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Internal Audit & Compliance


Frequently Asked Questions

Print friendly Modified July 9, 2009

Purchasing Cards

Q. I was recently issued a Purchasing Card for use in my job. Are there any restrictions on how the Purchasing Card can be used?
A. Use of a Purchasing Card is strictly regulated by state law, Department of Administrative Services (DOAS) regulations, the USG Business Procedures Manual (BPM), and by your institution’s policies. Failure to comply with the respective laws, rules, and regulations can subject violators to loss of employment, financial penalties, and criminal prosecution. See the USG BPM Section 3.3 for detailed guidance on Purchasing Cards to include references to state law and DOAS rules.
Q. I don’t have a Purchasing Card but one of my employees does use a Purchasing Card. As a supervisor of a cardholder, am I liable for that cardholder’s actions?
A. State law does provide for supervisor liability. The following is excerpted from the Official Code of Georgia Annotated 50-5-83 (d): An employee’s supervisor who knowingly intentionally, willfully, wantonly, or recklessly allows or who conspires with an employee who is issued a purchasing card to violate subsection (c) of this Code section shall be subject to immediate termination of employment and criminal prosecution. Any person violating this subsection shall be guilty of a misdemeanor of a high and aggravated nature if the value of the items improperly purchased or retained is less than $500.00 in the aggregate and shall be guilty of a felony if the value of the items improperly purchased or retained is $500.00 or more in the aggregate and, upon conviction of such felony, shall be sentenced to not less than one nor more than 20 years imprisonment, a fine not to exceed $50,000.00, or both.

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Food & Travel

Q. I recently travelled out of state on official business. I ate all of my meals in the other state with the exception of lunch on my return trip to Georgia. I ate lunch in Georgia. What per diem amount should I claim?
A. You should claim the per diem amount for which you were eligible by location at the time you consumed, or would have consumed, your meal. In this instance, you would claim the federal per diem rate for your out of state meals. However, you would revert to the normal state of Georgia rate for your lunch meal.
Q. I do not always eat three meals a day when on travel status or sometimes I am provided a complimentary breakfast at my hotel. Do I still claim per diem for those meals that I skipped or when I was provided a breakfast by the hotel?
A. Employees are eligible for a per diem payment based on the meals for which they were eligible. This is determined largely by when the employee started from and returned from travel. You may skip a meal and still receive a per diem for that meal. You also are still eligible to claim per diem for breakfast if you stay at a hotel that provides a complimentary breakfast. However, you may not claim per diem for a meal that has already been paid for using state funds, e.g., a meal paid through a conference registration fee. See USG BPM Section 4.3 for additional guidance on per diem payments.
Q. As a USG employee, are there ever any instances when I can be reimbursed for food or eat food that has been purchased with state funds?
A. USG employees in a travel status are governed by USG BPM Section 4.0. However, there are instances when an employee not in travel status may incur a reimbursable expense for a meal purchase or may be allowed to participate in a meal that has been paid for with state funds. Generally speaking, these “instances” apply to situations where the employee is required by the nature of their job to participate in a meal. An example includes an advisor to a student group who is expected to participate in the student group meeting that takes place over lunch. The students will often purchase pizza or sandwiches for the meeting using student fees. It is permissible for the advisor in this instance to partake of the food that has been purchased. However, employees should refer to the USG BPM Sections 19.7 and 19.8 for detailed guidance on specific situations.

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Federal Grants

Q. Some of my salary is paid with a federal grant. Does this place any additional reporting requirements on me or my institution?

A. The use of any federal funds by the institution subjects both the employee and the institution to multiple regulations, reporting requirements, etc. Please see Office of Management & Budget (OMB) Circular A-21 for a detailed set of guidelines.

Employees should take particular note of what is traditionally termed “Effort Reporting” guidelines. Effort Reporting requires periodic certification by the employee or an individual with knowledge of the employee’s schedule to certify as to the percent of effort expended on behalf of the federally funded activity. Without detailing every nuance of this regulation, it should be noted that the percentage of effort refers to the total effort by that employee. For example, an employee who spend 20 hours a week on grant activities and 30 hours a week on institutional activities is expending 40% of their time on behalf of the grant as opposed to 50% of their time. This also means that the grant should be funding roughly 40% of the employee’s personnel costs. Note that Federal auditors will particularly question employees who reflect 100% of their effort in support of grant-funded activities. Serious penalties may be imposed for falsely certifying an effort report. Both the institution and the certifier may be charged with violations of criminal law resulting in serious financial penalties and potential incarceration.

Please submit your own recommendations for a FAQ by emailing the USG Compliance Program at john.fuchko@usg.edu.

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