Contract Management
Government Faces Challenges in Gathering Socioeconomic Data on Purchase Card Merchants Gao ID: GAO-03-56 December 13, 2002Government purchase cards have streamlined the process of acquiring goods and services by allowing employees to purchase directly from merchants rather than going through the regular procurement process. The government spent $13.8 billion using purchase cards in fiscal year 2001. However, the government does not know how purchase card spending impacts small businesses and other socioeconomic categories, such as woman-owned small businesses, and small disadvantaged businesses. Because of these uncertainties, the General Services Administration (GSA), which administers the purchase card program, has begun to collect socioeconomic data on merchants doing business with the federal government through purchase cards. This report assesses GSA's efforts and identifies the challenges to collecting and reporting this data.
GSA's effort to collect socioeconomic data in fiscal year 2001 was ineffective because of incomplete, inconsistent, and, therefore, unreliable data gathered by banks and payment card associations on behalf of GSA. The data were inconsistent primarily because GSA did not precisely define criteria for the information it was seeking from the banks. Therefore, no meaningful conclusions can be drawn at this time about where agencies spend purchase card dollars or the effect of purchase cards on small businesses. Nevertheless, GSA has been working with the Small Business Administration, the Department of Defense, and the private sector to develop strategies to improve the data's reliability. By building on the lessons learned in its initial attempt to collect the data, GSA hopes to produce more reliable socioeconomic data for future fiscal years. We identified several challenges that prevent GSA from gathering data on 100 percent of the merchants doing business with the federal government. These challenges stem from the nature of the purchase card transaction processing system, which focuses on the data needed to ensure that the merchant is paid and the cardholder's account is charged. It is not designed to collect socioeconomic data for the government. Despite the challenges that prevent the collection of socioeconomic data on all purchase card merchants, well-defined criteria and consistent use of available data sources would provide decisionmakers with a clearer picture of the extent to which small businesses are receiving federal dollars through purchase cards.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-03-56, Contract Management: Government Faces Challenges in Gathering Socioeconomic Data on Purchase Card Merchants
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Report to Congressional Committees:
United States General Accounting Office:
GAO:
December 2002:
CONTRACT MANAGEMENT:
Government Faces Challenges in Gathering Socioeconomic Data on Purchase
Card Merchants:
GAO-03-56:
Highlights:
Highlights of GAO-03-56, a report to Congressional Committees
CONTRACT MANAGEMENT
Government Faces Challenges in Gathering Socioeconomic Data on
Purchase Card Merchants
Why GAO Did This Study:
Government purchase cards have streamlined the process of acquiring
goods
and services by allowing employees to purchase directly from merchants
rather than going through the regular procurement process. The
government
spent $13.8 billion using purchase cards in fiscal year 2001. However,
the government does not know how purchase card spending impacts small
businesses and other socioeconomic categories, such as woman-owned
small
businesses, and small disadvantaged businesses. Because of these
uncertainties,
the General Services Administration (GSA), which administers the
purchase card
program, has begun to collect socioeconomic data on merchants doing
business
with the federal government through purchase cards. This report
assesses
GSA‘s efforts and identifies the challenges to collecting and
reporting this
data.
What GAO Found:
GSA‘s effort to collect socioeconomic data in fiscal year 2001 was
ineffective
because of incomplete, inconsistent, and, therefore, unreliable
data gathered
by banks and payment card associations on behalf of GSA. The data
were
inconsistent primarily because GSA did not precisely define
criteria for the
information it was seeking from the banks. Therefore, no meaningful
conclusions
can be drawn at this time about where agencies spend purchase card
dollars or the
effect of purchase cards on small businesses. Nevertheless, GSA has
been working
with the Small Business Administration, the Department of Defense,
and the
private sector to develop strategies to improve the data‘s
reliability. By building
on the lessons learned in its initial attempt to collect the data,
GSA hopes to
produce more reliable socioeconomic data for future fiscal years.
We identified
several challenges that prevent GSA from gathering data on 100
percent of the
merchants doing business with the federal government. These
challenges stem from
the nature of the purchase card transaction processing system,
which focuses on
the data needed to ensure that the merchant is paid and the
cardholder‘s account
is charged. It is not designed to collect socioeconomic data
for the government.
Despite the challenges that prevent the collection of
socioeconomic data on all
purchase card merchants, well-defined criteria and consistent
use of available data
sources would provide decisionmakers with a clearer picture of
the extent to which
small businesses are receiving federal dollars through purchase
cards.
Overview of the Purchase Card Transaction Data Flow.
[See PDF for Image]
[End of Figure]
What GAO Recommends:
We recommend that the Administrator of GSA (1) clarify the
socioeconomic
information requested from banks and payment card associations
and ensure
the data is consistent, and (2) specify a disciplined approach
for identifying
sources of socioeconomic data. GSA agreed with our
recommendations.
To view the full report, including the scope and methodology,
click on the
link above. For more information, contact Dave Cooper at
(202) 512-4841 or
cooperd@gao.gov.
Contents:
Letter:
Results in Brief:
Background:
Data Collected to Date Are Inconsistent and Incomplete, but
Improvements Are Being Made:
Inherent Challenges Prevent Collection of Socioeconomic Data on All
Purchase Card Merchants:
Conclusions:
Recommendations for Executive Action:
Agency Comments:
Appendix I: Scope and Methodology:
Appendix II: Comments from the General Services Administration:
Appendix III: Comments from the Small Business Administration:
Appendix IV: Comments from the Bank of America:
Appendix V: Comments from Austin-Tetra:
Table:
Table 1: Small Business Categories:
Figures:
Figure 1: Overview of the Purchase Card Transaction Data Flow:
Figure 2: Overview of the Socioeconomic Data Collection Process:
Abbreviations:
DOD Department of Defense
FPDS Federal Procurement Data System
GSA General Services Administration
NAICS North American Industrial Classification System
SBA Small Business Administration:
United States General Accounting Office:
Washington, DC 20548:
December 13, 2002:
The Honorable John F. Kerry
Chairman
The Honorable Christopher S. Bond
Ranking Minority Member
Committee on Small Business and Entrepreneurship
United States Senate:
The Honorable Donald A. Manzullo
Chairman
The Honorable Nydia M. Velázquez
Ranking Minority Member
Committee on Small Business
House of Representatives:
The amount of money spent on goods and services via government purchase
cards has increased rapidly over the past decade. In fiscal year 2001,
the federal government spent $13.8 billion in transactions using
government purchase cards for individual purchases--the vast majority
of which are under $2,500--and for payment on existing contracts.
