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110th Congress 
 2d Session                      SENATE                          Report
                                                                110-437
_______________________________________________________________________

                                     

                                                       Calendar No. 933


          GOVERNMENT CREDIT CARD ABUSE PREVENTION ACT OF 2008

                               __________

                              R E P O R T

                                 of the

                              COMMITTEE ON

                         HOMELAND SECURITY AND

                          GOVERNMENTAL AFFAIRS

                          UNITED STATES SENATE

                              to accompany

                                 S. 789


              TO PREVENT ABUSE OF GOVERNMENT CREDIT CARDS




                 August 1, 2008.--Ordered to be printed
        COMMITTEE ON HOMELAND SECURITY AND GOVERNMENTAL AFFAIRS

               JOSEPH I. LIEBERMAN, Connecticut, Chairman
CARL LEVIN, Michigan                 SUSAN M. COLLINS, Maine
DANIEL K. AKAKA, Hawaii              TED STEVENS, Alaska
THOMAS R. CARPER, Delaware           GEORGE V. VOINOVICH, Ohio
MARK L. PRYOR, Arkansas              NORM COLEMAN, Minnesota
MARY L. LANDRIEU, Louisiana          TOM COBURN, Oklahoma
BARACK OBAMA, Illinois               PETE V. DOMENICI, New Mexico
CLAIRE McCASKILL, Missouri           JOHN WARNER, Virginia
JON TESTER, Montana                  JOHN E. SUNUNU, New Hampshire

                  Michael L. Alexander, Staff Director
                     Kevin J. Landy, Chief Counsel
                      Nora K. Adkins, GAO Detailee
     Brandon L. Milhorn, Minority Staff Director and Chief Counsel
               Richard A. Beutel, Minority Senior Counsel
                   Eric B. Cho, Minority GSA Detailee
                  Trina Driessnack Tyrer, Chief Clerk


                            C O N T E N T S

                              ----------                              
                                                                   Page
  I. Purpose and Summary..............................................1
 II. Background and Need for the Legislation..........................1
III. Legislative History..............................................3
 IV. Section-by-Section Analysis......................................3
  V. Evaluation of Regulatory Impact..................................5
 VI. Congressional Budget Office Cost Estimate........................5
VII. Changes in Existing Law Made by the Bill, as Reported............6
                                                       Calendar No. 933
110th Congress                                                   Report
                                 SENATE
 2d Session                                                     110-437

======================================================================



 
          GOVERNMENT CREDIT CARD ABUSE PREVENTION ACT OF 2008

                                _______
                                

                 August 1, 2008.--Ordered to be printed

                                _______
                                

Mr. Lieberman, from the Committee on Homeland Security and Governmental 
                    Affairs, submitted the following

                              R E P O R T

                         [To accompany S. 789]

    The Committee on Homeland Security and Governmental 
Affairs, to which was referred the bill (S. 789) to prevent 
abuse of Government credit cards, having considered the same, 
reports favorably thereon with an amendment and recommends that 
the bill do pass.

                         I. Purpose and Summary

    S. 789 requires specific internal controls at the agency 
level to ensure that purchase and travel cards are used only 
for approved spending and that agencies take appropriate 
personnel actions for misuse of cards. The bill also makes 
permanent language that has appeared in appropriations bills 
for the last several years clarifying and requiring agencies to 
conduct creditworthiness checks of individuals before they are 
issued travel cards.
    As reported, the bill also clarifies that the Office of 
Management and Budget will be responsible for issuing the new 
guidelines for purchase cards and travel cards, and requires 
agencies and their Inspectors General to report to OMB on card 
abuses and the personnel actions taken by agencies in response 
to such abuses.

