GOVERNMENTWIDE COMMERCIAL PURCHASE CARD (GPC) PROGRAM POLICIES AND DIRECTIVES DENISE REICH AND SHEILA MCGLYNN OFFICE OF THE UNDER SECRETARY OF DEFENSE (OUSD) ACQUISITION AND SUSTAINMENT (A&S) DEFENSE PRICING AND CONTRACTING (DPC) CONTRACTING EBUSINESS (CEB) JULY 2019 AGENDA 1. Available DoD SmartPay3 (SP3) Resources 2. GPC Insights On Demand (IOD) Training Requirements and Tracking of Training Completion 3. GPC Policy Memos 4. DoD SP3 GPC Policies, Procedures and Tools (SP3 Transition Memo #6 Requirements)
Overview DoD Procurement Integrated Enterprise Environment (PIEE) / Joint Appointment Module (JAM) Access Online (AxOL) IOD 5. IOD Behind the Scenes and the SP3 Governance Process 6. IOD Deployment Challenges 7. Priorities 2 Available DoD SP3 Resources 3 DPC/CEB WEBSITE https://www.acq.osd.mil/dpap/pdi/pc/index.html
4 DPC ONE-PAGERS https://www.acq.osd.mil/dpap/pdi/pc/index.html 5 GPC PROGRAM ONE-PAGERS 3OP001 Understanding Cardholder Special Designations 3OP011 Certifying Officer Registration, Role Request, and Appointment 3OP002 Understanding the New MPTs 3OP012 Registration for the DD577 View-Only Role 3OP003
3OP004 3OP005 3OP006 3OP007 3OP008 OA/OPC and A/OPC Registration, Role Request, and Appointment CPM Registration, Role Request, and Appointment DAA Registration and Role Request Reactivating Inactive and Archived PIEE Accounts/Roles When Do I Need Multiple Roles or Appointments How to Add Additional Details to Appointment Letters 3OP013 3OP014 Understanding Army / Air Force / Defense Agencies Refunds under SmartPay3 A/BO Nomination, Registration, and Appointment 3OP015
Who is the Head of Activity? 3OP016 What is the Semi-Annual HA Review? 3OP017 PIEE JAM Statuses (Pending) 3OP018 What DoDAAC Should I Enter? 3OP009 AA Registration and Role Request 3OP019 3OP010 Uploading Training Certificates to PIEE/JAM 3OP020
Understanding How DoDAACs Are Used in PIEE/JAM Nomination, Registration, and Appointment of CHs 6 JAM WEB-BASED TRAINING 1 3 https://wawf.eb.mil/ 2 4 7 GPC IOD Training Requirements and Tracking of Training Completion 8 COMPLETING IOD TRAINING IOD training is designed to help individuals learn how to navigate the IOD platform and leverage its features to review, research, and resolve cases, and conduct program oversight
IOD training is: MANDATORY for all DoD Approving/Billing Officials (A/BOs) and Agency/Organization Program Coordinators (A/OPCs) HIGHLY RECOMMENDED for Oversight A/OPCs (OA/OPCs) and Component Program Managers (CPMs) Four Training Completion Options: 1. Attend a DoD GPC IOD GSA Training Forum session Insights on Demand: Case Management Course (DoD Government Purchase Card) Insights on Demand: Case Management, Completing the Monthly Checklist, and Performing Oversight Functions Course (DoD Government Purchase Card) 2. 3. 4. Attend online IOD webinar Watch recorded IOD webinar Attend in-person training: Reserved for groups of 20 or more. Work with your U.S. Bank representative to acquire the request form. The form will be added to AxOL Web-Based Training materials in October. For any IOD access issues, contact [email protected] to obtain the necessary credentials. Separate GPC Head of Activity (HA) oversight IOD training is being developed. 9 DOD GPC IOD SESSIONS OFFERED AT GSA TRAINING FORUM Date Start Time
End Time Session Location Insights on Demand: Case Management, Completing the Monthly Checklist, and Performing Oversight Functions Course (DoD Government Purchase Card)* 7/16/2019 7/16/2019 7/16/2019 7/17/2019 7/17/2019 7/17/2019 7/18/2019 7/18/2019 7/18/2019 7/18/2019 11:00 12:30 15:30 08:00 11:00 14:00 09:30 12:30 14:00 15:30 12:10
13:40 16:40 09:10 12:10 15:10 10:40 13:40 15:10 16:40 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Insights on Demand: Case Management Course (DoD Government Purchase Card)** 7/16/2019 7/16/2019 7/17/2019 7/17/2019 7/17/2019
7/18/2019 7/18/2019 09:30 14:00 09:30 12:30 15:30 08:00 11:00 10:40 15:10 10:40 13:40 16:40 09:10 12:10 *For A/OPCs, OA/ OPCs, & CPMs **For A/BOs Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301
Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 Marriott - Atrium Level, M301 As of 7/5/19 10 TRACKING IOD TRAINING COMPLETION Mastercard/IOD track IOD training completion Attend a DoD GPC IOD GSA Training Forum session. Complete the training form available on each computer at your GSA Training Forum session. Certificates will be published by IOD in the subsequent weeks. Attend online IOD webinar, watch recorded IOD webinar, or attend in-person training Print and fill out the training certificate (last slide in the training deck).* Additionally, for all of the above training completion options, scan completed certificate and upload to your PIEE profile See subsequent slides on how to upload training certificates to PIEE. *If you complete training by watching the IOD webinar (Option 3), YOU MUST ALSO SEND AN EMAIL TO [email protected] with the subject IOD DoD Training Video Completion, leaving the body of the email blank. DO NOT send an email for other training completion options. 11
