Frequently Asked Questions

No. In accordance with legal precedence, IBAs are subject to any tax that a state deems appropriate. There are states that choose to extend exemption for state sales tax only. For a list of states that provide state sales tax exemption for IBAs, please visit the State Tax Information page.

All states are required to honor state sales tax exemption for travel CBAs. In summary, for both CBA and IBA solutions, states have the sovereign authority to levy any tax other than sales tax for transactions using a GSA SmartPay program solution, unless specifically exempt in state law.

Applies to both CBAs and IBAs.

No. State sales tax exemption is determined by method of payment, not by the federal entity that employs the card/account holder. Vendors are only required to honor state sales tax exemption (when applicable by state law) to users that present valid federal government forms of payment, and many states specify GSA SmartPay payment solutions.

Nearly all agencies require the use of a federal government method of payment on travel. If you have any questions regarding mandatory usage of the GSA SmartPay Travel card/account, please reach out to your agency’s charge card program directly.

Applies to both CBAs and IBAs.

If the sixth digit in the bank identification number (BIN) is 0, 5, 6, 7, 8, or 9, then the charge card statement is paid directly by the federal government and should not be subject to state sales tax. If the sixth digit in the BIN is 1, 2, 3, or 4, then the charge card is not paid directly by the federal government and therefore may be subject to state sales tax. Each state may have different documentation requirements for exemption.

Applies to both CBAs and IBAs.

Yes. The card artwork on the GSA SmartPay website and provided to hotels and state taxation offices is the default card art for the GSA SmartPay 3 program. Some agencies requested permission from the Center for Charge Card Management to deviate from the default card artwork, or to issue “generic” card artwork. The most reliable way to determine if a card is a GSA SmartPay charge card is to verify the prefix (first four digits of the card).

Applies to both CBAs and IBAs.

States have the authority to assess state sales taxes on consumers, and hotels are responsible for collecting taxes on behalf of a state’s revenue authority. Once a hotel has determined that a card/account holder qualifies for state sales tax exemption under state law, the hotel must document the evidence for sales tax exemption eligibility.

Each state determines the level of information needed to constitute sufficient documented evidence, and that is usually collected through forms and documentation requirements.

Once information has been collected, the state has the right to review the evidence and determine if the exemption was appropriately applied. If the state deems that the hotel did not collect the proper documentation, the state has the authority to collect the state sales tax and penalties from the hotel.

Applies to both CBAs and IBAs.

As stated in the previous answer, if a state determines that a hotel did not collect sufficient information in accordance with state law, the state has the authority to collect the state sales tax and penalties from the hotel. To mitigate this risk, hotels may over-document or ask for information not required by state law (e.g., tax identification numbers or tax exemption numbers).

Card/account holders are not required to provide forms or information to hotels if the state does not require it. If the hotel is insistent, recommend the hotel contact the state taxation department directly for clarification.

Applies to both CBAs and IBAs.

GSA and the broader federal government do not have the authority to dictate state sales tax exemption documentation requirements. Each state has the sovereign authority to determine individual state requirements.

Applies to both CBAs and IBAs.

Recommend that the hotel reaches out to the state taxation department directly for clarification. If the hotel is not willing to, there may be an opportunity to reclaim the taxes assessed directly from the state after your trip.

Reclamation requirements vary by state, and card/account holders should contact states directly for more information about the process. As a best practice, travelers are encouraged to contact the hotel and confirm state sales tax exemption status and documentation requirements to avoid confusion.

Applies to IBAs only.

No. Due to complexity in state law as applied to federal government tax exemption, there is often confusion around tax exemption. In efforts to provide customer service to federal government employees, hotels in states that do not honor state sales tax exemption for IBA travel may provide incorrect forms for tax exemption. Card/account holders should not complete these forms and claim exemption.

Applies to IBAs only.

Yes. Legal precedence only supports exemption for state sales tax, unless state law also extends tax exemption to other specific types of taxes

Applies to both CBAs and IBAs.

