Frequently Asked Questions

Question: What is an electronic part?

Answer: An integrated circuit, a discrete electronic component (including, but not limited to, a transistor, capacitor, resistor, or diode), or a circuit assembly. The term “electronic part” includes any embedded software or firmware.

Question: What is an electronic counterfeit part?

Answer: A counterfeit electronic part is an unlawful or unauthorized reproduction, substitution, or alteration that has been knowingly mismarked, misidentified, or otherwise misrepresented to be an authentic, unmodified electronic part from the original manufacturer. The United States (U.S.) Congress has directed that the Department of Defense (DoD) take specific actions to “prevent, detect, investigate, and remediate counterfeiting in the DoD supply chain.”

Question: How does this policy pertain to GIT?

Answer: DoD contracts that are subject to DFARS 252.246-7007 are required to develop and execute a counterfeit parts policy in order to prevent counterfeit parts from entering the government supply chain. This policy describes the set of controls designed to eliminate or mitigate the risk of utilizing counterfeit electronic components in GIT’s delivered hardware.

Question: To whom does this policy apply?

Answer: The Counterfeit Electronic Part Detection and Avoidance Policy applies to all GIT Personnel who purchase or specify the purchase of electronic components for use in DoD delivered hardware on contracts that are subject to DFARS 252.246-7007.

This process applies to electronic components utilized by, or incorporated into, the fabrication, assembly, or test of prototype hardware that is to be provided for evaluation or service to U.S. Government sponsors. This process is also provided as a recommended practice for all programs. This includes electronic assemblies or subsystems that are designed and built to project requirements by third party original design manufacturers (ODMs), as well as hardware that is designed by GIT but then outsourced to a contract manufacturer (CM) for assembly.

Excluded from these requirements are electronic components procured for use in equipment intended for internal purposes (e.g. research, development, problem resolution, testing theories, trying new ideas, etc.), and which are not planned to be provided to sponsors. However, GIT still encourages the procurement of parts through approved venders as identified in this policy.

Also excluded are unmodified commercial off-the-shelf (COTS) assemblies or subsystems, procured from original equipment manufacturers (OEMs), unless otherwise specified in the project plan or mission assurance plan.

Question: Who is responsible for the implementation of this policy?

Answer: Implementation is the responsibility of any individual or organization, internal or external to GIT, which is involved in sourcing such parts in support of program hardware provided to U.S. Government sponsors.

Question: What types of counterfeits are there?

Answer: Counterfeit parts may consist of recycled, remarked, overproduced, out-of-specification/defective, cloned, received forged documentation, cloned, or tampered parts.

Question: Are parts other than electronic parts to be covered by this policy?

Answer: This policy currently addresses only counterfeit electronic parts. As future DFARS pronouncements expand the scope of the required Counterfeit Detection and Avoidance System (CDAS) to additional parts categories, the scope of this policy will expand accordingly.

Question: How does this policy affect parts purchased for internal projects or use (IRAD, Testing, RI needs, etc.)?

Answer: Although not subject to DFARS 252.246-7007, the purchase of any electronic parts for internal use can also introduce counterfeit parts into GIT supply and affect the safety and/or quality of assemblies and products.  It is advisable to mitigate this risk by following the purchasing guidelines outlined within this policy.

Question: What is the process for reporting suspected counterfeit parts to GIDEP?

Answer: GIT PDs, PIs, and Program Managers (PMs) shall work with the supplier to verify counterfeit determination and shall issue a Government-Industry Data Exchange Program (GIDEP) Advisory (suspect counterfeit part, but confirmed genuine) or GIDEP Alert (confirmed as counterfeit). Such reports are to be issued within 30 days of the initial escalation. For access to GIDEP, please direct any inquiries to PMO.

Refer to Section 5.6 for quarantine procedures if a suspected counterfeit part is identified and notify PMO.

Question: Is the supplier’s certification, listed on their website that considered reliable?

Answer: No.  GIT Personnel may, however, rely on the original manufacturer’s list of authorized suppliers to gain comfort that electronic parts purchased from that supplier are genuine.  However, any certification must come from the Original Component Manufacturer (OCM), not the reseller.

Question: What is the importance of visual inspections?

Answer: Visual inspection on electronic parts and packaging is important to detect nonconforming and suspect counterfeit characteristics ahead of time, to prevent, investigate, and remediate counterfeiting into the government supply chain.

Visual Inspection is required on projects that purchase electronic components for use in DoD delivered hardware on contracts that are subject to DFARS 252.246-7007. PMO has PM Professionals who are certified component inspectors. Please direct any inquiries to PMO.

Question: What if traceability cannot be established?

Answer: Contact PMO if traceability of parts cannot be obtained.

Question: What should a Risk Matrix for Counterfeit Parts look like?

Answer: The sponsor may have specific requirements of what the Risk Matrix should contain. If no specifics are required, a template is attached to this policy.

Question: Who can help determine the level of risk and associated tests needed if purchasing Category 3 electronic parts?

Answer: Contact PMO for assistance with establishing a risk assessment and test sequence program as prescribed in SAE-AS6171.

Question: How often is the Counterfeit Electronic Part Detection and Avoidance Policy updated?

Answer: This policy is reviewed and updated on a yearly basis.

Question: Who should be contacted for questions or assistance?

Answer: Contact PMO or unit management with any questions or requests for assistance.

Classification of Independent Contractors Versus Employees

The department/unit makes the initial determination whether an individual is an employee or independent contractor because of the familiarity of the relationship. Prior to engaging any individual for services as an independent contractor an assessment based on IRS guidelines must be made and documented. The prospective worker must complete the “Employee - Independent Contractor Classification Checklist” 

If additional review is required, a review committee which will include the Tax Compliance Manager, Procurement and Business Services, and Legal Affairs staff will make a determination.

