The purpose of this business process is to review all transactions on all p-cards within the college/department in order to:

• identify and investigate any irregular transactions, such as those prohibited by university policy
• review the transactions for 'red flag' fraud indicators

MAPP 04.01.11 - P-Card Guidelines, section IV.E. “Review for Irregular Transactions on P-Cards”

• The CDA (or designee) must review all transactions on the P-Cards issued to employees within the college/division. The review should be completed no later than 30 days after the end of the billing cycle. The CDA is responsible for identifying and investigating irregular transactions, such as transactions prohibited by university policy. If fraudulent activity is suspected, the CDA must report the suspected fraud in accordance with SAM 01.C.04, Reporting/Investigating Fraudulent Acts.

Red Flags - Red Flags of P-Card and Travel Card Fraud

• Each month Accounts Payable provides a report of all transactions within each college. The file is saved in a college share drive. CDAs are notified when the file is ready for review.
• CDA (or designee) places a copy of the file in a location that is centrally accessible by the DBAs.
• CDA (or designee) conducts a review of all transactions within the college and flags and investigates any irregular transactions.
• DBAs conducts a review of all transactions within their departments and of any flagged by the college as irregular transactions.
• The review should be completed no later than 30 days after the end of the billing cycle. If fraudulent activity is suspected, the CDA must report the suspected fraud in accordance with SAM 01.C.04.

1. Import the report into Smartsheet (NSM Business Administrators workspace/FYxx folder). Note: once the first sheet for the fiscal year is created with the additional columns and filters described below, it can be duplicated and used as a template for the subsequent month reports. In this way the filters do not have to be recreated each month.
2. Add columns to the report:
   1. Billing Cycle - fill in with the applicable billing cycle
   2. Selected for Review - check only if the transactions is considered an irregular transaction that warrants further investigation, clarification, or information.
   3. Selected Reason - Examples: Split transaction, Pay Pal, Gift Card, or any of the other reasons listed in #3 below.
   4. Required Action - explain what action the DBA needs to take.
   5. Dept Action Taken - to be completed by the DBA to explain what action was taken.
   6. Assigned To - DBA
   7. Date Completed - to be completed by DBA
   8. Due Date - 30 days from the billing cycle end date
   9. Confirmed - to be completed by the college once the Selected Transaction action items have been confirmed as completed.
3. Create Filters and review for irregular transactions. Mark any irregular transactions as 'Selected for review' and provide the action the department should take.
   1. Amount >$1500 - filter for amount >$1500 and sort by vendor name to see if any vendor has transactions exceeding $3,000 on federal funds or $5,000 on non-federal funds. Rationale: to identify split transactions. PCard Guidelienes I.E prohibits splitting transactions to avoid the transaction limit, $3,000 per transaction for federal funds and $5,000 per transaction for non-federal funds.
   2. PayPal - search for PayPal vendors. Mark as a selected transactions and request a copy of the screenshot showing that the vendor only accepts PayPal. Rationale: PCard Guidelines (III.B.2.l) prohibit the use of PayPal unless the vendor only accepts PayPal as the payment method.
   3. State card - review for unallowable expenses on state cards/funds. See Pcard Guidelines, III.B, pages 3-5.
   4. State card and Fund Type Mismatch - review for any state cards that have a fund code other than 1xxx (state)
   5. Local card - review for unallowable expenses on local cards. See Pcard Guidelines, III.B, pages 3-5.
   6. Local card and Fund Type Mismatch - review for any local cards that have a fund code 1xxx (state). Rationale: Pcard Guidelines, I. A&B. local cards must have local cost centers; state cards must have state cost centers.
   7. Grant Transactions - review the account code/description for any expenses that are unallowable on grants, such as food and entertainment, alcoholic beverages, etc.
   8. Non-Tejas Office Supplies - review for any office supplies (account 53900 purchased from vendors other than Tejas, which is the state contracted office supply vendor).
   9. Dell vendors - review for any purchases made from Dell. Mark as a Selected Transaction. Per UH Purchasing Requirements, all orders for Dell and HP products, regardless of dollar amount, must be placed on a requisition and sent through Purchasing, and paid via a PO voucher.
   10. HP vendors - review for any purchases made from HP. Mark as a Selected Transaction. Per UH Purchasing Requirements, all orders for Dell and HP products, regardless of dollar amount, must be placed on a requisition and sent through Purchasing, and paid via a PO voucher
   11. Blank Description - filter for transactions in which the "Expense Description" is blank. Flag as a Selected Transactions. Request the description and supporting documentation. Rationale: need to confirm the purpose benefit of the purchase to determine if it is an appropriate expense.
   12. Gift Card - filter for transactions in which the "Expense Description" contains 'gift card.' Flag as a Selected Transactions. Request confirmation that a Gift Card Request form has been approved by the CDA and a Gift Card log is completed or in progress. Rationale: P-Card Guidelines, III.C.5. "Gift cards may be purchased if approved by the appropriate CDA."
4. Create Conditional Formatting to find and review transactions with keywords. Create conditional formatting to highlight transactions with the following keywords in the Expense Description column:
   1. error - Review to determine what type of error. Look for frequent errors by same cardholder. (Red Flags of Pcard and Travel Card Fraud: Red Flag indicator #4)
   2. gift - Gifts not allowed on state funds;
   3. tax - review to determine if tax is charged in error and due to be refunded. If so, mark as a selected transaction and ask department to add as a pending credit, or show proof that tax was refunded. Rationale: P-Card Guidelines, III.B.7. Purchases from Texas vendors should be exempt from tax. Taxes should not be charged to state or grant cost centers.
   4. credit - review to determine if tax is charged in error and due to be refunded. If so, mark as a selected transaction and ask department to add as a pending credit, or show proof that tax was refunded.
   5. gas, consulting, travel, scholarship, stipend, tuition, fees, parking - these are unallowable on pcards. See Pcard Guidelines, III.B, pages 3-5.
5. Once all transactions have been reviewed and the Selected Transactions have been flagged, notify the DBAs that the report is ready for review. Add/update it as a task in the DBA task list with a due date no later than 30 day after the billing cycle end date.
6. Follow up 30 days after the billing cycle end date to ensure DBAs reviewed the transactions and provided the information requested. Update the 'Selected Transactions' list with any comments and check the 'confirmed" box once the requested action has been successfully completed.
7. Prepare a report for the Executive Director, showing any irregular transactions and the actions taken or need to be taken. If fraudulent activity is suspected, the CDA/Executive Director must report the suspected fraud in accordance with SAM 01.C.04.

DBAs must review all pcard transactions within their departments, thoroughly searching for irregular transactions and red flag fraud indicators.

1. Access the Pcard Transactions Report from the designated location: Smartsheet/NSM Administrators workspace/PTCard/FYxx
   1. October Billing Cycle Report
2. Filter the sheet for your department and review all transactions. Make note of any comments in the "Action Taken by Dept" column or the comments tool in the row. Best practice: Open the Pcard Guidelines, III.B, pages 3-5 and the Red Flags of Pcard and Travel Card Fraud documents as a guide for reviewing for unallowable or inappropriate expenses.
3. Review the Selected Transactions list and take the appropriate action as indicated in the sheet. Selected Transactions are those transactions reviewed by the college and flagged for further review and/or information from you. They are indicated with a check mark in the Selected Transactions column.
4. If any unauthorized, inappropriate, or fraudulent transactions are identified, notify the CDA and Executive Director immediately. If fraudulent activity is suspected, the CDA (Executive Director) must report the suspected fraud in accordance with SAM 01.C.04.