CHARGE CARD PROGRAM ADVISORY Date: Mon, 16 Aug 1999 09:22:38 -0400 To: "AO - All Administrative Officers" From: "Alice A. Sabatini, Division Administrative Officer, WRD" Subject: Charge Card Misuse Please distribute this Departmental message to card holders in your office. There are penalties being applied for much smaller abuses than the ones listed here. What is not stated here is that charge card misuse is on the rise again presumably because with the other problems with the new cards, employees believe that no one is paying attention. I think these misuses are few and far between but the Department is promising a "crack down" on misuse and delinquency. After January, 2000 when use of the card is mandatory, the employee whose card has been cancelled for misuse or nonpayment will not be permitted to travel for the government (even if he/she plans to use their own money) and disciplinary action against the employee will be mandatory. Sorry to start your week out on a depressing note...this is what I got hit with this morning. I'm refusing to let it get to me...today is my birthday (happy 41). Have a smile on me today... June 23, 1999 Memorandum To: Bureau and Office Assistant Directors for Administration From: Debra E. Sonderman, Director, /s/ Office of Acquisition and Property Management Subject: CHARGE CARD PROGRAM ADVISORY This memorandum is intended as an advisory to officials with Department of the Interior charge card program responsibilities and charge cardholders regarding possible administrative and criminal penalties associated with charge card misuse. The ultimate success of the charge card program as a quality of work life enhancement for Interior employees rests with our charge card program managers, reviewing officials, and cardholders. Fortunately, the vast majority of our charge cardholders use the charge card in a responsible and compliant manner. However, as pointed out in the following three case abstracts published in the Department of the Interior Office of Inspector General's (OIG) April 1999 Semiannual Report to the Congress, criminal penalties associated with charge card misuse are real and prosecution can follow an individual regardless of their present employment status. Criminal Case #1: An OIG investigation disclosed that a former business technician at a school operated by a DOI bureau in the Midwest "used her Government credit card to make personal purchases of more than $12,000. On May 14, 1998, the individual was charged with theft of public money, property, or records and of making false statements." Results: "After entering a guilty plea to the charges, the former employee was sentenced to 14 days of imprisonment, 4 months of home detention, and 5 years of probation. She was ordered to make restitution of $12,269 and to pay a special assessment of $200 to the Victims' Assistance Fund." Criminal Case #2: A DOI bureau employee in the Southwest admitted to credit card misuse during an interview with an OIG agent. The OIG investigation, which included a search of the employee's residence (to which the employee consented), disclosed that the employee made personal purchases of more than $20,000 with a Government credit card in 1995 and 1996. Results: On February 23, 1999, the employee was sentenced in Federal court to 4 years of probation and ordered to make restitution of $19,912 after pleading guilty to embezzlement and theft of public money. The individual is no longer employed by DOI. Criminal Case #3: Another OIG investigation disclosed that the former employee of another Federal agency, who had recently accepted a position with a DOI bureau in Minnesota, "misused a Government-issued purchase card by charging items valued at approximately $5,200" while working at the other agency. Results: "On March 9, 1999, the employee was sentenced to 3 days of imprisonment, 60 months of probation, and 120 hours of community service." The employee was ordered to make restitution and pay a fine. The individual is no longer employed by DOI. As was mentioned above, while these cases are shocking, they remain the exceptions to standard charge card practices. We can keep it that way by responsibly doing our part as program administrators, reviewing officials, and charge cardholders in accordance with Federal acquisition requirements, Departmentwide and bureau charge card guidelines. Fraudulent acts of any kind should be reported to the OIG Hotline at 1-800-424-5081 or through the OIG Hotline web site at: http:www.oig.doi.gov. While not criminal in nature, inappropriate use of charge cards is possible even if purchases are made for official business. For example, when planning and making purchases, charge cardholders are required to comply with the mandatory sources of supply identified in Part 8 of the Federal Acquisition Regulation (FAR), e.g., purchases from the Committee for People Who Are Blind or Severely Disabled (also know as the Javits-Wagner-O'Day or JWOD Program) for supplies or services, and Federal Prisons Inc. for certain supplies, including furniture. The mandatory source for printing cited in FAR Subpart 8.8 is the Government Printing Office. In compliance with FAR Subpart 8.8's requirements, section 2.9E(4) of the DOI Integrated Charge Card Guidelines prohibits use of the charge card for "printing and copying services unless a waiver has been issued by the Government Printing Office." A DOI employee recently found out the "hard way" when he or she solicited and committed to a printing requirement well over $1,000 with a commercial printing source without first checking with, and receiving a waiver from the GPO. Legally, that individual may now be held personally responsible for the cost of the printing job. (Note: You can access FAR Part 8 at the following web site: http://www.arnet.gov/far. Choose Part 8 after clicking on the button marked "Parts 1 - 51.") Under section 2.9E of the charge card guidelines, cardholders are required to consult with a warranted contracting officer or the Agency/Office Program Official, as appropriate, when any question exists about a potential purchase of a restricted service or supply. This requirement is intended to support charge cardholders as well as the federal acquisition and charge card programs. Remind your respective charge cardholders of its importance. (For printing requirements, cardholders should also check with their bureau's Printing Liaison Officer.) Please circulate this advisory to cardholders within your bureaus and offices. If you have any questions, please contact me on (202) 208-6352.