10. Violations
To ensure that all cardholders are clear on expectations associated with the policy violations (versus something that requires a corrective action be taken) a policy violation matrix was created to clearly identify known violations. A cardholder can incur five (5) total policy violations over a rolling two-year period of time, a card will be suspended for at least one two-year cycle. For example, if a pcard violation occurs on September 20, 2022 - that counts as an infraction until September 20, 2024 and the clock resets on September 21, 2024 for another 2 year period of time.
In extraordinary circumstances, the cardholder may receive executive approval to continue card usage as approved by the Executive Vice President and Provost (for academic and academic support units) or the Vice President for Finance and Administration (for administrative units).
If a cardholder requires suspension of their card due to receiving five policy violations during the two-year measurement period, the CFAO will be contacted. If the CFAO feels that they want to invoke the exception process, the CFAO will be required to document why they feel the card should not be suspended and that information, along with the history of the cardholder, will be forwarded to either the Executive Vice President and Provost (for academic and academic support units) or the Vice President for Finance and Administration (for administrative units) for review and determination. In extraordinary circumstances, the cardholder may receive executive approval to continue card usage as approved by these individuals.
Certain violations may result in the university seeking restitution from the cardholder for inappropriate charges. Policy violations may also result in disciplinary action, up to and including termination, in accordance with applicable policies and rules or criminal charges, if appropriate.
Policy violations noted at the departmental level must be reported to Accounts Payable using the following process. Both the CFAO and the Financial Approver have responsibility to ensure that the appropriate policies, procedures and guidelines are followed by cardholders in their unit.
| Policy Violation | If the Approver or CFAO become aware of the violation they must: |
|---|---|
Late submission of report (28 CALENDAR DAYS + 9 CALENDAR DAYS FOR APPROVAL) in Concur after Concur posted date. Faculty with limited availability due to travel associated with research or student engagement activities may seek exception from CFAO who will then communicate to Finance | Finance receives notifications from Concur. No action needed. |
| Missing itemized receipt (except certain travel less than $75 as defined Policy 41.121 Reimbursement of Official Travel and Entertainment) | 1) Ask the cardholder to provide the information/attach it to the Concur transaction 2) If the cardholder cannot produce the required itemized receipt they need to document the policy violation on the transaction in Concur and 3) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record and in Concur. |
| Personal use - Accidental or Intentional | 1) Request reimbursement be made to the University from the cardholder and ensure that this occurs 2) Make note of the policy violation and the reimbursement information in Concur 3) Notify financecustomercare@ohio.edu of the policy violation so that it can be logged on the cardholder record. |
| Professional Services without prior Purchasing approval of terms & conditions | 1) Document the violation on the transaction in Concur and 2) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record. |
| Pyramiding - splitting a large dollar transaction into smaller amounts to circumvent card limits | 1) Document the violation on the transaction in Concur and 2) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record. |
| Software Purchases without prior OIT approval of use case and Purchasing approval of terms & conditions | 1) Document the violation on the transaction in Concur and 2) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record. * Software purchased without going through the appropriate review process may need to be reimbursed by the cardholder |
| Use of Pcard for unallowable purchases per the University Purchasing Guide | 1) Document the violation on the transaction in Concur and 2) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record. |
| Use of Pcard by another individual | 1) Document the violation on the transaction in Concur and 2) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record. *CFAO should also have a conversation with the cardholder about the unallowability of loaning out their university provided payment card as this is unallowable under policy |
| Use of another Pcard while card suspended | 1) Document the violation on the transaction in Concur and 2) Report the policy violation by sending the information to financecustomercare@ohio.edu so the violation can be logged on the cardholder record. *If a cardholder has had their pcard suspended, they cannot use any type of university payment card (including departmental cards) |