P-Card Transparency with OMB A-123 Appendix B

Published January 25, 2023

Transparency is the third topic in our 3-part series highlighting guidelines for Accountability, Compliance, and Transparency as contained in OMB Circular A-123 Appendix B, a Risk Management Framework for Government Charge Card Programs.

Transparency in any government P-Card Program can be measured on the ease with which data can be visualized, analyzed, and audited. Typical manual processes for P-Card Management fall short when compared to the guidelines in Chapter 5 of the OMB Circular A-123 Appendix B, which defines this data as “performance metrics”. Agencies are required to report three types of P-Card Program data: statistical reports, narrative reports, and reports on violations. Automations of data capture, feature rich reporting, and data visualization dashboards in currently available COTS SaaS applications enable P-Card Administrators to maintain the required transparency in reporting by enabling instant data retrieval.

Access to Data

Although statistical reports are no longer required to be submitted to OMB, all agencies are required to maintain statistical information for internal use and management of their charge card program. OMB memorandum M-17-26 requires agencies to consolidate their reporting requirements in a central location, GSA’s Center for Charge Card Management (CCCM). An agency’s ability to route appropriate statistical information to CCCM is dependent on its ability to gather the data. Examples of reports that must be manually generated in current Programs include ratio of approving officials to purchase cardholders and number of purchase cards with transaction limits over the micro-purchase threshold. Commercially available solutions for P-Card Program Compliance Automation enable instant access to statistical data for continuous monitoring and CCCM reporting.

Annual Reports

Memorandum M-17-26 reduced burden for federal agencies by discontinuing the requirement for narrative reporting to OMB. However, it requires that agencies maintain this information for their own use and for management of the P-Card Program. Agencies must report annually to the CCCM descriptions of their current process for monitoring delinquency, descriptions of any best practices in purchase card management, progress reports on agency integration of the GSA SmartPay e-payable payment processes, and other information such as increased revenue generated by using P-Card for payments, innovations to streamline business operations, and new creative internal controls systems. FedRAMP secure federal solutions for P-Card Program Compliance Automation enable agencies to report innovation, operational streamlining, and increased revenue generation through gains in card acceptance and usage.

P-Card Abuse

As outlined in the Government Charge Card Abuse Prevention Act of 2012, Executive agencies with more than $10M in annual purchase card spend must submit a joint agency and IG report to the OMB outlining any violations and identify internal control deficiencies. Commercial solutions for P-Card Program Compliance Automation enable agencies to prevent even accidental violations by using Robotic Process Automations (RPA) to enforce internal controls like Separation of Duties, proper approvals and documentation, and prevention of fraud, waste, and abuse. Agencies can leverage the solution to submit joint reports showing zero card violations.

Actus, a proven and agile SaaS solution for Purchase Card Program Automation and Management, is available in the FedRAMP Marketplace for agencies concerned about transparency and reporting.