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.
Quick answer: If a P-card purchase has its own requisition or purchase order, document the good faith effort in Core-CT using the normal process. If P-card activity is captured through a blanket P-card purchase order, use GFE9 on the blanket purchase order in Core-CT and document purchase-level good faith efforts separately through the agency’s P-card log, reconciliation, or approval process.
Key Distinction
There are two common P-card documentation paths:
- P-card purchase with its own requisition or purchase order: Document the GFE in Core-CT using the normal process.
- P-card activity captured through a blanket P-card purchase order: Use GFE9 on the blanket PO and document purchase-level good faith efforts separately at the agency level.
These are suggested documentation methods based on common ways agencies use P-cards. If your agency uses P-cards differently, your agency must identify an internal process to document purchase-level good faith efforts.
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 on the blanket purchase order in Core-CT.
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
Do not use GFE9 as the purchase-level code for each individual P-card transaction. GFE9 is used on the blanket P-card purchase order in Core-CT to show that purchase-level documentation is maintained separately. For each applicable P-card transaction, agencies should document the GFE code or explanation that best reflects what occurred.
DAS employees using individual P-Cards: DAS documents good faith efforts for individual P-card purchases on the P-Card Purchase Log (CO-501), using the same GFE codes used in Core-CT. Each individual P-card purchase must include the applicable GFE code or explanation on the CO-501. Other agencies may have their own documentation procedures; check with your business office if you have questions.
To learn more about GFE codes, read the Choosing the Right GFE Standard Comments Job Aid.
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.