If approved by Purchasing or Human Resources, the completed checklist must be attached to a requisition in Georgia Tech E-Procurement System for processing. If the consultant is a teaming partner and will be paid from sponsored funds, the agreement must be executed through the Office of Sponsored Programs on a "Request for Sub-Agreement Form".

Groups Usually Paid As Employees:

•Academic Activity – Instruction services provided to enrolled students and for Georgia Tech programs

•Former Georgia Tech Employees – Persons employed by Georgia Tech in any position within the last 36 months

•Graduate Research Assistant, Graduate Teaching Assistant, or Graduate Assistant – Graduate students providing teaching, research, and staff duties

•Individual who performs substantially similar services as those provided by Georgia Tech employees – All individuals, including student workers

•Office management and accounting services – individuals who perform substantially similar services to Georgia Tech employees not hired through an employment agency

•Retired Individuals from University System of Georgia who are receiving benefits – Retired-but-Working classification

•Short-term direct support staff supervised by Georgia Tech faculty or staff – duties often performed by Tech Temps

•Student providing non-skilled services – student assistants

•Support services for programs and activities – includes summer activities/camps, grading papers and other services

•Temporary help – includes event set-up, drivers, errands and various other services

A Pay Classification Matrix has been developed for your reference and the link can be found here and in the Related Information section of this policy.

Travel Expenses
The method for reimbursements made directly to the service provider (consultant, etc.) must be specified in the consultant's contract for services. Travel reimbursements may be made based on state travel regulations. The administrative unit is responsible for determining if charges for reimbursable expenses are proper and reasonable and the amount agreed to cover those travel expenses should be entered as a separate line item on the requisition. Specific requirements for documenting and itemizing those travel expenses will be detailed in the service agreement, but original receipts are not required. All payments to the consultant or firm will be reported on IRS Form 1099-misc or 1042-S, as appropriate. Tax withholding, where required, will apply at time of payment. Direct billing of airfare or hotel is not permitted.

When to Use

• An honorarium must be paid for services provided and cannot be used as a form of payment for an award.
• The service provided is one where Georgia Tech does not expect a particular deliverable.
• Examples include:
• presentation of research results
• reading of papers
• participation or leading of colloquiums, workshops, and seminars
• presentation of lectures
• The services provided must be short-term in length. Short-term is defined as 9 business days or less. Services over a longer period of time must be contracted.
   

Approval Responsibility

• Approval by an administrative unit indicates that payment is allowable from funding source. [If state funds, the service should be instruction, research or public service. If sponsored funds, service must be instruction, research, public service or is specifically authorized by grantor.]
• Approval by an administrative unit indicates that payment is within policy guidelines for honorariums.

Amount Limitations

• Each honorarium activity should typically not be greater than $5,000 unless a special exception has been granted by the Purchasing Department. Honorarium payments are processed as a direct expense and are not initiated through the requisition process.
• Amount of honorarium may include payment for services along with amount intended to cover travel expenses.
• Amount for services (honorarium) may be paid and expenses reimbursed with appropriate receipts and documentation. Payment of honorarium and expenses must be requested at same time.

IRS Reporting
In accordance with Internal Revenue Service regulations, payments to US tax residents, which total $600 or more in aggregate to payee, will be reported as income on a 1099-Miscellaneous Income form.
If recipient is Nonresident Alien, reporting on IRS Form 1042-S will be in accordance with guidelines outlined in separate procedures for payments to Nonresident Aliens.
 

Documentation Requirements

• An official announcement, invitation letter, flyer, etc. that outlines the need of the service provided must accompany the request for payment of honorarium.
• In all cases, requests must be accompanied by a Georgia Tech Vendor Profile Form completed by the recipient of the honorarium.
• If payee is Nonresident Alien, see separate procedures for restrictions and requirements may apply.
• Receipts for travel expenses if claimed as a separate expense line.
• If payee is State of Georgia employee, the following must be provided:
  • certification from requesting department of the need for services and why the best interest of the State will be served by obtaining such services from a person not presently employed by the State,
  • certification by department, agency, etc. employing employee that the performance of such services will not detract or have a detrimental effect on the performance of employee's full-time employment .

Procedure Guidelines Forms
Recipients of a honorarium will need to be set up as a supplier. Requests for payment of honorariums should be submitted electronically as a supplier invoice request (SIR) via the Institute’s Financial System. The appropriate spend category for honorariums is to be used.

Expense Account Classification
The appropriate expense category is also to be used for any associated travel expenses. Expenses must be reported by day and travelers must comply with Institute travel policies. Travel expenses that are not supported by receipts, or otherwise do not comply with Institute travel policies will have all expenses classified as honoraria income.
 

Georgia Tech utilizes the GLACIER Nonresident Alien Tax Compliance System to collect immigration and tax related information from foreign nationals receiving funds from the Georgia Institute of Technology. All foreign nationals receiving funds from the Institute must have a GLACIER record. GLACIER determines tax residency status and tax treaty eligibility for the foreign national. The system creates all forms required prior to payment, as well as the IRS form 1042-S for annual tax reporting.

The Accounts Payable Website includes payment request checklists to assist the campus administrator with the collection of required documentation for each category of international payment (How to pay an honorarium, How to make a fellowship payment, etc).

Please submit a ServiceNow request for additional guidance regarding payment processing for international payees.

General Guidelines
The purpose of this PCard Policy is to provide Institute guidelines for the issuance and use of the PCard along with instructions for reconciliation and review of transactions. The Policy will be reviewed for adequacy by the Institute’s PCard Program Manager annually.