Some municipalities may have separate tax exemption processes for federal government employees. As we are made aware of these, we add the information to the GSA SmartPay website.

Applies to both CBAs and IBAs.

CBAs are exempt from state sales tax in all states. However, states have the authority to assess state sales taxes on consumers, and merchants are responsible for collecting taxes on behalf of a state’s revenue authority.

If a merchant determines a card/account holder qualifies for state sales tax exemption under state law, merchants must document the evidence for sales tax exemption eligibility.

Each individual state determines the level of information needed to constitute sufficient documented evidence, and that is usually collected through forms and documentation requirements.

Once information has been collected, the state has the right to review the documented evidence and determine if the exemption was appropriately applied. If the state deems that the merchant did not collect the proper documentation, the state has the authority to collect the state sales tax and penalties from the merchant. As such, if a state determines that a merchant did not collect sufficient information in accordance with state law, the state has the authority to collect the state sales tax and penalties from the merchant. To mitigate this risk, merchants may over-document or ask for information not required by state law (e.g., tax identification numbers or tax exemption numbers).

Card/account holders are not required to provide forms or information to hotels if the state does not require it. If the merchant is insistent, recommend the hotel reaches out to the state taxation department directly for clarification.

No. However, there are a few states that do not directly tax the user and instead choose to tax the merchant. This is an indirect or pass-along tax, as the merchant can choose to pass along the amount of the gross receipts tax to the purchase card/account user. Once the merchant passes along the tax it is no longer a state sales tax and it is allowable. Please also note that the merchant is not required to pass along the amount of the gross receipts tax to the card/account holder. For more information about specific states, visit the State Tax Information page.

Yes. There may be instances where the state will exempt the merchant from the gross receipts tax on federal government transactions, which may result in the merchant choosing to not pass the tax to the card/account holder. In these states, the merchant is not required to engage in this process.

As a best practice, card/account holders should clarify with merchants, prior to purchase, that the merchants will honor the state sales tax exemption. If the merchants do not, explore other options with merchants that will honor tax exemption.

Recommend that the merchant reaches out to the state taxation department directly for clarification. If the merchant is not willing to, please contact your agency’s charge card program for further information.

The purchase card/account was not designed to be used for travel, especially for meals and incidental transactions. There may be agencies that allow limited use for specific types of travel-related expenses (e.g., booking room blocks). Prior to using a purchase card/account for travel-related expenses, card/account holders must confirm that agency policy allows for this type of use and follow applicable policies and procedures for documentation.

Yes. State sales tax exemption is based on payment liability and not by how an agency uses the charge card. For CBAs such as the purchase card/account, the sixth digit identifier determining payment liability does not apply.

The Amazon Tax Exemption Program includes a process in which applicants must complete all tax exemption forms from each individual state. This occurs once during the application process to streamline future purchases as applicable tax exemption forms are saved and then applied for each individual transaction. Applicants should refer to agency policy to determine if participation in the Amazon Tax Exemption Program is allowable.

For items sold by third party vendors, please contact the sellers directly with the proper documentation for more information.

It depends on the state. Some merchants are required by law to charge taxes based on where the business is based, but most are required by law to charge taxes based on where the card/account holder is based. Merchants are responsible for being familiar with this information.

If the state does not require this information, the card/account holder is not required to provide it. If a merchant is insistent or refuses to honor tax exemption, recommend that the merchant contact the state taxation department directly for clarification. If the state does require this information, please reach out to your agency’s budget or finance divisions to find out where this information may be housed within your agency/organization.

No.

Yes.

Foreign and tribal governments are sovereign entities that have the discretionary authority to tax any person belonging to any other sovereign nation or entity. There may be treaties or agreements between the United States Government and these entities that govern taxation or exemption circumstances. In the instances that there are no treaties or agreements, card/account holders are responsible for paying these taxes.

