Controversial P-Card Spend Due to Lack of Policy

Another organization landed in the news concerning frivolous P-Card spend. Namely, food purchases and various gifts created the biggest stir. Is your organization at risk, too? Are your policies and procedures explicit enough about prohibited P-Card purchases and practices? It is not enough to say “Use your P-Card wisely to make business purchases.” Keep reading to see tips on what to convey, as well as an overview of the controversial spend situation.

About the Controversial Spend

As reported by The News-Gazette in Illinois a couple months ago, employees of Champaign Community Unit School District No. 4 (“Unit 4”) used their Purchasing Cards to buy “scores of catered meals, working lunches and snacks, a $200 retirement print from the Larry Kanfer Gallery, flowers for funerals, and thousands of dollars in gift cards…” There was no written policy—and, I assume, little to no training—to direct cardholders on appropriate and inappropriate purchases. When concerns about P-Card usage were brought to the superintendent’s attention nearly a year ago, she failed to properly address the issue.

One employee had over 100 personal purchases with Smoothie King, which she documented with receipts, but no one ever questioned until recently. Food purchases occurred throughout Unit 4 by employees at various job levels, including school principals. Many transactions were over $500, which is not necessarily bad depending on the event, but there were no parameters or rules.

What About Your Organization?

Do your policies (P-Card or other) specifically address food and gifts, including flowers, balloons, gift cards, and charitable donations? If not, you are risking more than frivolous purchases and possible budget issues. It could be hard to terminate an employee for improper purchases unless the policy is clear and you can prove there was a violation.

What to Include in Your Policies

The Circumstances

Under what circumstances will the organization pay for food and gifts? For example:

  • The purchase of funeral flowers are only allowed if the deceased person was a current employee.

  • Purchasing flowers/plants for decoration purchases are prohibited except for approved landscaping projects managed by the Maintenance Department.

  • Charitable contributions of any kind or any dollar amount are prohibited (e.g., allowing a vendor to add a $5 donation for a local food shelf).

  • The organization will not pay for food/beverages for onsite organization meetings, celebrations, etc. except when an event is intended for all employees and planned by Human Resources.

What are the dollar limits for allowed purchases? For example:

  • Funeral flowers cannot exceed $X.

  • Food for a working lunch should not exceed $X per person.

Purchasing Authority

Is any employee/cardholder allowed to purchase food, flowers, and/or gifts? Or is this privilege granted to only certain employees? Monetary gifts like gift cards have tax implications and must be tracked appropriately, such as by Human Resources.

The Process

Are pre-purchase approvals required? If yes, by whom? What information must be documented within the request and approval? What other supporting documentation is required? Are there any related approved/preferred vendors?

Final Thoughts

Just when I think nothing will surprise me, I was surprised to read that Unit 4 did not have a written P-Card policy and the people in power allowed it to be this way for years. Policies and procedures are the foundation of any P-Card program. As a best practice, review yours annually and update when needed.

Related Guide Available

How to Revitalize Your Purchasing Card Policies and Procedures, $29.99

Related Webinar This Week

  • What: Creating a Robust P-Card Policy and Procedures Manual

  • When: Thursday, July 25, 2019

  • Hosted by AP Now; delivered by Lynn Larson, Recharged Education

    For more information and to register, please visit AP Now.

Ensure your policies explicitly address when food purchases are prohibited and allowed.

Ensure your policies explicitly address when food purchases are prohibited and allowed.

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About the Author

Blog post author Lynn Larson, CPCP, is the founder of Recharged Education. With 20 years of Commercial Card experience, her mission is to make industry education readily accessible to all. Learn more

The Party’s Over for Two Cardholders Taken into Custody

Two cardholders from a university are facing federal charges in conjunction with internal card fraud, but, as always, I keep thinking about the reviewers/approvers in this case. They are supposed to be the first line of defense against cardholder fraud and misuse, but we all know that managers’ vigilance can be hit or miss. This reality means the auditing process better be sound to catch anything missed at the cardholder and manager levels. Keep reading to see more about the fraud case, obtain six audit recommendations, and learn about a May virtual workshop for auditors.

About the Case

The two employees, who both held research-related positions at the University of New Hampshire (UNH), allegedly used their P-Cards to make thousands of dollars in personal purchases, including Amazon gift cards, and then falsified receipts. As reported by, a service of

  • The cards were intended for expenses incurred through research covered by federal grants.
  • They were required to provide receipts and written justification for their purchases.
  • Another UNH department reviewed and approved their transactions, seeking reimbursement from the appropriate grants.
  • A federal grand jury recently indicted both men on 31 counts of theft of government funds.

Read the complete article published by It indicates that the fraud was caught via a random audit, but the exact details are unknown.

Since managers’ vigilance (in overseeing cardholders’ activity) can be hit or miss, the auditing process better be sound...

