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This brief provides a summary of reports required by Public Law 112-194, including agency assurance statements, charge card management plans, audit recommendation implementations, joint purchase card violations reports, statistical reports, narrative reports, and IG risk assessments. Key due dates are highlighted, along with references to relevant laws and guidelines.
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Public Law 112-194Government Charge Card Abuse Prevention Act of 2012 (Charge Card Act)REPORTS December 2013
Purpose and Objectives • The purpose of this brief is to provide a quick summary of reports required by Public Law 112-194 • The objectives are to • inform agencies on report due dates • provide links and references for report preparation
Agency Assurance Statement • Public Law 112-194 requires agencies to verify charge card internal controls as part of their annual assurance statement reviews • Federal Managers’ Financial Integrity Act of 1982 (31 U.S.C. 3512(d)(2)) each agency shall provide an annual certification that the appropriate policies and controls are in place or that corrective actions have been taken to mitigate the risk of fraud and inappropriate charge card practices • No new statement is needed • PARs /AFRs are normally due on November 15; however due to the October 2013 Government-wide shutdown, the date has been adjusted to December 16, 2013
Charge Card Management Plan • Report requirements and content guidelines are found in OMB Circular A-123, Appendix B – Chapter 2.3 • For all agencies, the Charge Card Management Plan is due Annually on January 31 via the OMB Max Portal https://max.omb.gov/community/x/LgISCQ
IG Report on Audit Recommendation Implementation • The IG Report required by Public Law 112-194 will document agency implementation of purchase and travel card audit recommendations, or indicate no audit was conducted via a cover sheet memo • Due Annually via the OMB Max Portal on January 31 https://max.omb.gov/community/x/LgISCQ
Joint Purchase Card Violations Report • Required for agencies with $10M or more in annual purchase card (integrated—purchase business line only) spend • Previous FY is used to determine $10M spend threshold • Report is a joint effort between IG, A/OPC, and HR • Report template: https://smartpay.gsa.gov/about-gsa-smartpay/policies/OMB-M-13-21/Violations-Report • Submitted via the OMB Max Portal on a Semi-Annual basis • January 31 • July 31 • https://max.omb.gov/community/x/LgISCQ
Statistical Report • Statistical Report requirements are found in OMB Circular A-123, Appendix B – Chapter 5.3.1 • CFO Act Agencies submit to OMB Quarterly • Q1 – January 31 • Q2 – April 30 • Q3 – July 31 • Q4 – October 31 • Non CFO Act Agencies – due to OMB Annually • For previous fiscal year – January 31 • All reports are submitted via the OMB Max Portal • https://max.omb.gov/community/x/LgISCQ
Narrative Report • Narrative Report requirements and content are found in OMB Circular A-123, Appendix B – Chapter 5.3.2 • For all agencies this report is now due annually on January 31 via the OMB Max Portal https://max.omb.gov/community/x/LgISCQ
IG Risk Assessment(s) • Public Law 112-194 requires agency IGs to conduct periodic (annual) risk assessments on purchase cards • IGs will use these risk assessments to determine the necessary scope, frequency, and number of IG audits or reviews of these programs • Risk assessments are provided to the head of the executive agency • IGs will report to the Director of OMB 120 days after the end of each fiscal year on agency progress in implementing audit recommendations, beginning with fiscal year 2013 submission due by January 31, 2014
Quick Synopsis of Report Dates • November 15 (December 16, 2013 exception for FY 13) • Annual Agency Assurance Statement • January 31 • Charge Card Management Plan • IG Report on Audit Implementations (Purchase & travel) • Summary Joint Purchase Card Violations Report • Statistical Report • Narrative Report • April 30 • Statistical Report (CFO Act Agencies Only) • July 31 • Summary Joint Purchase Card Violations Report • Statistical Report (CFO Act Agencies Only) • October 31 • Statistical Report (CFO Act Agencies Only) • IG Risk Assessments to Agency Heads • Purchase Cards (Annually) • Travel Cards (Annually for > $10m)
References Public Law 112-194 • http://www.gpo.gov/fdsys/pkg/PLAW-112publ194/pdf/PLAW-112publ194.pdf OMB Circular A-123, Appendix B • http://www.whitehouse.gov/sites/default/files/omb/assets/agencyinformation_circulars_pdf/a123_appendix_b.pdf OMB M-13-21 • http://www.whitehouse.gov/sites/default/files/omb/memoranda/2013/m-13-21.pdf OMB Max Portal • https://max.omb.gov/maxportal/home.do • Click the green “Register Now” button on the top right side of the screen for new registrations • Report submissions are on page: https://max.omb.gov/community/x/LgISCQ GSA Implementation Tools • https://smartpay.gsa.gov/about-gsa-smartpay/policies/OMB-M-13-21 • https://smartpay.gsa.gov/about-gsa-smartpay/policies/OMB-M-13-21/FAQs