Card/account holders should reach out to their Agency/Organization Program Coordinator (A/OPC), who will be able to answer most account-related questions.

Card/account holders can also contact the bank directly by calling the customer service phone number listed on the back of their card.

If the issue cannot be resolved by the A/OPC or bank, reach out to the GSA Center for Charge Card Management (CCCM) at gsa_smartpay@gsa.gov.

To obtain a GSA SmartPay card/account, employees should reach out to their A/OPC and supervisor. Each agency has different criteria for issuing cards/accounts.

Card/account holders should contact their A/OPC to learn more about their agency’s specific policies on purchases. In general:

• Purchase cards/accounts are used to pay for supplies or services.
• Travel and Tax Advantage Travel cards/accounts are used to pay for travel and travel-related expenses.
• Fleet cards/accounts are used to pay for fuel, maintenance and repair of government owned/operated motor equipment, aviation, small marine vessels and large marine vessels.
• Integrated cards/accounts involve two or more business lines (i.e. fleet, purchase and/or travel) on a single card/account.

The Treasury Financial Manual is the Department of the Treasury’s official publication of policies, procedures and instructions concerning financial management in the federal government.

There are a number of policies that govern the use of government payment solutions, including:

• Federal Acquisition Regulations (FAR).
• Federal Travel Regulations (FTR).
• Federal Management Regulations (FMR).
• OMB Circular A-123, Appendix B.
• Public Law.
• American Recovery and Reinvestment Act.

For more information on the policies listed above, visit the Policies page.

Additionally, many agencies have regulations that are specific to their program and tailored to their agency’s mission and operating procedures. Contact your A/OPC to learn more information about your agency’s specific policies.

Per OMB Circular A-123, Appendix B, all GSA SmartPay program participants must take the required training and receive a certificate of completion prior to their appointment. In addition, refresher training must be completed every three years (or more often as required by your agency’s training policy).

If permitted by your agency’s A/OPC:

• Card/account holders may complete the required training and obtain a certificate of completion via the GSA SmartPay Training website.
• Card/account holders may retake the course and quiz as refresher training. A passing score will enable the card/account holder to reprint the certificate with the new date of completion.

Note: If an card/account holder has previously taken the course and passed the quiz on the training website, a certificate can be reprinted by accessing past certificates through the training site.

In some cases, when using certain types of cards/accounts, card/account holders are exempt from taxes on their purchases. Please visit the State Tax Information page to learn more.

• Centrally Billed Accounts (CBA): Purchase, fleet and some travel accounts where payment is made directly to the bank by the government.
• Individually Billed Accounts (IBA): Travel accounts where payment is made directly to the bank by the individual. Each state determines the exemption status for IBAs.
• Integrated Accounts: Considered CBAs, but may involve both CBA and IBA transactions, which is determined at the agency’s task order level.
• Tax Advantage Travel Accounts: Combines CBA and IBA transactions to provide tax exemption at the point of sale for rental car and lodging expenses.

Intentional use of government cards/accounts for other than official government business constitutes misuse, and depending on the situation, may constitute fraud. Each agency develops and implements policies related to employee misuse.

Examples of misuse include:

• Purchases that exceed the card/account holder’s limit.
• Purchases that are not authorized by the agency.
• Purchases for which there is no funding.
• Purchases for personal consumption.
• Purchases that do not comply with the policies.

Potential consequences for the card/account holder may include:

• Counseling.
• Cancellation of the card/account.
• Written warning.
• Notation in the employee’s performance evaluation.
• Reprimand.
• Suspension.
• Termination of employment.

In the case of purchase card/account or CBA travel card/account misuse, the employee may be held personally liable to the government for the amount of any unauthorized transactions. Depending on the agency and the circumstances, there are a number of applicable laws that can result in fines or imprisonment.

Both Visa and Mastercard state in their guidelines that a merchant is allowed to make/store a photocopy of a charge card provided they do NOT record or copy the PIN and/or Card Verification Code (CVC) data in any manner or for any purpose.