              II. Background and Need for the Legislation

    Since 1998, federal departments and agencies have utilized 
government charge cards through the General Service 
Administration's (GSA) SmartPay program. Through this program, 
agencies can issue to employees two different types of cards: 
purchase cards and travel cards. Government purchase cards are 
used for the acquisition of commercial goods and services and 
are paid directly by the agency, while government travel cards 
are used to pay for individual government travel expenses and 
issued directly to government employees, who are responsible 
for the charges.
    Government charge cards were introduced as a low cost 
method to streamline government acquisition and travel 
processes. However, this new tool was implemented without 
sufficient internal controls to prevent waste, fraud, and 
abuse. A series of Government Accountability Office (GAO) 
reports over the last decade have identified inadequate and 
inconsistent controls across numerous federal agencies with 
respect to both government purchase and travel cards.\1\ This 
has led to millions of dollars in taxpayers' money wasted on 
purchases ranging from those that are outright fraudulent, to 
ones that were of questionable need or that were unnecessarily 
expensive. While travel card vendors are not paid directly with 
taxpayers' money like purchase cards, failure by employees to 
repay travel card charges results in the loss of millions of 
dollars in rebates to the Federal Government.
---------------------------------------------------------------------------
    \1\GAO, Purchase Cards: Increased Management Oversight and Control 
Could Save Hundreds of Millions of Dollars. GAO-04-717T, Washington, 
D.C.: April 28, 2004; GAO, Purchase Cards: Steps Taken to Improve DOD 
Program Management, but Actions Needed to Address Misuse. GAO-03-156, 
Washington D.C.: December 2, 2003; GAO, Purchase Cards: Control 
Weaknesses Leave Army Vulnerable to Fraud, Waste, and Abuse. GAO-02-
844T, Washington, D.C.: July 17, 2002; and GAO, Purchase Cards: Control 
Weaknesses Leave Two Navy Units Vulnerable to Fraud and Abuse. GAO-02-
32, Washington, D.C.: November 30, 2001.
---------------------------------------------------------------------------
    Most recently, GAO issued a report in March 2008 entitled 
Governmentwide Purchase Cards: Actions Needed to Strengthen 
Internal Controls to Reduce Fraudulent, Improper, and Abusive 
Purchases.\2\ This report found, despite previous GAO reports 
on this issue and new regulations, that many of the same 
internal controls were still lacking in various government 
agencies with respect to government purchase cards, 
perpetuating a series of oversight deficiencies leading to 
waste, fraud, and abuse.
---------------------------------------------------------------------------
    \2\GAO, Governmentwide Purchase Cards: Actions Needed to Strengthen 
Internal Controls to Reduce Fraudulent, Improper, and Abusive Purchase. 
GAO-08-333, Washington D.C.: March 14, 2008.
---------------------------------------------------------------------------
    The Government Credit Card Abuse Prevention Act is founded 
upon recommendations by GAO regarding what controls are 
necessary to prevent the kinds of waste, fraud, and abuse that 
have been uncovered by GAO and agency inspectors general. It 
mandates a consistent set of core internal controls that should 
be utilized by every federal agency to prevent and detect 
improper use of government charge cards. For example, it 
mandates the use of innovative technologies to prevent or 
identify fraudulent purchases. This could include controlling 
merchant codes to prevent a card from being used with specific 
vendors who do not provide goods and services that are 
appropriate for purchase. It could also include utilizing 
statistical machine learning and pattern recognition 
technologies that review the risk of various transactions. This 
technology is currently being used in commercial credit cards 
to flag purchases that do not fit normal purchasing patterns 
for cardholders.
    The Government Credit Card Abuse Prevention Act also 
provides that each agency inspector general will periodically 
conduct risk assessments of agency purchase card and travel 
card programs and perform periodic audits to identify potential 
fraudulent, improper, and abusive use of government charge 
cards. GAO and agency inspectors general have successfully used 
techniques like data mining to reveal instances of improper use 
of government charge cards. Having this information on an 
ongoing basis will help in strengthening and maintaining a 
rigorous system of internal controls to prevent future 
instances of waste, fraud, and abuse with government charge 
cards.
    In addition, GAO's investigations often found inconsistent 
or nonexistent consequences for federal employees who misused 
or abused government charge cards. The Government Credit Card 
Abuse Prevention Act requires that penalties be in place so 
that employees who abuse government charge cards face 
consistent and appropriate consequences, including dismissal 
and even criminal investigation in the most serious cases, thus 
creating a deterrent effect that will prevent future misuse.
    In implementing the requirements of the Government Credit 
Card Abuse Prevention Act, the Committee urges federal agencies 
to review and utilize best practices for conducting purchase 
card and travel card programs. In this respect, the GAO's Audit 
Guide for Auditing and Investigating the Internal Control of 
Government Purchase Card Programs is a useful summary of the 
best practices for establishing and monitoring internal 
controls for government purchase card programs.\3\
---------------------------------------------------------------------------
    \3\GAO, Audit Guide: Auditing and Investigating the Internal 
Control of Government Purchase Card Programs. GAO-03-678G, Washington 
D.C.: May 1, 2003.
---------------------------------------------------------------------------

