What is delinquency?
Delinquency is an undisputed account balance that is unpaid for the prescribed number of calendar days or more past the statement due date. The statement due date will generally be 25 to 30 days after the closing date on the statement, depending on the contractor bank. The closing date is often referred to as the billing cycle date and is assigned by the contractor bank for your accounts and will generally be the same each month for all accounts under your control.
For an IBA Account, liability for all charges rests with the individual account holder. If the account holder fails to pay his/her account on a timely basis, it will be considered delinquent and the contractor bank may suspend or cancel the account and assess late charges and fees. The agency/organization is never responsible or legally liable for the account.
It is important to remember that under the terms of the GSA SmartPay Master Contract, an account is considered past due if payment for the undisputed principal amount has not been received within 45 calendar days from the closing date on the statement of account in which the charge appeared.
- Suspending an account: The bank may suspend the account, unless otherwise directed by the program coordinator, if the payment for the undisputed principal amount has not been received 61 calendar days from the closing date on the statement of account in which the charge appeared.
- Cancelling an account: If payment for the undisputed principal amount has not been received 126 calendar days from the closing date on the statement of account in which the charge appeared, the contractor bank may cancel the account, unless otherwise directed by the program coordinator.
What is a write-off or credit loss?
A write off is a canceled account with an unpaid balance determined to be uncollectible by the contractor bank.
How do I notify account holders regarding past due accounts?
Notify an account holder regarding past due accounts by:
- Letter/ correspondence/ memorandum
- Personal visit
Always document your contacts with account holders regarding their delinquent accounts. If you contact the account holder by telephone or personal visit, make a note of the date and time of the call/visit, the results of the call/visit, and any follow-up you or the account holder agreed to. If you contact the account holder by email, be sure to save the email. Keep a file copy of all written correspondence. It is important to keep your documentation so that there are records in the event of an audit, investigation, or later inquiry into a specific account.
Note: Your agency/organization may have additional policies requiring notifying the account holder's supervisor, your human resources office, and/or your finance office by sending a list of delinquent travel accounts. Be sure to always comply with agency policy.
How is action initiated on delinquent accounts?
You should become familiar with the policies and standards of conduct applicable to account holders at your agency. Your agency may have developed guidance that addresses the range of actions that may be taken in the event that the account holder violates agency policy. You may be responsible for advising the appropriate personnel (e.g., the account holder's supervisor, Human Resources, the Office of Inspector General, the agency/ organization Ethics Official) when an account holder has misused their account. Generally, you will not initiate the personnel action, but you may be called upon to provide supporting documentation.
How do I inform delinquent account holders about disciplinary actions?
If you are required to do so by your agency/ organization, inform account holders who are delinquent that disciplinary actions may be taken by the agency/ organization if payments for delinquent accounts are not received in a timely manner. You may be required to cite or provide a copy of the relevant agency policy pertaining to disciplinary actions. Although travel account delinquency policies vary from agency to agency, you may be expected or required to remind account holders of the consequences for repeated delinquencies and/or misuse of their travel account. You are also encouraged to work with your Human Resources office, your legal office and anyone one else who may need to be involved in the disciplinary action process.
Disciplinary actions that may occur, depending on the severity of the problem, include:
- Counseling/informal admonishment;
- Oral and/or written reprimand;
- Suspension without pay; and
- Removal from federal service employment
In addition, it is important to notify account holders with cancelled IBAs, in accordance with agency specific policy, may be:
- Reported to credit bureaus or similar entities by the contractor bank
- Referred to an outside collection agency by the contractor bank, and
- Subject to late fees for which will not be reimbursed.
Note: Agencies/organizations may elect to allow the Contractor to charge their standard commercial late fee in accordance with standard commercial practice; however, inclusion of standard commercial late fees at the task order level is contingent upon the agency’s/ organization’s successful negotiations with union officials, as appropriate and at the sole discretion of the agency/organization ( See the GSA SmartPay 3 Master Contract, Section C.126.96.36.199).
Why should my agency/organization care about delinquency?
Liability for an IBA is the account holder's responsibility, not the Government's. So, why should the Government even care whether an employee is delinquent in paying the amount owed on time?
There are a number of reasons why it is important to manage delinquency, such as:
- Federal employees must abide by the Standards of Official Conduct and agency ethics rules. (link to the Office of Government Ethics).
- Federal agencies are responsible for ensuring that employees follow the Federal Travel Regulation (FTR) and Joint Travel Regulations (JTR) for DoD. (Link to the FTR website and JTR website ).
- As participants in the GSA SmartPay program, all agencies/organizations are responsible for following the terms of the GSA SmartPay Master Contract, including the requirements to ensure that account holders use the account correctly, monitor account activity, manage delinquency, and mitigate suspension/cancellation of accounts. (Link to a copy of the GSA SmartPay 3 Contract).
How can I track account holder misuse and delinquency?
Use the contractor bank's EAS exception reports to track misuse and delinquency.
What ethical standards apply to travel account holders?
Executive agency account holders are subject to the Standards of Official Conduct. These standards require that:
- Public service is a trust, requiring account holders to place loyalty to the Constitution, the laws, and ethical principles above private gain.
- Account holders shall not use public office for private gain.
- Account holders shall satisfy in good faith their obligations as citizens, including all just financial obligations, especially those - such as federal, state, or local taxes - that are imposed by law.