Safeguarding of the Institute's Assets

• Rebates or refunds from vendors shall be the property of the Institute and shall be paid promptly into the Institute’s accounts.
• Criminal and consumer credit checks will be performed in accordance with BOR and DOAS policy. The Institute will ensure that the results of background checks are provided the privacy protections required by law.
  • New cardholders, are required to have criminal and consumer credit checks prior to being issued a PCard. Additionally, credit checks must be done again at the time of card renewal.
• Cardholders will be required to personally reimburse the Institute for purchases made that are not appropriately documented.  Approving officials may be required to reimburse the Institute if the approving official approved the purchase.
• Habitual loss of receipts/documentation may require personal reimbursement by the cardholder and/or approver and may also result in termination of the PCard.
• Items of value purchased for distribution to students are allowed only in support of the educational objectives of the Institute.  Additionally, the cardholder must maintain sufficient documentation to identify the individual receiving an item.  The requirement to track individual recipients does not apply to items of de minimis value.
• Departments must ensure that PCards are promptly cancelled upon employee transfer or termination.
• PCard purchases can only be shipped to GT addresses. Items shipped to non-GT locations must have written approval from the cardholder’s supervisor and the PCard Administrator.
• Positions identified by the employing department as PCard cardholders will be considered to be "positions of trust".

Card Issuance

• PCards may be issued to “permanent, regular-status” employees only. No student employees, affiliates or Tech Temps may be issued cards. Only one card is allowed per employee.
• Authorization - A PCard Request Form is completed by/for the employee and then signed by Department Head to indicate authorization, cardholder spending limits, and cost allocation information. Spending limits should be determined based on the cardholder’s job responsibilities, anticipated card usage levels, historical spending patterns, and budget limitations. The completed form with the required signatures is submitted to PCard Administration by the PCard Coordinator.  After all background checks have been verified, the request will then be reviewed and approved by the CFO. Upon approval by the CFO, the PCard Administrator will order the card from the bank and maintain the form in a cardholder file.
• Distribution – PCard Administration will notify the cardholder and appropriate PCard Coordinator when the card has been received. Cards will be distributed to employees after completion of appropriate background checks, cardholder training and submission of the signed Employee Agreement Form.
• PCard Administration will review cardholder accounts annually to identify and close unused or low-usage cards for which there is no longer a business need.

Employee Agreement Form

Before being issued a PCard, a completed Employee Agreement Form, signed by the employee and Department Head must be submitted to Business Services. By signing the form, the employee acknowledges:

• Receipt of training and understanding of the regulations for use and protection of card.
• Understanding of responsibilities in reconciliation process and billing disputes.
• Understanding and acceptance of consequences for PCard violations.

Card Limits

• Since Georgia Tech, not the individual employee, will pay for the purchases made with the card, additional controls have been added to the card accounts. These limits are imposed at the point of sale when the card is swiped.
• Institute Limits – The PCard may be used for purchases not to exceed the cardholder’s single transaction or cycle limit in the PCard Plan. The cardholder’s Department Head working with the PCard Coordinator may identify additional limits based on card usage and budget limitations. These limits should be noted on the approved Request Form and kept in the cardholder’s file.
  • Increased Limit PCards may be used by department buyers and other specifically designated and pre-approved cardholders for purchases requiring increased limits on an as needed basis. Requests for transaction increased limits must be approved by the Department Head and submitted to the PCard Program Administrator for review and approval. The PCard Program Administrator will coordinate with the State Cards Program Manager when an exception to State PCard Policy is required. Increased Limit cards may not be used to circumvent the State’s no-bid limit.
• Cardholder Spending Limits – Adjustable limits per card are:
  • Dollar amount limit per transaction
  • Dollar amount limit per cycle (month)
• Changes to Limits - Requests for changes to card limits should be submitted on the “Limit Change Request” via ServiceNow ticket. Change requests will be kept in the cardholder’s file. Additional information can be found at the link to PCard Requisition Instructions and Exceptions for the requisition process and limit increases.
• Merchant Activity Type Limits - Specific types of businesses identified by a Merchant Category Code (MCC) are restricted on the card. If you have difficulty using your card with any particular vendor, please contact your department PCard Coordinator or the PCard Help Desk via ServiceNow.
• Policy Limits - In addition to the limits that are controlled at the point of sale by the card, Georgia Tech limits the use of the card through policy. The card may be used only for purchases that are made under delegated authority or items exempt from review and approval by the Procurement Department.

Authorized Uses of PCards

All purchases made with a PCard must be for official Institute business.  Cardholders and approving officials are designated as Institute purchasing agents and are subject to the provisions of O.C.G.A. § 45-10-1 et.seq. (State Employee Code of Ethics, Conflicts of Interest, etc.). 

The PCard may be used for:

• Equipment: Single units under the cardholder’s single transaction limit Equipment over $3000 (single unit) is considered a capital asset and should be purchased via the Georgia Tech E-Procurement System.
• Supplies, Materials, and Services may be purchased for less than the cardholder’s single transaction limit.  The Institute will monitor activity for purchases for the same supplies, materials, or services from the same vendor so as not to exceed $9,999.99 per year unless competitively procured as detailed in Georgia Tech, DOAS regulations and BOR policies and procedures.  Supplies and materials purchased may also include items purchased for resale.
• Purchases from Statewide and Agency Contracts are permitted. 
• Conference Registration Fees for Institute personnel on official Institute business with the requirement that employees not request reimbursement for meals paid with the conference registration fees.
• Departments must ensure that conference registration fees for employees paid pursuant to this section are recorded as required by Institute Travel Policy.  
• Student food, student travel, and food for instructional uses is permitted as outlined in the Institute Policy 5.2.1.9 and 6.16 subject to the documentation requirements outlined in this policy.  Additionally, food purchased for sponsored research use as approved by an Institutional Review Board (IRB) is permitted.
• Employee food may be purchased with a PCard in alignment with GT Policy 5.2.1.9. Employees participating in off-campus events or in a travel status must request reimbursement. 
• Repairs and maintenance are authorized for Institute vehicles.  All costs associated with vehicle repair and maintenance must be reported in accordance with DOAS fleet management regulation..

