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Card / Account Holders and Approving Officials Purchase Training

Purchase Training

Introduction: Welcome to the Course

Welcome to the GSA SmartPay® Purchase Training for Card/Account Holders and Approving Officials

This training course is intended to teach the basic roles and responsibilities of a card/account holder or approving official and can be used as refresher training as required by your agency. We encourage you to also learn about your agency’s specific purchase program requirements and policies. After reviewing each lesson, click on the button to go to the next lesson. The quiz is only available on the website and can be accessed after you complete the final lesson. .

Note: The GSA SmartPay training website is an independent training system and does not connect/communicate with any other agency training systems.

Lesson 1: Purchase Program Overview

What is the GSA SmartPay® program?

Established in 1998, the GSA SmartPay program is the world’s largest government charge card and commercial payment solutions program, providing services to more than 250 federal agencies/organizations and Native American tribal governments with 4.5 million total accounts. GSA SmartPay payment solutions enable authorized government employees to make purchases on behalf of the federal government in support of their agency’s mission. The GSA SmartPay program includes the following business lines:

  • GSA SmartPay Purchase.
  • GSA SmartPay Travel.
  • GSA SmartPay Fleet.
  • GSA SmartPay Integrated.

Through the Master Contract with multiple banks, the GSA SmartPay program enables agencies/organizations across the federal government to obtain payment solutions to support mission needs. The Master Contract, administered by GSA, is a fixed price, indefinite delivery, indefinite quantity (IDIQ) contract. The maximum base period for the initial order is four years with three, three-year options.

Agencies/organizations issue a task order under the GSA SmartPay 3 Master Contract to one of the GSA SmartPay contractor banks – Citibank or U.S. Bank. Then, the awarded bank provides payment solutions to the agency.

Through the task order, your agency/organization program coordinator (A/OPC) sets up accounts for the card/account holders, manages the accounts using the bank’s Electronic Access System (EAS), and resolves issues or questions by working directly with a bank representative.

To become a GSA SmartPay Purchase card/account holder, your personal credit history is not criteria for receiving a purchase card/account. In addition, use of the purchase card/account will not affect your personal credit history. Any government employee authorized to use the GSA SmartPay program who has a responsibility to make purchases and completes the necessary training is eligible to become an card/account holder. Card/account holders are either appointed by their agency/organization program coordinator (A/OPC) or designated by an approving official (AO).

What are the benefits to using the GSA SmartPay Master Contract for obtaining payment services?

The GSA SmartPay program has continued to grow through increased adoption as agencies/organizations realize benefits afforded under the program.

Utilizing the GSA SmartPay Master Contract means:

  • A faster contract acquisition process and reduced risk of protest, as compared with a full and open competitive procurement.
  • Favorable negotiating platform and contract terms.
  • Awards to contractor banks based on a competitive bidding process.
  • Established relationships with contractor banks.
  • A broad range of flexible products and services for agencies/organizations as well as the flexibility to add products and services.
  • Ongoing support for your agency/organization.

What are some of the overall benefits to using the GSA SmartPay program?

Agency Refunds

Agencies have the opportunity to earn refunds based on the dollar volume of transactions and the speed of payment.

Safety and Transparency

The GSA SmartPay program provides secure solutions for efficient payment transactions. Customers also have access to tools that provide increased transparency to spend and performance data.

Electronic Access to Data

Through the GSA SmartPay contractor bank’s electronic access system (EAS), account managers and card/account holders have immediate access to complete transaction-level data, helping to mitigate fraud, waste and abuse.

Worldwide Acceptance

Through the use of commercial payment infrastructure, customers are able to use GSA SmartPay solutions anywhere in the world where merchants accept cards.

Identification for Discount Programs

GSA SmartPay solutions provide automatic point-of-sale recognition for many GSA discount programs, including Federal Strategic Sourcing Initiative (FSSI), the GSA City Pair Program (CPP) and more.

Other Benefits

GSA SmartPay payment solutions provide other less tangible benefits including travel insurance and eliminating the need for imprest funds or petty cash at the agency.

What is a GSA SmartPay Purchase card/account?

A purchase card/account is a type of payment solution issued by a GSA SmartPay contractor bank and used to pay for supplies or services procured at the direction of a federal agency/organization under official purchase authority.

The GSA SmartPay purchase program is the preferred method of payment for federal employees to make official government purchases for supplies, goods and services under the micro-purchase threshold (MPT).

For micro-purchases, the GSA SmartPay purchase card/account may be used as a procurement, ordering and payment mechanism.

For purchases above the MPT, the GSA SmartPay purchase card/account may be used as an ordering and payment mechanism, but cannot be used as a procurement mechanism.

Card/account holders can purchase any commercially available supply or service within their spending limits and not prohibited by either federal or agency-specific procurement regulations.

What are some specific benefits associated with use of the GSA SmartPay Purchase card/account?

  • Provides the government with financial and cash management control over low dollar value, high volume procurements and can serve as a payment tool for larger transactions consistent with agency policy.
  • Saves money by making only one payment to the contractor bank rather than thousands of payments to individual merchants.
  • Improves the use of the government’s time and resources by freeing up contracting personnel so they are able to focus on more complex activities that derive greater benefit from their expertise.
  • Provides card/account holders with the flexibility to decide what to purchase, when to buy it, and from whom.
  • Allows card/account holders to monitor funds on their own.
  • Provides merchants with a familiar method to accept payment as they already understand how to accept commercial credit cards.
  • Provides a quick way to pay merchants for their supplies and services.

What are the regulations that govern the use of the purchase card/account?

The GSA SmartPay Purchase card/account has a solid grounding in key statutes and regulations. Although many small-scale purchases are low in dollar amount, taken together, small-scale purchases account for billions of dollars in contracting and are a critical part of the government’s acquisition process.

Here are some of the key statutes and regulations:

Please note that your agency also may have supplemental policy governing account use.

What is a Centrally Billed Account (CBA) and an Individually Billed Account (IBA) and why is it important to know the difference?


  • Agency is invoiced for purchases.
  • Payments are made directly to the contractor banks by the federal government.
  • Examples include purchase, fleet and some travel cards/accounts.


  • Card/account holder is invoiced directly.
  • Payment is the responsibility of the card/account holder, who is then reimbursed by the agency/organization.
  • Most common travel cards/accounts.

The distinction between CBAs and IBAs is important when determining state tax exemption. All GSA SmartPay CBAs should be exempt from state taxes. In addition, with a CBA, the federal government accepts liability for charges made by an authorized card/account holder, but is not liable for any unauthorized use. Unauthorized use means the use of an account by a person, other than the card/account holder, who does not have actual, implied or apparent authority for such use and from which the card/account holder receives no benefit. When the CBA has been used by an authorized card/account holder to make an unauthorized purchase, the Government is liable for the charge and the agency is responsible for taking appropriate action against the card/account holder.

How do I recognize GSA SmartPay Purchase cards/accounts?

Typically, purchase cards have this design:

Red charge card with the word Purchase and numbers 1234 5678 9012 3456 and the name John Smith, with a bird in the background

Please note that card designs may vary.

GSA SmartPay Purchase Account Prefixes

GSA SmartPay Purchase cards/accounts use the following prefixes:

BrandCard Prefix
Visa4614, 4715, 4716
Mastercard5565, 5568

Lesson 2: Key Participants

Who are the key participants in the GSA SmartPay® program within my agency/organization and what are their responsibilities?

