West Chester University
|PURPOSE||MAKING A PURCHASE|
|ABBREVIATIONS||CARDHOLDER RECORD KEEPING|
|DEFINITIONS||REVIEW OF CARD TRANSACTIONS (STATEMENT OF ACCOUNT)|
|PROCEDURE||MONTHLY ACCOUNT SUMMARIES|
|RECEIVING A PURCHASING CARD||CARD SECURITY|
|AUTHORIZED PURCHASING CARD USE||CARDHOLDER SEPARATION, TRANSFER or TERMINATION|
|UNAUTHORIZED PURCHASING CARD USE|
To establish a methodology for use and to define the limits of use of University issued purchasing cards provided to certain University employees in order to make purchases of goods. The card program is for OFFICIAL UNIVERSITY USE ONLY.
AP... Accounts Payable (WCU disbursements office)
GL... General Ledger (WCU accounting records)
MCC... Merchant Category Code (used to block prohibited acquisitions)
PC or PCard... Purchasing Card (a credit card for official university acquisitions)
PO... Purchase Order
2.2.1 Act 57: The [Pennsylvania] Commonwealth Procurement Code, all provisions of which are incorporated herein by reference.
2.2.2 “Additional Approval Required” items: Also referred to as items that require “Technical Standards Approval”, such as computers. See “Purchasing Guidelines” at web-site referenced below for complete listing of such items. For the purpose of the Purchasing Card program, a department may acquire such advance approvals via e-mail and then attach a copy of the approval document to their receipt document for end-of-month reconciliation of purchasing card purchases, explained in further detail below.
2.2.3 Bank: The banking or financial institution that issues or arranges the issue of cards based upon Enrollment Forms approved by the University. This institution fulfills contractual obligations of the Purchasing Card Program in accordance with a separate contract instrument with the University and the Pennsylvania State System of Higher Education.
2.2.4 Cardholder: Employees who have been issued purchasing cards and who are authorized to make purchases in accordance with these procedures.
2.2.5 Card Administrator (Purchasing Card Administrator): The person responsible for the day to day operation of the program and for training cardholders regarding policy, procedures, and information retrieval.
2.2.6 Fiscal Officer: The person responsible for management of the program, including approval or coordination of approval for all requests for card issuance and changes to accounts. The Assistant Vice President for Finance and Business Services shall serve in this capacity and delegate assignments as needed.
2.2.7 Department or No Name Card: Cards must contain the name of an employee for authentication purposes by merchants and by VISA. Cards that contain only a department name or no (individual's) name are not permitted. Without a name, the cardholder loses the right to dispute unauthorized charges and loses the right of charge backs for incorrect postings or fraudulent use (in the case of lost or stolen cards). All purchasing cards carry "corporate liability" despite the names of individual employees being shown on the card, which is needed to verify the legitimacy of the person who presents the card or a claim against a card. The Department Manager is responsible for reconciliation of all purchases by individuals they authorize to use their department’s assigned card. All cards are imprinted with the words WEST CHESTER UNIVERSITY.
2.2.8 Dispute Charges: Transactions that appear in the cardholder’s statement of account, which the cardholder determines to be incorrect or invalid. The cardholder must immediately activate a dispute resolution, first with the vendor, and if unsuccessful, via the dispute process for any disputed charges.
2.2.9 Level I, II and III data: Varying degrees of specificity in the description of items reflected on card system generated documents or reports, ranging from very limited detail (I level) to much more detailed (III level). The level of data actually obtained is dependent in large part on the quality of card reader equipment at the point of sale (i.e., merchant location).
2.2.10 Merchant: A vendor from which a cardholder is purchasing goods under the provisions of this procedure.
2.2.11 Official Use: The Purchasing Card is for “official university use only”. It may NOT be used for personal use in any manner whatsoever. It may not be used to acquire any goods or services for personal use even with the intent of reimbursing the University for such purchases.
2.2.12 Cost Center Manager: A manager of a unique, WCU organizational or program unit with authority and responsibility for allocation and expenditures of funds from and within the limits of the unit’s approved budget for official university purposes. This individual shall review and approve all cardholder monthly statements of account that are by default charged to the org for which they are responsible.
