0101 Overview

This chapter establishes the Department of Veterans Affairs’ (VA) financial policies and procedures regarding the procurement of goods and services under the micro-purchase limit using convenience checks.

Key points covered in this chapter:

• The use of convenience checks is strongly discouraged due to inherent risk associated with their use;
• All rules, requirements, penalties, standards, and internal controls found in Volume XVI, Chapter 1A, and Chapter 1B must be adhered too when using Convenience checks;
• Convenience check accountholders must be nominated by either the employee’s direct-line supervisor or their AO and must be permanent VA employees;
• Convenience checks may not be written for an amount in excess of one half of the micro-purchase threshold [for purchase cards] per section 1902(a) of title 41, United States Code;
• When a convenience check is used, the accountholder must document the fact that the vendor would not accept the purchase card and that no other sources were available; and
• The convenience check accountholder must report lost or stolen checks to their AO, Level 4 A/OPC, and the servicing bank immediately.

0102 Revisions

Section	Revision	Requesting Office	Reason for Change	Effective Date
Various	Completed full review	OFP	Updated guidance	December 2024
0103	Updated several definitions	OFP	Consistency among financial policies	December 2024
0106	Updated Authorities and References to current guidance	OFP	Full review	December 2024

0103 Definitions

Convenience Check – Convenience checks are written against a purchase card account in the issuing bank. Convenience checks are a payment and/or procurement tool intended only for use with merchants that do not accept purchase cards. Convenience checks should be used as a payment method of last resort, only when no reasonable alternate merchant is available who accepts the purchase card.

Convenience Check Accountholder –A VA employee who has been delegated authority to commit funds on behalf of the government and has successfully completed all mandatory training requirements.   

VA Form 0242c – Government Convenience Check Certification Form is used to delegate authority to an individual to use the convenience check to procure and pay for goods and services.

Internal Controls –Systematic measures which include periodic and continuous monitoring, checks and balances, policies, procedures, and segregation of duties implemented to reduce the risk of error, fraud, waste, and abuse.

0104 Roles and Responsibilities

Assistant Secretary for Management and Chief Financial Officer (ASM/CFO) oversees all financial management activities relating to the direction, management, and administration of the VA Purchase Card Program.

Supervisors are responsible for ensuring that checkholders, AOs, or A/OPCs in their line of authority are in compliance with this policy and for assessing appropriate disciplinary actions.

Agency/Organization Program Coordinators (A/OPCs) oversee the card program(s) for his or her agency/organization; establish convenience checkholder accounts in the servicing bank’s Electronic Access System (EAS); serve as liaison between the checkholder and the servicing bank; provide on-going advice; review purchase card account activity; maintain necessary account information; monitor and track card program participants that violate policy; and ensure that the offices take appropriate action to address any instances of policy violations.

Level 1 A/OPC The Financial Services Center (FSC) Charge Card Operations Division serves as the Level 1 A/OPC.

Level 2 A/OPC provides technical advice and guidance to the lower-level A/OPCs and reports within 15 days any policy violations and resulting corrective actions to the Level 1 A/OPC. Also provides oversight of the Purchase Card Program at the Administration level for the Veterans Health Administration (VHA), Veterans Benefits Administration (VBA), National Cemetery Administration (NCA), Office of Information and Technology (OI&T), Office of the Inspector General (OIG), and VA Central Office (VACO).

Level 3 A/OPC serves as a liaison between Level 2 A/OPC and Level 4 A/OPCs. Level 3 A/OPCs are currently only being utilized by VHA. Level 3 A/OPCs, also known as Purchase Card Program Managers, are responsible for:

• Providing technical advice and guidance to the lower-level A/OPCs;
• Providing initial and refresher training and guidance to Level 4 A/OPCs;
• Reporting violations and disciplinary actions to the next level A/OPC;
• Providing oversight of the Purchase Card Program at the station-level;
• Providing technical guidance for all convenience checkholders and AOs under his/her hierarchy;
• Analyzing the effectiveness, efficiency, and productivity of the Purchase Card Program;
• Investigating potential violations and fraud indicators; and
• Managing and responding to external oversight organizations.

Level 4 A/OPC is responsible for the following:

• Entering the checkholders account application in the servicing bank’s EAS;
• Monitoring and tracking policy violations;
• Ensuring that supervisors take appropriate actions to address violations;
• Reporting violations and disciplinary actions to the next level A/OPC;
• Providing oversight of the Purchase Card Program at the station-level;
• Ensuring mandatory purchase card training is completed and up to date for all checkholders;
• Providing technical guidance for all checkholders and AOs under his/her hierarchy;
• Analyzing the effectiveness, efficiency, and productivity of the Purchase Card Program;
• Investigating potential violations and fraud indicators; and
• Managing and responding to external oversight organizations.

Approving Officials (AOs) are responsible for the following:

• Working with direct line supervisors to identify qualified employees to be convenience checkholders;
• Recommending single purchase and monthly purchase thresholds in conjunction with the A/OPC, Fiscal Office, and the delegating authority;
• Providing guidance to convenience checkholders in response to issues they raise related to use of the purchase card;
• Ensuring that only authorized purchases are made;
• Ensuring timely reconciliation of charges made by checkholders;
• Reporting to the Level 4 A/OPC whenever checks are lost, stolen, or compromised;
• Monitoring and reporting to the A/OPC when checkholders transfer, retire, are terminated, or for any other reason have no further need of a purchase card;
• Monitoring and reporting disciplinary actions resulting from checkholder misuse within 5 days to the Level 4 A/OPC;
• Review spending thresholds and the need for cards annually in accord with 41 U.S.C. §§ 1902, 1909; and
• Completing mandatory training related to their approving official duties.