ADDING IOD TRAINING COURSE AND UPLOADING SCANNED CERTIFICATE TO PIEE/JAM PROFILE If you dont have a PIEE account yet: When establishing an account, the system will take you to the Training page as part of your GPC Role registration process. If you have a PIEE account but have not completed your JAM role/appointment: The system will prompt you to upload your CLG 001 or CLG 006 certificates when the appointment is initiated. At this time, you could select the applicable IOD class and upload your IOD certificate as well. If you have a PIEE account and a JAM role/appointment: Log into PIEE, go to My Account, select My Training under your Profile, select the applicable IOD class, and upload your certificate. 12 ADDING IOD TRAINING COURSE AND UPLOADING SCANNED CERTIFICATE TO PIEE/JAM PROFILE (CONT.) Select appropriate class title under Add Training Then upload scanned IOD training certificate to your PIEE profile: Step 1: Select Appropriate Class Title 13
ADDING IOD TRAINING COURSE AND UPLOADING SCANNED CERTIFICATE TO PIEE/JAM PROFILE (CONT.) Step 2: Add Your Training Certificate Step 3: Fill in additional fields; specify 1 for Hours and Oversight for Provider 14 TRACKING IOD TRAINING COMPLETION (CONT.) Once accomplished, your PIEE My Training profile will look like: DLA will run PIEE queries and generate training completion reporting for CPMs By FY2021, CPMs will be able to run their own training completion reports in PIEE 15 GPC Policy Memos Please note that on these slides the Contingency thresholds apply to procurements of property or services by an executive agency that the agency determines are in support of contingency operations, to facilitate the defense against or recovery from cyber, nuclear, biological, chemical, or radiological attack against the United States, to support a request from Secretary of State or the Administrator, to support USAID for the provision of international disaster relief assistance pursuant to the Foreign Assistance Act of 1961, to support an emergency or major disaster defined under
the Robert T. Disaster Relief and Emergency Assistance Act (42 U.S.C. 5122). Support for Humanitarian or Peacekeeping Operation (10 U.S.C. 2302) is not addressed in the law. 16 GPC POLICY AND TRAINING MEMOS DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Tr avel, and Fuel Card Programs (1/9/2019): DPC/CeB will no longer support coordination of the subject Guidebook across the Department's charge card programs. The existing Guidebook will be replaced with a GPC-unique policy document by FY 2020. Cancellation of GPC DAU Training Courses - GPC CLG 004 and CLG 005 (12/17/2018): To ensure GPC program officials receive a complete and up-to-date topical review during their refresher training, CLG 001 is now the required course to fulfill both initial and refresher GPC training requirements. CLG 004 (GPC Refresher Training) and CLG 005 (PCOLS) are permanently cancelled. 17 GPC SP2 PCOLS CASE CLOSURE MEMOS PCOLS Data Mining Case Closure Non-Compliance Ramifications SP3 Transition Memo #5 (12/20/2018): On October 11, 2018, OUSD (A&S) DPC/CeB mandated that all open SP2 data mining (DM) cases $1,000 shall be closed NLT 12/21/18. Until such closure, SP3 successor accounts are to have transaction authority of $1. On 1/7/19 DPC directed U.S. Bank to reduce the managing account (MA) transaction authority for each SP3 successor account with open DM cases to $1.
S Of the 6,716 cases, only 4 remain open. ucce ss Story ! PCOLS Data Mining Case Closure Non-Compliance Ramifications SP3 Transition Memo #7 (4/18/2019): Addresses the status of the required closure of PCOLS data mining cases under SP2. The remaining unadjudicated PCOLS cases with transactions valued at $1,000 or greater that posted after 9/15/18 must be closed by mid-May 2019. DPC to instruct U.S. Bank to reduce the associated SP3 Managing Accounts transaction authority to $1 for all cases remaining open past the suspense date. DPC/CeB to work with U.S. Bank to ensure preexisting MA account thresholds are reinstated once all cases past the suspense date are closed. No additional phases are anticipated. Of the 980 cases, only 38 remain open. Succe ss Story ! 18 GPC SP2 CLOSEOUT POLICY MEMOS Closeout of Air Force/Defense Agencies (AF/DA) SP2 Task Order SP3 Transition Memo #8 (5/3/2019): Following the 11/30/18 SP3 go live date, DPC initiated the SP2 AF/DA Tailored Task Order (TTO) closeout process.