Agency/Organization Program Coordinators (A/OPCs)

  • Overall management and oversight of the accounts under their span of control.
  • Set up accounts and designate authorization controls.
  • Serve as a liaison between card/account holders and the bank.
  • Provide ongoing advice and assistance to card/account holders.
  • Develop agency program procedures and policies as necessary.
  • Audit accounts as required by the agency’s policy.
  • Use the bank’s Electronic Access System (EAS) to perform account management and oversight.

Approving Officials (AO)

  • Typically the card/account holder’s supervisor.
  • Assure proper use of the account.
  • Determine if purchases are necessary for accomplishing the mission of the agency.

Card/Account Holders

  • Designated by an agency/organization to receive an account.
  • Secure the payment solution.
  • Maintain records relating to transactions, as required.
  • Use the account ethically for official government purposes only.

Designated Billing Offices (DBO)

  • Serve as the focal point for receipt of official centrally billed invoices.
  • Oversee the proper processing of invoices.
  • Ensure invoices are paid within the Prompt Payment Act timeframes.

Transaction Dispute Officers (TDO)

  • Assist the agency/organization and the bank in tracking and resolving disputed transactions.

EC/EDI Offices (EO)

  • Focal point for electronic commerce/electronic data interchange (EC/EDI) for the agency/organization.
  • Oversee the proper implementation of the EC/EDI capabilities and processes.

Who are the key participants in the GSA SmartPay program that are outside of my agency/organization and what are their responsibilities?

Contractor/Issuing Banks

  • Enable merchant payments for purchase transactions.
  • Establish accounts.
  • Issue cards, if required.
  • Prepare the monthly statement for each card/account holder.
  • Issue invoices to the Designated Billing Offices (DBO).
  • Provide 24-hour customer service.
  • Prepare reports that assist the agency in effectively utilizing the program.
  • Examples include Citibank and U.S. Bank.


  • Financial institutions that dictate where payments can be processed.
  • Facilitate the payment process between card/account holders, merchants, and issuing financial institutions.
  • Examples include Visa and Mastercard.


  • Source for supplies or services.
  • May be a required source inside or outside the government, another government agency, or a private sector merchant.

GSA Contracting Officer

  • Administers the GSA SmartPay Master Contract on behalf of all authorized users, including your agency/organization.
  • Make changes to the GSA SmartPay Master Contract requirements.
  • Legally commit or obligate the government to the expenditure of public funds for the GSA SmartPay Master Contract.
  • Render a final decision on a dispute pertaining to the GSA SmartPay Master Contract.

Is there anyone else who will be involved with the GSA SmartPay program?

Because the GSA SmartPay program is a highly visible program and receives a lot of interest both within and outside your agency/organization, your agency/organization’s management, the Inspector General (IG) staff and other investigators/auditors will likely be interested in the performance of the purchase program. Many agencies/organizations will have periodic audits of the purchase program and your A/OPC will likely be a key player in those audits. Additionally, you may find that the Office of Management and Budget (OMB) and Congress take an interest in the performance of your program.

Lesson 3: Preparing to Purchase

I have just been selected to become a GSA SmartPay® Purchase card/account holder. What should I know?

Basic Reminders

  • Your GSA SmartPay Purchase card/account is issued to you for official government business only.
  • The purchase card/account can never be used for personal reasons.
  • Do not share your account information with anyone. Only you are authorized to use the account. This means that no family member or member of your staff, including your supervisor, may use your purchase card/account.
  • Safeguard your purchase card/account information at all times. Unauthorized use of the account due to your failure to secure the account may result in disciplinary action.

Setting Up Your Account

  • The agency/organization program coordinator (A/OPC) for your organization will be the one who sets up your account with the contractor bank and assists you with any specific questions about your account or agency specific policy.
  • To become a GSA SmartPay Purchase card/account holder, your personal credit history is not criteria for receiving a purchase card/account. In addition, use of the purchase card/account will not affect your personal credit history.
  • New applicants should receive their GSA SmartPay Purchase card/account from the contractor bank within 10-14 calendar days from the time the application is submitted by your A/OPC.
  • Replacements for lost, stolen, broken or otherwise unusable cards will be sent within 48 hours of the agency/organization request.
  • In the case of an emergency, such as response to a natural disaster, threat to national security and military mobilization, the contractor bank will send the GSA SmartPay Purchase card/account within 24 hours of the request.

Verifying Your Card/Account

After receipt of your card/account the following steps should be taken:

  • Verify the accuracy of the card/account information (for example, your name and address).
  • Call the toll-free number provided by the contractor bank to confirm receipt and activate the card/account.
  • If you are given a physical card, sign the back of the card.
  • Review the card/account holder guide provided by the contractor bank.

Planning Your Monthly Purchases

As a purchase card/account holder, it is important to carefully plan your monthly purchases. For example:

  • Decide which items are best handled using your purchase card/account and when is the best time to purchase those items.
  • Combine requirements in order to qualify for volume discounts (as long as you remain within the authorized per transaction and monthly spending limits).
  • Make small-scale purchases to avoid wasteful stockpiling.
  • Purchase items in order of priority, where higher priority items are purchased before lower priority items.

Please note that many agencies require card/account holders to obtain management approval before each purchase. Double check your agency policy and plan time for the approval process. Tools to help you request and track approvals are available on the Purchase Publications page of the GSA SmartPay website.

Ensuring Availability of Funds

  • Establish the amount of available funds before making any purchases.
  • Some agencies require card/account holders to verify the amount of available funds before each purchase.
  • Track purchases throughout the month to ensure that there remains sufficient funds available to make all required purchases. Using a system to record purchases and dollar amounts committed can be very helpful in tracking. It will allow you to know at a glance the amount of your unobligated funds or certified fund availability.

Conducting Market Research

  • Market research allows you to make an informed, responsible and reasonable purchase.
  • Do enough market research to ensure that the government gets the best value for its money in terms of a reasonable price and timely, reliable quality service.
  • Each purchase should represent the best value that meets the government’s minimum requirements.
  • Use the Green Procurement Compilation (GPC), a comprehensive green purchasing resource designed for federal contracting personnel and program managers, to identify environmental attributes applicable to your purchase, such as energy efficiency or recycled content. The GPC also identifies GSA Sources (Multiple Award Schedules (MAS) or GSA Global Supply) and links to the GSA Advantage! website.
  • Your contracting activity can assist you with your market research by providing information on required sources of supply, existing contracts, good merchants and support in many other areas.
  • Compare prices and check with your contracting activity to see if there are existing contracts that offer a good price, service and quality. These existing contracts have been negotiated at your agency or by other agencies and can sometimes offer advantages and money savings.

Selecting the Best Value

  • When making micro-purchases, identify the supply or service that best satisfies the requirement, weighing both price factors and non-price factors. For example, you can purchase a higher priced item if it represents a better value. It is your responsibility as the card/account holder to perform basic comparison-shopping and to briefly document the basis for your purchase decisions.
  • Check the vendor’s schedule price list at GSA eLibrary.
  • Check the GPC for life cycle cost information, especially for energy using products.

Seeking State Sales Tax Exemption

  • Each state handles tax exemption a little differently.
  • Be sure to visit the State Tax Information page on the GSA SmartPay website to find out more about requirements in your state.
  • Centrally Billed Accounts (CBAs) are exempt from state sales taxes in every state, but there may be special requirements or required forms in order to obtain state tax exemption in some states.

Talking to Merchants

Create a checklist when talking to merchants and be as specific as possible. Ask about:

  • Price.
  • Shipping costs.
  • Time of delivery.
  • Discounts for government purchases.
  • Merchant’s return policies (if different).
  • Product/service warranty.

How can I ensure that I am getting an accurate quote?