Note: Exceptions may be granted by the PCard Manager.

Prohibited Use of PCards

The PCard may not be used for:

• Personal items.  The use of the PCard for personal expenditures is strictly prohibited.  Cardholders who violate this rule must reimburse these funds and, if the violation is determined to be intentional, may be subject to both losses of employment and criminal penalties.
• Employee Travel expenses (lodging, transportation, meals).
• Entertainment expenses (must be done as a reimbursement through the Foundation or GTRC).
• Alcoholic beverages or tobacco products.
• Motor vehicle fuel (except for authorized rental vehicles for official student program group travel).
• Professional services as listed in BOR Business Procedures Manual (BPM) Section 3.1.2 including certified public accountancy, architecture, professional engineering, doctors & registered nurses, lawyers, and veterinary medicine.
• Gift cards, funding the GT BuzzCard, stored value cards, prepaid cards, calling cards, gift certificates, or other cash equivalent items.
• Food except as authorized under BFM Section 5.2.1.9.(PCard cannot be used for purchases of bottled water, beverage/coffee service, snacks, or entertainment)
• Cash advances, cash refunds, or “store credit.”
• Memberships and/or fees to wholesale shopping clubs or “warehouse type” retailers.(e.g. Sam’s, Costco, Amazon Prime)
• Agency (funds held on deposit) or affiliated organization expenditures except as permitted for Study Abroad Programs as detailed in BPM Section 21.4.
• Purchases made from units of the Institute. No internal Institute charges are allowed on the PCard. This includes, but is not limited to, OIT printing services, Library, and Parking. Please note: The PCard may be used for official Institute business at outsourced businesses including the GT Bookstore, VWR, and Aramark.
• Split purchases. Dividing one purchase into two or more to circumvent the single transaction limits and procurement requirements previously enumerated is not allowed.(more than one transaction to the same vendor on the same day which exceeds the single transaction limit of the cardholder) 
• Sales tax.  Sales tax should not be paid for purchases made from vendors within the State of Georgia using institutional funds.  Institutional funds used to further institutional business purposes are not subject to sales tax as outlined in O.C.G.A. § 48-8-3 (8).  Sales tax may be paid when required for vendors out of state.

Note: All purchases must align with the Allowable Cost Matrix. 

Limitations on Vendors

High Risk Vendors:

• Georgia Tech does not encourage the use of high risk vendors such as PayPal and eBay. If no other form of payment is accepted by the vendor, then the PCard High Risk Vendor Purchase Authorization Form (high risk vendors are listed on the form) must be completed, signed, and approved prior to each purchase and appended with the receipt as part of the accountable documentation for the PCard Statement. Violations of policy will be evaluated as noted in the Violations of Policy section of this policy.

Additional Restrictions:

• Cardholder must not make PCard purchases from vendors where the cardholder has a financial interest.
• Cardholder must not accept any gift or gratuity from any source when it is offered, or appears to be offered, to influence your decision-making regarding PCard purchases. 

Cost Allocation

Charges must be reconciled to the appropriate Worktag through the Institute's E-Procurement system. PCard transactions are loaded daily by the bank and once transactions are available in the E-Procurement system cardholders should reconcile them immediately, and no longer than 30 days. 

Training
Department PCard Coordinators are required to complete the annual PCard Training and Certification online training tutorial. Cardholders are required to complete the “PCard Cardholder Training & Certification” online training tutorial prior to receiving a card.

Cardholders are required to re-certify annually. Failure to re-certify will result in card suspension until the re-certification is completed. Departments must ensure that Approvers complete the “PCard Cardholder Training & Certification” online training tutorial initially and annually thereafter.

Georgia Tech's E-Procurement System Training
Cardholders and Pcard Cost Center Managers must complete the Georgia Tech’s E-Procurement System Pcard Training module prior to taking on either role.

Departments are responsible for ensuring Cardholders and Approvers are trained in internal departmental PCard policies and procedures. Departments should ensure that non-procurement personnel are acquainted with small value purchase procedures.

Card Security

The cardholder should use basic security measures, as outlined below, to prevent unauthorized use and limit the potential for fraud.

• Sign the card as soon as you receive it.
• Always keep PCards and account numbers in a secure place.
• Safeguard the PCard as you would your personal credit card.
• Be aware of your surroundings when using the card.
• Monitor card activity in Georgia Tech's E-Procurement System.
• Reconcile and submit monthly statements in a timely manner.

Lost or Stolen Cards

• Lost, stolen, or fraudulently used PCards must be reported to Bank of America via the number on the back of the card as soon as possible after discovering the loss, theft, or fraudulent use.  The cardholder’s approving official and the PCard Coordinator must also be notified. Evidence of fraudulent use may be requested to include transaction detail. Lost or stolen cards require card cancellation. Failure to report the loss, theft, or fraudulent use of the PCard may result in increased financial loss to the institution.
• The PCard Coordinator has the responsibility for communicating the information to PCard Administration.

Surrendering the PCard

• The Pcard is the property of the State of Georgia. The cardholder is to surrender the PCard to the PCard Coordinator upon request, retirement, termination, or transfer to another department if the PCard is not required for the new role. 
• The PCard Coordinator should destroy (cut up) the card and notify PCard Administration via email to cancel the PCard.

Documentation Requirements

Requisition Form:
Unless covered by an approved exception, every purchase requires two prior approvals prior to purchase.  These prior approvals must be documented via a requisition form designated by Procurement and Business Services. If the purchase is approved, the cardholder may make the purchase. The signed requisition form must be appended to the receipt image during the reconciliation process. 