Purchase cards streamlined the process of acquiring goods and services
by authorizing a broad range of government employees to purchase
directly from merchants[Footnote 1] rather than going through the
regular procurement process. However, because the government does not
collect detailed socioeconomic data on purchase card expenditures and
cannot accurately determine the share of such expenditures going to
small businesses, the impact of purchase cards on small businesses is
unknown. Currently, individual purchase card transactions are not
counted toward achievement of the annual governmentwide goal of
awarding 23 percent of prime contract dollars to
small businesses.[Footnote 2]
Federal agencies, along with the congressional small business
committees, would like to capture data on purchase card merchants to
track the amount of spending that is going to small businesses. They
believe that better data would enable decisionmakers to assess the
impact of purchase card policies on small businesses. In October 2001,
the General Services Administration (GSA), which administers the
purchase card program, took steps to collect socioeconomic data on
merchants doing business with the government through purchase cards
during fiscal year 2001. The Department of Defense (DOD), payment card
associations (MasterCard and Visa), and the five banks under contract
with GSA as card issuers[Footnote 3] also participated in GSA‘s effort.
Because of the uncertainties about the impact of purchase cards on
small businesses, you requested that we (1) assess GSA‘s governmentwide
efforts to collect data on the socioeconomic status of merchants and
(2) identify the challenges to collecting and reporting the data. You
also asked us to verify the information collected by the banks and
payment card associations by means of a survey. However, due to the
lack of basic data on many purchase card merchants, we determined that
such a survey would not be feasible. Our scope and methodology section
sets forth our rationale in greater detail (see app. I).
Results in Brief:
GSA‘s effort to collect socioeconomic data on purchase card merchants
for fiscal year 2001 was ineffective due to inconsistent and
incomplete--and therefore unreliable--data. Thus, it is impossible to
come to any meaningful conclusions about the distribution of purchase
card dollars based on that effort. Due to GSA‘s lack of clear
definitions and guidance for the collection of socioeconomic data, the
banks and payment card associations--MasterCard and Visa--interpreted
the initial data request differently and reported the data
inconsistently. In addition, payment card associations were unable, in
many cases, to collect complete and reliable information from the
available sources of socioeconomic data. Since May 2002, GSA has taken
a number of steps to improve the data it collects from banks and
associations. For example, GSA has hosted several working meetings with
officials from the Small Business Administration (SBA), DOD, the Office
of Management and Budget‘s Office of Federal Procurement Policy, and
the private sector to develop strategies to improve the data‘s
reliability. GSA hopes to collect more reliable socioeconomic data on
purchase card merchants for future fiscal years.
Notwithstanding the ongoing efforts to improve the reliability of the
data, inherent challenges will limit the government‘s ability to gather
data on 100 percent of the merchants. These challenges suggest that
complete socioeconomic information cannot be captured for all of the
purchase card merchants. The data captured by the transaction
processing systems focus on information needed to ensure that the
merchant is paid and the cardholder‘s account is charged. Challenges to
collecting data include:
* GSA‘s contract with the card-issuing banks cannot ensure collection
of socioeconomic data on purchase card merchants.
* A purchase card transaction between the government and a merchant
does not establish a contractual relationship that requires the
merchant to provide socioeconomic data, and, in fact, a significant
number of merchants are not reporting such data. Attempts by government
agencies, banks, and payment card associations to collect socioeconomic
data directly from merchants have produced poor results.
* According to banks and payment card associations, banks do not
generally collect socioeconomic data when merchants apply to accept
payment cards, because the banks are concerned about possible
discrimination complaints as well as client privacy.
While these challenges suggest that the government cannot capture
complete socioeconomic data on all purchase card merchants, our
recommendations to GSA focus on steps that can provide more
consistent and complete data on those merchants whose information
is retrievable. In comments on a draft of this report, GSA concurred
with our recommendations. We also received comments from SBA, the
Office of Federal Procurement Policy, Visa, Mastercard, the three
largest card-issuing banks, and Austin-Tetra, a private sector firm,
none of which disagreed with our findings.
Background:
The Federal Acquisition Streamlining Act of 1994 established a
micropurchase threshold of $2,500. Purchases that do not exceed the
threshold are not subject to the Small Business Act reservation
requirement,[Footnote 4] may be made without obtaining competitive
quotations (if the price is reasonable), and may be made by authorized
government employees--such as those who will be using the supplies or
services--not just by contracting officers. Under the Federal
Acquisition Regulation, the governmentwide commercial purchase card is
now the preferred method of paying for micropurchases. Further, the
purchase card is also authorized to be used in greater dollar amounts
to place a task or delivery order under an existing contract (if
authorized in the basic contract, basic ordering agreement, or blanket
purchase agreement) and to make payments under existing contracts when
the contractor agrees to accept payment by the card.
GSA administers the purchase card program governmentwide. This program
has issued more than 2 million purchase cards to federal employees at
government agencies, organizations, and Native American tribes.
Purchase card volume increased by almost $1.5 billion, to $13.8
billion, between fiscal years 2000 and 2001. GSA‘s master contract for
the purchase card program defines the agreement between GSA and the
five banks that issue purchase cards to government agencies. The
government may exercise the option to renew the contract for up to five
1-year periods beginning in December 2003.
In October 2001, GSA requested that the five banks provide data on
the socioeconomic status of merchants who did business with the
government via purchase cards in fiscal year 2001. An estimated
4 million U.S. merchants accept MasterCard, Visa, or both, and at least
2.1 million of these merchants did business with the government in
fiscal year 2001.[Footnote 5] Because the banks that issue purchase
cards do not have access to data on all of the merchants accepting the
cards, MasterCard and Visa collected this information on the banks‘
behalf, contracting in one case with Austin-Tetra, a private firm, to
assist in the task.[Footnote 6] GSA compiled the information provided
by banks and associations in a March 2002 preliminary report.
In their efforts to improve the collection of socioeconomic information
on purchase card merchants and to track governmentwide small business
goals, SBA and GSA are interested in targeting the categories of
businesses outlined in table 1.
Table 1: Small Business Categories:
Category: Small business; Definition: A business entity organized for
profit, including affiliates, that is independently owned and operated,
not dominant in the field of operations in which it is bidding, and
qualifies under SBA‘s criteria for determining the size of the
business. The definition varies by industry and is based on the number
of employees or the gross revenues..