Requires closeout of all SP2 Cardholder (CH) and MA accounts, involving multiple tasks under three broad categories: SP2 Annual MA Reviews (Required only for CPMs who have not completed SP2 Annual MA Reviews by 12/1/17 or later) SP2 GPC and convenience check closeout actions Other SP2 closeout items First DPC closeout status call was held on 6/11/19; additional calls to follow. Upon closeout completion, each CPM is required to submit a memo to DPC validating completion of all SP3 Transition Memo #8 requirements. Army and Navy are separately managing closeout of their SP2 TTOs. 19 GPC REFUND VALIDATION MEMO Refund Validation under SP3 SP3 Transition Memo #9 (6/11/2019): The CPM or designee is responsible for working closely with the Comptroller to ensure that: Accuracy of quarterly refunds earned is validated. Can use Quarterly Refund Summary and Quarterly Refund Detail reports to validate refunds earned. These reports are available via U.S. Banks Access Online Data Exchange upon request. Refund receipts are properly recorded. 20 Denise Reich GPC PROHIBITED PURCHASES MEMOS
GPC Prohibited Purchases Memo (8/15/2018): Added Video Surveillance Cameras and Commercial Unmanned Aerial Systems to the prohibited purchase list. GPC Prohibited Purchases Memo (3/1/19): (FOUO) memorandum provides additional information on Governmentwide Commercial Purchase Card prohibitions. 22 GPC MICRO-PURCHASE THRESHOLD (MPT) POLICY MEMOS GPC Guidance Related to Class Deviation 2018-O0018 dated August 31, 2018 (9/21/2018): This memorandum provides GPC implementing guidance related to the $10K MPT. MICRO-PURCHASE THRESHOLDS Threshold 1 Construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate Requirements (Construction) $2,000 2 Services subject to 41 U.S.C. chapter 67, Service Contract Labor Standards $2,500
3 Federal-wide Open Market Micro-Purchase 4 Federal-wide Higher Education Open Market Micro-Purchase 5 6 GPC Contingency (Inside U.S.) GPC Contingency (Outside U.S.) $10,000 $10,000 or Greater $20,000 $30,000 1 2 3 CONVENIENCE CHECK THRESHOLDS GPC Convenience Checks (Non-Contingency)
GPC Contingency (Inside U.S.) GPC Contingency (Outside U.S.) Threshold $5,000 $10,000 $15,000 Cardholders with single purchase limits exceeding $3,500 must be trained to follow Federal, DoD, and Component procedures for purchasing or requesting waivers from Federal Prison Industries. See FAR Parts 8.0 and 8.6 and Reference (C) Appendix A, Section A.1.2.2, GPC Purchasing Steps, paragraph g). 23 DoD SP3 GPC Policies, Procedures and Tools (SP3 Transition Memo #6 Requirements) 24 OVERVIEW: SP3 OVERSIGHT PROCEDURES MEMO DoD SP3 Government-wide Commercial Purchase Card Policies, Procedures and Tools SP3 Tran sition Memo #6 (4/18/2019): Specifies updated policies, procedures, and electronic program management and control compliance tools mandated for use by all DoD Components executing transactions under the Army, Air Force, and Defense Agencies; and Navy GPC SP3 TTOs. Each Component must assess its progress in deploying and utilizing IODs oversight capabilities and publish Component-level guidance for transitioning to these updated oversight procedures no later than 30 November 2019.
This guidance must require appropriate oversight to be performed as the Component phases out the requirement to conduct Annual MA Reviews and adopts the integrated three-pronged, system-enabled review cycle described in the attached document. Components are required to ensure full deployment and use of IODs oversight capabilities no later than 1 March 2020. 25 DOD PIEE/JAM JAM is the PIEE module used to initiate, review, approve, store and terminate required delegations of procurement authority and/or appointments. As appropriate, JAM GPC appointments result in issuance of not only GPC Delegation and/or Appointment letters, but also: - Limited-scope SF-1402 Certificate of Appointment (commonly referred to as a warrant). - DD Form 577 Appointment/Termination Record Authorized Signature (commonly referred to as a Certifying Officer appointment). 26 UPDATED JAM GPC APPOINTMENT COMPLETION DATES DoD GPC Program participants are required to register for a PIEE account and request the GPC role(s) appropriate for their program function(s). Electronic GPC Delegation of Authority and/or Appointment Letters must be granted for GPC Program participants as follows: Up Role Name
JAM Release Date da 6/28 ted /201 JAM Appointment 9 Completion Date CPMs 9/7/2018 Completed Maintain as Required Oversight A/OPCs (Individuals responsible for overseeing the work of other A/OPCs) A/OPCs (Individuals responsible for directly overseeing A/BO MAs and CH Accounts) GPC Certifying Officers (DD Form 577) 9/7/2018 8/31/2019
9/7/2018 7/30/2019 12/14/2018 8/31/2019 A/BOs 1/25/2019 8/31/2019 GPC CHs (Includes Convenience Check Account Holders) 6/23/2019 10/31/2019 27 JAM CH FUNCTIONALITY RELEASED 23 JUNE 2019 JAM GPC Cardholder Special Designation Authority Type Delegation NTE Limit
Micro-Purchase Cardholder $10K 2 Micro-Purchase Convenience Check Writer $5K Non-Contingency $10K Contingency Inside the U.S. $15K Contingency Outside the U.S. 3 Higher Education Micro-Purchase Cardholder 4 Micro-Purchase Contingency Contracting Cardholder 5 Warranted Contingency Contracting Cardholder 6 7
8 9 10 Contract Ordering Official Cardholder Overseas Simplified Acquisition Cardholder Contract Payment Official Cardholder SF-182 Training Payments Cardholder Inter/Intra-Governmental Payment Official Cardholder 1 Warrant Issued? $10K but HCA determination can result in higher value (unlimited) $20K Inside the U.S. $30K Outside the U.S. $750K Inside the U.S. $1.5M Outside the U.S. Simplified Acquisition Threshold $25K Unlimited $25K $24,999
X X A/OPCs & OA/OPCs with Delegating Authority JAM Appointment also equivalent to warrant. CH must already be a warranted KO. Recommend KO load an image of warrant to their PIEE profile. JAM improvements and JAM enhanced-view ECPs Requirements developed and ECP funded. 28 GPC OVERSIGHT PROCEDURES MEMOS Deployment of Cardholder Appointment Capability in the PIEE / JAM SP3 Transition Memo #10 (6/28/2019): Announces deployment of PIEE JAM CH appointment capability; updates JAM GPC appointment completion dates; and requires Components that authorize issuance of GPC CH Special Designation Authority Types other than Micro-Purchase Cardholder, Micro-Purchase Convenience Check Holder, and Micro-Purchase Contingency