Receipts:
For each transaction, accountable documentation (i.e. a sales draft or receipt) must be obtained as proof of purchase. This documentation will later be used to verify the purchases shown on the cardholder's transaction in Georgia Tech's E-Procurement System. The documentation must contain line item description and line item pricing for the purchase. The documentation should include:

• Vendor name
• Transaction amount
• Date of the purchase
• Itemized list of items purchased
• Other information as required by the department

If a sales draft or receipt does not provide a description, the cardholder should write the description on the document. For items such as subscriptions and registrations, where a receipt is not normally generated by the merchant, a copy of the ordering document may be used so long as it contains a description and price. Copies or facsimiles of the original receipt may be acceptable if the original is not available.

If the documentation for a transaction has been lost, it is the cardholder’s responsibility to obtain a duplicate from the vendor. If a duplicate cannot be obtained, the cardholder should complete the PCard Receipt Replacement Form for to serve as the receipt. The PCard Receipt Replacement Form should contain the itemized information for the transaction, as listed above, and describe the cardholder’s attempt to obtain a duplicate from the vendor. PCard Receipt Replacement Forms may only be used on an exception basis. Excessive use of the form (defined as more than three times in one fiscal year), may result in suspension of card privileges.

Receipts are attached to each transaction in Georgia Tech's E-Procurement System by uploading the receipt and attaching it to the transaction.

Maintaining PCard Documentation

Documentation will be retained in accordance with records retention and fund requirements.  

Using the PCard - Making the Purchase

The PCard can be used to make purchases over the counter, by mail, by fax, by telephone, or by Internet at any vendor that accepts Visa. The following procedures should be followed for PCard purchases.

Obtain Best Value

When accepting a PCard, the cardholder becomes an authorized purchaser for the Institute with specific responsibilities for expending public funds. The cardholder should ensure the purchase is appropriate and in accordance with all Institute and State rules and regulations. Additionally, PCard purchases must comply with requirements of the Georgia Procurement Manual concerning Order of Precedence and Competitive Bidding. When purchasing goods or services, the order of precedence that should be followed in selecting the appropriate vendor is: (1) Statewide Mandatory Contracts, (2) GT Agency Contracts, (3) Georgia Correctional or Georgia Enterprises, and then (4) Statewide Convenience Contracts and the open market.

After verifying the item is not available on a Statewide or Agency contract, the cardholder must utilize lowest cost based on requirements, quality, and availability to obtain the maximum value of each dollar expended.    

Vary the suppliers to give fair treatment to all suppliers and to assure that the price obtained is reasonable. Transactions you make may be on behalf of Federal sponsors. Purchasing on behalf of government clients requires special sensitivity on the part of the purchaser to obtaining fair and reasonable prices, spreading purchases among many suppliers including small, small-disadvantaged, and women-owned businesses, and adhering to strict ethical conduct.

Sales Tax

When using the PCard, the cardholder should inform the vendor that the purchase is for official State of Georgia purposes, and therefore, may not be subject to Georgia state or local sales tax. If requested by the vendor, cardholders must present an “AP - Sales & Use Tax Certificate of Exemption / Georgia Form”. The form is available online in the Forms section of the Business Services website at:  http://www.procurement.gatech.edu

If sales tax is erroneously charged by the vendor, cardholders should make every effort to obtain a credit directly from the vendor. Documentation of attempts to obtain credits should be maintained with the transaction receipt by appending to the receipt. Please note: Sales tax may not be disputed through the bank.

Making the Purchase - Over the Counter

• Verify that supplier accepts the Visa. (Note: If not and it is a supplier you will need for future purchases, notify PCard Administration.)
• Provide the PCard for payment.
• Inform the clerk that the purchase is for official State of Georgia purposes, and therefore, exempt from state and local sales tax. The PCard indicates sales tax exemption, but cardholder should verify that clerk does not charge sales tax.
• Verify the dollar amount is correct and no sales tax has been included, then sign the sales draft.
• Retain your copy of the sales draft and receipt. If the copy does not provide a description of item(s) being purchased, the cardholder should write the description on sales draft or receipt.
• Follow PCard transaction/documentation process established by the department. 

Making Purchase - Mail, Fax, Telephone, or Internet Orders

• Provide supplier with requested card information.
• Inform supplier that the purchase is for official State of Georgia purposes, and therefore, exempt from state and local sales tax.
• Give supplier detailed shipping instructions. It is recommended that you have the goods shipped directly to your campus address (this would normally be the cardholder’s Billing Address). Please note: Goods should be shipped to official Georgia Tech business addresses only. Occasionally, researchers will be in the field at a sponsor’s site and will need the goods shipped to that location or the location specified, (never a home address). Shipments to an address other than a campus Georgia Tech address must be approved by PCard administration via email from the PCard Coordinator, with the cardholder’s supervisor’s approval included. This documentation should be appended to the receipt as accountable documentation.
• Retain documentation for purchase. Acceptable documentation includes: a copy of order form, copy of catalog page showing cost, or email/faxed order confirmation showing price along with packing slip, print out of the online order form, print out of the online order confirmation, or a print out of the e-mail confirmation. 

Returning Purchases Made With PCard

If you determine that the material is defective or incorrect, notify the supplier that the item needs to be returned and request an address to ship to, and a Return Authorization Number. Request that the supplier process a credit transaction through the PCard. Document that the goods have been returned for credit and communicate information through proper channels within your unit. Ensure that the credit appears in Georgia Tech's E-Procurement System. If not, process the charge as a Disputed Transaction.

It is a good practice to keep original boxes, containers, and special packaging until you are certain you are going to keep the goods. Some items must be returned in the original packaging.

Disputed Transactions

It is the cardholder’s responsibility to resolve discrepancies and ensure credits are received. When a cardholder discovers an incorrect amount has been charged for goods or services received, or a questionable purchase or transaction appears for verification in Georgia Tech's E-Procurement System, the cardholder must immediately seek to resolve the problem with the vendor. Any communications should be documented and the documentation including dates, persons involved, and a brief description of the problem should be either appended to the receipt or appended to the PCard Dispute Form.