Category: Woman-owned small business; Definition: A small business that
is at least 51 percent woman-owned, and whose management and daily
business operations are controlled by one or more women..
Category: 8(a) business; Definition: A small business that is at least
51 percent owned by and whose management and daily business operations
are controlled by socially and economically disadvantaged individuals
who are eligible to receive federal contracts under the SBA‘s 8(a)
Business Development Program. Under this program, SBA enters into
contracts with federal agencies and lets subcontracts for performing
those contracts to eligible firms. To qualify for the program, a firm
must be certified by SBA..
Category: Small disadvantaged businesses; Definition: A small business
that is at least 51 percent owned by, and (with certain exceptions)
whose management and daily business operations are controlled by, one
or more socially and economically disadvantaged individuals. SBA
certifies small disadvantaged businesses to make them eligible for
certain procurement benefits. Certification strictly pertains to
benefits in federal procurement. Firms certified as 8(a) automatically
qualify for certification as a small disadvantaged business..
Category: HUBZone small business; Definition: The HUBZone (Historically
Underutilized Business Zone) Empowerment Contracting Program[A]
provides Federal contracting assistance to small businesses that are
located in designated rural and urban areas and that hire employees who
live in such areas. SBA certifies firms for eligibility to receive
HUBZone contracts and maintains a listing of qualified HUBZone small
businesses that federal agencies can use to locate prospective
vendors..
Category: Veteran-owned small business; Definition: A small business
that is at least 51 percent owned by, and whose management and daily
business operations are controlled by, one or more veterans..
Category: Service-disabled veteran-owned small business; Definition: A
small business concern that is at least 51 percent owned by, and whose
management and daily operations are controlled by, one or more service-
disabled veterans, or, in the case of a veteran with a permanent and
severe service-connected disability, by the spouse or permanent
caregiver..
[A] Established by the Small Business Reauthorization Act of 1997.
Source: GAO analysis.
[End of table]
The purchase card transaction process involves the agency cardholder,
the merchant and its bank, the payment card associations, and the banks
that issue purchase cards to government agencies. When an agency
cardholder purchases goods or services from a merchant that accepts
MasterCard or Visa, the merchant transmits the transaction to its bank,
through the MasterCard or Visa computer systems, to the issuing bank
for payment. Figure 1 shows how transaction data are shared between the
key players.
Figure 1: Overview of the Purchase Card Transaction Data Flow:
[See PDF for Image]
[End of Figure]
Socioeconomic data are generally collected after a transaction takes
place. The payment card association or its contractor collects
socioeconomic information from a variety of sources. This information
is appended to transaction data to create reports to GSA and the
agencies. Figure 2 shows the key players involved in collecting
socioeconomic information on the purchase card merchants.
Figure 2: Overview of the Socioeconomic Data Collection Process:
[See PDF for Image]
Note: Pro-Net is the SBA‘s internet-based database of information on
more than 91,000 small businesses. Central Contractor Registration is
the primary vendor database for DOD, the National Aeronautics and Space
Administration, and the Departments of Transportation and Treasury.
Current and potential government vendors are required to register in
order to be awarded contracts by these agencies. The Federal
Procurement Data System is the central repository of statistical
information on federal contracting. The system contains detailed
information on contract actions over $25,000 and summary data on
procurements that do not exceed $25,000.
[End of Figure]
Data Collected to Date Are Inconsistent and Incomplete, but
Improvements Are Being Made:
In response to GSA‘s request for fiscal year 2001 socioeconomic data
on purchase card merchants, banks and payment card associations
reported that they could obtain size or socioeconomic information on
about 40 percent of the merchants. They reported that about 50 percent
of the purchase card dollars spent with these merchants went to small
businesses. However, this information is not useful because the data
collected were inconsistent and incomplete, making them unreliable.
The lack of clear definitions and guidelines from GSA for the
collection of socioeconomic data resulted in inconsistent reporting by
the banks and payment card associations. In addition, some available
sources of socioeconomic data are incomplete and unreliable. Therefore,
at this time, no meaningful conclusions can be drawn about where
purchase card dollars are spent or the effect on small businesses of
the government use of purchase cards. Drawing on lessons learned in its
first attempt at a governmentwide socioeconomic data report, GSA is
continuing to work with SBA, DOD, and the private sector to improve the
reliability of the data for subsequent reports.
Inconsistent Data Due to Lack of Clear Definitions and Guidelines:
To verify and identify the characteristics of those merchants doing
business with the government through purchase cards, a match had to be
made between transactional data and the socioeconomic data from
government and private databases.[Footnote 7] However, in its initial
data collection effort, GSA did not precisely define the information it
was requesting or clearly specify the criteria to be used by the banks
and associations as they categorized merchants. Therefore, the data
reported to GSA contained widely varying information on the
socioeconomic status of merchants. The following are examples of the
inconsistencies we found:
* A payment card association, reporting on behalf of some of the card-
issuing banks, reported that it had socioeconomic information for
89 percent of the merchants, while another bank reported that it had
this information for 23 percent of the merchants. These differences do
not reflect relative success or failure in collecting the information;
rather, they were due to varying interpretations of GSA‘s guidance.
* Neither the associations nor the banks reported the number of
merchants whose socioeconomic status was unknown. As a result, the
information presents an incomplete and misleading picture of the
socioeconomic status of purchase card merchants.
* MasterCard, Visa, and the banks used different methods to classify
merchants. One method placed businesses that were corporations but
where no socioeconomic data were available in the same category with
large businesses. Another method followed SBA standards more closely in
categorizing the size of businesses.
In one case, GSA‘s guidance compounded the problem. GSA instructed
banks to use the criterion of 500 employees or fewer to identify small
businesses, if no other verification was available, rather than
directing them to follow SBA‘s guidance that ties size to specific
industry classifications. SBA officials, who had not been involved in
GSA‘s initial data collection effort, raised concerns about this
definition and are now providing GSA with assistance in determining
appropriate guidelines to categorize the data. An SBA official
explained that, in certain industry categories such as construction,
using 500 employees or fewer as a criterion would encompass virtually
all businesses.