Audit Recommendations

  1. Do not rely solely on random transaction audits. Be strategic; see examples.
  2. Ensure every cardholder is thoroughly audited at least once per year.
  3. If your organization does not already have it, seriously consider an auditing solution/technology. It covers more ground than what a human can do and is less prone to errors.
  4. For suppliers with whom your organization has an ongoing relationship, obtain reports showing what cardholders have purchased. This can help uncover falsified receipts.
  5. If purchases from Amazon are allowed, audit a high percentage of these transactions every month (audit 100% if using technology). Better yet, switch to Amazon Business, which offers various controls. 
  6. Occasionally verify the presence/location of purchased items to ensure the goods are not somehow “missing,” especially those that might be tempting for personal use.  

See also recommendations related to manager-approvers and how to help them be successful. I wish I knew what the aftermath was for the department that approved the two cardholders’ transactions! Accountability is critical.

P-Card eWorkshop for Auditors

Purchasing Card Audits—Best Strategies for Internal Audit

In early May, I will be delivering a four-hour virtual training course for The Institute of Internal Auditors/American Center for Government Auditing. Targeted at auditors in the public sector, but still suitable for all sectors, the content will help auditors better understand Purchasing Cards and what should be audited. Learn more about this event...  

About the Author

Blog post author Lynn Larson, CPCP, is the founder of Recharged Education. With 20 years of Commercial Card experience, her mission is to make industry education readily accessible to all. Learn more

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Danger signs of card misuse.

Another case of Commercial Card misuse has made its way into the news. Once again, the culprit is a person who held a high-ranking position, which created a tricky situation for staff. Keep reading to learn what happened and the unique action that exposed the problem. As for your organization, what mechanisms are in place to protect against abuse by executives? Do you discuss the potential warning signs of card misuse or fraud? See examples below of what your organization should pay attention to.

Card Misuse Case

The situation occurred within a Minneapolis suburb—at the Shakopee Public Schools—but it could happen anywhere. If folks in the public sector are taking chances even with taxpayers’ eyes on them, imagine what could be happening at private organizations.

The following content is based on reporting by Shakopee Valley News.

Rod Thompson, the former superintendent (he recently resigned), began making personal purchases on his P-Card soon after he was hired in 2011, but it was not discovered until this year. In all, he made more than 100 such purchases—many were shipped directly to his home—totaling approximately $15,000. There could be more, as the investigation is still ongoing. Missing or partial receipts, as well as a lack of cooperation by the district, have made the investigative process more difficult.

Thompson reimbursed the district for some personal purchases, claiming he made them accidentally. Based on articles I’ve read, it seems he did not initiate reimbursement unless someone questioned him.

“Dr. Thompson realized the P-card (credit card) had been used as a default card when he made purchases through Amazon and PayPal,” district spokeswoman Ashley McCray said earlier this year.

Gee, how convenient. He never noticed that his personal card was not charged or his P-Card was used. All the more reason for organizations to adopt Amazon Business if Amazon purchases are allowed.

Things began to unravel in March when Thompson announced a $4.5M shortfall within the district due to “human errors made through a series of inaccurate budgeting assumptions, omissions and errors.” In addition, the school district’s cash reserves have been in a downward spiral since 2012. Further, when Thompson left his previous position with a different school district, there was a $700,000 accounting error. Hmmm…

Ultimately, it was a group of concerned Shakopee citizens, not the school board, that began digging into records, which revealed Thompson’s card use and led to police involvement. As a side note, the district is currently revising its P-Card policies and procedures.

More Information 

Shakopee Valley News offers more information on this story.

2018 update: See a follow-up blog post from Recharged Education about the outcome of this internal fraud case.

Credit cards are not dangerous; rather, inaction in response to questionable activity and/or a lack of controls are dangerous.

Credit cards are not dangerous; rather, inaction in response to questionable activity and/or a lack of controls are dangerous.

Possible Warning Signs

Some of the below are demonstrated in the Shakopee story, but I am adding others to round out the list. However, please keep in mind that the presence of a sign does not solidify misuse or fraud. It may simply highlight the need for further review.

  • Cardholder has self-reported (and paid back) more than one or two instances of accidental P-Card use for personal purchases

  • Any “accidental” use that is found by someone other than the cardholder

  • Cardholder fails to provide, or is late in providing, receipts for P-Card purchases; Thompson was guilty of this, even though his executive assistant said she tried repeatedly to get him to turn in late receipts

  • Receipts/supporting documentation do not clearly reflect what was purchased

  • Purported business purchases cannot be located

  • Budget issues within a department

  • A cardholder’s spend is higher than historical averages and/or that of other cardholders with a similar job position

  • Cardholder has personal financial struggles and/or obviously lives beyond their means

Final Thoughts

If an executive has a sense of entitlement, he or she can wreak havoc on an organization by pulling rank on anyone who questions a purchase. While some type of board must provide oversight, they cannot scrutinize everything, as nothing would get done. At some level, a board needs to trust executives. There is a fine line, but controls must prevail. See a related blog post Executive card fraud beyond beliefincluding some tips.

About the Author

Blog post author Lynn Larson, CPCP, is the founder of Recharged Education. With more than 15 years of Commercial Card experience, her mission is to make industry education readily accessible to all. Learn more

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