+ OMB Circular A-123 (Appendix B): Improving ... - The White House

• Identify specific risks associated with charge card programs, and implement strict internal
controls to mitigate these risks to the greatest possible extent;
• Develop policies and procedures to mitigate risks associated with charge card programs;
• Ensure that the agency has policies in place that require managers to review charge card
reports, as necessary;
• Develop and impose disciplinary action deemed appropriate by the agency in cases of charge
card misuse;
• Implement proper training for cardholders, approving officials, and all other staff involved in
using charge cards consistent with Chapter 3 of this Guidance;
• Review charge card statements and account activity reports to identify questionable or
suspicious transactions;
• Review ATM cash withdrawals for reasonableness and association with official travel;
• Contact employees to inquire about questionable or suspicious transactions;
• Confirm that the correct appropriation/line of accounting is cited for the purchase card
transaction;
• Require charge card statement reconciliation or transaction reconciliation in a timely manner;
• Initiate administrative and/or disciplinary actions for each occurrence of charge card misuse;
and
• Incorporate all controls, practices and procedures related to charge card misuse into the
agency’s charge card management plan, consistent with Section 2.3 of this Guidance.
In cases where a cardholder fails to resolve and/or timely dispute (if necessary) an erroneous
charge, the cardholder, consistent with agency policy, shall reimburse the government for the
cost of that transaction. When a cardholder makes an improper purchase, the cardholder, in
accordance with agency policy, shall: (a) reimburse the government for the cost of the purchase
and (b) be subject to disciplinary action.
In instance where an official directs an erroneous purchase to be made by a cardholder or directs
a cardholder to purchase items or services that are subsequently determined to be improper, the
official who directed the purchase shall, in accordance with agency policy: (a) reimburse the
government and (b) be subject to disciplinary action.
4.9 What administrative and/or disciplinary actions may be imposed for charge card
misuse?
Improper, fraudulent, abusive, or negligent use of any Government charge card is prohibited.
The agency may impose disciplinary action for charge card infractions, including removal for
serious or repeated infractions. Appropriate agency personnel may impose, but are not limited
to, the following administrative and/or disciplinary actions for negligence, misuse, abuse, or
fraud:
Appendix B
OMB Circular A-123
(Revised January 2009)