It’s important to ask the right questions before making your purchase. Specifically, double check that the quote includes items like shipping/handling and/or a tax charge (if applicable), so that it matches the invoice when billed. Price differences between quotes and statement amounts cannot be disputed with the contractor bank. You must contact the merchant and ask for a credit if this occurs. The charge must be paid as it stands on your monthly invoice.

What are spending limits and account restrictions?

Spending limits are determined by the agency/organization program coordinator (A/OPC) for each individual account and established when the account is set up. The limits are based on your delegation of authority and the budgetary limits of your office.

There are two types of spending limits applied to the purchase card/account:

  • Single purchase limit - the dollar limit for an individual transaction.
  • Monthly purchase limit - the cumulative dollar limit for purchases in one month. The monthly purchase limit may be set to any dollar amount equal to or greater than the single purchase limit.

Verify both your single purchase limit and your monthly purchase limit with the A/OPC or approving official (AO).

In addition to spending limits, other restrictions such as the number of transactions and merchant category codes (MCC) blocks may apply to your account. A MCC is a four-digit code used to identify the type of business a merchant conducts (such as gas stations, restaurants, airlines, etc). MCCs may be blocked to prevent fraud and misuse.

What should you do if you exceed your spending limit?

Prior to processing your purchase, the merchant will check if the transaction exceeds any spending limits on your account. All attempted transactions that exceed either the single or monthly spending limit will be automatically declined at the POS.

As a card/account holder, it is your responsibility to plan ahead and keep track of how much has been spent against your limit before you make the purchase. Do not rely on the authorization system to do this for you. Reach out to your A/OPC or contractor bank immediately if your account is declined. The contractor banks’ customer service phone numbers can be found on the bank contact page on the GSA SmartPay website and are listed on the back of the charge card.

What is “splitting the requirement”?

It might seem logical for you to divide a purchase into parts so each purchase would then be below your agency limits. But, it is never permissible to intentionally divide purchases into parts just to get under your limits. This is called “splitting the requirement”. When you have a defined need, all the parts of that need are considered one purchase.

For example, Joe, a card/account holder, needs to buy one hundred widgets. The total value of the transaction is above the micro-purchase threshold. In order to make the transaction fit under the micro-purchase limit, he asks the store to split his order into two separate transactions. This action is called a split transaction and is a violation of federal government procurement regulations.

Lesson 4: Shop Small, Smart, and Green

How do purchase card/account holders support small businesses?

Purchase card/account holders should consider shopping at small businesses. Increasing opportunities for small businesses in federal contracting is a top priority. The Office of Management and Budget (OMB) and the Small Business Administration (SBA) are working to improve access for small businesses to the federal market and boost communications about federal business opportunities. Remember, it is important to consider small businesses when buying goods and services at or below the micro-purchase threshold.

How can purchase card/account holders shop smarter?

The FAR states that use of the GSA SmartPay Purchase card/account is the preferred method for buying small purchases.

Here are some tips to help you shop smarter when using your purchase card/account:

  • Use GSA Advantage! to conduct quick and easy market research and to order already negotiated low-price items.
  • Take advantage of the Blanket Purchase Agreements (BPAs) your agency has negotiated to get better prices.
  • Utilize the Best-in-Class contract vehicles.
  • Always ask for discounts at the register - whether or not POS discounts are given.
  • Locate merchants that accept Mastercard and Visa by using merchant/supplier locator tools at and

What does it mean to “buy green”?

Sustainable acquisition or green purchasing refers to the procurement of products and services that have a lesser or reduced effect on human health and the environment when compared with competing products or services that serve the same purpose.

Benefits to using your purchase card/account to buy green products are that you help your agency to perform its mission while:

  • Saving money.
  • Enhancing energy security.
  • Protecting public health.
  • Promoting environmental stewardship.
  • Reducing greenhouse gas emissions.
  • Fostering markets for sustainable technologies, materials, products and services.

In addition, regulations require federal buyers to purchase products with specific environmental or energy attributes and services under which those products will be used or supplied.

There are multiple components to the federal green purchasing program:

  • Recycled content products.
  • Energy Star and Federal Energy Management Program (FEMP) designated energy efficient products, low standby power devices and renewable energy.
  • Alternative fuel vehicles/alternative fuel.
  • Biobased products.
  • WaterSense and other water efficient products.
  • Environmentally preferable products and services.
  • Alternatives to ozone-depleting substances.
  • Environmental Protection Agency (EPA) Safer Choice labeled products.

Green purchasing is required by law or executive order unless the products do not meet your performance needs, are not reasonably available or are only available at an unreasonable price. However, most green products are commercially available off-the-shelf items and can be purchased through the GSA stock and schedule programs, Federal Strategic Sourcing Initiative (FSSI) solutions, the Defense Logistic Agency (DLA), mandatory sources such as the National Industries for the Blind (NIB) and commercial open market sources.

GSA assists you with identifying which products have environmental requirements by consolidating federal green purchasing information into one location where you can identify applicable green purchasing requirements, legal references and potential purchasing options such as GSA’s Multiple Award Schedules and GSA Global Supply, as well as other guidance for purchasing green products and services.

What are recycled content products?

Recycled content products, also known as Comprehensive Procurement Guideline (CPG) items, are designated by EPA. Under the CPG program, EPA designates products that are or can be made with recovered materials and recommends minimum recycled content levels you should specify when buying these products. Examples of recycled content products include copier paper, file folders, and other office paper products, notebook binders and remanufactured toner cartridges.

Refer to the Green Procurement Compilation (GPC) for the current list of EPA-designated CPG products or go to for more information.

What are energy efficient products?

Energy efficient products include:

Energy efficient products typically include desktop computers, laptops, printers and small appliances. As of early 2015, the EPEAT registry includes computers and displays (including tablets), printers and copiers and televisions.

Refer to the GPC for the current list of designated energy efficient products. In addition, Energy Star and the Federal Energy Management Program may have efficiency recommendations, cost-effectiveness examples, buyer tips and product sources. Lastly, the Electronic Product Environmental Assessment Tool has additional information about EPEAT-registered electronic products.

What are biobased products?

Biobased products, also known as BioPreferred products, are designated by the U.S. Department of Agriculture (USDA). They are made from agricultural materials like soy and corn and wood by-products. As with EPA’s CPG program, the USDA designates biobased products and recommends minimum biobased content levels you should specify when buying these products.

The USDA also manages a “USDA Certified Biobased Product” labeling program for both the designated BioPreferred products and other products that contain biobased materials. Examples of BioPreferred products typically include hand sanitizers, glass cleaners and dish detergent.

Refer to the GPC for the current list of BioPreferred products and visit for more information.

What are water efficient products?

WaterSense labeled products are 20% more efficient than similar items. Water efficient products include bathroom sink faucets, shower heads, low flow toilets and urinals.

Refer to the GPC for the current list of water efficient products. In addition, go to for efficiency recommendations and information, qualified products, case studies and a water savings calculator.

What are alternatives to ozone depleting substances?

Although the United States has been very successful in reducing releases of ozone-depleting substances (ODSs), the amount of ozone-depleting substances in the atmosphere is still significant and will be for decades to come. EPA identifies alternatives to ODSs through its Significant New Alternatives Policy (SNAP) program and provides recommendations for specific products, such as refrigerants and chemicals used in fire extinguishers.

Refer to the GPC for the current list of products that use alternatives to ODSs, like appliances. And, go to for the latest list of products and alternatives approved by EPA.

What are safer choice-labeled products?

EPA’s Safer Choice label helps consumers, businesses and purchasers find products that perform well and are safer for human health and the environment.