Note: According to U.S. Code Title 18, Part 1, Chapter 33, 701, it is illegal for a merchant to photocopy your government ID.

Third Party Payment processors (such as PayPal) offer e-commerce/internet payment solutions for commercial transactions. The processors own merchant accounts that allow them to accept and process orders on behalf of other companies. Many vendors choose to utilize third party payment processors in order to accept online payments without having to establish a merchant account through a bank. Some vendors find that this is a more cost-effective option, especially if they do not process enough transactions to establish their own merchant account to accept charge cards. Vendors pay third-party processors a transaction fee for these services rather than processing transactions through a merchant bank.

Transactions that are made using third-party payment platforms are considered to be high-risk transactions. We recommend GSA SmartPay card/account holders consider alternative methods of payment.

Although there are not any existing governmentwide policies or procedures outlining the use of third-party payment processors, several agencies have developed internal policies related to this issue. These policies range from the complete restriction of third party payment processors to less restrictive policies which allow for transactions to be made when a workaround cannot be identified.

Agencies and/or individual card/account holders are not liable for charges made on a lost or stolen card after the card is reported as lost or stolen. A new card with a new card/account number will be issued to the card/account holder within 48 hours of the request. Any previous authorized activity will be transferred to the new card/account.

Since banks are required to conform to the Know Your Customer (KYC) requirements, they must confirm the identity of every applicant and card/account holder. KYC requirements are driven from the Bank Secrecy Act and Patriot Act. Documentation, such as a marriage certificate, is needed to support this requirement. This also allows the banks to maintain account accuracy throughout the life of the customer relationship. Supporting documentation also decreases the chance of fraud and assists the banks in ensuring they are in compliance with the Fair Credit Reporting Act in the event an account is reported to the credit bureaus.

The Tax Advantage Travel card/account is issued to an employee designated by the agency/organization in the employee’s name. The agency will work directly with the contractor bank to:

• Establish the billing and payment procedures for Centrally Billed Account (CBA) transactions versus Individually Billed Account (IBA) transactions.
• Determine if credit checks or other creditworthiness assessments will apply.
• Identify Merchant Category Codes (MCCs) for rental cars and lodging, in order to exclude those transactions from taxes.

When the card/account is used, invoices will be sent to the agency and the card/account holder for payment. The agency is responsible for the CBA charges on the card/account, while the card/account holder is responsible for the IBA charges.

Yes. In accordance with the Federal Travel Regulations (FTR), Section 301-51, Paying Travel Expenses, agencies are required to pay for official travel expenses using a government authorized travel payment solution, unless granted an exemption in accordance with FTR policies.

For the Department of Defense, see DoD Instructions 5154.31 and the Joint Travel Regulations (JTR).

The payment process called split disbursement as described in OMB Circular A-123, Appendix B divides a travel voucher reimbursement between the contractor bank and the traveler, sending the balance owed directly to the appropriate party.

Note: Although OMB Circular A-123, Appendix B in Chapter 2.5 requires all executive branch agencies to implement split disbursement, it may not yet be operational in your agency. Please contact your A/OPC for further details.

There are several ways to actively participate within the community:

• Attend the Quarterly A/OPC meetings, monthly “Discussions with Dave” calls, and other special meetings and events: Level 1 A/OPCs receive email invites to these meetings.
• Attend the annual GSA SmartPay Training Forum: Learn about all aspects of how to successfully manage your agency’s charge card program. Network, collaborate and share best practices with other card managers, bank representatives and GSA personnel.