If the cardholder is unable to resolve the problem with the vendor, a PCard Dispute Form should be completed and faxed directly to Bank of America at the fax number on the form. The PCard Coordinator should be notified of the dispute and a copy of the dispute form should be appended to the monthly statement. The cardholder should check the following month’s statement to ensure that credit was received. Please note: Disputes must be submitted within 60 days of the statement date.

Reconciling PCard Transactions
General:
Pcard Transactions post to Georgia Tech’s E-Procurement System for verification on a daily basis. As the transactions post to Georgia Tech’s E Procurement System, the cardholder should review the transactions and attach receipts to the transactions. If the cardholder believes a transaction listed on the statement is incorrect, the procedures outlined in the “Dispute Transactions” section should be followed.

Approval Workflow:
All PCard transactions must be reconciled (verified) in Georgia Tech’s E Procurement System.  All transactions must be submitted for approval by the cardholder.  At a minimum a PCard Cost Center manager must also approve each transaction.

Timeliness and Escalations:
The PCard Office will provide direction on how/when transactions should be reviewed, submitted and approved in the online system. This direction will be provided to ensure that transactions are fully verified and posted to the ledger within sixty days of the transaction post-date.

Delinquency:
Cardholder’s cards whose online transaction verifications have not been submitted and completely approved within the 45 day time-frame may be suspended. Repeated non-compliance will result in card cancellation. Cards will be suspended/canceled as follows:

• First Offense - PCard(s) suspended 7 days or until written notification (email is acceptable) is received that the reconciliation package is complete and the cardholder is in compliance, whichever is greater. PCard Coordinator notified of suspension.
• Second Offense - PCard(s) suspended 30 days or until written notification (email is acceptable) is received that the reconciliation package is complete and the cardholder is in compliance, whichever is greater. Cardholder must re-certify by completing the on-line “PCard Cardholder Training & Certification” tutorial. PCard Coordinator and Department Head notified of suspension.
• Third Offense - PCard(s) cancelled. Department Head may request cardholder be re-instated after 90 days provided written notification (email is acceptable) is received that all reconciliation packages are complete. Cardholder must re-certify by completing the on-line “PCard Cardholder Training & Certification” tutorial. PCard Coordinator, Department Head, and OHR notified of cancellation.

Please note: In extenuating circumstances (such as extended travel, on leave, etc), departments may request that specific cards be exempted from suspension for a brief period.

Reviews/Approvals

Monthly review and approval of PCard transactions is required at the department level. The Department Head/PCard Coordinator will determine who the approvers will be for their departments.

Departments are responsible for reviewing all transactions to:

• Ensure the appropriateness of purchases and funds being utilized.
• Verify the completeness of documentation (detailed receipts, disputed transactions, approved requisition forms).
• Identify any policy violations and take appropriate action. 

Payment

Business Services will receive a consolidated monthly billing statement from Bank of America for all Institute cardholders. The statement will be reconciled and processed for payment, in accordance with a plan on file in Business Services.

Compliance Reviews

Business Service and Internal Audit Reviews:
Transactions will be reviewed online in accordance with plans on file in Business Services and Internal Auditing. Cardholder files will be reviewed in accordance with a plan on file in Business Services. Internal Auditing periodically conducts on-site compliance reviews in each department. These visits will be designed to:

• Review departmental records and record keeping practices
• Monitor adherence to policy guidelines
• Identify opportunities for process enhancements
• Offer “best practice” procedures

Results of these reviews will be used to enhance Georgia Tech’s PCard processes and will be shared with the Department Heads.

I. Georgia Tech Employee Business and Training Meetings using Institutional Funding
Under certain infrequent circumstances, employees may be required to remain at the work site during mealtime. Such circumstances include emergency situations such as natural disasters or significant public safety events, but may also include intra-departmental meetings or training sessions, where the meeting or training session continues during the meal and the employees are not permitted to leave the premises of the meeting site. The following standards will be used when deciding whether a meal may be purchased under this policy:

Group meals should be held only to facilitate the effective and efficient operations of the departments involved. For example, it may be that scheduling an intra-departmental meeting or training session is the most effective and efficient use of employees’ time given teaching schedules, other meeting commitments, etc. In this instance, requiring employees to participate in a meeting over lunch may be the best means available to get the required participants in the same place for the period of time required.

Group meals should only be provided in those instances where the meeting lasts for at least four (4) hours. A meeting less than four hours could generally be scheduled prior to or after a normal meal without significantly impacting employees on different work schedules. The PCard may be used to purchase meals for employees in this scenario.

Group meals held at the start and/or finish of a meeting are not eligible for payment under this policy. Purchase of a group meal is authorized solely as a convenience to the employer and in those instances where employees may not leave for a normal meal due to the time constraints associated with the meeting or training session. Those events not starting until the normal meal time should be delayed until after the normal meal time, or employees may bring employee-purchased food (“brown-bag”) to the meeting.

Authorized group meal expenditures are limited to the purchase of meals only and do not include snacks. Purchase of group meals are to be approved by the Director, Department Head, or his/her designee, prior to the date of the event (for non-emergency situations). The Food / Group Meal Event Documentation Form will be used to document event details and ensure compliance with this policy. All of the documents that were a part of the approval process should be submitted with the payment request.

Meal limits outlined in Georgia Tech Travel Policy "Meals and Incidental Travel Expenses", must be followed. Meal limits apply to the actual food and drink purchased for the meal. Set-up and delivery costs associated with the group meal are allowable and shall not be included in the meal limit calculation.

