Examples of bulk purchases, include, but are not limited to fuel cards, gift cards, personal hygiene items, and tools.
Custody
For each bulk purchase, an agency staff representative must be the designated custodian of the items. One or two staff backups may be designated. The provider’s internal controls must clearly designate the custodian and backups. The custodian is responsible for ensuring that all purchasing, security, dispensing, tracking, and replenishing procedures are followed.
Security
All purchased bulk items must be secured at all times, i.e., in a locked box inside a locked cabinet or drawer accessible only by the custodian and designated backup and identified as BFET items.
Issuance Receipts
All distributions from the bulk items issued should be documented in a log (spreadsheet) or in a standard (pre-numbered) receipt book. The log must uniquely identify each payment receipt in order to document the appropriate use of the card or item for audit purposes.
Audit Log
The custodian must also keep an inventory log (e.g., a spreadsheet) of fuel/gift card bulk purchases and disbursements for audit purposes.
The log should include the following: card type, entire card number, date received (or list the bulk item), who received the card/item, and who issued it. A reconciliation of fuel/gift cards should be conducted whenever gift cards are purchased or at least quarterly. This reconciliation should consist of verifying that the number of cards purchased minus the number of cards disbursed agrees with the number of cards on hand. In addition, the value of the cards purchased should agree with the amount recorded in the general ledger. The inventory reconciliation needs to be performed by an individual who is not responsible for the issuance or custody of the fuel/gift cards (preferably the department approver) and in the presence of the custodian.
Reimbursement via A-19
The completed BFET Participant Reimbursement (PR) form including signatures and card number is not enough to request reimbursement for invoice/billing purposes. A participant receipt must also be provided with the following: date, last four digits of the card, item(s) purchased. Before submitting the PR for reimbursement, the participant receipt is required showing the date, last four digits of the card, and item(s) purchased before reimbursement is allowed. The original receipts of the bulk purchases of the fuel/gift cards does not replace the need for the participant receipt. Once all supporting documentation is received, reimbursement for the PR is allowed.