2.2.13 Purchasing Guidelines: A publication that is provided by the University Purchasing Office to departments and/or employees to assist them in obtaining supplies, and equipment. It is intended as a quick reference to the basic purchasing policies and procedures. The guidelines may be viewed on line via WCU’s homepage. Questions not answered by the Purchasing Guidelines should be referred to the Card Program Administrator designated herein. The “Purchasing Guidelines”, its appendices and all revisions thereto are incorporated herein by reference.
2.2.14 Reconciliation: To check the accuracy of transaction information contained in the Internet based reporting/reconciliation system against cardholder’s receipts/log of transactions; to approve or dispute such transactions; and to authorize payments against default cost center data provided in the report. With the on-line system, transactions can be checked at anytime, but must always be checked at least monthly, i.e., before such transactions are automatically entered into the University’s general ledger. Failure to complete a reconciliation by the expected due date will result in a temporary suspension of account privileges until said reconciliation is provided for review.
2.2.15 Requisitioner: An employee who has a need for goods that can only be fulfilled by a vendor. Under this Purchasing Card Program, a requisitioner may be a cardholder.
2.2.16 Reimbursement Purchases: (STRICTLY PROHIBITED) Employees may NOT make purchases with these cards for personal use goods or services, nor may the cards be used to make such acquisitions even with the intent to reimburse the University.
2.2.17 Statement of Account: This is the listing of all transactions by the cardholder, provided by the bank to cardholders.
2.2.18 Single Purchase Limit: A dollar amount limitation of purchasing authority delegated to a cardholder. This dollar limit may vary from cardholder to cardholder. The Finance and Business Services department will establish appropriate transaction and monthly limits.
2.2.19 Travel Guidelines: A publication that is provided by the University Accounts Payable / Disbursements Office to departments and/or employees to assist them in obtaining travel expense regulations, policies and procedures. This guideline may be viewed on line via WCU’s home page. The “Travel Guidelines”, its appendices and all revisions thereto are incorporated herein by reference.
2.2.20 Velocity Checks: Electronic validation and approval that vendor requests/receives from the Bank (or Bank designee) each time card use is attempted.
This program is being established in order to provide a rapid turnaround of requisitions for low dollar value goods, and to reduce paperwork. By using the Purchasing Card Program the traditional requisition - pricing inquiry - order placement - delivery of goods - invoice - voucher review - payment cycle is greatly reduced. Those requisitioners who have been issued purchasing cards may initiate transactions in-person or by telephone, fax or internet, within the limits of this procedure, and receive goods. Payments to vendors are made via the Visa settlement system. Accounts Payable will make periodic settlements with the bank.
3.2.1 Cost Center managers may propose employees to be cardholders by:
1) Completing the web based Cardholder
2) Submitting (in hard copy form) the completed Cardholder Enrollment Form to the Card Administrator for review and approval.
Following approval, the Card Administrator shall:
1) Notify applicant of any requests denied or requiring additional information.
2) Forward approved applications to the Fiscal Officer for review.
3.2.2 The proposed Cardholder shall be issued a copy of this procedure and shall be required to sign a Cardholder Enrollment Form and an Employee Agreement (see attachments for sample forms). The Employee Agreement indicates that the Cardholder understands the procedure and the responsibilities of a Purchasing Card Program cardholder. The Enrollment Form indicates all information needed to set the Cardholder up properly in the purchasing card system, and shall be electronically submitted to the Bank by the Card Administrator.
3.2.3 The Card Administrator shall, for a minimum of 3 years, maintain all records of Purchasing Card requests approved or disapproved by the Contracting Officer, and limits, cardholder transfers and lost/stolen/destroyed card information.
3.2.4 All cards issued by the Bank shall be received and inspected by the Card Administrator, and then issued to the cardholder.
3.3.1 The Purchasing Card shall only be used by University employees who have been provided training, provided a copy of the University’s applicable Purchasing Card Policy, and who have signed a Cardholder Agreement acknowledging receipt of the above and willingness to comply with all provisions therein.
a) The Finance and Business Services Division
shall provide training sessions and documents to employees
in order to fulfill the above mandatory requirement.
b) Primary cardholders (cost center supervisors) who allow subordinate employees to use cards assigned to them accept full responsibility for training their subordinates, providing them with the current policy documents, and for obtaining a signed Cardholder Agreement from the subordinates, a copy of which much be forwarded to the Card Program Administrator’s office. Primary cardholders may request the Finance and Business Services Division to provide such training, but in any event, employees shall not use cards unless properly trained and authorized.