                        III. Legislative History

    On March 7, 2007, S. 789 was introduced by Senator Chuck 
Grassley and referred to the Senate Committee on Homeland 
Security and Governmental Affairs. The bill's original co-
sponsors were Senators Lieberman, Collins, and Coleman; 
subsequent co-sponsors included Senators McCaskill, Levin, 
Carper, and Kerry. On April 10, 2008, S. 789 was reported 
favorably by the Committee by voice vote as amended by the 
Lieberman-Collins substitute.
    The substitute amendment clarifies that the Office of 
Management and Budget will be responsible for issuing the new 
guidelines for purchase cards and travel cards. It also 
requires agencies and their Inspectors General to report to OMB 
on card abuses and the personnel actions taken by agencies in 
response to such abuses. Finally, the substitute makes 
technical and conforming amendments throughout the bill. 
Members present for the vote on the bill as amended were 
Senators Lieberman, Levin, Akaka, Carper, Landrieu, McCaskill, 
Tester, Collins, Voinovich, and Sununu.

                    IV. Section-by-Section Analysis


Section 1. Short title

    Section 1 designates the name of the act as the 
``Government Credit Card Abuse Prevention Act of 2008.''

Section 2. Management of purchase cards

    Subsection (a) requires the head of each executive agency 
that issues and uses purchase cards and convenience checks to 
establish and maintain safeguards and internal controls to 
ensure effective management, such as, keeping a record in each 
executive agency of each holder of a purchase card issued by 
the agency for official use, assigning each cardholder an 
approving official, requiring reconciliation of the charges by 
the purchase cardholder and approving official and supporting 
documentation, ensuring payments are made promptly for valid 
purchases, retaining records of each purchase card transaction 
in accordance with government policies on disposition of 
records, and invalidating purchase cards for employees who 
cease to be employed by the agency or transfer to another unit.
    Subsection (b) provides that no later than 180 days after 
the date of the enactment of this Act, the Director of the 
Office of Management and Budget shall prescribe guidance 
governing the implementation of the safeguards and internal 
controls required by subsection (a) by executive agencies.
    Subsection (c) requires the that the guidance required by 
subsection (b) provide for appropriate adverse personnel 
actions or other punishment in cases in which employees of an 
executive agency violate such safeguards and internal controls 
or are negligent or engage in misuse, abuse, or fraud with 
respect to a purchase card, including: from employees who are 
suspected of fraud, referral to the Inspector General of the 
agency for investigation, and, upon determination by the 
Inspector General that a crime may have occurred, referral of 
the case to the United States Attorney with jurisdiction over 
the matter, and for employees who are found guilty of fraud or 
found by the Inspector General of the agency to have 
egregiously abused a purchase card knowingly and willingly, 
dismissal of the employee. This subsection also requires that 
the guidance required by subsection (b) mandate that each head 
of an executive agency, and each Inspector General of an 
executive agency, on a semi-annual basis, submit to the 
Director of the Office of Management and Budget a report on 
violations or other actions, such as misuses or abuse, by 
employees of such executive agency.
    Subsection (d) requires the Inspector General of each 
executive agency to periodically conduct risk assessments of 
the agency purchase card programs and analyze identified 
weaknesses; perform periodic audits of purchase card 
transactions designed to identify potentially fraudulent, 
improper, and abusive uses, patterns of improper transactions, 
and categories of purchases that should be made by means other 
than purchase cards; report to the head of the executive agency 
on the results of the audits; and, report to the Director of 
the Office of Management and Budget and the Comptroller General 
on the implementation of recommendations made to address 
findings during audits of purchase cardholders.
    Subsection (e) provides the definition of an executive 
agency as having the meaning given such term in section 4(1) of 
the Office of Federal Procurement Policy Act (41 U.S.C. 
403(a)), expect as provided under subsection (f).
    Subsection (f) provides the relationship to the Department 
of Defense purchase card regulations and reports conforming 
amendments to section 2784 of title 10, United States Code. 
Subsections (a) through (d) do not apply to the Department of 
Defense.

Section 3. Management of travel cards

    Section 3 amends the Travel and Transportation Reform Act 
of 1988 Section 2 (Public Law 105-264; 5 U.S.C. 5701 note) by 
adding new subsections that requires the head of each executive 
agency to establish safeguards and internal controls over 
travel cards; requires the director of the Office of Management 
and Budget to prescribe guidance governing the implementation 
of the safeguards and internal controls; requires the head of 
each executive agency and each Inspector General of an 
executive agency on a semi-annual basis to submit to the 
director of the Office of Management and Budget a report on 
violations or other actions; requires the Inspector General of 
each executive agency to assess the travel card program and 
report findings to the head of the executive agency, the 
director of the Office of Management and Budget and the 
Comptroller General; and provides definitions relevant to the 
program.