Refer to the GPC for the current list of Safer Choice products. In addition, visit for the list of Safer Choice products by product name and manufacturer.

Lesson 5: Making Purchases

What can I buy using my GSA SmartPay® Purchase card/account?

It is important to understand the limits on purchase card/account use and to manage your purchases against those limits.

You are allowed to purchase any commercially available supply or service not prohibited by either federal government or agency-specific procurement regulations. To find out your agency specific procurement requirements regarding purchase amounts, receipt documentation and approvals contact your A/OPC or contracting officer. An approval may be required prior to purchase and may be needed in conjunction with a subsequent review of the purchase activity. If a purchase appears questionable, consult your A/OPC or contracting office.

What are the required sources of supply?

Use of the GSA SmartPay Purchase card/account should be consistent with established guidelines for required sources of supply and acquisition procedures, such as those applicable to micro-purchases or to acquisitions below the simplified acquisition threshold. Procurements paid for with the GSA SmartPay Purchase card/account are subject to the acquisition rules established in the FAR, as well as your agency/organization policies and procedures.

The Federal Acquisition Streamlining Act did not abolish the priorities for use of the government supply sources as stated in FAR Part 8 (Required Sources of Supplies and Services). Micro-purchases are not exempt from the sources of supply and services requirement.

The following information from FAR Part 8 lists the priorities for use of government supply sources:

FAR 8.002 - Priorities for Use of Mandatory Government Sources

Except as required by FAR 8.003, or as otherwise provided by law, agencies shall satisfy requirements for supplies and services from or through the sources and publications listed below in descending order of priority.

For Supplies:

  • Existing inventories.
  • Excess from other agencies.
  • Federal Prison Industries, Inc.
  • Supplies which are on the Procurement List maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled.
  • Wholesale supply sources, such as stock programs of the GSA, the Defense Logistics Agency, the Department of Veterans Affairs and military inventory control points.

For Services:

  • Services that are on the Procurement List maintained by the Committee for Purchase From People Who Are Blind or Severely Disabled

Sources other than those listed above may be used as prescribed in the Code of Federal Regulations (specifically 41 CFR 101-26.301) and in an unusual and compelling urgency as prescribed in FAR 6.302-2 and in 41 CFR 101-25.101-5.

The statutory obligation for government agencies to satisfy their requirements for supplies or services available from the Committee for Purchase From People Who Are Blind or Severely Disabled also applies when contractors purchase the supplies or services for government use.

FAR 8.003 Use of Other Mandatory Sources

Agencies shall satisfy requirements for the following supplies or services from or through specified sources, as applicable:

  • Public utility services.
  • Printing and related supplies.
  • Leased motor vehicles.
  • Strategic and critical materials (like metals and ores) from inventories exceeding Defense National Stockpile requirements.
  • Helium.

FAR 8.004 Use of Other Sources

If an agency is unable to satisfy requirements for supplies and services from the required sources of supply, agencies are encouraged to consider satisfying requirements from or through the following non-mandatory sources:

For Supplies:

  • Federal Supply Schedules (FSS).
  • Governmentwide acquisition contracts.
  • Multi-agency contracts.
  • Any other procurement instruments intended for use by multiple agencies, including blanket purchase agreements (BPAs) under FSS contracts (e.g. Federal Strategic Sourcing Initiative (FSSI) agreements).

For Services:

  • Agencies are encouraged to consider Federal Prison Industries, Inc., as well as the sources listed under “Supplies” above.
  • Commercial sources (including educational and nonprofit institutions) in the open market.

When satisfying requirements from non-mandatory sources, give consideration to small business, veteran-owned small business, service-disabled veteran-owned small business, HUBZone small business, small disadvantaged business (including 8(a) participants) and women-owned small business concerns.

GSA Advantage! is an online shopping mall with thousands of commercial products and services including JWOD/NIB/NISH and UNICOR products, designed to link GSA schedule products and services, stock items, catalog descriptions, current pricing and delivery information in a single location to make ordering easier for you. To place an order, you can use your GSA SmartPay Purchase card/account.

Is it necessary to distribute purchases amongst merchants? For example, if I am not required to get quotations, can I always buy from the same source?

Federal Acquisition Regulation (FAR) Part 13.203(a)(1) recommends that micro-purchases be equitably distributed among qualified merchants to the extent practicable.

What are Point-of-Sale (POS) discounts?

POS is the point where a transaction is finalized or the moment where a customer tenders payment in exchange for goods and services. Certain merchants offer automatic discounts when you use the purchase card/account to make purchases. These merchants have the ability to recognize the GSA SmartPay Purchase card/account based on the account number and apply a discount at the time of the sale.

What is Section 889 and how does it apply to purchases?

Section 889 of the John S. McCain National Defense Authorization Act (NDAA) for Fiscal Year 2019 (P.L. 115-232 [PDF, 789 pages]) and the Federal Acquisition Regulation (FAR) Case 2018-017 prohibit the purchase of covered telecommunications equipment and services from vendors who sell products containing spyware. These devices could pose a threat to U.S. security by spying on or disrupting communications within the U.S. Therefore, purchase card/account holders should follow their agency’s policy regarding Section 889 compliance.

What are convenience checks?

Some agencies allow for the use of convenience checks.

Convenience checks are:

  • A contractor-provided instrument that is written, dated and signed against an account within established dollar limits.
  • Intended only for the use with merchants that do not accept the GSA SmartPay Purchase card/account.
  • A payment method of last resort, only when no reasonable alternative merchant is available who accepts the GSA SmartPay Purchase card/account.

If your agency/organization determines a need for convenience checks, your contractor bank will provide a supply of checks to the designated card/account holder drawn on the card/account holder’s purchase card/account. The checks will be processed as they are presented for payment.

Convenience checks are multi-copied (one copy for the card/account holder’s records and the original copy for the merchant). Due to the increased potential of fraud and abuse, specialized training on convenience checks is required prior to being authorized to write checks. If any misuse or abuse is discovered, the employee will lose convenience check and purchase card/account privileges. That employee will then be referred for disciplinary action in accordance with agency procedure.

Convenience checks may not be written for purchases above the maximum dollar limit established by your agency. In addition, convenience checks may not be written to:

  • Vendors who accept the GSA SmartPay Purchase card/account.
  • Vendor transactions already under another method of acquisition (purchase orders, contracts, etc.).
  • Employee reimbursements.
  • Cash advances.
  • Salary payments, cash awards or any transaction processed through the payroll system.
  • Travel-related transportation tickets.
  • Meals or lodging related to employee travel except as related to emergency incident response.
  • Other restrictions as determined by agency policy.

Checks must be used in sequential order. Each convenience check must be entered in a check register or log for tracking purposes. The following information must be written on each check:

  • Date the check is being issued.
  • The name of the payee.
  • Amount of the check.
  • An original signature.

When a convenience check is used to purchase services, the Internal Revenue Service (IRS) requires the collection of that information, so that it can be reported as income to the IRS. If a person is “engaged in a trade or business and, in the course of that trade or business, pays any person $600 or more of rent, salaries, wages, premiums, annuities, compensations, remunerations, emoluments, or other fixed or determinable gains, profits and income during a calendar year, [IRS] Code Section 6041 generally requires them to file an information return with the IRS and to furnish an information statement to the payee.”

The IRS states that agencies may rely on the merchant category code (MCC) in determining whether a transaction is subject to Form 1099 reporting. Failure to file a correct information return Form 1099 by the due date may result in a penalty imposed by the IRS.

What are Government-to-Government transactions?