Data Are Incomplete and Unreliable:
No meaningful conclusions can be drawn using the data compiled by GSA
for fiscal year 2001, as the reported data are incomplete. The banks
and payment card associations were only able to establish merchants‘
size or socioeconomic status for about 40 percent of total purchase
card dollars because, in some cases, available data sources did not
provide complete and reliable information. For example, Pro-Net yielded
information on size status for only 9.5 percent of merchants. While
some categories of small businesses are required to register in SBA‘s
Pro-Net in order to be certified, other categories of small business
are not required to register. Therefore, businesses requiring
certification, such as HUBZone and small disadvantaged businesses, are
easier to categorize than businesses for which registration is
voluntary, such as woman-owned small businesses.
Further, according to industry officials, it is not uncommon for the
data in some merchant transaction data fields to contain incorrect
information. For example, merchants sometimes place their customer
service telephone numbers in the field designated for city so that
their telephone number is included on the customer‘s credit card
statement. In our review of MasterCard and Visa reports and merchant
data files, we found obvious errors such as this, as well as duplicate
files for the same merchant, the same telephone number for multiple
businesses, and missing zip codes.
GSA, Agencies, and Private Sector Working to Improve Data:
Since the spring of 2002, GSA has been working with SBA and other
agencies to create more specific guidance for banks and payment card
associations. GSA has also included banks and payment card associations
in these discussions. GSA‘s efforts include defining small business
categories, establishing quality standards for data sources, and
standardizing reporting. After some initial data have been collected,
SBA officials agreed to develop policies for the use of the data in
tracking progress towards agencies‘ small business goals. According to
officials from Austin-Tetra, if definitions and guidelines are agreed
upon and adhered to, information about size status may be available for
an estimated 65 to 80 percent of merchants.
Some officials expressed concern about the potential for double-
counting small business dollars if, in the future, purchase card data
are automatically transferred to the Federal Procurement Data System
(FPDS) and socioeconomic data are applied toward agencies‘ small
business achievements. If purchase cards are used for payments on
contracts or orders that have already been reported to FPDS, double-
counting could occur. However, it is not clear that this problem would
materialize on a widespread basis. For example, the Director of DOD‘s
Purchase Card Joint Program Management Office told us that there is
little likelihood that DOD‘s dollars would be double-counted.
Currently, DOD generates automatic reports to FPDS for contracts or
orders that are placed through traditional procurement methods such as
purchase orders. The official said that it is extremely rare for a
purchase card to be used for payments that have already been reported
to FPDS.
Inherent Challenges Prevent Collection of Socioeconomic Data on All
Purchase Card Merchants:
While GSA‘s efforts eventually may enable the government to obtain
socioeconomic information on a large percentage of purchase card
merchants, inherent challenges suggest that it is not possible to
gather complete data on all merchants. Payment card associations‘
transaction systems were designed to clear transactions, not to meet
the socioeconomic reporting needs of the federal government. The data
exchanged during transactions generally focus on information needed to
ensure that the merchant is paid and the cardholder‘s account is
charged. As a result, the infrastructure and processes of the purchase
card systems and the legal relationships between the merchants, banks,
payment card associations, and the government were not designed to
accommodate the collection of socioeconomic data.
Purchase Card Master Contract Cannot Ensure the Collection of
Socioeconomic Data:
The master contract between GSA and the five banks that issue purchase
cards cannot ensure the collection of socioeconomic information.
Although the contract requires the contracting banks to provide
transaction data to the government, which might include limited
socioeconomic data, banks are only required to provide this information
if the merchant provides it and the contracting banks obtain it. The
contract clauses referring to reports containing socioeconomic data are
vague, both in specifying the data required and in establishing the
level of obligation involved. While the contract mentions a report that
includes ’summary merchant demographic information,“ and ’size
standard,“ which ’is generally used by the agency/organization in
fulfilling its small business and small disadvantaged business goals,“
it does not require that the actual size status of the merchant be
provided, nor does it expressly require that the reports be provided at
all. Rather, in describing the reporting requirements, the contract
states that ’the Government prefers that the data . . . be provided,“
and that ’agencies/organizations may choose to receive some or all of
[these] reports.“:
Moreover, there is no contractual relationship between GSA and the
merchants‘ banks or the payment card associations, the parties most
likely to have access to the information. While GSA is currently
considering modifications to the master contract with the card-issuing
banks to include more specific guidance on reporting socioeconomic
data--such as decision rules for data sources and business status--
these changes will not alter the fact that the contract can only
establish obligations between the parties to the contract. The master
contract is only binding on the five issuing banks, which do not have
access to information on other banks‘ customers and cannot compel the
merchants‘ banks to provide information on the socioeconomic status of
their customers. While payment card associations do have relationships
with both the issuing and acquiring banks, and might be better
positioned to collect socioeconomic data on behalf of the issuing
banks, they are under no contractual or other legal obligation to
collect the information, and there are significant practical
impediments to doing so.
Many Merchants Do Not Provide Socioeconomic Data:
A purchase card transaction between the government and a merchant does
not establish a contractual relationship that requires the merchant to
provide socioeconomic data. Further, merchants that are not government
contractors have no incentive to report this data if they do not
anticipate contracting with the government. Attempts by government
agencies and payment card associations to gather missing data through
surveys and mailings have been largely unsuccessful. Visa has been
involved in two campaigns to collect and update merchant data.
According to Visa officials, as recently as last year, Visa mailed half
a million letters to merchants requesting socioeconomic information,
but less than 2 percent of merchants responded. In January 2000,
MasterCard sent out 30,000 letters on behalf of DOD to current DOD
suppliers accepting the government MasterCard from DOD buyers. The
letter encouraged merchants to update their socioeconomic information
with their banks.[Footnote 8] However, information on only 16 percent
of merchants was subsequently updated.
Attempts to use government databases are also ineffective due to the
relatively small proportion of merchants who have registered in
governmentwide databases, such as Pro-Net, or other government
databases that are limited to certain agencies (such as the Central
Contractor Registration, used for merchants contracting with DOD, the
National Aeronautics and Space Administration, and the Departments of
Treasury and Transportation). Of the roughly 360,000 vendors with whom
DOD uses the purchase card, very few were included in government
databases. According to agency officials, merchants may be inclined to
register in these databases only if they are trying to win government
contracts. Furthermore, Pro-Net relies on merchants to update their own
profiles. Of the 173,374 firms registered in Pro-Net as of August 1,
2002, records for only 87,257, or 50 percent, had been updated within
the prior 18 months. According to SBA officials, Pro-Net merged with
the Central Contractor Registration in October 2002, and SBA purged its
system of inactive firms. As of November 1, 2002, there were 91,656
firms in Pro-Net.