Section 4. Management of centrally billed accounts

    Section 4 requires the head of an executive agency that has 
employees who use a centrally billed account to establish and 
maintain safeguards and internal controls. This section also 
requires the director of the Office of Management of Budget to 
prescribe guidance implementing the requirements above not 
later than 180 days after the date of enactment of this Act.

                   V. Evaluation of Regulatory Impact

    Pursuant to the requirements of paragraph 11(b) of rule 
XXVI of the Standing Rules of the Senate, the Committee has 
considered the regulatory impact of this bill. The 
Congressional Budget Office states that the bill contains no 
intergovernmental or private-sector mandates as defined in the 
Unfunded Mandate Reform Act and would not effect state, local, 
and tribal governments. The enactment of this legislation will 
not have significant regulatory impact.

             VI. Congressional Budget Office Cost Estimate

                                                    April 18, 2008.
Hon. Joseph I. Lieberman,
Chairman, Committee on Homeland Security and Governmental Affairs, U.S. 
        Senate, Washington, DC.
    Dear Mr. Chairman: As you requested, the Congressional 
Budget Office has prepared the enclosed cost estimate for S. 
789, the Government Credit Card Abuse Prevention Act of 2008.
    If you wish further details on this estimate, we will be 
pleased to provide them. The CBO staff contact is Matthew 
Pickford.
            Sincerely,
                                                   Peter R. Orszag.
    Enclosure.

S. 789--Government Credit Card Abuse Prevention Act of 2008

    S. 789 would require executive branch agencies to establish 
credit card controls and safeguards, including periodic risk 
assessment analysis and audits by inspectors general (IGs). 
Under the legislation, the Office of Management and Budget 
(OMB) would be required to issue guidelines for the use of 
credit cards. In addition, executive branch agencies, IGs, and 
OMB would be required to produce a variety of reports to the 
Congress that assess compliance with the new guidelines. 
Finally, S. 789 would allow for the dismissal of employees 
found guilty of abusing government credit cards.
    CBO estimates that implementing S. 789 would cost $85 
million over the 2009-2013 period for agencies to conduct 
additional employee training and agency oversight, develop 
guidelines, and prepare additional reports, subject to the 
availability of appropriated funds. The bill could also affect 
direct spending by agencies not funded through annual 
appropriations, such as the Tennessee Valley Authority and the 
Bonneville Power Administration. CBO estimates, however, that 
any increase in spending by those agencies would not be 
significant.
    Implementing S. 789 could improve agencies' control of 
credit card usage, thus discouraging the fraudulent use of 
government cards and reducing wasteful and fraudulent 
purchases. The Government Accountability Office (GAO) recently 
reported that almost $17 billion is spent using government 
charge cards each year. GAO found that almost 50 percent of the 
government credit card transactions it reviewed failed to meet 
basic internal control standards, including ensuring that goods 
and services were properly authorized and actually received. To 
the extent that wasteful or fraudulent uses are discovered by 
implementing the procedures specified in S. 789, federal 
spending could decline, assuming that amounts provided in 
appropriation acts would be correspondingly reduced. However, 
the extent of improper usage of credit cards is undocumented, 
and CBO has no basis for estimating the potential savings from 
improved controls.
    Most of the provisions of S. 789 would expand the current 
practices of the federal government regarding the use of credit 
cards. The General Services Administration is the contract 
administrator for federal credit cards, while OMB provides 
overall direction for governmentwide procurement policies, 
regulations, and procedures. IGs are responsible for preventing 
and detecting fraud and abuse in government programs and 
operations. In addition, agencies must actively manage their 
individual credit card programs by establishing policies and 
procedures, conducting oversight, and pursuing any unauthorized 
use of credit cards. Based on information from some agencies 
about the ongoing costs to administer federal credit cards, CBO 
estimates that implementing the bill would increase costs by 
$25 million in 2009, primarily for additional employee 
training, increased agency oversight, and new reporting 
requirements, and $15 million annually in subsequent years, 
mostly for additional oversight responsibilities and reporting 
requirements.
    S. 789 contains no intergovernmental or private-sector 
mandates as defined in the Unfunded Mandates Reform Act and 
would not affect the budgets of state, local, or tribal 
governments.
    The CBO staff contact for this estimate is Matthew 
Pickford. This estimate was approved by Theresa Gullo, Deputy 
Assistant Director for Budget Analysis.