Contracting Cardholder to: 1. Ensure Component-level policies and procedures adequately address such use; 2. Specify additional mandatory training requirements for utilizing the alternate special designation authority that are commensurate with the authority to be delegated; and 3. Mandate additional controls and oversight procedures to mitigate the risks associated with each special designation authority. NOTE: Current DoD GPC policy and training is not sufficient for delegations other than Micro-Purchase Cardholder, Micro-Purchase Convenience Check Holder, and Micro-Purchase Contingency Contracting Cardholder. PIEE 6.0.0 Release (7/3/2019): Announces deployment of PIEE 6.0.0 release, which includes JAM CH appointment capability. This release also impacts the Electronic Document Access tool and the Contracting Officer Representative Tracking Tool. It provides training links found on the PIEE Web-Based Training page, including JAM training, at: https://wawftraining.eb.mil/wbt/xhtml/wbt/jam/index.xhtml 29 WHY ARE SOME GPC JAM DELEGATIONS EQUIVALENT TO A WARRANT? FAR 2.101 Micro-purchase means an acquisition of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the MPT. FAR Part 13 (Simplified Acquisition Procedures) does not include the following, so they are not micro-purchases:
Placing Orders against Contracts (FAR 16.5) Placing Orders against GSA Schedules (FAR 8.405) Purchasing from Federal Prison Industries (FAR 8.6) Contract Payments (FMR) SF-182 Payments (FMR) Intergovernmental Payments (FMR) a se h c r o-Pu ot r c i PC M ent is n ing G JAM pointm Hs tak rC Ap o f t o ns
ien ti c c ffi a su these Not below the MPT so they are not micro-purchases: Overseas GPC Use up to $25K (DFARS 213.301(2)) 30 WHAT ARE THE TWO AVAILABLE CONTRACTING AUTHORITIES? FAR 1.603-3, Appointment (a) Contracting officers shall be appointed in writing on an SF 1402, Certificate of Appointment, which shall state any limitations on the scope of authority to be exercised, other than limitations contained in applicable law or regulation. Appointing officials shall maintain files containing copies of all appointments that have not been terminated. (b) Agency heads are encouraged to delegate micro-purchase authority to individuals who are employees of an executive agency or members of the Armed Forces of the United States who will be using the supplies or services being purchased. Individuals delegated this authority are not required to be appointed on an SF 1402, but shall be appointed in writing in accordance with agency procedures. FAR 201.603-2, Selection (1) In accordance with 10 U.S.C. 1724, in order to qualify to serve as a Contracting Officer with authority to award or administer contracts for amounts above the simplified acquisition threshold, a person must [Education and
DAWIA Requirements]. FAR 201.603-3, Appointment (b) Agency heads may delegate the purchase authority in 213.301 to DoD civilian employees and members of the U.S. Armed Forces. o NOTE: This limits DoD Agency Heads from delegating authority to non-DoD federal employees. 31 DFARS 213.301(2) GPC USE OUTSIDE THE U.S. (2) An individual appointed in accordance with 201.603-3(b) also may use the Governmentwide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed $25,000, if s n ot (i) The purchase e o d S DFAR ese to the (A) Is made outside the United States for use outside the United States; and h add t efinition d (B) Is for a commercial item; but MPT (C) Is not for work to be performed by employees recruited within the United States; (D) Is not for supplies or services originating from, or transported from or through, sources identified in FAR Subpart 25.7;
(E) Is not for ball or roller bearings as end items; (F) Does not require access to classified or Privacy Act information; and (G) Does not require transportation of supplies by sea; and (ii) The individual making the purchase (A) Is authorized and trained in accordance with agency procedures; (B) Complies with the requirements of FAR 8.002 in making the purchase; and (C) Seeks maximum practicable competition for the purchase in accordance with FAR 13.104(b). OSD Legal Opinion, July 2019: Unless one of the exceptions in DFARS 213.270 or DFARS 213.301(2) applies, Overseas Simplified Acquisition Cardholders reaching back to the U.S. are limited to $10,000 32 AxOL AxOL is U.S. Banks internet-based system that provides account access and a variety of reports to assist users in effectively managing their charge card programs. 33 AXOL A/OPC REQUIREMENTS A/OPCs must use AxOL to: Issue and maintain GPC accounts. JAM appointment data will be provided to AxOL via a system interface (planned for 2nd quarter FY 2020). A/OPCs will access AxOL and link issued JAM appointments to the appropriate CH account or MA. Purchasing limits authorized in JAM appointments will serve as the ceiling for AxOL authorizations. The A/OPC will enter other purchasing limitations, such as Merchant Category Codes (MCCs), directly into AxOL.
Manage their programs. 34 AXOL RESOURCE MANAGER REQUIREMENTS Resource Managers must use AxOL to: Provide funding and valid Lines of Accounting (LOAs) for GPC accounts. 35 AXOL CARDHOLDER REQUIREMENTS Cardholders must use AxOL to: Create their Purchase Log (Order Management). DoD Standard AxOL Purchase Log Format Mandated Supports data transmission to IOD and WAWF. Document receipt and acceptance (Order Management Order Receipt). Improves property accountability and increases auditability. Retain their transaction supporting documentation (Transaction Management Attachments). Ensures A/BO, A/OPC, OA/OPC, and CPM access for use in completing reviews. Negates the need for storage of hardcopy documents. Loading documents with a marking of For Official Use Only or higher to AxOL is prohibited. Approve GPC Statements of Account (Order Management). AxOL Enterprise Purchase Log Requirements (FOUO CAC Required) are available at: https://www.acq.osd.mil/dpap/pdi/pc/SmartPay3_TI_and_PCET.html
36 AXOL A/BO REQUIREMENTS A/BOs must use AxOL to: Perform transaction reviews (e.g., review transaction supporting data). Approve GPC Statements of Account (Transaction Management). 37 AXOL CERTIFYING OFFICER REQUIREMENTS Certifying Officers must use AxOL to: Perform transaction reviews (e.g., review transaction supporting data). Electronically certify GPC invoices for payment (Transaction Management). 38 IOD IOD is an artificial intelligence data mining (DM) platform that automatically analyzes DoDs GPC data to identify highrisk transactions. It facilitates: Transaction Reviews Enables documentation of any findings identified and corrective actions taken. Monthly A/OPC Reviews Conducted to promote and measure compliance with purchasing and management internal controls and provide reasonable assurance of the effectiveness of these controls to mitigate program risk. Semi-Annual HA Reviews Conducted to ensure adherence to internal controls and facilitate senior managements awareness of their GPC programs health, and to help them promote the interdisciplinary communication necessary for successful GPC program operations. It enables the Department to fulfill the 10 U.S.C. 2784 requirement to use effective systems, techniques, and technologies to prevent or identify improper purchases.
