GSA Order OAS 4200.1C was recently issued to all executive branch agencies with the purpose of providing internal guidance on proper usage of the GSA SmartPay(R) purchase card. Federal Acquisition Regulation (FAR), other regulations and laws, as well as General Services Administration (GSA) policy require establishment and maintenance of safeguards and internal controls by all executive branch agencies in support of the Government Charge Card Abuse Prevention Act and pursuant to Office of Management and Budget (OMB) Circular A-123, Appendix B. Together, this guidance outlines standard minimum requirements and best practices for Government charge card programs.

In determining the availability of internal controls to manage the GSA SmartPay purchase card programs, agencies are increasingly seeking COTS SaaS solutions to supplement policies and training. “COTS SaaS solutions like Actus Procurement Compliance Automation utilizes machine learning and AI to reinforce ‘right actions’ and capture ‘right data’ that can’t otherwise be guaranteed with policies requiring training and without safeguards on manual procedures,” said Mike Tocci of Paperless Innovations. “Our government clients are amazed that complex requirements like separation of duties, split purchase avoidance, and timely Cardholder Audits are so automated while maintaining full compliance with agency policies and federal regulations.”

OMB Circular A-123 lists the benefits of efficient and effective purchase card management including reducing administrative costs of paying for goods and services and ensuring effective controls are in place to mitigate the risk of fraud, misuse, and delinquency. Purchase card data, if gathered in an automated system, can be leveraged to meet OMB’s guidance for analyzing and monitoring policy compliance and informing management decisions to drive a more cost effective card program. Government card programs adopting SaaS Procurement Compliance Automations can save money, and process more orders, while reducing administrative burdens required to meet a myriad of unfunded mandates and regulatory requirements.