Merchants‘ Banks Do Not Always Collect Socioeconomic Information on
Merchants:
Because the purchase card program only establishes a contractual
relationship between the government and the five card-issuing banks,
the merchants‘ banks are not contractually or otherwise legally
required to obtain socioeconomic information about their merchant
customers for the purchase card program. Further, according to bank and
payment card representatives, banks usually avoid requesting certain
customer socioeconomic information because of concerns about client
privacy and the prospect of discrimination complaints (should the bank,
for example, fail to approve a merchant account). In addition, the bank
officials say they do not need socioeconomic data to make a business
decision on whether to approve a merchant account. However, both
payment card associations have attempted to increase the availability
of socioeconomic information on merchants by providing financial
incentives, such as lower fees, to merchant banks for collecting
this data.
Conclusions:
Although the government likely will never be able to capture complete
socioeconomic information on 100 percent of purchase card merchants,
the available data can be strengthened to provide more accurate and
consistent information that would provide decisionmakers a clearer
picture of the extent to which small businesses are receiving federal
money through the purchase card program. GSA has made a first step
toward understanding the complexities of collecting socioeconomic data
on merchants accepting government purchase cards. With the lessons
learned from that effort, GSA, with the assistance of other federal
agencies and the private sector, can take additional steps toward
improving the reliability of the data.
Recommendations for Executive Action:
While the government faces a number of challenges in collecting
socioeconomic data on all purchase card merchants, there is an
opportunity to improve the available data. Therefore, in order to
strengthen the ongoing efforts, we recommend that the Administrator of
GSA (1) clarify the socioeconomic information that banks and payment
card associations are asked to report and conduct periodic assessments
to verify that they are interpreting and reporting the data
consistently, and (2) specify a rigorous, disciplined approach to
identifying and using appropriate information sources for the
socioeconomic data and ensure the participants agree to it.
Agency Comments:
We received written comments on a draft of this report from GSA, SBA,
Bank of America, and Austin-Tetra. The Office of Federal Procurement
Policy, MasterCard, Visa, Citibank, and US Bank offered oral or e-mail
comments. DOD did not provide comments.
GSA concurred with our findings and recommendations. GSA indicated that
it has begun taking steps to identify and solve problems related to
the capture of consistent, accurate, and reliable socioeconomic data,
toward a goal of modifying the GSA‘s purchase card contract and
reporting socioeconomic data to one centralized source, FPDS. GSA
reports that it has made significant progress in these areas and states
that its progress ultimately implements the recommendations in our
report. However, we do not believe that our recommendations have been
fully implemented. An October 2002 meeting with industry officials left
many issues open--including whether transactions over $2,500 would be
reported, how the socioeconomic information would be used, and who
would be responsible for reporting to whom. GSA should continue to work
with the agencies, banks, and payment card associations to ensure that
socioeconomic information on purchase card merchants is accurately and
consistently collected and reported. GSA‘s letter appears in
appendix II.
SBA provided technical comments, which we incorporated as appropriate.
SBA suggested that we include GSA‘s role in figure 1 to show that GSA
does not directly influence data collection; however, this graphic was
not meant to illustrate the data collection process. Figure 1 depicts
the flow of information during a purchase card transaction, a process
in which GSA is not involved. Figure 2 illustrates GSA‘s role in the
data collection process. SBA‘s letter appears in appendix III.
Bank of America offered written comments to assist in clarifying
sections of the report. We incorporated these comments where
appropriate. Bank of America expressed concern that there is an
expectation of a fully revised report on purchase card merchants‘
socioeconomic data for fiscal year 2002, despite the fact that
decisions on definitions and data elements have not been finalized. We
agree with this assessment. The letter further notes that double
counting of payments on existing contracts could be a problem if GSA
requires banks to include transactions over $2,500. As we discuss on
page 11 of this report, according to a DOD official, this issue is not
a concern; however, the working group, led by GSA, may want to clarify
this issue in subsequent meetings. Bank of America‘s comments appear in
appendix IV.
Austin-Tetra provided written comments, concurring with our findings
and providing additional recommendations to GSA for obtaining
socioeconomic data, such as providing incentives for merchants to
submit socioeconomic data to their banks. The letter notes that these
steps would come at an additional cost to the government. Austin-
Tetra‘s comments appear in appendix V.
In oral comments, Office of Federal Procurement Policy officials
concurred with our findings, stating that the report is balanced and
accurately portrays the difficulties the government faces in collecting
socioeconomic data on purchase card merchants. They suggested that
we add more background information on the impetus for GSA‘s data
collection effort.
A Visa official provided oral comments. He concurred with our report,
stating that it was enlightening, ’on the mark,“ and helped to clarify
some misconceptions. The official noted that there is a tradeoff
between the desired level of accuracy and the cost of obtaining
socioeconomic information on purchase card merchants. He said that,
because the purchase card makes up a relatively small proportion of
total procurement dollars, the level of granularity the government is
requesting might not be worth the dollars needed to obtain this
information on each merchant. Further, the official pointed out that
there is little known about how the purchase card affects small
businesses. Therefore, Visa‘s position is that care must be taken not
to assume that the effects are negative. Visa also provided technical
comments, which we incorporated as appropriate.
In e-mail comments, a US Bank official generally concurred with our
findings. However, he stated that our recommendations failed to account
for the inherent challenges the government faces in its efforts to
collect socioeconomic data on purchase card merchants. The official
stated that the government contracted with the banks for a
’commercially standard“ purchase card program, but then sought to
require a number of non-standard features from the contractors. He
stressed that the issuing banks and payment card associations have very
limited leverage to elicit this information from merchants. He
suggested that GSA ask the banks to report only that information that
is in their purview and expertise--namely, transaction data--and that
GSA could then use government-owned or private sector services to match
the transaction data against socioeconomic databases. Technical
comments were incorporated as appropriate.
Representatives from MasterCard and Citibank provided technical
comments, which we incorporated as appropriate.
As requested by your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution of it until 30
days from the date of this letter. We will then send copies of this
report to other interested congressional committees and the Secretary
of Defense; the Director, Office of Management and Budget; the
Administrator, GSA; the Administrator, SBA; and the Administrator,
Office of Federal Procurement Policy. We are also sending copies to
MasterCard, Visa, Citibank, Bank of America, US Bank, and Austin-Tetra.
