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    AFARS Appendix EE eludes that the GPC cannot be used "after the fact" but there are little to no inferences of it anywhere else. Can you use the GPC to pay for a bill 4 months after the fact, provided that money was allocated at the time to cover the purchase?


    Answer

    https://www.acq.osd.mil/dpap/pdi/pc/docs/3_GPC_Responsabilities.pdf

    I've pasted a link above to the overarching DoD guidance on Government Purchase Card responsibilities.  Moreover, local procedures that are in concert should always be followed for more detailed guidance as well.  That said, we will delve into the specific question a bit.

    Of course, proper documentation is always necessary.  This would include the request for purchasing action, funds availability, verifying that a mandatory source of supply does not exists, etc. The presumption is that the cardholder would document most of this in doing  the necessary due diligence before purchasing anything.  In this specific case, the crux of the problem is that the bill arrived after the fact and the devil is always in the details. 

    If the aforementioned due diligence was performed when placing the order, then an administrative billing error is not a significant problem; i.e., page 8 of 22 on the attached states that one of the cardholder responsibilities is to inform the merchant that billing can not occur until shipment or delivery occurs (or performance in this case).  More explicitly, if the cardholder had done the proper due diligence and documentation accordingly and in advance, the bill arriving late is not an issue because it was submitted appropriately after performance and the late billing impacts the merchant and not the U.S. Government pecuniarily.  If, however, the proper up front documentation and due diligence was not performed, then this is another matter entirely.  I recommend speaking with your approving official about this specific matter and get some guidance on how to proceed.


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