Purpose
This job aid explains how agencies should document Small Business Enterprise (SBE) and Minority Business Enterprise (MBE) good faith efforts (GFE) for P-card purchases. A P-card is a payment method, not a purchasing authority. It does not, by itself, determine which good faith effort comment should be used. Agencies should document good faith efforts based on the underlying purchasing scenario and how the purchase is handled in Core-CT.
Key Distinction
There are two common P-card documentation paths:
- P-card purchases that use their own requisition or purchase order
- P-card activity captured through a blanket P-card purchase order
The documentation process depends on which path applies.
These are suggested documentation methods based on common ways that P-cards are utilized. If your agency has other ways in which it uses P-cards, you will need to identify your documentation process for GFE internally.
Scenario 1: P-card Purchase With Its Own Requisition or Purchase Order
If the P-card purchase uses its own requisition or purchase order in Core-CT, agencies should follow the normal Core-CT good faith effort documentation process.
This means the person entering the requisition or purchase order should:
- enter the account code that accurately reflects the purchase;
- select the good faith effort standard comment that best matches the underlying purchasing scenario; and
- retain supporting documentation consistent with the agency’s normal procurement records process.
For these purchases, do not automatically use GFE9 just because a P-card is involved. Select the GFE code based on what occurred.
For example:
- Use GFE1 or GFE2 for multi-vendor contract purchases.
- Use GFE3, GFE4, or GFE5 for GL71 purchases.
- Use GFE6 for single-vendor or no-vendor-choice purchases.
- Use GFE7 when certified SBE/MBE vendors were contacted but did not respond.
- Use GFE8 when none of the standard scenarios fit and an agency-specific explanation is needed.
To learn more about Core-CT GFE codes, read the Choosing the Right GFE Standard Comments Job Aid.
Scenario 2: P-card Activity Captured Through a Blanket P-card Purchase Order
If P-card activity is captured through a blanket P-card purchase order, agencies should use GFE9: P-card, separate documentation
Use GFE9 when the purchase order is a blanket P-card purchase order and does not represent a single individual purchasing decision.
GFE9 indicates that purchase-level good faith effort documentation, where applicable, will be maintained separately at the agency level through the agency’s P-card reconciliation or approval process.
The blanket P-card purchase order serves as the Core-CT pointer record. It should not be treated as the complete good faith effort documentation for each individual P-card purchase.
Documentation for GFE9 Blanket P-card Purchase Orders
For P-card activity captured through a blanket P-card purchase order, agencies should document good faith efforts for individual purchases separately, where applicable.
DAS suggests documenting this information on the agency’s P-card log sheet. See OSC’s Purchasing Card Use Policy for more details on the log sheet.
DAS is working with the Office of the State Comptroller to update the standard P-card log sheet template to include a column for GFE documentation for purchases captured through blanket P-card purchase orders.
Agencies are NOT to simply code GFE9 on the log but they should have more specific documentation.
DAS will share the updated template once it is available.
Until the updated template is available, agencies retain documentation of purchase-level good faith efforts for GFE9 purchases, where applicable.
For applicable P-card purchases, the documentation may include:
- purchase description;
- purchase amount;
- account code;
- applicable GFE code or explanation;
- whether certified SBE/MBE vendors were available;
- whether certified SBE/MBE vendors were contacted, if applicable; and
- supporting documentation or notes explaining what occurred.
Supporting documentation may include:
- Small Business Certification Directory search results;
- CTsource contract vendor information;
- quote requests or emails;
- vendor responses;
- notes explaining why certified SBE/MBE vendors were not available or not contacted; or
- documentation showing that no meaningful vendor-choice opportunity existed.
The expectation is not that every P-card purchase will be awarded to a certified SBE/MBE vendor. The expectation is that agencies make and document reasonable good faith efforts when relevant purchasing opportunities exist.
