Separation of Duties

Separation of duties ensures that each person's work acts as a complementary check against another's. No one person should be responsible for an entire transaction. It is the department's responsibility to ensure that appropriate separations exist within their Purchasing Card roles. For more on the responsibilities of each role, see PPM 350-22.

To ensure adequate separation of duties, the Purchasing Card roles should be filled by a minimum of three people within the department. If you need assistance in establishing a 3-person separation of duties, you may want to contact your department's business or dean's office.

Place Order Reconcile Bank Statement Receive Items Initiate FPD Approve FPD Perform Monthly Ledger Review*

Cardholder Must Must May May No No

Account Manager/Delegate No No May May Must No

Ledger Reviewer No No May No No Must

If a department is unable to maintain a three-person separation of duties, a two-person option can be utilized:

Place Order Reconcile Bank Statement Receive Items Initiate FPD Approve FPD Monthly Ledger Review (Reconcile FPD*) Monthly Ledger Review (Reconcile DC)

Cardholder Must Must May May No Must, if applicable** No

Account Manager No No May May Must No Must

* Only necessary if transaction is not auto-annotated in the Ledger Review system.
** Only applicable if the FPD was fully approved in DaFIS.

Note: The account manager/delegate cannot be subordinate to the cardholder.

The following resources are available to assist departments in implementing a successful separation of duties:

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