We will make copies available to others upon request. In addition, the
report will be available at no charge on the GAO Web site at http://
www.gao.gov.
If you have any questions regarding this report, please contact me at
(202) 512-4841 or Michele Mackin, Assistant Director, at (202) 512-
4309. Other major contributors to this report were Heather L. Barker,
Lara L. Carreon, and Barbara A. Johnson.
David E. Cooper
Director, Acquisition and Sourcing Management:
Signed by David E. Cooper:
[End of section]
Appendix I: Scope and Methodology:
You requested that we include at least the following elements in
our report:
* Determine the steps that federal agencies have taken to require that
socioeconomic data be collected on purchase card use, including the
standards and requirements established for such collection.
* Identify the information that federal agencies, especially the
General Services Administration (GSA) and the Department of Defense
(DOD), have collected for fiscal year 2001 on the socioeconomic status
of purchase card merchants and the sources of such information.
* Identify and compile the information that credit card companies
issuing purchase cards for use by federal agencies have collected for
fiscal year 2001 on socioeconomic status of purchase card merchants and
the sources of such information.
* Determine the standards and criteria under which the credit card
companies collect socioeconomic information--including the definitions
of ’small business“ that are used and the extent to which such
definitions deviate from those promulgated by the Small Business
Administration (SBA).
* Identify, to the extent possible, whether in each transaction
purchase cards are being used to make payment on existing contracts or
are distinct purchase card transactions.
Each of these questions has been addressed in the report.
You also asked us to verify the information collected by the banks and
payment card associations by means of a survey. However, due to the
lack of basic data on many purchase card merchants, we determined that
such a survey would not be feasible. The challenges at each stage of
the survey process create significant potential for error. For example,
defining a universe of merchants from which to draw a sample would be
difficult, as the amount of information available for each merchant
varies widely. Because so little basic information on merchants exists,
a representative sample cannot be ensured. The lack of contact
information due to missing or inaccurate data would make it impossible
to reach some of the merchants. Because of short life cycles, small
businesses are generally more difficult to track. Given that response
rates to surveys of small businesses have historically been low, high
error rates can also be expected. Without basic information to describe
the universe, it would be impossible to determine whether response bias
exists. Further, the impact of the use of the purchase card on small
businesses cannot be determined without prior years‘ data. Finally,
because merchant data is separate from transaction data, and there is
no unique identifier that is consistent for all merchants, any analysis
would involve development of new data management and analysis
techniques--including extremely complex programs--to match merchant
and transaction data.
To assess GSA‘s governmentwide efforts to collect data on the
socioeconomic status of merchants, we reviewed (1) data reported to GSA
by the banks and payment card associations for fiscal year 2001,
(2) data provided to GSA for their internal purchase card program from
Visa, and (3) MasterCard‘s merchant file. Our analysis of electronic
data files included statistical information on missing data, obvious
errors, and duplication. We also reviewed relevant documents and
legislation. We interviewed officials at GSA, SBA, DOD, Visa,
MasterCard, the three largest banks contracting with GSA (Citibank,
Bank of America, and US Bank), and a third party data source, Austin-
Tetra.
Because of the associations‘ reliance on Austin-Tetra as a third party
data source, we also assessed the reliability of its database and
processes. We reviewed documentation, observed, and discussed Austin-
Tetra‘s business strategy and customers, the extensiveness of its
database, the matching methodology (including both electronic and
manual matching), the methodology for assigning socioeconomic
characteristics to businesses, the procedures for source attribution,
and their data assurance practices, including use of a data
assurance group.
To identify the challenges to the collection and reporting of
socioeconomic data on merchants, we interviewed government officials
from GSA‘s purchase card program, SBA, DOD, and the Office of Federal
Procurement Policy. We also interviewed industry officials from the
three largest banks providing purchase card services; MasterCard, Visa
and American Express; Austin Tetra; and a third party data processor,
First Data Merchant Services. We also gathered information on small
business and socioeconomic definitions from relevant guidance and
legislation and discussions with SBA. We gathered information on
sources of socioeconomic information and database matching processes
from payment card associations and third party data sources.
We conducted our review between March and September 2002 in accordance
with generally accepted government auditing standards.
[End of section]
Appendix II: Comments from the General Services Administration:
GSA Administrator:
December 2, 2002:
The Honorable David M. Walker Comptroller General of the United
States General Accounting Office Washington, DC 20548:
Dear Mr. Walker:
Thank you for providing us with the opportunity to comment on the
General Accounting Office (GAO) draft report entitled, ’Contract
Management: Government Faces Challenges in Gathering Socioeconomic Data
on Purchase Card Merchants“ (GAO-03-56), dated October 22, 2002. The
draft report recommends that the General Services Administration (GSA):
(1) clarify the socioeconomic information requested from banks and
payment card associations, and ensure the data is consistent, and (2)
specify a disciplined approach for identifying sources of socioeconomic
data. GSA concurs with the draft report‘s findings and recommendations.
Small business reporting by the GSA SmartPay® contractors to the
individual agencies has been a longstanding contractual requirement.
Since the inception of the contract, GSA recognized the weaknesses in
the reports that have been received from the contractors. In the spring
of 2002, we started a series of meetings with GAO, Small Business
Administration, Departments of Defense (DOD), Interior, and Veterans
Affairs, GSA SmartPay® contractors, and the MasterCard and Visa charge
card associations to identify and solve problems related to the capture
of consistent, accurate, and reliable socioeconomic data concerning
purchase card merchants. I am pleased to report that we have made
significant progress in these areas, which ultimately implement the
recommendations contained in your report. Specifically, the
aforementioned participants have, in principle, agreed upon business
size classifications, quality standards for data sources, and
standardized reporting methodologies.
Having clarified the data requirements and having specified a
disciplined approach for its collection, the GSA SmartPay® contractors
and card associations, along with GSA, are currently exploring the
technical feasibility of reporting socioeconomic data to a centralized
source, namely, the Federal Procurement Data System. Once this action
is completed, all new/revised reporting requirements will be
incorporated
formally in a contract modification. A contract modification is
necessary
not only to clarify the data and collection requirements, but also to
establish GSA as the recipient of the socioeconomic data reports. Under
current reporting requirements, individual agencies receive the
reports.