The GSA SmartPay program office provides a number of tools and types of assistance to support effective charge card/account program management across the government. Tips include:

• Ensure policies are being followed: Most agencies have comprehensive policies regarding the administration of their payment programs. This includes policies for card/account use as well as for program management. A/OPCs should ensure that the policies are clearly communicated and easily accessible to card/account holders. It is also important for agencies to follow through with the implementation of their policies, including distribution and compliance monitoring.
• Make training a priority for all card/account holders and A/OPCs:
  • GSA offers free basic online training covering regulations and best practices for all agencies.
  • A variety of free resources to support card/account management are available on the GSA SmartPay program’s website.
  • Contact the bank to schedule an in-person or virtual Electronic Access System (EAS) training for your A/OPCs.
  • Consider attending the annual GSA SmartPay Training Forum, which provides a large variety of training for all A/OPCs and charge card management staff.
• Initiate an Accounts Payable (A/P) File Review: An A/P File Review, performed by the contractor bank, is a no-cost tool to help agencies identify opportunities to leverage GSA SmartPay solutions as methods of payment to increase process efficiencies, cost savings and refunds.
• Participate in Workgroups: The GSA Center for Charge Card Management (CCCM) sponsors periodic workgroups to facilitate the sharing of information between agencies and to collect feedback on the performance of the GSA SmartPay program office and its contractor banks.

Under the GSA SmartPay program, there are many options available to assist your agency in meeting your mission critical needs. Products and related services under the GSA SmartPay program can offer customized payment solutions to help your agency achieve its goals. Under the GSA SmartPay Master Contract, each participating agency tags, joins a pool agreement, or awards its own task order to one of the contractor banks. Not all products and services offered under the GSA SmartPay program may be available to your agency, as each agency’s task order is different and unique. For this reason, it is important to review your agency’s task order. In addition, speak to those within your agency that are responsible for managing your agency’s task order, such as your Level 1 A/OPC and the task order’s Contracting Officer.

The Treasury Financial Manual is the Department of the Treasury’s official publication of policies, procedures and instructions concerning financial management in the federal government.

There are a number of policies that govern the use of government payment solutions, including:

• Federal Acquisition Regulations (FAR).
• Federal Travel Regulations (FTR).
• Federal Management Regulations (FMR).
• OMB Circular A-123, Appendix B.
• Public Law.
• American Recovery and Reinvestment Act.

For more information on the policies listed above, visit the Policies page.

Additionally, many agencies have regulations that are specific to their program and tailored to their agency’s mission and operating procedures.

There is a variety of free training offered to A/OPCs. All upcoming training opportunities for A/OPCs will be posted on the GSA SmartPay program website on the Events page.

• Online training for A/OPCs and card/account holders (Available 24/7).
• Annual GSA SmartPay Training Forum.
• Bank Electronic Access System (EAS) training.
• Other special training events offered throughout the year.

Mandating training that meets governmentwide standards for card/account holders and A/OPCs is the first step to preventing misuse. Currently, training varies widely among agencies, with many agencies relying on the training provided at the annual GSA SmartPay Training Forum and the online courses on the GSA SmartPay Training website. While these training courses review the necessary governmentwide rules and regulations, they do not reflect agency-specific requirements, which are important for card/account holders to know.

The GSA SmartPay Master Contract includes a number of tools that support agencies in controlling and monitoring card/account spend to prevent fraud, waste and abuse. Examples of these tools are:

• Credit limits: Restrict single purchase, daily, weekly or monthly expenditures by the card/account holders. In accordance with agency policy, limits are set to meet the agency needs.
• Merchant Category Code (MCC) Blocks: Established by the bankcard associations to classify different types of businesses. Merchants are assigned codes that describe their primary line of business. Agencies can limit the types of businesses where card/account holders are permitted to make purchases by limiting the MCCs available to card/account holders.
• Reports: Agencies have access to online management reports via their contractor bank’s Electronic Access System (EAS). Standard reports include Account Activity, Dispute, Unusual Spending Activity, Lost/Stolen Cards and Ad Hoc reports.
• Guidebooks: The banks are required to provide written A/OPC guides that serve as a stand-alone reference for A/OPCs to conduct program management for the GSA SmartPay Program. Topics include procedures for card/account setup and maintenance, card/account suspension/cancellation, transaction disputes and reconciliation. Agencies also have access to card/account holder, Designated Billing Office and Transaction Dispute Office guides from banks.