3.3.2 For all purchases of hazardous materials that trigger regulatory reporting requirements or require specialized handling or disposal, the cardholder must obtain written authorization from the West Chester University Department of Environmental Health & Safety before the purchase is made. Examples of these materials include but not limited to lead-based paint, asbestos-containing products, and chemicals identified as extremely hazardous by the Pennsylvania Department of Labor and Industry Worker and Community Right-to-Know regulations. Materials regulated by the Environmental Protection Agency and the Pennsylvania Department of Environmental Protection which include, but are not limited to pesticides, herbicides, insecticides, radioactive, and chlorofluorocarbons materials must be purchased for and handled by only those authorized University employees who hold current license and/or certifications for the use and handling of these materials.
3.3.3 The unique purchasing card that the Cost Center Manager (primary cardholder) receives shall ONLY be used by persons (secondary cardholders) authorized by the Cost Center Manager within his/her department. NO OTHER PERSON IS AUTHORIZED to use that card. The Cost Center Manager may make transactions on behalf of others in their department, and may authorize persons within the department to use his/her card for official university transactions. However, the cardholder is responsible for all use of his/her card.
3.3.4 Official Use: The card is for “official university use only”. It may be used to acquire goods that will be used directly and immediately for the benefit of official university activities, events, or operations. It may NOT be used for personal use in any manner whatsoever. It may NOT be used to acquire any goods or services for personal use even with the intent of reimbursing the University for such purchases.
3.3.5 Use of the Purchasing Card shall be limited to the following conditions:
a) The total value of a transaction shall not
exceed a Cardholder's single purchase limit. Payment for a
purchase MUST NOT BE SPLIT into multiple transactions to stay
within the single purchase limit.
b) Velocity checks must be passed (i.e. # and $ amount of transactions for a university defined frequency). Each card has a unique, maximum number of transactions that will be allowed each day, a unique dollar limit per transaction, and a credit line limit per month. These “limits” vary from cardholder to cardholder and are based on several factors, such as cost center manager recommendations, demonstrated acquisition needs, and budget allocations given to respective cost centers.
c) Spending limit shall be adhered to.
d) Spending must adhere to the Use of Public Funds policy as well as WCU Policies which supplement this policy.
3.3.6 TAX - The Cardholder shall inform the Vendor that the goods are NOT to be taxed, and point out to the Vendor the University’s tax exemption number which is imprinted on the card. If the vendor requires an official tax exemption certificate, the cardholder shall contact the Card Program Administrator who will fax a copy directly to the vendor.
3.3.7 The items that may be procured by using the credit card are limited by Section 3.4.
3.4.1 The purchasing card SHALL NOT be used for the following:
a) Personal purchases or use of the card for personal identification. The card shall not be used to authenticate your personal identity for non-university business purposes. The card is intended for official university business purposes only, i.e., it is not to be used in any manner for personal purposes. (Strictly Prohibited)
b) The purchase of items for personal use with the intention of reimbursing the University after the purchase. (Strictly Prohibited)
c) A single purchase that exceeds the Cardholder's single purchase limit.
d) Travel related lodging, subsistence, transportation and entertainment expenses. A separate “commercial card” (i.e., a travel card) is available for these type expenses. Contact the Card Program Administrator for more details.
e) Cash Advances
f) Telephone calls/monthly service
g) Development, printing and/ or distribution of any official University document or publication (with official name, seal or logo) without first securing approval of Publications Office, or official public advertising of without the consent of the Public Relations Office.
h) Restricted items, such as alcohol, weapons, drugs [controlled substances], hazardous materials, and other restricted goods and services as enumerated in the University’s “Purchasing Guidelines”, which may be viewed on WCU’s webpages.