Government-to-government — also referred to as “intra-governmental” — transactions are payments between government entities, including within the same agency. These transactions may be classified under Merchant Category Code 9399, Miscellaneous Government Services.

Effective October 1, 2022, the following apply:

  • The inter-governmental transaction card limit is $9,999.99, meaning no individual card transaction can exceed this limit.
  • The maximum daily limit from a single payor is $24,999.99.
  • Total monthly transactions, based on a 30 day rolling period, from a single payor can be no more than $100,000.00.

The government’s card acceptance policies can be found in Treasury Financial Manual (TFM) Vol. I, Part 5, Chapter 7000. It also addresses limitations on credit card transactions. Additionally, consider the following:

  • Customers cannot divide transactions into smaller pieces to evade these limits.
  • Treasury retains the option to change limits. One goal is to reduce the fees the government pays when it accepts the purchase card/account for large transactions.

Lesson 6: Transaction Types

What are the types of transactions when placing your order?

There are two types of transactions: card-present and card-not-present transactions.

What are card-present transactions?

Card-present transactions occur when you purchase an item in person using your GSA SmartPay® card as payment. You physically choose your item in the shop and take the item to the sales clerk, identifying it as an official government purchase.

All GSA SmartPay Purchase cards/accounts are centrally billed accounts (CBAs) and should be exempt from state taxes. However, there may be additional requirements in your state, such as a form or presenting federal government identification. Review the GSA SmartPay website for any additional state tax exemption requirements before making your purchase.

When making a card-present transaction, double check that:

  • You received an itemized receipt.
  • Sales tax was not charged.
  • You signed the receipt.
  • You safeguard the receipt for reconciling your monthly invoice statement.
  • You record the purchase in your purchase log.

Please note that all purchase documentation should be kept for your records, in accordance with agency policies and National Archives and Records Administration’s (NARA) General Records Schedule (GRS) 1.1 [PDF, 9 pages].

What are card-not-present transactions?

A card-not-present transaction takes place without a physical card. Examples include purchase by phone, fax or online.

Phone or Fax Orders

To place your order by phone or fax:

  • Contact the merchant and identify yourself as a federal government employee who is making a purchase with a GSA SmartPay Purchase card/account.
  • Indicate that the purchase will be tax exempt on a CBA.
  • Review the price of individual items as well as the total purchase price.
  • Be mindful when potentially giving out your account number. If placing an order by fax, we recommend that the fax asks for the vendor to contact the card/account holder for account information.
  • Identify the items to be purchased and reach an agreement as to the price of each item and any shipping charges.
  • Record the purchase in your purchase log.
  • Give your name and address for shipment, making sure your name appears on the mailing label and that an itemized shipping document or invoice is included in the shipment.
  • When the item arrives, make sure you have what you ordered, at the price you agreed to pay.
  • If there is any discrepancy, call the merchant immediately.
  • Keep all purchase documentation for your records, in accordance with agency policies and NARA’s GRS 1.1 [PDF, 9 pages]

Online Orders

Before placing an order online, review the merchant’s policies for placing orders and processing returns, as well as their security and privacy policies. If the website’s terms of use appear acceptable, proceed to place your order.

Please note that if the website is not government managed (such as GSA Advantage! or DoD eMall), registering your account is not recommended.

To place an online order:

  • Identify the merchant you want to use and bring up the merchant’s ordering screen.
  • Make sure the site is secure before transmitting any information. Hypertext Transfer Protocol Secure (HTTPS) is the secure version of HTTP, the protocol over which data is sent between your browser and the website that you are connected to. The “S”’ at the end of HTTPS stands for “Secure”. It means all communications between your browser and the website are encrypted.
  • Enter the requested data and indicate that you are a federal government employee and your purchase will be tax exempt.
  • Use your business address only.
  • Make sure the merchant will include an itemized shipping document or invoice with the shipment.
  • Record the purchase in your purchase log.
  • When the items arrive, make sure you are satisfied with the purchase. If not, notify the merchant immediately.
  • Keep all purchase documentation for your records, in accordance with agency policies and NARA’s GRS 1.1 [PDF, 9 pages].

Lesson 7: After Your Purchase

Is it important to obtain a copy of my sales receipt?

Yes. Obtain and save a copy of your sales receipts. You need a copy of a sales receipt in order to verify the purchase when reconciling your statement. If you misplaced the sales receipt and need a copy to verify an item on your statement, contact the merchant directly. If getting a reprinted receipt isn’t an option, contact your contractor bank to send you a copy. See the Administration section of this training to learn more about the requirements for maintaining records.

What is inspection and acceptance (receipt of supplies and services)?

Card/account holders, when possible, should use a third party to document independent inspection and acceptance of supplies and services they order or obtain in person. This simply means having another government employee sign off on the receipt or other purchase documentation verifying that the supplies/services were inspected and accepted. In some cases, such as when making an emergency purchase or when no other government employee is available, independent inspection and acceptance may be impossible. If that is the case, the card/account holder must document that independent inspection and acceptance was not possible and why.

Inspect each product to verify that it is in good condition with no visible damage or defects and the items meet the requirements of the purchase (color, size, quantity, etc.). Card/account holders should also verify that the purchase documentation (receipts, packing lists, shipping documents, etc.) matches what is provided by the merchant and that all requirements of the purchase are fulfilled. For services, verify that the work done is satisfactory. If upon inspection, all terms of the order as described above are fulfilled, the products or services may be accepted.

In the event the items purchased are defective, damaged or otherwise do not comply with the card/account holder’s order, the card/account holder shall attempt to resolve these issues as soon as possible directly with the merchant. Similarly, if services provided are not satisfactory, the card/account holder shall address deficiencies immediately and directly with the merchant and prior to payment, if possible.

What kind of accountability is there for items that I purchase?

Each year, agencies acquire billions of dollars of property with GSA SmartPay® Purchase cards/accounts. This means that the card/account holder’s responsibilities do not end when an item they purchased is inspected and accepted. The purchased item must be properly accounted for in accordance with applicable federal and agency policies and regulations.

Complying with Agency Policy

Card/account holders must be familiar with and comply with their organization’s policies regarding property management. This includes coordinating with your servicing property officer and appropriate custodians to ensure that all sensitive and otherwise accountable property is recorded in the applicable property tracking system, consistent with your agency’s policies and procedures. Card/account holders shall also familiarize themselves with agency policies for reporting property they acquired with a GSA SmartPay account that is missing, stolen or damaged after the initial receipt process.

Official Use Only

Supplies and services purchased with a GSA SmartPay Purchase card/account are for official use only. For example, an iPad purchased to view podcasts of work-related presentations and lectures should not also be used to store personal music and photos, nor should it be engraved with the user’s name. At any time, property could be taken back by the issuing activity or program and re-issued to another person within that program.

Sensitive Property

Because GSA SmartPay Purchase cards/accounts are frequently used to obtain sensitive items, an accurate property tracking system should be in place. Sensitive property includes items that are susceptible to loss, misuse or theft, such as mobile phones, laptops, monitors and printers.

Check with your agency policy on governing accountability for sensitive property as mentioned above. Card/account holders shall ensure applicable federal and agency accountability procedures are followed for property for which they are responsible. This activity includes providing information to agency/organization property officers and/or systems on items purchased, excluding consumables.

Buying For Another Government Employee

If the card/account holder is purchasing an item for another government employee, that employee is the user of that property and is therefore responsible for ensuring the proper accounting of that property. However, card/account holders should ensure they have documentation in their file demonstrating that the property acquired was delivered to another party and is no longer their responsibility.

What happens if I have to cancel an order?