39 OVERSIGHT REQUIREMENTS GPC program officials are required to: Use IOD to document DM Case review results for all: System-Generated Cases Management-Added Cases PCs O / A Os & n on B / A Both take actio must ery case ev May be opened at managements discretion. Must be opened for each finding and disciplinary category determination independently identified (i.e., not flagged by IOD) during compliance reviews. Suspend purchasing (e.g., reduce the managing account spending limit to $1) under account(s) with open DM cases, or Monthly A/OPC or Semi-Annual HA Reviews that are not completed within 55 days of the end of the billing cycle(s) under review.
Enforcement of mandatory account purchasing suspension for accounts with open DM cases is targeted for Q4 FY19. Complete Findings and Disciplinary Category Determinations records are necessary to automate GPC reporting requirements and support GPC program management and oversight. 41 DAILY DM CASE REVIEW CYCLE DM Case Review Cycle Milestones Compliance Mechanism DM Cases Initiated Daily for Review Throughout the Billing Cycle Not Applicable A/BO DM Reviews Complete SHOULD complete reviews throughout the billing cycle (rather than waiting until the end of the month) to promote timely resolution (e.g.,
transaction dispute, Cardholder re-training); SHOULD complete reviews within 5 days of the billing cycle end date; MUST complete reviews within 30 calendar days of the billing cycle end date. NOTE: Any case the A/OPC refers back to the A/BO for additional review may require action through day 55. Not Applicable SHOULD complete reviews within 30 calendar days of the billing cycle end date. NOTE: Any case the OA/OPC refers back to the A/BO for additional review may require action through day 55. MUST complete reviews within 55 calendar days of the billing cycle end date A/OPCs may suspend MAs with open DM cases 30 days after billing cycle end date. A/OPC Cases Closed OA/OPCs must suspend MAs
with open cases 55 days after the billing cycle end date. 42 A/OPC REVIEWS A/OPCs are required to conduct a Monthly A/OPC Review each billing cycle. During each Monthly A/OPC Review, A/OPCs must: 1. Validate that all DM cases are closed. 2. Assess the key purchasing and management internal controls (e.g., span of control, delinquencies, training). Key GPC Program controls are calculated and displayed in the Monthly A/OPC Review Report generated by IOD. 3. Perform a summary assessment that includes 100 percent of all transactions NOT flagged by IOD to: (a) ensure awareness of purchasing activity within their hierarchy; and (b) identify purchasing and behavior patterns not otherwise identified by IOD (e.g., patterns that span multiple CH accounts and/or MAs) or that may otherwise require A/OPC action. AxOL transaction detail reports are available for use in performing these reviews. At his/her discretion, the A/OPC may identify additional transactions for review using the IOD tool. A/OPCs are required to ensure a DM case is created for each of their findings and disciplinary category
determinations. 43 MONTHLY A/OPC REVIEW CYCLE DATES Action A/OPC completes Monthly Review and A/OPC Monthly Check List in IOD. OA/OPC completes Monthly Review and certifies completion in IOD. Higher-tier OA/OPC completes Monthly Review and certifies completion in IOD (if more than one level). CPM completes review and certifies completion in IOD. Review Cycle Milestones Cycle End Date + N/A 30 days Compliance Mechanism Cycle End Date + OA/OPCs may suspend the appropriate account(s) at 30 40 days days if DM cases and A/OPC Monthly Reviews are not complete.
Cycle End Date + Higher-tier OA/OPCs may suspend the appropriate 50 days account(s) at 40 days if DM cases and A/OPC Monthly Reviews are not complete. Cycle End Date + CPMs suspend appropriate account(s) at 55 days if DM 55 days cases and A/OPC Monthly Reviews are not complete. 44 SEMI-ANNUAL HA REVIEWS Semi-Annual HA Reviews are an aggregation of the A/OPCs six previous Monthly A/OPC Reviews. A/OPCs are required to: Brief their review results to their own HA (apprising the HA of program strengths and any concerns within their organizations). Obtain the HAs signature on the Semi-Annual HA Review Report. Provide a scanned version of the signed report and other review documents to the OA/OPC above them. Certify they have completed their HA Semi-Annual Reviews in IOD. Retain their final signed documents. OA/OPCs (up to two tiers), if assigned, are required to:
Summarize the reports provided by the A/OPCs or O/AOPCs at the tier directly below them in the hierarchy. Review the results with their HA. Obtain their HAs signature on their Semi-Annual HA Review Report. Provide a scanned version of the signed report and other consolidated review documents (if any / as required) to the OA/OPC or CPM at the next higher tier above them in the hierarchy. Certify they have completed their HA Semi-Annual Reviews in IOD. Retain their final signed documents. All HA reviews must be completed and provided to the CPM no later than 15 June and 15 December of each year. CPMs are required to brief their Components HA and provide their review results to the Agency Program Management Office no later than 15 July and 15 January of each year. 45 Sheila McGlynn IOD Behind the Scenes and the SP3 Governance Process 47 SP3 DM CASE GENERATION DETAILS IOD initiates cases for review using the tiered business rule sets addressed below. Use of these rule sets provides a standard to consistently measure trends across the Department.
