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Purchasing Card (P-Card) Internal Controls Checklist
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Helps a finance or internal audit function evaluate purchasing-card program controls including issuance, limits, transaction review, and prohibited uses.
GFOA Best Practices2 CFR 200.302GAO Green Book
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Program Governance
- Is there an adopted p-card policy defining eligibility, limits, and responsibilities? *
- Has each cardholder signed a cardholder agreement acknowledging the rules? *
- Is a program administrator designated to manage issuance and terminations? *
Card Issuance & Limits
- Are single-transaction and monthly credit limits set appropriate to the cardholder's role? *
- Are merchant category code (MCC) restrictions applied to block prohibited categories? *
- Are cards promptly cancelled upon employee separation or role change? *
Transaction Review & Approval
- Is each transaction supported by an itemized receipt? *
- Does a supervisor independent of the cardholder review and approve statements? *
- Are split purchases (to evade single-transaction limits) monitored and flagged? *
- Is sales/use tax exemption applied where the entity is exempt? *
Prohibited Uses & Monitoring
- Are personal purchases, cash advances, and gift cards prohibited and monitored? *
- Are exception/analytics reports run to detect misuse and unusual patterns? *
- Is a rebate/refund program reconciled and periodic audits conducted? *
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