If you need to cancel an order, immediately contact the merchant. Immediately contacting the merchant allows you to cancel before the item has been shipped. If the merchant has already processed the transaction, a credit should be issued. If the merchant has not processed the transaction, simply cancel the order. Special order items may include a restocking charge.

What happens if I have to return a purchase?

Return policies can vary by merchant. Merchants are responsible for establishing their own return and adjustment policies with their customers. If the return policy is unclear when making a purchase, please ask the merchant for clarification to avoid future misunderstandings. Merchants are required to disclose their return policies to the customer before the completion of a transaction.

How do card/account holders obtain the refund or replacement of defective items?

By accepting the GSA SmartPay Purchase card/account as payment, merchants agree to refund or replace any defective items. The first step is to work with the merchant on a resolution. This is usually a refund or replacement of the defective item. If the merchant refuses to issue a credit voucher, you must dispute the transaction through the issuing contractor bank.

What happens if I make a purchase that was not approved?

If it has been determined that the item cannot be returned, the government must pay for the purchase and recoup the amount of the purchase from the card/account holder. That is why it is important to fully understand what can and cannot be purchased with the GSA SmartPay Purchase card/account and ensure that your approving official is aware in advance of what you are purchasing.

Lesson 8: Disputes

What is a dispute?

A dispute is a disagreement between the card/account holder and the merchant with respect to a transaction. Disputable charges include double billings and charges to your account that belong to another account. Non-disputable charges include sales tax and shipping. You, the card/account holder, are responsible for notifying the contractor bank of any items in dispute and shall have 90 calendar days from the transaction date to initiate a dispute, unless otherwise specified by the agency/organization.

Payment of the undisputed charges must be made by the payment due date. Once you have submitted the dispute to the bank, delinquency of the disputed amount will be held in abeyance until the matter is resolved.

Please note that you relinquish your right to recover a disputed amount if you do not dispute it before 90 calendar days from the transaction date.

How should I handle questionable charges on the bill?

As a card/account holder, you are responsible for reviewing all charges on your statement. One of the first signs of fraud is at least one “mystery expense” showing up on your statement. Verify your statement by:

  • Looking for transactions or account withdrawals you do not recall making.
  • Checking for unknown vendors.

If you do notice a questionable charge, act promptly so that you will have the necessary information before payment is due.

Contact the merchant for clarification on the charge.

  • If you need help identifying the merchant, call the contractor bank’s customer service number.
  • If the charge is erroneous, generally the merchant will reverse it and it will appear as a credit on your next statement.
  • Be sure to follow up and make sure the credit was posted to your account and deduct the credited amount from your payment.
  • If the credit is not posted in a reasonable amount of time, dispute the charge with the bank.
  • If the merchant says it is a legitimate charge to your account, ask for proof, such as a signed receipt.
  • If, after receiving the additional information from the merchant, you do not agree that it is a legitimate charge, dispute the charge with the bank.

What do I do if I’ve been billed for an item, but I’ve not yet received it?

If you have been billed for an item that has not yet been delivered, you should first contact the merchant to determine if the item has been shipped. Try to resolve any issues with the merchant directly by arranging either receipt of the item or by requesting a credit. Also, double check your agency’s policy - some agencies will authorize payment of any item that has been shipped but not received.

What happens when I’ve returned an item, but it has not been credited?

If you have returned merchandise, but have not received a credit on your statement within a reasonable period of time and could not resolve the issue with the merchant, dispute the transaction.

What should I do if there are multiple billings on my statement?

If you have confirmed a double billing and could not resolve the issue with the merchant, dispute the duplicate transaction.

What should I do if I was billed for an item I did not order?

If you have been billed for an item that you never ordered, dispute the transaction.

Lesson 9: Administration

What are the requirements for maintaining my records?

Keep all necessary information on each transaction. FAR 4.805 states that agencies must prescribe procedures for the handling, storing and disposing of contract files in accordance with NARA’s GRS 1.1 [PDF,9 pages]. These procedures must take into account documents held in all types of media, including microfilm and various electronic media.

At a minimum, you must have the following information:

  • Description, unit number and quantity of the items purchased.
  • Amount of the purchase.
  • Name of the merchant.
  • Date you received the item purchased.
  • And, don’t forget to keep your receipts as mentioned previously.

Add supporting documentation to any receipts that are too general in the product description area so that it is very clear what you purchased. Your agency procedures along with NARA’s GRS 1.1 [PDF, 9 pages] will tell you how long you must keep the documentation on your purchases. For example, some agencies require you to keep all documentation on your purchases and others require you to forward your records to a central location. Failure to retain records can result in excess administrative burden when you attempt to reconcile your monthly invoice statement.

Tip: When Mary makes purchases at or above the micro-purchase threshold, she enters the contract number into the “Comments” field in the bank’s Electronic Access System (EAS) and her agency’s financial system. Taking this additional step strengthens the internal control processes and traceability of purchases.

How do I reconcile my statement?

You will receive a statement notification, either electronically or through the mail, from the contractor bank once a month for your GSA SmartPay® Purchase card/account. The statement is mailed directly to your business address unless the agency is using the bank’s Electronic Access System (EAS).

When you receive your monthly statement:

  • Identify and annotate any erroneous charges and work with the merchants and the issuing bank contractor on a resolution.
  • Review and reconcile your statement within the timeframes required by your agency (usually three to five days). Reconciling your statement includes reviewing receipts, citing proper accounting codes, documenting disputed items and completing any other documentation required by your agency.
  • Forward your statement to your AO and the appropriate payment/finance office for payment.

How do I reconcile a credit?

On occasion your statement will show a credit for a transaction that took place in a prior billing period. An example would be a credit for a returned item. When you get a credit several months after the original purchase, reconcile back to the original purchase documentation and note that the credit was received.

How do I request higher single and monthly spending limits?

After using your GSA SmartPay Purchase card/account, it is a good idea to review your single and monthly spending limits. You may discover that you need permanent higher spending limits to meet the needs of your agency. You can submit a request for either temporarily or permanently increasing your spending limits through your approving official (AO) or agency/organization program coordinator (A/OPC).

Be sure to obtain approval from your AO or A/OPC before using the purchase card/account for any purchase which exceeds your limit. If the request to increase your spending limits is approved, the A/OPC will submit it to the contractor bank.

Neither permanent nor temporary single and monthly spending limits can ever be higher than your delegation of authority.

What are my responsibilities with the Federal Procurement Data System Next Generation (FPDS-NG)?

FPDS-NG provides a comprehensive mechanism for assembling, organizing and presenting contract placement data for the federal government. In accordance with FAR 4.603(b) and FAR 4.606(a), agencies must report all transactions over the micro-purchase threshold and modifications to those transactions regardless of dollar value. The FPDS-NG website provides instructions for submitting data.

How do I report a lost/stolen card/account?

Report a lost or stolen travel account promptly to:

  • The contractor bank.
  • Your A/OPC.
  • Your supervisor.

Once a card/account has been reported as lost or stolen, the contractor bank immediately blocks that account from further usage and a new account number will be issued to the card/account holder.

Reporting the account as stolen does not relieve the card/account holder or the government of payment for any transactions that were made by the card/account holder prior to reporting it stolen. If you do not recognize a transaction appearing on your statement, you are responsible for notifying the contractor bank within 90 calendar days from the transaction date to initiate a dispute, unless otherwise specified by the agency/organization. This notification of transaction dispute may occur via the EAS, by telephone or other electronic means like email.

Please note that you relinquish your right to recover a disputed amount after 90 calendar days from the date that the transaction was processed. It is your responsibility to dispute questionable charges. If you don’t, you will be held personally liable for the amount of the questionable charge.