i) Purchases of items that will require additional approvals by other divisions of the University as defined in “Purchasing Guidelines” such as:
|Item||Additional Approval By|
|Hazardous materials||Environmental Health & Safety|
|Publications, use of logo, etc.||Publications Office|
|Grants/Sponsored Research||Restricted Funds Office|
j) "Check First" Category Items: Please check for existing sources of items before making acquisitions. Also, existing support capability (e.g., can a particular computer related item be supported by in-house support service area) must be considered in advance of making purchases. Consider these valuable resource contacts on campus:
|Item||Contact for information/availability|
|Memberships or Subscriptions||Library Director|
|Computing hardware/software||Information Services|
|Maintenance/Custodial Supplies||Central Storeroom|
|System or Commonwealth Contracts||Purchasing Office|
|Telephones, Cell Phones, Communication Service Agreements||Telecommunications Office|
Item: Contact for information/availability: Memberships or Subscriptions Library Director Computing hardware/software Information Services Maintenance/Custodial Supplies Central Storeroom System or Commonwealth Contracts Purchasing Office
k) Any other type of purchase prohibited by law, policy or regulation as referenced in the Purchasing Guidelines or during cardholder training.
3.4.2 Restricted Vendors: The Card Program Administrator shall, upon review of purchasing card applications, determine if the University’s card program should exclude some vendor classifications, in which cases certain Merchant Category Codes (MCC) will be blocked (embedded) in the card to be issued. For example, an administrative office would not have authority to make purchases from an automotive body shop and thus, the codes for that category merchant would be blocked from use. Attempts to make a purchase from a merchant of a “blocked” category would be rejected at the point of sale (during “velocity check” process). Denials (i.e., attempts to use the card that are denied) will automatically be included in reports to the Card Program Administrator. When a merchant applies for credit card processing capability, the merchant identifies the category name and code they feel is most appropriate to their business. Sometimes, however, the merchant may select the wrong making the use of the card impossible. a) Cardholders who experience problems with card acceptance by merchants should immediately notify the Card Program Administrator when such problems occur. b) Non-Acceptance of Purchasing Card. If a merchant (that you would routinely like to do business with) simply does not accept cards, the Card Program Administrator should be notified so that attempts can be made to encourage or assist the merchant acquire credit card processing capability. c) Until such a time as the card acceptance issue is corrected, the Cardholder must use non-card procedures to obtain the required goods, such as contacting the Purchasing Office to obtain a purchase order.
3.4.3 A Cardholder or subordinate authorized to use the card (i.e., the card user who makes unauthorized purchases or carelessly uses the credit card) may be liable for the total dollar amount of such unauthorized purchases plus any administrative fees charged by the Bank in connection with the misuse. The Cardholder or card user may also be subject to University disciplinary action. The card account may also be revoked.
3.5.1 University “Procurement Policy Regarding Purchases and Contracts Under $18,500” applies to all card purchases to insure compliance with Board of Governor policies and the Commonwealth Procurement Code (Act 57). This policy may be viewed at the “Purchasing Guidelines” website. Employees are reminded that, under these provisions, it is their responsibility to:
• Ensure purchase costs are reasonable
• Protect public funds as if they were your own
• Make official University business purchases only
• Remind vendors of the University’s tax exemption
• Maintain records for audits and public scrutiny (minimum of 3 years)
• Avoid prohibited purchases (such as alcohol and entertainment)
• Report inappropriate sales or purchase activities by any card user immediately to the University’s Card Program Administrator for further investigation. The Commonwealth Procurement Code, Act 57 requires that any breach of standards be reported to the State Ethics Commission and Attorney General. Purchases made with purchasing cards or travel cards are subject to the code or standards referenced therein.
• Adhere to General Ethical Standards of the Commonwealth, which may be viewed at http://www.ethics.state.pa.us/
• Whenever possible, utilize preferred suppliers who have entered into master contracts or pricing agreements established by the Purchasing Office (see Section 3.5.2a below).
3.5.2 Cardholders should utilize the following "checklist" when making a purchase:
a) Check first to see if goods are already available through existing University resources (Storeroom, Library, Information Services, master supply or service agreements via Purchasing, etc.).
b) Whenever possible, utilize Minority/Women and Small Business Enterprises. Minority/Women Business Enterprise information is available at the Purchasing Office to determine which firms may be able to provide the particular goods that are needed by your department.
c) Once a vendor is selected and confirms that the goods are available, and the vendor can meet your specifications and delivery requirements, etc.:
1. Confirm that the vendor agrees to accept
2. Direct the vendor to include the following information on the shipping label and packing list: Cardholder's name and telephone number, complete delivery address and the vendor's order number.
3. Ask the vendor to include the receipt with the goods when shipping the product.
4. It is extremely important that all purchases be sent to the cardholder ordering the merchandise as this will ensure that the documents necessary for the record keeping listed in Section 3.6 are readily available to the cardholder.
