder, copies of receipts, etc.) before you report it. Your agency/organization may ask you to report suspected misuse to one or more of the following personnel:

  • The Approving Official
  • The Finance Officer
  • The Office of Inspector General (via the hotline), OR the Office of Special Investigations (for Defense agencies)

Always follow your agency's policies and procedures when handling cases of suspected misuse.

Program management tools include:

  • Credit limits - Credit limits restrict single, daily, weekly, or monthly expenditures by the account holder. In accordance with agency/organization policy, an A/OPC may set the limits which best meet the agency's needs. Setting limits that are realistic, but not excessive, will deter account holder misuse. By reviewing account holder spending patterns, you may be able to lower limits without disrupting the agency's mission. A/OPCs also have the authority to raise limits at any time in response to emergency or unforeseen situations.
  • Merchant Category Code (MCC) Blocks - Merchant Category Codes (MCCs) are established by the associations or contractor banks to identify different types of businesses. Merchants select the codes best describing their business. You may limit the types of businesses where the account will be accepted by limiting the MCCs available to the account holder. The contractor bank has established sample templates that may assist you in determining which MCCs should be restricted. In the event that an account holder needs to make a purchase outside of his/her restricted MCCs, A/OPCs are authorized to override the restriction for a transaction by contacting the contractor bank's Customer Service Representative. Agency/organization policy should specify who is authorized to perform overrides.
  • Online Reports - A/OPCs have access to many standard and ad hoc reports online through the contractor bank’s EAS.
  • Account Deactivation - In those instances when the purchase account is not needed on a continuous basis, deactivation of the account may serve as a deterrent to fraud and/or misuse. You may deactivate the account when an account holder is not using or is not planning to use the purchase account. By understanding the account holder's need and use of the account, you can work with the account holder to establish deactivation guidelines. Deactivation and reactivation can be completed through the bank's EAS or by calling the bank's customer service phone number.
  • Guides - The banks have developed written guides for A/OPCs and account holders, as follows:
  • A/OPC Guide - This guide addresses issues of concern to the A/OPC, including responsibilities of program participants, account setup and maintenance, account suspension/cancellation, disputes, reports and invoicing procedures. The guide is available from the banks in hard copy and/or electronically.
  • Account Holder Guide - This guide addresses authorized uses of the purchase account, disputes and billing.
How do these tools make it easier to audit and manage the use of purchase accounts?

By providing electronic reports and transaction files, auditors and agency/organization program managers have immediate access to information such as merchant name, type of merchant, dollar amount of transaction, and date of transaction. These tools make it easier to identify questionable transactions and follow through to ensure that the transactions were proper. In some instances, merchants also provide line item detail of transactions, including quantities, prices and product descriptions. GSA continues to work with the associations to increase availability of line item detail.

What tools does GSA provide to assist agencies/organizations with preventative measures/program management for the purchase program?
  • GSA developed and hosts an online training course for account holders that discusses the proper use of purchase account
  • The annual GSA SmartPay Training Forum for A/OPCs provides training on the bank’s EAS, best practices, and program management.
  • Free online resources to assist purchase A/OPCs in detecting and preventing misuse and fraud.
  • Printable resources such as Helpful Hints for Purchase Account Use is a card-sized brochure that provides information on the purchase account. This brochure can be ordered on online and can be passed out to account holders when they receive their purchase accounts.

Liability for Purchase Account Transactions and The Review Process

Liability for Purchase Transactions

The GSA SmartPay Master Contract defines liability for purchase transactions:

  • Liability for transactions made by authorized account holders rests with the Federal Government.
  • If the account is used by an authorized account holder to make an unauthorized purchase, the Government is liable for payment and the agency is responsible for taking appropriate action against the account holder.
  • Use of the account by a person other than the account holder, who does not have actual, implied, or apparent authority for such use and for which the account holder receives no benefit, is not the liability of the Federal Government. If it is discovered that someone other than the account holder has used the account, it should be reported immediately to the A/OPC and the bank’s customer service representative.
The Review Process

Because an agency is liable for unauthorized purchases by an authorized account holder, agency purchase policy should address reviews conducted by the Approving Official (AO) and Agency/Organization Program Coordinator (A/OPC) to mitigate agency risk.

Approving Official Review:

The approving official is responsible for ensuring that all purchases made by the account holder were appropriate and the charges accurate.  All questionable purchases must be resolved with the account holder.  In the event an unauthorized purchase is detected, the AO must notify the A/OPC and other appropriate personnel in accordance with agency policy.  After review, the AO will sign the account statement and maintain the documentation in accordance with agency procedures.  Timely reviews of transactions are necessary to ensure detection of possible cases of account misuse and fraud.  The AO should have direct knowledge of the account holder’s role in the agency and the ability to verify receipt of the purchase.

Program Coordinator Review:

Program coordinator reviews of the purchase program must be accomplished to ensure adequate local internal controls are in place.  The review should consist of an evaluation of local operating procedures to ensure that account holders and approving officials are operating within the prescribed policies. A review includes: 

  • Compliance with agency policies;
  • Applicable training requirements;
  • Appropriate delegation of authority;
  • Integrity of the purchase process;
  • Compliance with procurement regulations;
  • Receipt and acceptance procedures; and
  • Records retention.

Reporting a Lost or Stolen Account

What happens if an account is lost or stolen?

Instruct your account holders to report a lost or stolen purchase account promptly to:

  • The contractor bank;
  • You, the program coordinator (A/OPC); and
  • Their supervisor.

Once an account has been reported as lost or stolen, the contractor bank immediately blocks that account from further usage and a new account number will be issued to the account holder.

Reporting the account as stolen does not relieve the account holder or the Government of payment for any transactions that were made by the account holder prior to reporting it stolen. If the account holder does not recognize a transaction appearing on their statement, they are responsible for notifying the contractor bank within 90 calendar days from the transaction date to initiate a dispute, unless otherwise specified by the agency/organization. This notification of transaction dispute may occur via the electronic access system, by telephone, or other electronic means (e.g. email).

Note: The account holder relinquishes their right to recover a disputed amount after 90 calendar days from the date that the transaction was processed. It is their responsibility to dispute questionable charges. If they don’t, they will be held personally liable for the amount of the questionable charge.

Best Practices

Best practices for managing a GSA SmartPay purchase program:

  • Engage management at the highest levels.
  • Train A/OPCs and account holders.
  • Review credit limits and lower as appropriate.
  • Use the bank’s Electronic Access System (EAS), data mining tools, and agency/ organization technology to run reports for monitoring questionable transactions.
  • Provide the GSA SmartPay card-sized booklet, “Helpful Hints for Purchase Card Use”, with each account holder application.
  • Publish frequently asked questions (FAQs) related to the purchase account on your agency’s/ organization’s website.
  • Create a monthly newsletter to reinforce agency/ organization policies and procedures.
  • Monitor spend by developing ad hoc reports that can be generated via Electronic Access Systems (EAS).
  • Perform an annual review of all issued accounts to determine if each account holder meets the criteria for continued participation in the federal government purchase program.
  • Provide comprehensive face-to-face account holder training as orientation for new account holders.
  • Address standards of conduct/ethics and clearly state consequences for misuse.
  • Discuss agency/organization policy.
  • Ensure account holders and A/OPCs fulfill the required refresher training requirements at a minimum every three years, or more frequently as per agency/ organization policy.
  • Ensure that training is easily accessible.

Common Questions

Click here for commonly asked questions.

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