How do I renew my account?

Your GSA SmartPay Purchase card/account is issued for a defined period of time and will expire.

  • You do not need to initiate any action to get your account renewed.
  • You will receive your new account before your current card/account expires.
  • If you do not receive your new account, contact your A/OPC.
  • If you possess a physical GSA SmartPay charge card, destroy the expired card; it does not need to be returned.

What is an accounting code and whom do I contact if there are changes?

An accounting code is the internal number that identifies the funds to be used to pay for your purchase. When you receive your purchase card/account, your A/OPC will assign a default accounting code(s) to your account. Check with your A/OPC to understand the process for:

  • Changing offices.
  • Updating your accounting code.
  • How to cite a different accounting code if you are acquiring items for other offices or projects/organizations.

What happens if my name changes or my address changes?

Changes in information occur from time to time. Please be sure to contact the bank immediately with your new information by one of the following means:

  • Calling the toll-free contractor bank number listed on the back of your card.
  • Using the bank’s EAS.
  • Asking your A/OPC to submit the change electronically.
  • Please also make sure to notify your local post office of your address change so that your mail will be forwarded.

What is account suspension and cancellation?

Accounts may be suspended and/or canceled by the contractor banks due to non-payment. If your account is suspended or canceled due to failure of the agency to make payment, you will be unable to use the account. If you are advised by the merchant or contractor bank that your account has been suspended or canceled, contact your A/OPC immediately. The contractor bank is required to notify your A/OPC prior to suspending or canceling accounts.

Is there a chart showing when cards/accounts may be suspended/canceled?

See below:

Number Calendar DaysAccount Status/Action
46 days from the billing datePre-Suspension
61 days from the billing dateSuspension/Pre-Cancellation
126 days from the billing dateCancellation
180 days from the billing dateCharge-Off/Write-Off

Please refer to your agency policy for specific delinquency stages as they may differ.

When would my purchase card/account be transferred or closed?

The GSA SmartPay Purchase card/account must be transferred or closed when:

  • You change jobs.
  • You leave employment at the government.
  • You change agencies.
  • You are no longer required to purchase items in support of your agency’s mission.

Your agency has specific procedures on closing accounts. To close or transfer your account, notify your A/OPC. The A/OPC will contact the contractor bank to close or transfer your account.

Lesson 10: Gifts

What is a gift and what are some exclusions?

A gift is considered to be anything of monetary value. Examples include gratuities, favors, discounts, entertainment, hospitality, loan, forbearance (forgiveness of a loan), services, training, transportation, travel, meals and lodging, etc.

An employee shall not, directly or indirectly, solicit or accept a gift from a prohibited source or a gift that is offered because of the employee’s official position.

  • Direct acceptance means you, the card/account holder, accept the gift.
  • Indirect acceptance means that someone gives a gift, with your knowledge and acquiescence, to your spouse or child, a sibling or other dependent relative because of that person’s relationship to you. A gift could also be indirectly given to a charitable organization at your recommendation or designation.

Gift rules specifically exclude certain things from being classified as gifts. The gift exclusions include:

  • Modest items of food and refreshments, such as soft drinks, coffee and donuts that are offered other than as part of a meal.
  • Greeting cards and items with little intrinsic value, such as plaques, certificates and trophies, which are intended solely for presentation.
  • Loans from banks and other financial institutions on terms generally available to the public.
  • Opportunities and benefits, including favorable rates and commercial discounts, available to the public or to a class consisting of all government employees or all uniformed military personnel, whether or not restricted on the basis of geographic considerations.
  • Rewards and prizes given to competitors in contests or events, including random drawings open to the public unless the employee’s entry into the contest or event is required as part of his official duties.
  • Pensions and other benefits resulting from continued participation in an employee welfare and benefits plan maintained by a former employer.
  • Anything which is paid for by the government or secured by the government under government contract.
  • Any gift accepted by the government under specific statutory authority, including travel, subsistence and related expenses accepted by an agency under the authority of the United States Code Title 31 Section 1353 in connection with an employee’s attendance at a meeting or similar function relating to his/her official duties which takes place away from his/her duty station. The agency’s acceptance must be in accordance with the implementing regulations in the Code of Federal Regulations (specifically 41 CFR, Part 304-1).
  • Other gifts provided in-kind which have been accepted by an agency under its agency gift acceptance statute.
  • Anything for which market value is paid by the employee.

Are there circumstances when you may accept a gift from a prohibited source?

The basic gift rules are written to ensure that you do not accept gifts inappropriately. However, there are circumstances under which you may accept a gift even when it is from a prohibited source or given because of your official position.

Gift exceptions include:

  • Gifts of $20 or less.
  • Gifts based on a personal relationship.
  • Discounts and similar benefits.
  • Awards and honorary degrees.
  • Gifts based on outside business or employment relationships.
  • Gifts in connection with political activities permitted by the Hatch Act Reform Amendments [PDF, 11 pages].
  • Widely attended gatherings and other events.
  • Social invitations from persons other than prohibited sources.
  • Meals, refreshments and entertainment in foreign areas.
  • Gifts to the President and Vice President.
  • Gifts authorized by supplemental agency regulation.
  • Gifts accepted under specific statutory authority.

What are the dollar thresholds to consider when receiving a gift?

Under the $20 rule, an employee may accept an unsolicited gift of $20 or less per occasion and no more than $50 in a calendar year from one person.

If the market value of a gift offered on any single occasion exceeds $20, the employee may not pay the excess value over $20 in order to accept the gift. For example, if Tim was offered a $55 item by a prohibited source, he could not apply the $20 rule to the gift and pay the other $35 to account for the total $55.

Please note that if the aggregate value of tangible items offered on a single occasion exceeds $20, the employee may decline any distinct and separate item in order to accept those items amounting to $20 or less.

Further information regarding the ethical conduct of federal government employees can be found on the U.S. Office of Government Ethics website or refer to your agency ethics training.

Lesson 11: Misuse/Abuse and Fraud

What ethical standards apply to purchase card/account holders?

Executive branch card/account holders are subject to the Standards of Official Conduct. These standards require that:

  • Public service is a trust, requiring card/account holders to place loyalty to the Constitution, the laws and ethical principles above private gain.
  • Card/account holders shall not use public office for private gain.
  • Card/account holders shall satisfy in good faith their obligations as citizens, including all just financial obligations, especially those such as federal, state and local taxes, that are imposed by law.

What are some examples of misuse/abuse?

Misuse/abuse of the GSA SmartPay® Purchase card/account can take many different forms, but here are some of the most common examples:

Purchases Exceeding Authorized Limit

Card/account holders may be limited to and may not exceed a specific spending limit per transaction, per day or per monthly billing cycle.

No Available Funding

Federal law requires that funds must be available before any government purchase is made. It is up to the card/account holder to ensure that the funds are available prior to making any transaction.

Allowing Others to Use Card/Account

Card/account holders must take steps to ensure the security of their account. This means the purchase card/account must be used only by the card/account holder and only for official government business. If the card/account holder allows others to use the purchase card/account, the card/account holder will be held personally liable to the government for any unauthorized transactions.

Split Transactions

The Federal Acquisition Regulations (FAR) limits the dollar threshold for micro-purchases. Any purchase that, as a whole, would exceed the micro-purchase limit but is separated into smaller transactions in order to avoid the micro-purchase limit is considered to be a split transaction and is not allowable.