Our target completion date for these actions is December 31, 2002.
The draft GAO report states in its conclusion that ’...the government
likely will never be able to capture complete socioeconomic information
on 100 percent of purchase card merchants....“ GSA concurs with this
finding. Nonetheless, the successful implementation of these
recommendations will mark the beginning of a new, more reliable, method
for measuring the impact of Government purchase card use on the small
business community. It will also mark the culmination of a tremendous
effort by GSA and other agencies to improve small business reporting.
Finally, we would like to offer the following additional comments on
the draft report. First, the term ’SmartPay“ should be revised to read
’GSA SmartPay®“ due to copyright and trademark restrictions. Second, we
recommend that the number cited for U.S. merchants accepting
MasterCard, Visa, or both be validated, as well as the number of
vendors accepting the purchase card from DOD. Based upon our
discussions with the card associations and banks, these numbers may be
understated.
In closing, I would like to express my sincere gratitude for the
guidance and support that Ms. Michele Mackin and her staff have
provided throughout this review. Their participation has been
instrumental in helping to identify the reporting challenges and
analyze viable solutions.
Stephen A. Perry:
Administrator:
Signed By Stephen A. Perry
cc:
Mr. David E. Cooper Director:
Acquisition and Sourcing Management United States General Accounting
Office Washington, DC 20548:
[End of section]
Appendix III: Comments from the Small Business Administration:
U.S. SMALL BUSINESS ADMINISTRATION WASHINGTON, D.C. 20416:
NOV 1 8 2002:
Mr. David E. Cooper Director:
Acquisition and Sourcing Management U.S. General Accounting Office
Washington, DC 20416:
Dear Mr. Cooper:
Thank you for your letter of October 22, 2002, giving the U.S. Small
Business Administration the opportunity to review and provide comments
on your draft report ’Contract Management, Government Faces Challenges
in Gathering Socioeconomic Data on Purchase Card Merchants.“ Our
detailed comments are provided as an enclosure to this letter.
If you have any questions or need additional information, please
contact Stephanie King in our Office of Congressional and Legislative
Affairs, at 202-205-6895.
Sincerely,
Fred C. Armendariz:
Associate Deputy Administrator for Government Contracting and Business
Development:
Enclosure:
SBA IS AN EQUAL OPPORTUNITY EMPLOYER AND PROVIDER Federal Recycling en:
Small Business Administration:
Comments on GAO Draft Report:
Contract Management, Government Faces Challenges in Gathering
Socioeconomic Data on Purchase Card Merchants:
1. Title Page:
a. Under GAO Highlights, the reference to ’woman-and minority-owned
business“ should be woman-owned small business and small disadvantaged
business (SDB).
b. Under ’What GAO Found“:
1) In the second and third paragraph, the report discusses ’challenges
that will prevent GSA from gathering data.“ GSA has in the past and is
currently having difficulty collecting data. Change the tense by
dropping the ’will.“:
2) In the graphic ’Overview of the Purchase Card Transaction Process“
include GSA‘s role where it enters into the process to show that it
does not directly influence data collection.
2. Page 2, first paragraph, the report refers to ’the five banks under
contract.“ The banks should be listed.
3. Page 4:
a. First paragraph, revise the wording of the sentence to conform with
the Federal Acquisition Regulation language. The sentence should read
’Further, the purchase card is also authorized to be used to place a
task order on an existing indefinite delivery/indefinite quantity
contract; and to make payments on existing contracts . . .“:
b. Last sentence of the third paragraph refers to a ’preliminary report
in March 2002.“ You should include a statement as to what the report
showed?
4. Page 5 lists the various Small Business Category definitions, revise
the following:
a. Small business should read ’A business entity, organized for profit,
including affiliates. . .“ (this change is made because non-profit
entities do not qualify as business concerns), and also change the
tense of ’qualified“ to ’qualifies;“:
b. 8(a) business should read ’A small business that is at least 51%
owned by and whose management ... ;“:
c. Under Small disadvantaged businesses, line four, change the word
’bidding“ to ’procurement;“:
d. Under Veteran-owned small business, on the first line, eliminate the
words ’one or more veteran(s)“ as it duplicates the next phrase and
change ’veterans“ to ’veteran(s);“ and:
e. Under Service-disabled veteran-owned business, on the first line,
eliminate the words ’and managed“ as it duplicates the next phrase.
5. In the graph on Page 6, as on the title page, include GSA‘s role
where it enters into the process to show that it does not directly
influence data collection.
6. On Page 7, in the overview graph, change the number of small
business
in Pro-Net to 91,656. When the system was merged with the Central
Contractor Registration system, SBA purged Pro-Net, eliminating
inactive profiles.
7. On Page 8, under ’Inconsistent Date Due to Lack of Clear Definitions
and Guidelines,“ the first paragraph discusses the matching between
transactional data and the socioeconomic data. Clarify how this
matching was accomplished (was it done by the use of a single
identifier such as the Duns number or TIN?).
8. On Page 9, under ’Data Are Incomplete and Unreliable,“ the first
paragraph, add the word ’small“ to the following:
a. On line eight ’businesses are required“ should read ’small
businesses
are required;“:
b. Online 10, ’for other categories of businesses“ should read ’for
other categories of small businesses;“ and:
c. On line 13, ’woman-owned businesses“ should read ’woman-owned small
businesses.“:
9. On Page 12, in the second paragraph, the reference to Pro-Net needs
to be revised. In October, when Pro-Net was merged with the Central
Contractor Registration, SBA purged its system of inactive firms. As of
November l, 2002, there are 91,656 firms in Pro-Net.
[End of section]
Appendix IV: Comments from the Bank of America:
Bank of America:
Mr. David E. Cooper, Director U.S. General Accounting Office
Washington, DC 20548:
Re: Feedback on the proposed report Small Business: Government Faces
Challenges in Gathering Socioeconomic Data on Purchasing Card Merchants
(GAO-03-56; job code 120126):
Dean Mr. Cooper:
We appreciate this opportunity to provide our comments. We have
reviewed the above referenced report and offer the following comments
that may assist in clarifying sections of the report:
Page 3, first paragraph, last sentence ’GSA hopes to produce a more
useful report for the fiscal year 2002.“ The completion of the report
GSA hopes to produce is contingent upon finalization of definitions and
data elements by the card associations (Visa and MasterCard),
contractors, and GSA. These elements are still undecided and
unresolved. Our concern is that an expectation is set that a fully
revised report will be available for the fiscal year 2002 when
decisions, driven by GSA and shared with all parties prior to
production, have not even been finalized.