Business rules to be modified as necessary through the SP3 Integrated Solutions Team (IST) governance process. 48 TIER 2 BUSINESS RULES TAILORING Tier 2 rules are mandatory rules that can be tailored as necessary at the local level (e.g., weekend/holiday purchases). First round of CPM requested Tier 2 Tailoring was due 4/11/19. All requests have been deployed in IOD. CPMs can continue to provide requests following the established process. Information about the submission process was emailed to CPMs by Sheila McGlynn on 3/19/19, Subject: Updated Tier 2 Configuration Worksheet. To ensure expedient processing of requests, watch the recording of the Tier 2 Tailoring training session, which was sent out by U.S. Banks Customer Relationship Manager on 4/10/19. It will be added to existing IOD training materials currently available in AxOL (part of AxOL October 2019 release). Oversight has/will: Generate cases associated with Tier 2 Tailoring, but each Tailored case is automatically closed by the system as Closed by System Customized Tier2 Business Rule (as of 5/29/19). Reopen 1% of Tier 2 systematically closed cases for adjudication (as of 7/15/19). Provide CPMs with a summary report detailing customized rules at which hierarchy nodes (as of 8/1/19). Provide statistics on the number of cases that have been systematically closed and reopened (i.e., the 1% of random Tier 2 cases assigned) (as of 8/15/19). 49 SP3 IST PROCESS
The IST consists of CeB personnel and CPMs, supported by U.S. Bank, Mastercard (card association), and Oversight (IOD vendor) personnel. The IST meets semiannually to discuss possible updates to: - Tier 14 business rules, given statistical data, projections, and observation, including: Number of violations per category (abuse, delinquency, internal fraud, and misuse) associated with each business rule Frequency with which each rule is triggered, and associated DM case disposition - Department MCC blocked lists - Additional system and process capabilities within U.S. Bank and Oversight First IST Meeting: 8/7/19 in CeB office 50 MCCS The following controls are established for the assignment of MCCs to DoD GPC CH accounts and MAs: 1. DPC will maintain a DoD SP3 GPC High-Risk MCC List (includes both High Risk and Very High Risk MCCs). It will be reviewed, and updated if necessary, biannually through the TTOs semi-annual IST governance process. 2. DoD CPMs will ensure Component-level guidance addresses procedures for both approving assignment of any MCC on the DoD SP3 GPC High-Risk MCC List to a DoD GPC CH account or MA, and measuring compliance. 3. A DM case will be automatically initiated for all transactions made from vendors categorized under the Very High Risk MCCs identified on the DoD SP3 GPC High-Risk MCC List. 4. A DM case will be initiated for all transactions for which a CH does not have authorization to use a given MCC on its account (could be a High-Risk MCC or any other MCC not authorized on the account).
The DoD SP3 GPC High-Risk MCC List (FOUO CAC Required) is available at https://www.acq.osd.mil/dpap/pdi/pc/SmartPay3_TI_and_PCET.html 51 IOD Deployment Challenges 52 IOD BACKLOG OF SERVICES TRANSACTIONS SUMMARY During a March 2019 briefing, several Service CPMs questioned the accuracy of the number of transactions that Oversight had been running through IOD DM. Days later, U.S. Bank confirmed that approximately 75% of transactions had not been mined for the Departments of the Army, Air Force and Navy. U.S. Bank and IOD stated the Defense Agencies were unaffected by this issue. Plan of Actions and Milestones were submitted by the bank team and approved by DoD Army/Air Force/Defense Agencies and Navy SP3 CORs. The file format limitations that caused this issue have been resolved. 100% of DoDs standard hierarchy transactions are being data mined (as of 6/18/19). In accordance with agreed-to stratified sampling procedures, the Services transactions going back to 11/30/18 will go through data mining. They are incrementally phased in, initially a week at a time beginning with transactions from the first week in December, then a month at a time. Backlog processing began on 7/1/19. The Weekend/Holiday Tier 2 business rule was turned on for ALL Components (as of 5/29/19). 53 SERVICES BACKLOG MILESTONE PLAN IMPACTS ON
DEFENSE AGENCIES No. Task Task Numbers 18 are accomplished. Services will experience a case initiation lag for current transactions during the periods for Services Backlog Processing. There will be no effect on Defense Agencies. Anticipate 3-week cycle. 1 Implement Tier 2 Business Rules configuration for Service Components 2 Implement Weekend/holiday rule 14
3 Turn on daily 100% transaction processing 4 Preparation for backlog processing 5 Process first backlog batch first week of December, re-open Tier 2 random 1% 6 Resume normal processing 7 Process next backlog batch Dec week 2, re-open Tier 2 random 1% 8 Resume normal processing
9 Process next backlog batch, re-open Tier 2 random 1% 10 Resume normal processing 5/29/19: Weekend/Holiday purchase rule turned on for ALL Components. 7/15/19: 1% of all cases systematically closed due to Tier 2 tailoring to be initiated and assigned to the A/BO & A/OPC for adjudication for ALL Components. 54 IOD DEPLOYMENT STATISTICS
DoD A/BO Deployment Status on IOD, 7/5/19 DoD A/OPC Deployment Status on IOD, 7/5/19 # of A/BO # of A/BOs Total # % OrganiLEVEL_ LEVEL LEVEL A/BOs Not of Deploy SERVICE zation 1 _2 _3 Logged In Logged In A/BOs ed SERVICE # of # of Total # A/OPC A/OPCs A/OPCs of % Organiza LEVEL LEVEL LEVEL Logged Not A/OPC Deploy
tion _1 _2 _3 In Logged In s ed DON Total 2713 1611 4324 62.74% DON Total 912 ARMY Total 8498 7629
16127 52.69% ARMY Total 904 94 998 90.58% USAF Total 7029 4789 11818 59.48% USAF Total 313 67 380 82.37%
ODA Total 1359 463 1822 74.59% ODA Total 70 6 76 92.11% 34091 57.49% ALL DOD Total 2199 ALL DOD Total 19599
14492 221 1133 80.49% 388 2587 85.00% Oversight DoD Training Forum sessions will include hands-on training using login credentials to log in. See slide 10 for session information. Stop by the Mastercard Welcome Center (Marriott - Atrium Level, M303) for additional help with IOD access or other issues. 55 Priorities 56 PRIORITIES Continue to: Ensure mission support. Timely certify invoices and work any electronic data interchange (EDI) issues. Promote A/BO and A/OPC IOD training and access as soon as possible. Work hierarchy issues with U.S. Bank. Close DM Cases. Complete Monthly Reviews. Brief HAs.