Every effort should be made to assist the contractor in collecting the balance due. Ensure that your card/account holders are aware of their responsibilities.

Yes. A reason must be documented for suspension or cancellation. Cards/accounts may be canceled through your bank’s EAS or through the bank’s customer service office.

As the A/OPC, you are responsible for the establishment and maintenance of your program’s accounts. Refer to your contractor’s A/OPC guide and EAS manual for instructions on how to set up cards/accounts.

Merchants that wish to obtain a GSA Multiple Award Schedule (MAS) contract to do business with the government are required to accept GSA SmartPay payment solutions as a method of payment for micro-purchases. The rules and requirements for accepting payment solutions are defined by the card associations.

To promote the use of the GSA SmartPay payment solutions at their establishments, merchants can:

• Provide point-of-sale discounts: Offering a point of sale discount to government card/account holders is a great way to differentiate your business from others and to increase the amount of government purchases.
• Provide Level 3 transaction data: Merchants that provide Level 3 transaction data are more attractive to government agencies because the data enables agencies to keep track of their purchases more accurately. Merchants who wish to learn more about Level 3 data should contact their financial institution for more information.

Most GSA SmartPay cards will use government-specific designs and will display the GSA SmartPay logo, including the phrase “United States Government” or “For Official Use Only.” The five standard card designs are displayed below:

GSA SmartPay cards/accounts operate just like the commercial market. For example, if you already accept these forms of payment for non-government purchases, you can accept the GSA SmartPay payment solutions. The same previously negotiated transaction fees apply to GSA SmartPay transactions.

GSA SmartPay card/account holders may carry the following brands: Mastercard, Visa, Voyager and Wright Express (WEX).

If you do not currently accept a particular form of payment, contact any financial institution to learn more about establishing a merchant account and maximizing your ability to capture government sales.

Both Visa and Mastercard state in their guidelines that a merchant is allowed to make/store a photocopy of a charge card provided they do NOT record or copy the PIN and/or Card Verification Code (CVC) data in any manner or for any purpose.

Note: According to U.S. Code Title 18, Part 1, Chapter 33, 701, it is illegal for a merchant to photocopy a government ID.

In some cases, certain purchases made using a GSA SmartPay card/account are exempt from taxes. Please visit the State Tax Information page for more details.

Businesses are required to label themselves by selecting a Merchant Category Code (MCC) that describes the products or services provided. Certain MCCs are blocked by agencies to prevent fraud and misuse. A business that has trouble accepting a GSA SmartPay card/account may be classified under a blocked MCC. To remedy this problem, merchants should talk to their financial institution to confirm that their MCC classification is accurate.

Mastercard and Visa rules and operating regulations can be found here:

• Mastercard Operating Rules
• Visa Operating Regulations

It depends. Card/account holders are advised to check with your agency regarding the continued use of GSA SmartPay cards/accounts due to a lapse in funding during a shutdown. You may not be authorized to use your cards/accounts if your agency determines such use does not relate to excepted or exempted activities.

The Anti-Deficiency Act prohibits most agencies from incurring obligations in the absence of appropriations (unless otherwise allowed by law or for emergencies involving the safety of life or limb, the protection of property or other excepted/exempted services). Card/account holders should coordinate with the appropriate officials in their agency/organization to ensure only authorized travel and purchases are made during a lapse in funding.

Absent of any agency-specific action to limit card/account use, purchase, travel, fleet and integrated cards/accounts will continue to function normally.

No, it is never appropriate to use your GSA SmartPay card/account for expenses not related to official government business. Doing so may result in your agency taking disciplinary action.

Yes. If you need to reach your contractor bank during the shutdown, please call the 1-800 number on the back of your GSA SmartPay card/account.

Citibank: For agencies, organizations, and card/account holders unable to make payments in the event of a governmentwide shut down, Citibank will ensure that during such periods accounts will not age delinquent or be suspended or cancelled and finance charges will not be assessed. The bank will continue to generate Statements of Account.

