(a) Purpose of Policy. The purpose of this policy is to ensure that credit/debit/purchasing cards (hereinafter, "credit cards") that are issued to and held in the name of the Village are closely controlled and monitored so as to provide for maximum security and to guard against misuse and/or losses for which the Village may be held liable. This policy is meant to comply with the mandates of Sub HB 312 enacted by the 132nd General Assembly. Village use includes situations where a purchase order is not accepted by the provider for needed services, supplies and/or materials, or are purchased from a provider who issues a purchase card to be used in conjunction with a purchase order. There may also be instances where discounts and/or rebates that are deemed to be advantageous to the Village are associated with this type of payment. The Village-held credit cards (sometimes referred to as "card(s)") are NOT for personal use, and will not be permitted to be carried by personnel on a regular basis for any reason.
(1) General Guidelines.
A. The Mayor shall designate a Village employee to serve as the "Credit Card Compliance Officer" (hereinafter referred to as "Compliance Officer") for the purpose of review and enforcement of this policy. The Law Director shall assist the Compliance Officer.
B. All credit/debit/purchasing cards shall first be obtained by the Finance Director and placed under the control of the Compliance Officer. The Compliance Officer shall require each card to be signed out and signed in by the designated card user specifying the dates and reason for use of the card. Designated card user will be assigned in writing and kept on file by the compliance officer and updated annually.
C. When using the card, the card user shall comply with the Village purchase order policy and procedures. Prior to the use of any card for making any Village related purchase, a valid purchase order must be assigned or the purchase may be deemed to be illegal. The purchase order must contain the full identity of the vendor and provide descriptions, account numbers and estimated dollar amounts of the products purchased. No single vendor purchase shall exceed a spending limit of five thousand dollars and no cents ($5,000.00) without the express written consent of the Mayor or his/her designee. This is required to assure that sufficient appropriations exist to cover the anticipated charges. Once an invoice is received, the card user must return a copy of the P.O. along with the receipts accumulated directly to the Finance Director, to complete the transaction.
(2) Finance Director Responsibilities. The Finance Director is authorized to apply for and establish one or more credit card accounts as he/she deems necessary for the conduct and benefit of Village business. Only designated Village employees and/or Village Elected Officials are eligible to have custody and authorization to use a Village credit card.
A. Opening Accounts/Cancellation. All credit cards will be obtained by the Finance Director subject to written authorization by the Mayor or his/her designee. In the event that a credit card has not been used during any previous twelve (12) month period, the Finance Director, after consulting with the Mayor, Compliance Officer shall determine if the card and/or account should be cancelled.
(3) Compliance Officer Responsibilities.
A. Issuing Credit Cards to Authorized Card Users. Designated credit card users will be assigned in writing and kept on file by the compliance officer. This list shall be updated annually. The Compliance Officer shall issue credit card(s) only to designated credit card users. He/she shall require each designated credit card user to sign an acknowledgement that they have read and understood this policy and the Village purchasing policy and ethics policy prior to issuance of the card. The credit card shall be signed out and signed in by the designated card user specifying the dates and reason for use of the card.
B. Retrieving cards from employees. The Compliance Officer shall retrieve any credit card issued to any employee and/or Elected Official, including those who leave employment with the Village.
C. Overseeing appropriate use of the card. Compliance Officer is required to:
1. Review the all credit card transactions and management reports to ensure that the cards are being used appropriately.
2. Ensure all transactions are marked "Viewed" and "Approved" in the system prior to mapping into the General Ledger.
3. Report lost and stolen cards immediately to the Finance Director for reporting to appropriate card companies.
4. Ensure necessary details and documentation are provided on all transactions.
5. Ensure that itemized receipts and card statements are retained and kept in accordance with the Village's Records Retention Schedule.
(4) Reporting and Reviewing Requirements.
A. The Finance Director, annually, shall file a report to the Mayor and/or Village Council detailing all rewards received based on the use of the Village's credit card accounts. To the extent permissible by the entity issuing the credit card, said rewards shall be reduced to cash and the funds placed in the Village General Fund.
B. The Compliance Officer, at least quarterly, shall review the number of cards and accounts issued, the number of active cards and accounts issued, the cards' and accounts' expiration dates, and the cards' and accounts' credit limits and provide a report to the Finance Director.
(5) Rules and Procedures for Use.
A. A credit card obtained by the Village and provided to a Village employee and/or Elected Official is for Village business expenses only. It shall not be used for personal purchases.
B. The card is not transferable. It may be used by the authorized Village employee and /or Elected Official cardholders/card users only.
C. Itemized receipts must be obtained for all transactions.
D. Pyramiding - i.e., dividing one purchase into two or more, in order to stay within your transaction limit - is not allowed.
E. Authorized Village employee and/or Elected Official cardholders may not receive cash advances.
F. Authorized Village employee and/or Elected Official cardholders are responsible for resolving discrepancies and ensuring credits are received.
