PC 13: Violations

Procedures and consequences for PCard vilolations

PCA reviews and documents violations of PCard Procedures. PCA has the authority to deactivate a card through the review process. Violations may be reported to the RD’s Executive Team Member, the Director of Human Resources, or the Board. The decision of the Director of Procurement is final.

PC 13.1 - Procedures

PCA will notify cardholders of any transaction(s) under review and “cc” the RD’s director and coordinator. Cardholders are given the opportunity to respond to additional information for consideration within five (5) business days.

After the five (5) business day period, PCA either finalizes a Violation Report and distributes it as outlined in the paragraph above or submits a notification that the provided information satisfactorily explains the transaction and rescinds the notice of pending inquiry.

PC 13.2 - Punitive Actions

Violations may result in any one or more of the following punitive actions:

30-Day PCard suspension
Three (3) month PCard suspension and refresher training
Six (6) month PCard suspension and refresher training
Canceled PCard
Revoked PCard
Other disciplines in accordance with County Administrator Procedures Manual, including but not limited to employee counseling and progressive discipline.

PC 13.3 - Additional Impositions Due to Violations

Cardholder may be required to:

Obtain a credit from the vendor
Reimburse the County for non-approved purchase(s). Such reimbursed purchases would then become the employee’s property.
Be subject to legal action by the County

PC 13.4 - Punitive Actions by Violation Type

Issue	Violation Types	Adverse Action
A	Purchase should have been made using a BPA⁴or CPA	Warning
B	Declined transaction from an attempted personal purchase	Warning
C	Failure to notify PCA within one (1) business day of discovering a card account has fraudulent activity or has been lost or stolen.	Warning
D	No pre-approval obtained when required by an AD.	Warning
E	Purchase with a Vendor using Square Technology or third-party billing Vendor setup in an individual’s name, not the Vendor’s name.	Warning
F	Transaction processed through another Vendor’s merchant account (excluding third- party billing Vendors like Pay Pal)	Warning and vendor credit
G	Third-party billing vendor fee (e.g., Pay Pal)	Warning and vendor credit or reimbursement
H	A third (3rd) warning for any violation type	Six (6) month suspension and refresher training
I	A fourth (4th) warning for any violation type	Card Canceled

Issue & Violation Frequency	Violation Types	Adverse Actions
J - 1st violation	Used PCard to pay a receipt/invoice dated outside the parameters in sections PC 7.3 and PC 7.4 of this chapter.	Three (3) month suspension and refresher training
J - 2nd violation	Used PCard to pay a receipt/invoice dated outside the parameters in sections PC 7.3 and PC 7.4 of this chapter.	Six (6) month suspension and refresher training
J - 3rd violation	Used PCard to pay a receipt/invoice dated outside the parameters in sections PC 7.3 and PC 7.4 of this chapter.	Card Canceled
K - 1st violation	A billing issue unresolved within 60 calendar days after the date of the OnBase flagged transaction notification.	Three (3) month suspension and refresher training
K - 2nd violation	A billing issue unresolved within 60 calendar days after the date of the OnBase flagged transaction notification.	Six (6) month suspension and refresher training
K - 3rd violation	A billing issue unresolved within 60 calendar days after the date of the OnBase flagged transaction notification.	Card Canceled
L - 1st violation	Personal Purchase - When credit is processed, or reimbursement is submitted within two (2) business day of purchase date.	Three (3) month suspension and refresher training
L - 2nd violation	Personal Purchase - When credit is processed, or reimbursement is submitted within two (2) business day of purchase date.	Six (6) month suspension and refresher training
L - 3rd violation	Personal Purchase - When credit is processed, or reimbursement is submitted within two (2) business day of purchase date.	Card Canceled
M - 1st violation	Personal Purchase - When not resolved as stated in “L” of this chart.	Six (6) month suspension, credit or reimbursement and refresher training
M - 2nd violation	Personal Purchase - When not resolved as stated in “L” of this chart.	Card Canceled
N - 1st violation	Use of PCard by someone other than the named person embossed on the card.	Six (6) month suspension, credit or reimbursement and refresher training
N - 2nd violation	Use of PCard by someone other than the named person embossed on the card.	Card Canceled
O - 1st violation	Split Purchase⁶	Card Canceled
P - 1st violation	Unauthorized Purchase - A purchase that does not relate to the mission of the Requesting Department or serve a public purpose.	Three (3) month suspension and refresher training
P - 2nd violation	Unauthorized Purchase - A purchase that does not relate to the mission of the Requesting Department or serve a public purpose.	Six (6) month suspension and refresher training
P - 3rd violation	Unauthorized Purchase - A purchase that does not relate to the mission of the Requesting Department or serve a public purpose.	Card Canceled
Q - 1st violation	Card account reported lost/stolen/fraud for the third time.	Card Canceled
R - 1st violation	Personal expenses charged in connection with lodging accommodations not settled within 10 business days following completion of travel.⁸	Three (3) month suspension and refresher training
R - 2nd violation	Personal expenses charged in connection with lodging accommodations not settled within 10 business days following completion of travel.⁸	Six (6) month suspension and refresher training
R - 3rd violation	Personal expenses charged in connection with lodging accommodations not settled within 10 business days following completion of travel.⁸	Card Canceled
S - 1st violation	Any violation after card account issued with an approved Reconsideration Request	Card Revoked
T - Violation frequence varies	Other Violations	Adjudication will depend on the degree of the violation

PC 13.5 - Noncompliance of Adverse Actions

If the cardholder does not comply with defined adverse actions by the end of their suspension period, the card will be automatically suspended for an additional three (3) months. If after the additional period, the cardholder still does not comply with defined adverse actions the card will be canceled.

PC 13.6 - Card Reconsideration Request Process

The RD initiates a Card Reconsideration request⁹ by completing a New OnBase eForm and submitting a memorandum from the RD director with all supporting details to PCardadmin@HCFL.gov. The Director of Procurement reviews the request, approving or denying it. If approved, PCA processes the request, and the cardholder receives their PCard after completing PCard Training. If denied, PCA notifies the RD director. The Director of Procurement's decision is final.

If an approved reconsideration request results in any subsequent violation, the card will be permanently revoked.

PC Notes

Suspension: A card’s spend profile is changed to zero for a defined period less than one (1) year.
Canceled: The card will be close for a minimum of one (1) year.
Revoke: The card is permanently closed.
Business Purchase Agreement
Cardholder must provide a copy of the credit memo or reimbursement receipt to PCA.
Split Purchase: Occurs when two or more transactions are deliberately divided between the same vendor to misrepresent the total value of a single purchase. This practice is used to circumvent competitive solicitation requirements, spending thresholds, or other procurement policies. Split purchases may involve one or multiple cardholders intentionally breaking up a purchase to remain within single transaction limits or avoid triggering formal procurement processes.
As stated in AD #AD-09
The Card Reconsideration Request is for a reinstatement of a PCard that has been canceled.