Follow Component guidance for conduct of Oversight during transition. 57 QUESTIONS? http://www.acq.osd.mil/dpap/pdi/pc/index.html 58 Back Up 59 DPC GPC SHARED MAILBOX ([email protected]) Please do not reach out to the DPC GPC shared mailbox with policy questions unless you have first verified that answers are not provided in the Guidebook or other applicable references. If, after performing your own research, you still have a question, please describe the research you have performed and include all relevant references for DPCs use in providing targeted responses. Please thoughtfully consider whether DPC is the correct resource to provide a response. DPC has recently received numerous questions that should instead have been directed to your Component Resource Managers, attorneys, or CPM peers for answers. 60 A/OPC
Monthly Review Checklist Refund Validation 4/19 Q3 7/19 Q4 10/19 Q1 1/19 Q2 4/19 Q3 7/19
Q4 10/19 Q1 1/19 Q2 Mar Feb Jan Dec Nov Oct Sep Aug
Jul Jun May Apr Mar Feb Jan Dec Nov Oct Sep Aug Jul Jun
May Apr Cycle FY 4/19 55 days ? days (MONTHLY) SemiAnnual HA Review GPC / OMB Statistical & Violation Reporting 55 days
D ? days A R ? days HA Review to CPM 12/15 HA Review to CPM 6/15 HA Review to CPM 12/15 T F TRANSITION CONFIGURATION MANAGEMENT PROCESS Anticipated Schedule 22nd of Month 30th of Month 4th of Month 8th of Month
10th of month 15th of Month 20th of Month 22nd of Month Master CI list updated with new CIs SME Meeting to discuss new CIs, and priority New CI list with updated priorities sent to CPMs for concurrence CI CI list list updated updated with with
CIs CIs received received during during this this cycle cycle CPM Meeting Approved and Rejected CIs are added for historical reasons CIs can be Approved and prioritized , or Rejected Process DPC Requests CIs via Email/CPM call SMEs discuss PIEE/JAM CIs with CPMs CPMs submit PIEE/JAM
CIs to DPC The Bank Team Requests CIs via Email/CPM call DPC Performs initial triage of received CIs SMEs discuss AxOL/IOD CIs with CPMs CPMs submit AxOL/IOD CIs to the Bank Team The Bank Team performs initial triage of received CIs Notes CIs may be accepted or rejected at this point. CI: Configuration Item (Enhancement, Defect, Configuration change ) DPC: Defense Pricing and Contracting || The Bank Team: US Bank, MasterCard and Oversight Systems CPM: Component Program Manager || SME: Subject Matter Expert Triage: Initial assessment to determine whether the CI is valid
Legend CPMs to work with SMEs to provide concurrence. No responses = concurrence DPC This cycle ends, but the next cycle begins and progresses the same way in the Transition period Bank Team CPMs Discuss new CIs that have yet to be triaged since last CPM Meeting SMEs
62 GPC Systems Overview 63 SMARTPAY 2 SMARTPAY 3 SYSTEM TRANSITION Hierarchy EMMA TBR PIEE TBR Delegation & Appointment PCOLS EAS Paper JAM
TBR Data Mining PCOLS PAT EAS IOD EAS PAT PCOM EAS IOD Reporting PCOLS EAS PAT EAS
PIEE PBIS EAS DM PIEE EAS EAS Invoice Certification & Payment EAS ERPs Accounting Systems Account Issuance & Maintenance PCOLS
EAS Oversight EAS PCOLS System Access PIEE TBR Archive EAS DMDC PBIS EAS 64 SP3 GPC Systems Summary Functional Workflow
TO 1 2 3 D BE E Y O L P ED Y A M 1 20 Supervisor Electronically Signs DAS Electronically Signs
Group Account Manager Approves 9 ND RG A T E D TE F 2 R O QT R 2 FY
0 PIEE HIERARCHY All Components have an existing PIEE Hierarchy Already agreed to and fixed through Level 3. Defense Agency GPC Level 3s moved to Level 2 CPMs. Component Group Administrators (GAMs) own and are responsible for coordinating changes at Level 4 and below. U.S. Bank is required to map TBR/Reporting Hierarchy to PIEE hierarchy and run reports. A/OPCs must work with their local PIEE GAMs to: Understand their Components hierarchy. Identify Home Organization DoDAACs for the organizations they support. 66 GPC DATA MINING AND OVERSIGHT Cases are initiated and referred to the A/BO daily. Timely completion of A/BO DM Questionnaire is required. Delayed responses will result in mandatory account suspensions. A/OPCs are required to: Validate review 100% of DM cases and perform a summary assessment of all transactions. Complete A/OPC DM Questionnaireenter corrective action taken for all cases of improper GPC use.