G. Authorized Village employee and/or Elected Official cardholders may not receive cash back or in-store credits for any refunds or exchanges. Such amounts must be credited to the credit card account. If a supplier mistakenly issues a refund check, it must be submitted to the Compliance Officer within five days of receipt by the cardholder.
H. Authorized Village employee and/or Elected Official cardholders should not pay Ohio sales tax. The cardholder must tell in-state suppliers the Village is exempt from Ohio sales tax. A copy of the Village's Tax Exempt Certificate is available if the supplier needs to see it and can be obtained from the Finance Director.
I. If grant funds are being charged, Authorized Village employee and/or Elected Official cardholders are responsible for seeing that all granting agency regulations and requirements are fulfilled.
J. Authorized Village employee and/or Elected Official cardholders may not make purchases that violate Village policy restricting business transactions that may be perceived as a conflict of interest (purchases from a business in which you or a relative have a financial interest).
(6) Documentation Requirements. Authorized card user should always obtain an itemized receipt for each transaction. If a cash register tape does not have descriptions, write them on the tape. Any transaction without a properly substantiated receipt is subject to reimbursement to the Village by the card user.
A receipt is defined as an invoice, cash register receipt, sales slip, or packing slip which contains an itemized list of goods purchased, with dollar amounts, and the name and location of the supplier. An employee of the supplier must sign handwritten receipts.
A. Purchases Made in Person. Retain the itemized receipt in addition to the credit card copy to properly substantiate the purchase.
B. Faxed or Mailed Purchases. Retain a copy of the order as faxed or mailed and the fax confirmation (if available) for your records.
C. Internet Purchases. At least one of the following types of documentation is required:
1. Print-out of the completed online order form;
2. Print-out of the online order confirmation; or
3. Print-out of the e-mail confirmation.
The user must immediately advise the Compliance Officer if a card is damaged, lost, stolen or the subject of suspected fraudulent activity.
(7) Preventing Fraud. The cardholder should use basic security measures, as outlined below, to guard against fraud:
A. DO Keep the card in a secure location; guard the card number carefully.
B. DO Save receipts and statements in a secure area (they may contain your card number).
C. DO Keep an eye on the card during the transaction, and retrieve it as soon as possible.
D. DO Always know where your card is. If you can't find the card, assume the worst: Notify Budget and Finance so that the account can be canceled.
E. DO Be aware of what you are signing: Your signature can copy through to other slips deliberately placed underneath.
F. DO Audit your monthly statement closely. Make sure all charges shown are legitimate charges.
G. DO Visit reputable, familiar merchants whenever possible.
H. DO Report possible fraud immediately.
I. DO NOT Discard credit card slips in public areas, or discard them whole. Thieves can acquire your card number from receipts, slips and statements.
J. DO NOT Lend your card to anyone.
K. DO NOT Give your card number to anyone over the phone unless you know you are dealing with a reputable vendor.
(8) Personal Liability; Unauthorized Purchases. The Card user is or may be liable, in person, and upon any official bond the card user has given to the Village, to reimburse the Village the amount for which the card user does not provide itemized receipts in accordance with this policy or for any use of the credit card that is deemed improper or in violation of this policy.
Below is a list of actions or omissions that qualify as "misuse" of the Village credit card. Village credit card accounts may not be used to purchase the following items:
A. Personal items
B. Alcohol and entertainment
C. Controlled substances requiring a DEA license
D. Employee relocation and relocation-related expenses
E. Purchases that involve signing an agreement, license, or contract (e.g., leases).
F. Long term rentals (1 year or longer).
G. Contracted or personal service providers - specific to unincorporated 1099 service providers (e.g., photographic studios, dry cleaners, physicians, medical labs, auto towing or repair, etc.).
H. Donations
I. Fuel for a privately-owned vehicle or aircraft
(9) Inappropriate Use of Cards.
A. Employees and/or Elected Official using Village-held cards are responsible for safeguarding the card. If inappropriate use of the card is discovered, disciplinary action up to and including discharge from employment is possible. In the event of fraudulent use, the Village may pursue legal prosecution.
B. Improper costs associated with prohibited purchases will be collected by requesting the employee and/or Elected Official voluntarily repay the Village, by the employee and/or Elected Officials voluntarily agreeing to a payroll deduction or by any legal action available to the Village.
C. Upon the first notice of suspected credit card abuse, the Compliance Officer should advise the Mayor and consult with the Law Director. The Compliance Officer and Law Director will initiate and coordinate an investigation of the suspected card abuse. The employee and/or Elected Official shall be given an opportunity to respond to the allegations being investigated.
(10) Employee and/or Elected Official Acknowledgment. All employees and/or Elected Officials permitted and assigned to use a credit card pursuant to this policy shall sign an Employee Acknowledgement in the same form as attached to original Ordinance 2020-47.
(Ord. 2020-47. Passed 7-15-20.)