5. If necessary, advise the individual within your area who receives merchandise, of the vendor's name and order number, anticipated delivery date, number of boxes expected, carrier (UPS, Fed Ex, etc.) and to notify the Cardholder when delivery is made.
CAUTION: Cardholders should make prudent selection of shipping options. The cost of shipping heavier packages and/or routine packages via Federal Express or UPS overnight or 2-day express can be very expensive. Such priority handling or expediting of shipments should only be utilized when absolutely necessary. As with all expenditures of public funds, prudence must be demonstrated and expenses justified.
3.6.1 Whenever a purchasing card purchase is made, either over the counter or by telephone, fax or Internet, documentation shall be retained as proof of the purchase or order placement. Such documentation will be used to verify the purchases listed on the Cardholder's monthly statement of account.
3.6.2 When the purchase is made over the counter, the Cardholder shall retain the invoice and "customer copy" of the charge receipt. The Cardholder is responsible to check that the vendor lists the quantity, fully describes the item(s), and has EXCLUDED sales tax, prior to the Cardholder signing the slip. If there is an error or dispute, see section 3.7.10 for details.
3.6.3 When making a purchase by telephone, fax or internet, the cardholder shall also obtain documentation of the transaction.
3.6.4 If the Cardholder instructs the vendor to deliver any items via the Central Receiving Department of the University, the CARDHOLDER MUST NOTIFY Central Receiving immediately regarding the anticipated shipment and receipt of goods. Items received at that location without advance notice of a valid purchase order or purchasing card order will be returned to sender. Purchasing card items received via the Central Receiving Department are treated as “pass through” or “mail handling” transactions, i.e., they will not be inspected nor will receiving reports be generated by Central Receiving for any Purchasing Card purchases.
3.6.5 When the goods are received after placing the telephone, fax or internet order, retain all shipping documentation.
3.6.6 CAUTION: Any documents that contain your Credit Card number should be kept in a secure location to prevent unauthorized personnel from acquiring the number and making fraudulent purchases against your account or any other University account. The number from your card, as well as the card itself and any documents related to card transactions must be treated with security at all times. Don’t leave files, logs, receipts, delivery tickets, statements or other any card number records in vulnerable (insecure) locations.
3.7.1 With the Internet (web-based) reporting system, cardholders can view their accounts on-line at any time. The accounts are updated nightly, so that purchases made one day are normally listed in the cardholder’s on-line statement of account the next day. Some cardholders prefer to monitor and reconcile their account daily (while transactions are fresh in their minds), rather than wait for end of billing cycle reconciling.
3.7.2 At a minimum, cardholders must review their card transactions monthly to insure the accuracy of charges, and to dispute (right away) any inaccurate or incorrect charges.
3.7.3 Training, passwords, and separate instructions will be provided to cardholders to enable them to access, review, dispute, or approve payments (i.e., to reconcile their accounts).
3.7.4 When applicable, submit to the Program Card Administrator written authorization obtained from the Environmental Health & Safety Department and/or license and certification information for the purchase of any hazardous materials identified in section 3.4.
3.7.5 The Cardholder shall…
A) Check each transaction listed against his/her purchasing log, receipts, and shipping documents to verify the statement of account.
B) Create a Statement of Account utilizing PaymentNet® at the end of each billing cycle.
C) Attach the original sales documents, (packing slip, invoice, cash register tape and credit card slips, etc.) in chronological order to the statement of account. This data attachment is critical to provide audit substantiation. IF THIS ROUTINE IS NOT ADHERED TO, THE CREDIT CARD WILL BE REVOKED. The careful matching of complete support documents to the log and to the on-line statement is vital to the successful use of this program. After this review, the Cardholder shall sign the statement, and present the monthly statement (with receipts) to his/her approving Org Manager for approval and signature. The Org Manager shall verify that the reviewed and approved statement is forwarded to the Card Administrator, for incorporation with other cardholders' statements to be reconciled with a monthly summary provided by the bank and consolidated bill to be paid by the University’s Accounts Payable Office.
D) Retain log sheet in department file for future reference or audits.
E) Retain a copy of the statement of account and make copies of receipts for your own department records.
3.7.6 The approving Cost Center Manager shall check the Cardholder monthly statement and receipts and confirm the following items as a minimum:
• Receipts and shipping documents exist
for each purchase.