Convenience check accountholders ensure proper adherence to convenience check policies, and are limited to acquisition, logistics, finance personnel, prosthetics, and other such personnel approved on a limited basis by the level 2 A/OPC. Accountholders are responsible for the following:

• Completing mandatory training related to their convenience check duties;
• Surrendering the convenience checks upon termination of employment, retirement, or transfer to a new position;
• Being knowledgeable of convenience check policies, hierarchy of purchases, and the limitations on spending thresholds and vendor selection; 
• Reporting to the AO, Level 4 A/OPC, and servicing bank whenever convenience checks are lost, stolen, or compromised;
• Making authorized purchases; and
• Uploading documentation related to purchases to an automated imaging system.  Documentation must include proof that the merchant does not accept a charge card or use EFT.

0105 Policies

010501 General Policies

1. The use of convenience checks is strongly discouraged due to inherent risk associated with their use. Convenience checks may only be used as a last resort and only when a vendor cannot be located who will accept the purchase card or EFT. When a convenience check is used, the accountholder must document the fact that the vendor would not accept the purchase card and no other sources were available.
2. The convenience check program is a subset of VAs government purchase card program, as such all rules, requirements, penalties, standards, and internal controls found in Volume XVI, Chapter 1A Administrative Actions for Government Purchase Cards, and Chapter 1B Government Purchase Card for Micro-Purchases, must be adhered too when using Convenience checks.
3. The employee seeking checks must have completed all training required in Volume XVI, Chapter 1A Administrative Actions for Government Purchase Cards, and Chapter 1B Government Purchase Card for Micro-Purchases before requesting convenience checks from the bank.
4. Per Public Law 115-91, “[a] convenience check may not be used for an amount in excess of one half of the micro-purchase threshold [for purchase cards] under section 1902(a) of title 41, United States Code, or a lower amount established by the head of the agency.” Refer to Volume XVI, Chapter 1A Administrative Actions for Government Purchase Cards, and Chapter 1B Government Purchase Card for Micro-Purchases for the current micro-purchase thresholds associated with the purchase card program.

010502 Obtaining Convenience Checks from the Bank

1. A convenience check accountholder must be nominated by either the employee’s direct-line supervisor or their AO.
2. Convenience check accountholders, AOs and A/OPCs must be permanent VA employees. Contractors cannot be accountholders, AOs, or A/OPCs.
3. Government-wide Convenience Check Certification Form (VA FORM 0242c) must be completed to appoint a convenience check accountholder or AO.
4. VA Form 0242c must be updated when the following changes occur:
   • Change in AO or Alternate AO;
   • Increasing the single purchase limit higher than the originally requested amount; and
   • When a convenience check accountholder has a legal name change.
5. Level 4 A/OPCs must submit new convenience check account applications in the servicing bank’s EAS/OPCs
6. Level 4 A/OPCs must ensure that issued convenience checks bear the convenience check accountholder’s name as it appears in the Global Address List (GAL).
7. All new convenience check accounts as well as orders for new checks on existing accounts must go through the Level 1 A/OPC for approval.

010503 Use of Convenience Checks

1. Convenience checks may not be written for an amount in excess of one half of the micro-purchase threshold [for purchase cards] under section 1902(a) of title 41, United States Code.
2. Convenience checks may only be used as a last resort when acquiring goods or services.
3. Convenience checks should only be used when a merchant  or supplier cannot be found that accepts purchase cards.
4. The convenience check accountholder shall verify that the selected vendor does not accept charge cards or electronic funds transfer (EFT) and no other vendor can be located who will accept a charge card or EFT for the same goods or services.
5. All checks written to an individual must be reported to the FSC.
6. FSC will track all checks written to individuals and issue 1099’s in accordance with all applicable rules and regulations.
7. Check Requirements:
   • The convenience check accountholder’s legal name must be printed on the face of the convenience checks;
   • Only the accountholder may sign convenience checks;
   • Convenience checks must be used in sequential order;  
   • Any convenience check that is issued or voided must be entered in a check register or log for tracking purposes.
8.  Convenience checks may not be used for honorarium payments.

010504 Special Circumstances

1. The convenience check accountholder must report lost or stolen checks to their AO, Level 4 A/OPC, and the servicing bank immediately. The local level A/OPC will contact the Level 1 A/OPC for replacement convenience checks.
2. Payment can be stopped on a convenience check if it has not yet posted to the account. To initiate a stop payment request, accountholders should contact the issuing bank.

0106 Authorities and References

• Public Law
  • Public Law 104-134, the Debt Collection Improvement Act of 1996
  • Public Law 115-91, National Defense Authorization Act for Fiscal Year 2018
• Executive Order 12931, Federal Procurement Reform
• OMB Circular A-123, Appendix B, Improving the Management of Government Charge Card Programs
• Federal Acquisition Regulation part 32.1103
• Federal Acquisition Streamlining Act of 1994
• VA Directive and Handbook 7401.7, Unauthorized Commitments and Ratification

0107 Rescissions

VA Financial Policy, Volume XVI, Chapter 1, Government Purchase Card Program dated February 27, 2019.

Appendix A: Previous Policy Revisions

Section	Revision	Office	Reason for Change	Effective Date
Various	Added reference language	OFP (047G)	Updated language referencing 1A and 1B to avoid any potential confusion on the word “requirement”	February 2019
All	New Policy	OFP (047G)	Create separate chapters from Volume XVI – Charge Card Programs/Chapter 1 Government Purchase Card Program	June 2018
Various	Reformatted to new policy format and completed 5 year review.	OFP  (047G)	Reorganized chapter layout	June 2018
Various	Roles and Responsibilities	OFP  (047G)	Strengthened Internal Controls and updated language on accountability to be more clear and concise.	June 2018