Products/Services Do Not Meet Requirements

Card/account holders must use discretion when making purchases to ensure that they meet the government’s requirements. Due to the wide array of products and services available, there may be occasions when card/account holders may be requested or tempted to buy luxury or deluxe versions of products and services that exceed the government’s actual requirements. For instance, it would be questionable for a card/account holder to buy a $500 designer fountain pen when there are many quality fountain pens available for $50 or less.

Purchases for Personal Consumption

All purchases must be for official government use only. Thus, any purchase made that is for the card/account holder’s personal use rather than for official government purposes is considered to be misuse. For example, a card/account holder who uses the purchase card/account to buy himself lunch because he had no cash available that day is misusing the purchase card/account.

Unauthorized Purchases

Purchases must be authorized by the agency/organization. Your agency/organization may have additional limits on the use of the purchase card/account, such as limiting certain categories or types of products or services.

What are some consequences of misuse/abuse?

Consequences for misuse/abuse may include:

  • Reprimand.
  • Purchase card/account cancellation.
  • Counseling.
  • Suspension of employment.
  • Termination of employment.
  • Criminal prosecution.

Please note that some agencies have agency-specific penalties and consequences for misuse/abuse of the purchase card/account.

What is fraud?

Fraud is a deception deliberately practiced with the motive of securing unfair or unlawful gain. Fraud can be an attempt to cheat the federal government and corrupt its agents by using GSA SmartPay payment solutions for transactions not part of official government business. Like any deception, fraud has its fair share of victims.

Some of the different types of fraud include:

Counterfeit Cards/Accounts

To make fake cards, criminals use the newest technology to “skim” information contained on magnetic stripes of cards.

Lost or Stolen Cards/Accounts

Often physical cards are stolen from a workplace, gym or unattended vehicle.

Card-Not-Present (CNP) Fraud

Internet fraud occurs whenever card/account information is stolen and used to make online purchases. Usually, a merchant will ask for the Card Verification Code (CVC) (located on the back of the card itself) to help prevent this type of fraud.


Occurs whenever a card/account holder receives a fake email directing him or her to enter sensitive personal information on a phony website. The false website enables the criminal to steal information from the card/account holder.

Non-Receipt Fraud

Occurs whenever new or replacement cards are mailed and then stolen while in transit.

Identity Theft Fraud

Whenever a criminal applies for a card/account using another person’s identity and information.

What should card/account holders know about fraud?

As a card/account holder, you must:

  • Be alert to the indicators of fraud (including false charges/transactions, mischarging, bribes, gratuities and kickbacks).
  • Report suspected fraud immediately through the proper channels at your agency (AO, A/OPC, Financial Officer, Office of the Inspector General or Office of Special Investigations).

Please note that any intentional use of the GSA SmartPay Purchase card/account for other than official government business is considered an attempt to commit fraud against the U.S. Government and may be cause for disciplinary actions. The card/account holder is held personally liable to the government for the amount of any non-government transaction. Under the United States Code Title 18 Section 287, misuse of the purchase card/account could result in fines or imprisonment or both. Military members who misuse the purchase card/account may be subject to court martial under United States Code Title 10 Section 932 - Art 132.

Lesson 12: Approving and Certifying Officials

What is an Approving Official (AO)?

Specific to the purchase programs, the AO is an individual (typically a supervisor) responsible for ensuring that the purchase card/account is used properly by the agency. The AO also authorizes card/account holder purchases (for official use only) and ensures that the statements are reconciled and submitted to the Designated Billing Office (DBO) in a timely manner.

What is my role as an AO?

There are many important responsibilities entrusted to the AO, including:

  • Ensuring that all purchases made by the card/account holder(s) within his/her span of control are appropriate and the charges are accurate. Purchases should not only be legal and proper, but also should be considered “mission essential”. In order to ensure proper purchases, the AO must review and approve card/account holder statements belonging to all card/account holders within their purview. The AO’s review should include looking at all required receipts and card/account holder logs.
  • Counseling card/account holders within his/her span of control regarding regulations, misuse and delinquency.
  • Resolving all questionable purchases with the card/account holder. Upon review of receipts and account-holder logs, if the AO finds a questionable purchase, they must work with the card/account holder to receive more information regarding the purchase in order to determine the legitimacy of the purchase.
  • Elevating unresolved, questionable purchases to the agency/organization program coordinator (A/OPC). In the event an unauthorized purchase is detected or there is a purchase that is still in question after review of supporting card/account holder documentation, the AO must notify the A/OPC as well as any other appropriate personnel in accordance with agency policy. This may include notifying the agency’s Office of the Inspector General (OIG) for further investigation relating to potential misuse.
  • Ensuring monthly billing account accuracy. The AO signs the account statement and maintains documentation regarding the account in accordance with agency procedures.
  • Conducting informal compliance reviews for all card/account holders under their span of control. These reviews should be completed in accordance with the agency-specific policies (e.g., frequency, format).
  • Assisting A/OPCs and card/account holders with their responsibility to obtain, maintain and retain complete documentation of all purchases.

Many agencies may provide additional responsibilities for the AO within their agency’s policies. It is important that the AO reviews the agency-specific policies before beginning their official duties.

Please note that AOs may be held financially responsible for payments made on accounts because of failure to ensure billing account accuracy. It is also important that the AO reviews the agency-specific policy regarding reimbursement and disciplinary actions.

What is a Certifying Official?

A Certifying Official is an individual who has been charged with the responsibility of authorizing certified vouchers for payment and ensuring that funds are available for obligation before payment. The Certifying Official is held accountable for verifying that payments made by the federal government are legal, proper and correct.

Please note that the OMB Circular A-123, Appendix B [PDF, 71 pages] and the GSA SmartPay® Master Contract language use the terms AO and Certifying Official synonymously. In the case of many agencies/organizations, the individual that holds the title of AO also holds the title of Certifying Official. However, the roles of AO and Certifying Official may be separate functions in some agencies/organizations.

What is my role as a Certifying Official?

United States Code Title 31 Section 3528 states the roles and responsibilities of a Certifying Official.

Certifying Officials are responsible for:

  • Information stated in the certificate, voucher and supporting records.
  • Computation of the certified voucher.
  • The legality of the proposed payment under the appropriation or fund involved in the payment. In other words, the Certifying Official must make sure that the line of accounting that is utilized to pay the voucher aligns with the type of items purchased.
  • Repaying a payment if the payment was certified and was illegal, improper or incorrect due to negligence on the part of the Certifying Official or was not paid out of the correct appropriation due to negligence on the part of the Certifying Official.

In the case of the purchase program, the Certifying Official will most often rely on other members of the Government Purchase Team (such as the card/account holder and the AO) to review the supporting records. However, the Certifying Official still has a responsibility to assess the accuracy of the data while performing the certification process and to report suspect transactions to the A/OPC and appropriate investigative office.

Many agencies may provide additional responsibilities for the Certifying Official within their agency’s policies. It is important that the Certifying Official reviews the agency-specific policies before beginning their official duties.

Lesson 13: Resources


  • 800-790-7206 (within United States)
  • 904-954-7850 (collect calls from outside United States)
  • Citibank Online Account Access (self register, commercial site).

U.S. Bank

  • 888-994-6722 (within United States)
    Note: To speak with a live person, do not press any buttons.
  • 701-461-2232 (collect calls from outside United States)
  • U.S. Bank Online Account Access (self register, commercial site).

Where am I able to access the GSA SmartPay® Master Contract?

The terms and conditions of the Master Contract identify specific contractual requirements that the GSA SmartPay program has with the contracting banks.

The GSA SmartPay Master Contract can be viewed on the GSA SmartPay website. Download a copy and review relevant clauses and sections that pertain to the GSA SmartPay Purchase program, as well as to the GSA SmartPay program in general.

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