Purchasing cards
facilitate the State’s
procurement efforts.
Spending limits for some
cards could be lowered.
Compliance with
documentation
requirements could
be improved.
Use of purchasing cards
for personal gain
was rare.
Key Facts
and Findings
Expenditures with
purchasing cards typically
do not require preapproval.
Purchasing card expenditures
accounted for 4.0 percent
of all supplies and services
expenditures in 2008.
As of December 2008,
agency employees held
8,615 purchasing cards and
UW employees held 9,402.
Adequate documentation
is important in ensuring
accountability for purchases.
Agencies and UW institutions
have generally implemented
adequate internal controls
for purchasing cards.
We identified 131 exceptions
to purchasing policies
totaling $74,499.
Cardholders violated
procurement rules
for 16 purchases
totaling $128,541.
Since 1996, the Department of Administration (DOA) has administered
a program that allows state employees to use credit cards to make
purchases for state business purposes. In calendar year 2008, executive
branch agencies and University of Wisconsin (UW) institutions used the
cards to purchase a total of $161.7 million in goods and services. The
average purchase amount was relatively small$233 per transaction
but some purchases exceeded $25,000.
DOA has established rules for appropriate card use, as well as documentation
requirements for purchases. To evaluate purchasing card oversight
procedures and expenditures, we reviewed:
trends in purchasing card expenditures;
the State’s contract with U.S. Bank, the company that issues the cards;
purchasing card policies and procedures at executive branch agencies
and UW institutions;
the number of cards issued and the spending limits assigned to them;
and
a sample of selected expenditures we deemed to have a potential for
fraud or abuse, to determine whether they were consistent with state
purchasing rules and good business practices.
Purchasing Card Use
Purchasing card use by agencies
and UW institutions has increased
significantly, with total expenditures
increasing from $109.8 million
in 2005 to $161.7 million in 2008.
UW institutions accounted for
73.7 percent of all purchasing card
expenditures in 2008. All other state
agencies combined accounted for
26.3 percent.
Although purchasing card use
has increased, purchasing card
expenditures represented only
4.0 percent of all supplies and
services expenditures in 2008.
Spending Limits
Agency employees held
8,615 purchasing cards and
UW institution employees held
9,402 as of December 2008. DOA
policies do not limit the number of
cards an employee may hold, and
40 cardholders held 10 or more
cards as of December 2008.
Each purchasing card is assigned
two limits to control spending:
a credit limit, which is the card’s
maximum balance for each
two-week billing cycle; and
a single purchase limit, which
is the maximum amount that
can be charged in a single
transaction.
Agencies and UW institutions are
permitted to set spending limits
on cards but are generally required
to seek approval from DOA before
setting any card’s single purchase
limit to exceed $5,000. We observed
a wide range of spending limits. At
agencies, the average credit limit
was $9,382, while at UW institutions
it was $14,576.
We compared spending limits to
spending activity in 2008 and found
that spending limits were in many
instances higher than necessary.
For example, at the Department
of Revenue, 96 cards with single
purchase limits of $5,000 were used
exclusively for purchases of less
than $400 each. Similarly, at the
Department of Health Services,
27 cards with bi-weekly credit limits
of $20,000 were used exclusively
for transactions totaling less than
$100 each. The potential financial
risk to the State could be reduced
by setting spending limits at a
level that is more consistent with
cardholder needs.
In addition, we found 1,101 cards
that were active for all of 2008
but never used in that year, and
377 cards that were never used since
they were issued, including 97 that
were issued more than three years
ago. We include a recommendation
for DOA to work with agencies and
UW institutions to close unused
accounts.
Documentation of
Purchases
The State’s accounting and procurement
manuals require cardholders
to retain original, itemized receipts
for each transaction; document each
transaction on a purchase record;
and sign their purchase records and
submit them, along with receipts,
to their supervisors for review. Of
the 3,071 transactions we reviewed,
2,341, or 76.2 percent, satisfied
these documentation requirements,
but 730 did not. The percentage of
transactions that met the requirements
ranged from 58.4 percent at
UW-Milwaukee to 90.7 percent at
the Department of Regulation and
Licensing.
In addition to requirements contained
in the State’s procurement and
accounting manuals, s. 16.53(1)(c)1,
Wis. Stats., requires documentation
of the nature and particulars of
all state purchases. However, the
purchasing card policies established
by DOA do not specifically require
cardholders to document a state
business purpose for purchases,
and we found that documentation
for only 1,278 of 2,506 transactions,
or 51.0 percent, included an explicit
description of the state business
purpose.
Adequate documentation of
the business purpose enables
supervisors and other agency
reviewers to determine whether
purchases are appropriate. We
therefore include a recommendation
for DOA to require documentation
of the business purposes of
purchasing card transactions.
Exceptions to Purchasing
Policies
We generally found that agencies
and UW institutions had established
adequate controls, and instances of
inappropriate purchases were rare.
In the 3,071 transactions we reviewed,
we identified 131 purchase exceptions
totaling $74,499. The exceptions
we identified included:
$52,463 in excessive or unnecessary
purchases, including
purchases that have a state
business purpose but appear
to be luxury items or to include
avoidable costs such as late fees;
$9,181 in inappropriate purchases,
including purchases made
for personal use or that are
otherwise unallowable;
$5,580 in third-party error or
fraud, including erroneous or
fraudulent charges made by
vendors or unauthorized
users;
$4,378 in unknown purchases,
including instances in which
there was not sufficient documentation
for us to determine
what was purchased or whether
it was appropriate, typically
because of a lack of a receipt; and
$2,897 in purchases that
represented misapplication of
a purchasing card, including
purchases that had a state
business purpose but were not
allowed to be made using a
purchasing card.
Recommendations
Our report includes recommendations
for DOA to work with agencies
and UW institutions to:
reduce spending limits
whenever possible and close
the accounts of cards that are
unused
(p. 29);
develop procedures requiring
cardholders to explicitly
document the state business
purpose of purchases made
with purchasing cards
(p. 39);
reinforce prohibitions regarding
the use of purchasing cards to
pay for certain travel expenses
(p. 46);
clarify purchasing card policies
in an effort to eliminate
purchases from ineligible
vendors
(p. 49); and
ensure state employees
receive adequate training in
appropriate card use, including
documentation requirements
and other program rules
(p. 50).
In addition, we include a recommendation
for DOA to:
incorporate procedures for the
vendor to contact purchasing
card administrators or
supervisors, as well as cardholders,
regarding possible fraud
(p. 34).