Work with Supervisors as appropriate. Open DM cases for all improper GPC use otherwise identified. Supports automated GPC Reporting (formerly OMB Reporting). Complete Monthly A/OPC Checklist. Brief HA every 6 months to obtain signature on Semi-Annual HA Report. Oversight A/OPCs are required to: Perform Summary Review of DM closed cases and review Monthly and Semi-Annual Review Reports. Brief HA every 6 months to obtain signature on Semi-Annual HA Report. CPMs are required to: Ensure Cases are closed, and spot-check Monthly and Semi-Annual Review Reports. Brief HA every 6 months to obtain signature on Semi-Annual PMR Report. 67 Micro-Purchase Threshold and Simplified Acquisition Threshold (SAT) 68 MPTS MICRO-PURCHASE THRESHOLDS 1 Federal-wide Open Market Micro-Purchase
2 Convenience Check 3 Federal-wide Higher Education Open Market Micro-Purchase 4 5 6 7 GPC Construction GPC Service Contract Labor Standard Services GPC Contingency (Inside U.S.) GPC Contingency (Outside U.S.) Threshold $10,000 $5,000 $10,000 or Greater $2,000 $2,500 $20,000
$30,000 69 CONTINGENCY CONTRACTING MPTS Category Inside U.S. Outside U.S. Acquisitions of supplies or services that, as determined by the Head of the Agency, are to be used to: Construction subject to 40 U.S.C. chapter 31, subchapter IV, Wage Rate $2,000 Requirements (Construction) (41 U.S.C. 1903) Support a Contingency Operation Facilitate defense against or recovery from the following types of attacks: - Cyber - Nuclear - Biological - Chemical Card: $20,000 Card: $30,000 - Radiological Check: $10,000 Check: $15,000 Support a request from the Secretary of State or the Administrator of the U.S. Agency for International Development to facilitate provision of international disaster assistance pursuant to 22 U.S.C. 2292 et seq. Support a response to :
- Emergency - Major Disaster Support for Humanitarian or Peacekeeping Operation (10 U.S.C. 2302) Not Addressed 70 SATS Category Inside U.S. Outside U.S. General DoD SAT $250,000 Acquisitions of supplies or services that, as determined by the Head of the Agency, are to be used to: Support a Contingency Operation Facilitate defense against or recovery from the following types of attacks: - Cyber - Nuclear - Biological - Chemical - Radiological $750,000 $1,500,000 Support a request from the Secretary of State or the Administrator of the U.S. Agency for International Development to facilitate provision of international disaster assistance pursuant to 22 U.S.C. 2292 et seq.
Support a Response to: - Emergency - Major Disaster Support a Humanitarian or Peacekeeping Operation (10 U.S.C. 2302) N/A $500,000 71 HOW DOES THE SAT IMPACT THE GPC PROGRAM? Contingency Contracting Officers may use the GPC up to: - $750K Inside the U.S. $1.5M Outside the U.S. DFARS 213.301(3) A contracting officer supporting a contingency operation as defined in 10 U.S.C. 101(a)(13) or a humanitarian or peacekeeping operation as defined in 10 U.S.C. 2302(8) also may use the Governmentwide commercial purchase card to make a purchase that exceeds the micro-purchase threshold but does not exceed the simplified acquisition threshold, if (3) (i) The supplies or services being purchased are immediately available; (ii) One delivery and one payment will be made; and (iii) The requirements of paragraphs (2)(i) and (ii) of this section are met.
72 DoD Micro-Purchase Regulations 73 WHAT IS A MICRO-PURCHASE (FAR 2.101)? Acquisition.gov FAR Site Micro-purchase means an acquisition of supplies or services using simplified acquisition procedures, the aggregate amount of which does not exceed the micro-purchase threshold. Hill AFB FAR Site - Missing Important Words Micro-purchase means an acquisition of supplies or services, the aggregate amount of which does not exceed the micro-purchase threshold. SAP (FAR 13) does not include the following, so they are not micro-purchases: Placing Orders against Contracts (FAR 16.5) Placing Orders against GSA Schedules (FAR 8.405) Purchasing from FPI (FAR 8.6)
Overseas GPC Use up to $25K (DFARS 213.301(2)) Contract Payments (FMR) SF-182 Payments (FMR) Intergovernmental Payments (FMR) ase h c r o-Pu s not r c i i M GPC intment taking s o App t for CH s. cien action ffi u s e thes 74
HOW DO THESE RELATE TO AVAILABLE JAM CH APPOINTMENTS? Authority Type Threshold 1 Micro-Purchase Cardholder $10K 2 Micro-Purchase Convenience Check Writer $5K 3 Higher Education Micro-Purchase Cardholder 4 Micro-Purchase Contingency Contracting Cardholder 5
Warranted Contingency Contracting Cardholder 6 7 8 Contract Ordering Official Cardholder Overseas Simplified Acquisition Cardholder Contract Payment Official Cardholder $10K - but HCA determination can result in higher value (unlimited) $20K Inside the US $30K Outside the US $750 Inside the US; $1.5M Outside the US Simplified Acquisition Threshold $25K Unlimited 9 SF-182 Training Payments Cardholder $25K
Warrant Issued? 10 Inter/Intra-Governmental Payment Official Cardholder $24,999 75 Planned GPC Policy Memos 76 PLANNED SP3 TRANSITION MEMO SP3 Nonappropriated Funds (NAF) policy memo SP3 Transition Memorandum # X (Date TBD, 2019): All SP3 NAF cards are required to follow all DoD Government Charge Card Guidebook for Establishing and Managing Purchase, Travel, and Fuel Card Programs requirements SP3 NAF card accounts shall be established under separate MAs (i.e., no co-mingling of appropriated and nonappropriated funded cards under a single MA) GPC JAM Role Descriptions are available at: https://www.acq.osd.mil/dpap/pdi/pc/SmartPay3_TI_and_PCET.html. 77