• The goods were received.
• The Cardholder/s has/have complied with applicable procedures, including this Purchasing Card Program procedure and Purchasing Guidelines.
The Approving Cost Center Manager’s signature/approval of a Cardholder monthly statement indicates that the Cardholder was authorized to make those purchases and those purchases were made in accordance with the applicable procedures for valid, official university purposes.
3.7.7 The Cardholder (if other than the Cost Center Manager) shall review the monthly statements and secure his/her Cost Center Manager’s approval within five (5) working days of receipt. Approved statements and appropriate receipt documents shall be forwarded immediately to the Card Administrator. Statements are due no later than the 10th of the month following the billing date of the account.
3.7.8 If the Cardholder does not have documentation for a transaction listed in the statement, he/she shall attach a “Purchasing Card Missing Receipt Form” for each missing receipt that includes a description of the item(s) purchased, date of purchase, Vendor's name and reason for the lack of supporting documentation.
3.7.9 Purchasing Card Returns - If an item is not satisfactory, received wrong, damaged and/or defective, duplicate order, etc., the cardholder should make contact with the vendor to explain the problem and inquire about return policies.
3.7.10 Errors and Dispute Resolution – If you do not agree with a charge posted to your statement, dispute the charge directly with the vendor. If the error cannot be resolved with the vendor, then the cardholder fills out a dispute form and sends it to the Commercial Card provider. Your next statement should be reduced by the amount of the disputed items. Customer Service will resolve the item within 90 days. Also make a copy of any dispute form/documents and attach it to your end-of-month reconciliation package of materials that is forwarded to the Cost Center Manager and then to the Card Administrator.
3.7.11 If an item has been returned and a credit voucher received, the cardholder shall verify that this credit is reflected on the next statement. If purchased items or credits are not listed on the statement, the appropriate transaction documentation shall be RETAINED by the Cardholder until the next statement. If the purchase or credit does not appear on a statement within 60 days after the date of purchase, the Cardholder or Cost Center Manager shall notify the Card Administrator.
3.7.12 If items purchased by the use of the credit card are found to be unacceptable, the Cardholder is responsible to obtain replacement or correction of the item as soon as possible. If the Vendor has not replaced or corrected the item by the date the Cardholder receives his/her statement, then the purchase of that item will be considered in dispute.
3.8.1 Monthly Account Summaries, listing all transactions (including valid and denied transactions), shall be issued by the Bank (or will be made available on-line) to the appropriate cardholders and Card Program Administrators. These listings will allow the tracking of cardholder activities; act as a checklist for the Card Administrator to anticipate which approved monthly statements are due from which cardholders; and provide information to monitor transaction activity and University policy compliance.
3.8.2 More than two (2) reminders to a Cardholder that an approved monthly statement is delinquent will be grounds for cancellation of the cardholders account.
3.9.1 It is the Cardholder's responsibility to safeguard the purchasing card, passwords and account number to the same degree that a Cardholder safeguards his/her personal credit information. The Cardholder must not allow anyone to use his/her account number for other than authorized purposes. A violation of this trust will result in that Cardholder having his/her card withdrawn and disciplinary action may be taken.
3.9.2 If the card is lost, misplaced, stolen or damaged the Cardholder shall immediately notify the Bank at 1-800-270-7760. Representatives are available 24 hours a day. Advise the representative that the call is regarding a Visa Purchasing Card. The Card Administrator is also to be notified immediately. This phone number may also be used for emergency closure of cards or accounts, or dispute process inquiries.
3.9.3 A new card shall be promptly issued to the Cardholder after the reported loss, damage or theft. A card that is subsequently found by the Cardholder after being reported lost or stolen shall be destroyed.
3.10.1 Prior to separation, transfer or termination from University employment, the Cardholder shall surrender the purchasing card and current receipts and the current purchasing card transaction log to his/her Cost Center Manager. Upon its receipt, the Cost Center Manager shall review, approve and forward to Card Administrator the month end Billing Statement with receipts and the destroyed card (cut in half). The University’s Card Program Administrator must confirm notification (to the Bank) of “End of Employment” or “End of Card Authorization” within 2 business days of the ending date. Failure to recover cards, documentation and provide prompt notice increase the University’s potential liability for card misuse.