Page 5, last paragraph, 2nd sentence ’When an agency cardholder
purchases ... through the MasterCard or Visa computer system,“ We
recommend that the word ’computer system“ be changed to ’interchange
system“ (in this paragraph as well as throughout the document wherever
applicable) to better describe the system utilized by the card
association.
Page 10, first paragraph. We recommend that GAO solicit and document
input from other agencies as to the likelihood of double counting. The
issue of double counting hinges upon what GSA defines as a 1057
reporting requirement. Should GSA include transactions over $2,500 in
the reporting requirement, that will likely increase the possibility of
double counting as those transactions are already reported under an
existing reporting mechanism.
If you have any questions, please do not hesitate to contact me.
Sincerely,
Frank J. Chunderlik:
Senior Vice President Manager, Contract
Administration 757-677-4470:
FJC/mkb:
[End of section]
Appendix V: Comments from Austin-Tetra:
Austin Tetra:
November 15, 2002:
Mr. David E. Cooper:
Director Acquisition and Sourcing Management U.S. General
Accounting Office:
441 G. ST. NW Washington, DC 20548:
Re: Report to Congress - Contract Management. Government Faces
Challenges in Gathering Socioeconomic Data on Purchase Card Merchants:
Dear Mr. Cooper:
As the primary provider of merchant business demographic and
socioeconomic information to both MasterCard and Visa in support of
their merchant data tracking and reporting efforts related to the
Federal SmartPay Purchase Card Program, we have appreciated the
opportunity to participate with the GAO in this report to Congress.
Because of our extensive work in the private sector to provide supplier
information management services to the largest corporations in the U.S.
and our business data collection expertise, we are in concurrence with
the GAO‘s recommendations as outlined in the proposed report to
Congress entitled: Small Business: Government Faces Challenges in
Gathering Socioeconomic Data on Purchase Card Merchants. These
recommendations are restated as follows: the Administrator of GSA (1)
clarify the socioeconomic information requested from banks and payment
card associations and ensure the data is consistent, and (2) specify a
disciplined approach for identifying sources of socioeconomic data.
We believe that if these two recommendations are implemented, that
consistent and comprehensive socioeconomic data can be captured,
tracked and reported for 65 - 80% of merchants with government
procurement card transactions.
We also believe that the percentage of merchant business demographic
and socioeconomic information available can increase further as a
result of additional efforts to capture and analyze more merchant data.
We also recognize that these additional efforts will come at an
additional cost that must be addressed by the GSA. Following are some
suggested steps to capture better, more comprehensive merchant business
demographic and socioeconomic data:
1. Provide an incentive for merchants to provide and merchant banks to
collect better data. One suggested incentive for the merchants
themselves is that upon completing a more detailed business profile,
their information would go into a central procurement database used by
both the public and private sectors to source and solicit suppliers.
2. Provide an easier means for merchants to initially submit and then
update their business demographic and socioeconomic data to merchant
banks. One suggestion here is for all merchant or acquiring banks to
offer Web-based merchant data intake portals similar to ones developed
and managed by Austin-Tetra for U.S. corporations. These Web-based
merchant intake systems would not only allow for more centralized
information gathering for the merchant banks, but would also allow for
the more consistent and comprehensive collection of business
demographic and socioeconomic data. Additionally, information provided
by the merchants can be compared to other public and private sector
databases to identify inconsistencies. Through the electronic link
established with the merchant, inconsistencies and incomplete answers
can be brought to the attention of the merchant and corrected. The Web-
based system will also allow for an automated e-mail process reminding
and encouraging merchants to update their merchant profiles online on a
regular basis.
3. Conduct additional and consistent mailings to merchants directing
them to the new Web-based merchant data intake portals.
4. Expand the utilization of reliable third party sources to gather
business demographic and socioeconomic data on merchants that have not
responded to attempts to gather information directly. The GSA can and
should audit the third party sources on a regular basis for data
accuracy.
With the aforementioned additional steps taken over a period of a few
years, it is our belief that consistent merchant business demographic
and socioeconomic data could be collected for more than 80% of
merchants with government procurement card transactions. Again, we
caveat this recommendation acknowledging that the additional
recommended steps come at an additional cost that is not currently
accounted for in the Federal SmartPay Program.
Thank you for this opportunity to provide our comments. We offer our
continued assistance wherever and whenever it can be useful.
Sincerely,
Philip A. Berkebile, Jr.
President and CEO Austin-Tetra, Inc.
Signed by Philip A. Berkbeile, Jr.
[End of Section]
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FOOTNOTES
[1] We are using the term ’merchant“ to refer to all suppliers of goods
and services procured by the government using the purchase card.
[2] The Small Business Reauthorization Act of 1997 directed the
President to establish a goal of not less than 23 percent of the
federal government‘s prime contracting dollars to be awarded to small
businesses for each fiscal year. The federal government did not meet
this goal in fiscal years 2000 or 2001.
[3] Bank of America, Bank One, US Bank, Mellon Bank, and Citibank have
contracts with GSA to issue purchase cards.
[4] Prior to the Federal Acquisition Streamlining Act, each contract
for the procurement of goods or services that had an anticipated dollar
value of less than $25,000 and that was subject to small purchase
procedures was reserved exclusively for small businesses unless the
contracting officer was unable to obtain offers from two or more small
businesses competitive with market prices and in terms of quality and
delivery. The Federal Acquisition Streamlining Act amended this
reservation so that purchases with an anticipated value greater than
$2,500 but not greater than $100,000 are reserved for small businesses.
[5] The 2.1 million figure is based on Visa‘s estimate.
[6] During the fiscal year 2001 effort, MasterCard contracted with
Austin-Tetra to assist with gathering socioeconomic data. Visa has now
also contracted with this firm to assist with further data gathering.
[7] As the transaction information does not always contain unique
identifying numbers, such as a Taxpayer Identification Number, banks
and associations said that they used business names and addresses found
in transaction data to match to other databases.
[8] The letter specifically asked merchants to verify their business
ownership classification using a merchant type code worksheet (which
indicates socioeconomic status), verify the accuracy of their Merchant
Category Code, and request a software or terminal upgrade, so that DOD
could receive accurate data with merchants‘ purchase card transactions.
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