II. Food and Group Meals for Students, Volunteers, Visitors, and Participants Using Institutional Funding
The purpose of this section is to clarify those instances when food may be purchased for consumption by students, potential students, volunteers and employees using institutional funds. Food includes meals, beverages, snacks, etc., but specifically excludes alcohol as an allowable food expense.

An individual may be subject to different rules depending on the capacity in which they are participating in an event. For example, volunteers might include employees or students if the individual is operating in a capacity separate from their employee or student role. An employee or volunteer attending a student event in the capacity of a student would be considered a student. A student worker participating in an event while being paid as an employee would be considered an employee.

Note: Employees working additional hours in their own area, using work time to provide volunteer service, or otherwise participating in activities expected of employees, are not volunteers for the purposes of this policy.

III. Business Entertainment Meals and Alcohol Purchases using Agency Fund, Foundation or GTRC funding
Institute related entertainment charges and meals purchased for business development include business related breakfast, lunch or dinner, catered meeting, fund-raising or alumni event, etc. Entertainment, individual professional achievement/milestone receptions, holiday and end-of-year receptions, retirement events, faculty recruitment entertainment and extraordinary development activities must be processed directly through the GT Foundation or GTRC.

Business related entertainment charges may only be processed using the funding sources listed below:

• Custodial funds
• Routine development activity using Foundation or GTRC funds

Employee business and training meetings are not restricted by the meal per diem limits (see the Promotional Funding for Meals and Entertainment section for additional guidelines) or the 4 hour minimum meeting length that is required for use of Institutional Funds. The Food/Group Meal Documentation Form is required for payment requests processed through the Institute’s Accounts Payable Team.

• Events using custodial or GTF funds do not require this form.
• Events processed directly through the GT Foundation or GTRC do not require this form.

Alcohol is an allowable expense only if specifically permitted by the funding source or for conference programs that specify receptions in the conference agenda and are funded by participant registration fees, such as the GT Executive Masters program and DLPE conferences.

Link to GT Foundation policy
GTRC policy requires a copy of the invitation or agenda and the number of guests.

Promotional Funding for Meals and Entertainment
Meals and entertainment to conduct official Institute business with external person(s) or for Institute functions with a clear business purpose should be reasonable and appropriate to the occasion. The selection of meal sites and/or catering vendors should be consistent with the image of Georgia Tech and not excessive regardless of funding source. Food or beverage (non-alcoholic) consumed at an event, provided the value is reasonable under the circumstances should not exceed the maximum allowable under USG Policy 8.2.18.4 - Gratuities. If GTF funds will be used, request approval consistent with the Expenditure of GTF Funds process here: https://policylibrary.gatech.edu/business-finance/expenditure-gtf-funds.  If GTRC funds will be used, request approval by submitting the GTRC/GTARC Expenditure Request Form found at https://gtrc.gatech.edu/other-forms and include and explanation of the reasons for exceeding the per person threshold.The GT Alcohol Policy should be followed when alcohol is provided.

IV. Food and Group Meals Using Sponsored Grant/Contract Funding
Sponsored funding will be treated the same as Institutional funding for the purpose of food and group meal purchases.

As the Institute must comply with federal cost accounting standards, which require consistency in the treatment of costs, the Institute typically cannot use sponsored funds for business related entertainment since Institute state accounts do not specifically allow the purchase of business related entertainment. Therefore, discretion must be exercised when charging such expenses to sponsored restricted accounts. As such, the cost of purchased meals or food within 50 miles of the Georgia Tech headquarters will normally not be allowed as a direct charge to a sponsored restricted project because the Georgia Tech employee or trainee is not "traveling" and the cost is normally considered a personal expense. See below for special circumstances.

In special situations such as all day seminars or meetings when a food, beverage, or meal cost meets the three criteria of allowable, allocable and reasonable to the specified sponsored project, the PI may provide written justification of the business purpose of the expenditures and how they relate to the specific sponsored project including purpose of the meeting, list of attendees, a formal written agenda, and the beginning and end times of the meeting. To be allowable:

1. Meal or food expenses must be included in the budget and approved by the sponsor.
2. An agenda must be provided with the request
3. Must specify each participant on the Food/Group Meal Documentation form
4. Must be attended by non-Georgia Tech personnel. Meetings comprised of all Georgia Tech personnel are more often designated as an employee business meeting (See section I of policy).
5. Meal per diem limits are imposed, unless sponsor provides an exception in writing.

Examples of allowable food charges:
Lunch and refreshments provided for periodic all-day meeting of collaborators on a program project (with formal agenda and participants from different locations).
A post-doc being recruited to fill an open position on a research grant. Meal may be charged to the grant since they are on official travel status.
Sponsored projects which specifically allow for business related entertainment

Examples of unallowable food charges:

Meals for lab personnel meeting weekly to discuss progress on the grant

PI has lunch/dinner with a colleague and discusses research

While these expenses may not be allowable on sponsored restricted accounts, they may be reimbursed from discretionary type restricted accounts or directly from the Georgia Tech Foundation.

V. Meals and Receptions Provided in Conjunction with Professional Education Conferences and Institute-sponsored Conferences and Camps
Meals and receptions provided for participants of conferences, workshops, and campus events that are funded by registration fees can be paid through the Institute using participant revenue funds if the meals are specifically noted on the conference agenda and/or registration material. Meal per diem limits are not imposed. The source of funds must be primarily external to the Institute. Campus training designed primarily for Georgia Tech employees must comply with the employee business and training meeting policy, section I.

VI. Meals for Employees, Students, and Guests on Official Travel
Employees who are on official overnight business travel, are eligible for meal reimbursement, according to Institute travel regulations. See Travel policy 6.4 Meal Allowances for detailed policy and procedures.
 