U.S. Bank: Accounts could become past due until budgetary issues are resolved, and as such, no cards/accounts will be deactivated without authorization from the GSA Contracting Officer. U.S. Bank will work with the government to implement risk-mitigation measures to monitor fraud and unusual delinquencies, as well as to bring past due accounts up to date once the budget is approved.

In general, the answer is “no.” Cards/accounts in good standing as of the start of the shutdown will not be reported by the contractor banks to credit bureaus for late payment. Additionally, “past due” notices will not be issued and collection activities will not occur. However, statements of account will continue to be issued and will likely show a balance due. This balance does not need to be paid until funding becomes available. These measures apply only to card/account holders affected by the shutdown with cards/accounts in good standing prior to the shutdown. For organizations (or components thereof) with funding, routine account management and payment rules apply. Generally, there is no need for individually billed GSA SmartPay Travel card/account holders to contact the contractor banks in order for these shutdown measures to be implemented, but card/account holders should comply with instructions issued by their agency. GSA SmartPay participating agency Headquarters (HQ) card/account managers (or other authorized HQ staff) are advised to coordinate with their servicing GSA SmartPay contractor bank(s) to ensure a clear understanding of how the individually billed travel cards/accounts impacted by the shutdown will be handled.

No. Payment is due to the contractor bank per the statement due date. If your card/account was delinquent prior to the shutdown, it will continue to be considered delinquent until full payment is made to the contractor bank. The time elapsed after payment is due continues to accrue in the event of a government shutdown.

Yes. In accordance with the terms of the GSA SmartPay Master Contract, if your card is due to expire during a shutdown, your new card will still be mailed. If your agency elects to have the charge card sent directly to you (for example, an individually billed travel card), then you will receive the card at the address on file. Or, your agency may elect to have the card mailed to the government offices for dissemination by an Agency/Organization Program Coordinator (A/OPC) or other government employee. The card will most likely be held by the distributing government office until the shutdown is over. If you are deemed an exempt or excepted employee, your agency will most likely ensure card delivery to you, but we recommend that you confirm these procedures with the appropriate officials in your agency.

Unless your agency takes action to limit or deactivate cards/accounts, your travel card/account will continue to work during a shutdown. For government travelers on official travel that are recalled to return home due to shutdown, GSA SmartPay contractor banks operate under a “no-strand” policy. This policy ensures that cards/accounts operate to support your return trip. But as policies vary, please be sure to check with your agency regarding travel during a shutdown.

Please coordinate with your agency’s finance officials and A/OPCs to ensure that these payments are properly addressed in the event of a shutdown. Be advised that purchase card/account holders may need to contact merchants to stop any automatic payments which may be scheduled to occur during the shutdown period.

The Anti-Deficiency Act prohibits most agencies from incurring obligations in the absence of appropriations (unless otherwise allowed by law or for emergencies involving the safety of life or limb, the protection of property or other excepted/exempted activities). Card/account holders should therefore coordinate with the appropriate officials in their agency to ensure only authorized travel, purchases and payments are made in the event of a shutdown, as this issue can become especially complicated given the wide variety of agency missions, funding types, etc.

Yes. The program will continue to operate normally in that cards/accounts will function and GSA SmartPay contractor bank account management staff and systems, reporting, call centers, etc., will continue to operate.

A/OPCs should consult with their contractor bank to help ensure appropriate internal control measures are maintained during a shutdown.

The PPA only applies to centrally billed accounts under the GSA SmartPay program. These account types include purchase, centrally billed travel, fleet and any centrally billed aspects of integrated accounts. PPA does not apply to individually billed accounts, as they do not constitute a federal government liability. GSA SmartPay cards/accounts will continue to function during a shutdown (except for those deactivated at agency direction) even though agencies may not be able to pay proper, official contractor bank invoices (which will continue to be generated) in a timely manner. Upon availability of funding, agencies must reconcile and pay these invoices as promptly as possible.