VII. Purchase of Bottled water, Coffee/beverage Service, and Office Snacks
Water and other beverages purchased as part of a group meal are allowable, but the cost of the beverage is rolled into the meal per diem limit. Beverage service and office snacks are not classified as group meals. Institute funds cannot be used the purchase of water and beverage service or snacks purchased for general departmental use. An allowable exception is water/hydration products that are used in compliance with OSHA or for safety related to environmental or workplace conditions. If Foundation funds are used, payment can be processed through Accounts Payable and the Food/Group Meal Documentation Form is not required.

Documentation Requirements and Compliance with Per Diem Limits at Group Events
The Food / Group Meal Event Documentation Form is used to provide documentation for all group meal purchases funded with institutional, sponsored, and Foundation funds processed through Accounts Payable or via the PCard. This form serves to document details of the event, participants, and the approval signature of the department head that is required for employee business meetings using Institutional funds. The original receipt or invoice must accompany all payment requests and/or PCard documentation.

While the meal per diem limits also apply to group events where food is purchased on a group basis of more than 15 participants (pizza parties, buffets, etc), departments are not required to document the actual numbers or names of participants; However, an estimate of the number of participants should be noted to certify that the appropriate per diem limits were followed.

In the event that an employee expends funds in excess of the authorized State of Georgia per diem (see "Meals and Incidental Travel Expenses"), then the amount spent in excess is considered a personal expense and is not reimbursable to the employee or payable to the catering vendor.

Meal per diem limits apply only to food purchased with institutional funds. Food purchased by outside organizations does not fall under the scope of this policy. However, employees must comply with the provisions of BOR Policy 8.2.18.4: Gratuities as it pertains to receiving gifts.

Payment Process

• Reimbursement for employees are to be claimed on an expense report and submitted through the Institute’s Financial System using the appropriate spend category for Group Meals
• Invoices should reference a valid GA Tech PO number and are to be submitted directly to apinvoices@gatech.edu
• P-Card (only for group meal expenses that comply with meal per diem limits and employee meeting length restrictions. No bottled water, coffee/beverage service or snacks). Review PCard policy 5.2.1.8 for specific requirements.

Regardless of payment method, documentation of the purchase must be submitted as outlined above in support of the payment. Itemized, original receipts are required.

Payment for entertainment and extraordinary development activities, including the purchase of alcohol will be via the Foundation or GTRC Check Request process processed directly through the Foundation or GTRC. Original, itemized receipts are required in addition to the other documentation (invitation, agenda, etc) to support the request.

Payments made directly through Georgia Tech Accounts Payable or via the Pcard are exempt from sales tax. Payments made through the GT Foundation and GTRC are subject to sales tax.

Authorized Caterers for Events on Georgia Tech Campus
University System of Georgia policies grant exclusive rights to provide food services on campuses to Auxiliary Services. See the Catering Providers Policy for details regarding authorized caterers and policy details.
 

The Food/Group Meal Procurement form, and links to related policies are available via the Business Services Web Site: http://www.procurement.gatech.edu/payables/forms.

Expenses
Employees may be reimbursed via Expenses in the Georgia Tech E-Procurement System for supplies and allowable expenses up to $1500. Reimbursement requests for the allowable exceptions, referenced previously, are allowable for amounts over $1500, if approved by the unit financial approver. Any expenses over $1500 that are not an exception as noted above must be approved by the Director of Procurement in advance of the purchase. These requests should be submitted through ServiceNow for review. Reimbursements associated with program and participant research advances are processed via Expenses.

Non-employees (including students) will be reimbursed via the Georgia Tech E-Procurement System for approved reimbursements up to $1500. Allowable exceptions outlined above apply to non-employees.

Reimbursements
Reimbursements for employees that pay for meal expenses for official guests/visitors, or seek reimbursement for food/group meals, may also be reimbursed via Expenses in the Georgia Tech E-Procurement System. In that case, documentation requirements include the Food Group Meal Documentation Form, list of attendees (if fewer than 15), an agenda and an itemized receipt. Employees should not pay for travel-related expenses on behalf of other GT employees, due to state reporting requirements. In all cases, the receipt is to be the vendor's normal and customary receipt. The receipt must reflect the vendor's name, date of purchase, quantity, description, price of items purchased and the total amount paid.

Supplier Invoice Request (SIR)
International payments for non-employees (including Students) will be reimbursed through Accounts Payable via the Supplier Invoice Request in the Georgia Tech E-Procurement System for approved reimbursements up to $1500. Allowable exceptions outlined above apply to non-employees.

Petty Cash Replenishment/Reimbursement Request Form
Reimbursements for students, up to $250, may also be made through the Bursar’s Office petty cash process by using the Petty Cash Replenishment/Reimbursement Request Form.

Individuals providing a service to the Institute as Continuing Education speakers, OPTIONS instructors, CRC instructors, and other short-term instructors may be handled as independent contractors OR employees depending upon the number of payments involved and the "Classification of Independent Contractors Versus Employees" determination. For speakers and instructors employed through independent business firms, refer to the Consultants—(Individuals and Firms) section of the "Procurement of Service" procedures.
If the review of the questions under "Classification of Independent Contractors Versus Employees" (see procedure Purchase of Services -- Consultants –(Individuals and Firms)) indicates that the individual should not be classified as an employee, the payments may be processed through Accounts Payable on a Check Request Form. The individual will receive a Form 1099 at year end. If the instructor is a not a U.S. citizen or resident, refer to the "Payments to Nonresident Aliens (Non-employees)" procedure.
If the review of the questions under "Classification of Independent Contractors Versus Employees" (see consultants individuals and firms) indicates that the individual should be classified as an employee. Refer to Office of Human Resources Procedures for employment through the Tech Temp Program.

Unauthorized Purchase
If a purchase request/requisition has been submitted in the Georgia Tech E-Procurement System and the buyer ascertains that the purchase has already occurred or that work has commenced, the requisition may be subject to rejection and the purchaser required to follow unauthorized purchase procedures.