Agencies should first consult with the GSA Center for Charge Card Management at gsa_smartpay@gsa.gov. Changes in card/account types can lead to reconciliation challenges and affect dispute rights. All other potential implications should be fully explored and discussed prior to changes being made.

In general, the answer is “no,” provided you are affected by the shutdown and therefore unable to pay. Payment would be required once funding is restored.

In the event of a shutdown, the contractor banks recognize that affected agencies and card/account holders may be unable to make timely payments and cards/accounts could therefore become past due until funding becomes available. For individually billed travel cards/accounts in good standing as of the start of the shutdown, the contractor banks will:

• Keep accounts open unless deactivation is requested by agency officials.
• Take appropriate action to prevent accounts from becoming delinquent, suspended or canceled.
• Ensure finance charges are not assessed.
• Waive all applicable late payment fees.
• Continue to generate account statements.
• Work with agencies to maintain risk mitigation measures.
• Coordinate with agencies and card/account holders to bring accounts up to date once funding becomes available. The banks use highly automated account management processes that may require manual intervention by bank staff during a shutdown. As a result, isolated instances of errant activities such as the issuance of late payment notices on a card/account affected by the shutdown can occur. Should this happen, please follow your agency procedures or contact your servicing contractor bank as appropriate.

For accounts that were past due prior to the start of the shutdown, routine account management and payment rules apply.

Agencies may issue supplemental card/account holder guidance regarding individually billed account management and payments during a shutdown, consistent with applicable GSA SmartPay contract and task order terms.

Please contact us via email at gsa_smartpay@gsa.gov. We remain available to assist your agency during a government shutdown.

No, use of the purchase card does not automatically designate a purchase as a “rated order.”

Yes, the purchase card may be used as a payment mechanism for “rated orders” so long as it is in accordance with the terms and conditions of the contract under which the order is placed.

GSA Fleet does not have a policy precluding the use of the purchase card/account for services not covered by GSA Fleet leases, including interior vehicle cleanings. You must check with your agency’s policy on whether or not a purchase card/account can be used to pay for vehicle cleanings.

This is an agency determination. Items must be for official use only (i.e., no personal use).

Any method the agency determines acceptable can be used in a contingency or telework environment to verify receipt of goods or services for audit purposes.

Examples of verification/validation of receipt of orders are:

• Recipient can take pictures of items received for verification of receipt and provide those to the card/account holder for their log, or
• Sign off on the shipping receipt after verifying all items were delivered to “certify” all items were delivered/received and provide a copy to the card/account holder.

Both are acceptable when there is no third party available to verify receipt and/or the recipient is not at the same physical location as the purchase card/account holder.

The appropriate agency decision-makers for each agency’s purchase card program will need to determine if a card/account holder can receive deliveries at their home, ship products to the home address of other employees, or if they must still be sent to a government address. This is usually the Level 1 A/OPC, Purchase Card Program Office, and/or Purchasing/Policy Office.

Considerations at the agency level may include, but are not limited to:

• Ability of card/account holders to access the Government building where shipments would be sent.
• Ability to verify/validate receipt of goods or services.
• Ability to maintain proper control of supplies/products.
• Ability to ensure supplies/products are only for official government use.

No, the MPTs for services and construction remain at the lower thresholds:

• $2,500 for services subject to Service Contract Labor Standards (SCLS).
• $2,000 for construction.

Interior vehicle cleanings during the COVID-19 pandemic must be reviewed on a case-bycase basis to assess risk in accordance with CDC guidance. All environmental cleaning and disinfecting that occurs should follow CDC’s guidance. Drivers should consult their agency fleet manager for agency-specific policy.

Washes charged to your GSA Fleet leased cards in excess of the established zonal policy will be billed to your agency by your Fleet Service Representative (FSR) through our Agency Incurred Expense (AIE) process.