       VII. Changes to Existing Law Made by the Bill, as Reported

    In compliance with paragraph 12 of rule XXVI of the 
Standing Rules of the Senate, changes in existing law made by 
S. 789 as reported are shown as follows (existing law proposed 
to be omitted is enclosed in brackets, new matter is printed in 
italic, and existing law in which no change is proposed is 
shown in roman):

                         TITLE 10--ARMED FORCES

                    Subtitle A--General Military Law

               PART IV--SERVICE, SUPPLY, AND PROCUREMENT


CHAPTER 165--ACCOUNTABILITY AND RESPONSIBILITY

           *       *       *       *       *       *       *



SEC. 2784. MANAGEMENT OF PURCHASE CARDS

    (a) * * *
    (b) Required Safeguards and Internal Controls.--Regulations 
under subsection (a) shall include safeguards and internal 
controls to ensure the following:
          (1) * * *
          (11) That each purchase cardholder is assigned an 
        approving official other than the cardholder with the 
        authority to approve or disapprove expenditures.
          (12) That the Department of Defense utilizes 
        technologies to prevent or identify fraudulent 
        purchases.
          (13) That the Department of Defense takes appropriate 
        steps to invalidate the purchase card of each employee 
        who--
                  (A) ceases to be employed by the Department 
                of Defense immediately upon termination of the 
                employment of the employee; or
                  (B) transfers to another unit of the 
                Department of Defense immediately upon the 
                transfer of the employee unless the units are 
                covered by the same purchase card authority.
          (14) That the Department of Defense takes appropriate 
        steps to recover the cost of any improper or fraudulent 
        purchase made by an employee, including, as necessary, 
        through salary offsets.
          (15) That the Inspector General of the Department of 
        Defense conducts periodic risk assessments of purchase 
        card programs and associated internal controls and 
        analyzes identified weaknesses and the frequency of 
        improper activity and uses such risk assessments to 
        develop appropriate corrective actions.
    (c) * * *
    (d) Semi-Annual Report.--The Secretary of Defense shall 
submit to the Director of the Office of Management and Budget 
on a semi-annual basis a report on misuse, abuse, or fraud with 
respect to purchase cards by employees of the Department of 
Defense. At a minimum, the report shall include the following:
          (1) A description of each incident covered by the 
        report.
          (2) A description of any adverse personnel action, 
        punishment, or other action taken against the employee 
        in connection with each such incident.
          (3) A description of actions taken by the Department 
        of Defense to address findings arising out of risk 
        assessments and audits conducted pursuant to this 
        section.
                              ----------                              


              TRAVEL AND TRANSPORTATION REFORM ACT OF 1998


(Public Law 105-264; 5 U.S.C. 5701, note)

           *       *       *       *       *       *       *


    (a) * * *

           *       *       *       *       *       *       *

    (h) Management of Travel Charge Cards.--
          (1) Required safeguards and internal controls. The 
        head of each executive agency that has employees that 
        use travel charge cards shall establish and maintain 
        safeguards and internal controls over travel charge 
        cards to ensure the following:
                  (A) There is a record in each executive 
                agency of each holder of a travel charge card 
                issued by the agency for official use, 
                annotated with the limitations on amounts that 
                are applicable to the use of each such card by 
                that travel charge cardholder.
                  (B) Rebates and refunds based on prompt 
                payment on travel charge card accounts are 
                monitored for accuracy and, unless otherwise 
                provided by law, properly recorded as a receipt 
                of the agency that employs the cardholder.
                  (C) Periodic reviews are performed to 
                determine whether each travel charge cardholder 
                has a need for the travel charge card.
                  (D) Appropriate training is provided to each 
                travel charge cardholder and each official with 
                responsibility for overseeing the use of travel 
                charge cards issued by an executive agency.
                  (E) Each executive agency has specific 
                policies regarding the number of travel charge 
                cards issued by various organizations and 
                categories of organizations, the credit limits 
                authorized for various categories of 
                cardholders, and categories of employees 
                eligible to be issued travel charge cards, and 
                that those policies are designed to minimize 
                the financial risk to the Federal Government of 
                theissuance of the travel charge cards and to 
ensure the integrity of the travel charge cardholders.
                  (F) Each executive agency negotiates with the 
                holder of the applicable travel card contract 
                to evaluate the creditworthiness of an 
                individual before issuing the individual a 
                travel charge card, and that no individual be 
                issued a travel charge card if the individual 
                is found not creditworthy as a result of the 
                evaluation (except that this paragraph shall 
                not preclude issuance of a restricted use 
                travel charge card or pre-paid card when the 
                individual lacks a credit history or has a 
                credit score below the minimum credit score 
                established by the Office of Management and 
                Budget). The Director of the Office of 
                Management and Budget shall establish a minimum 
                credit score for determining the 
                creditworthiness of an individual based on 
                rigorous statistical analysis of the population 
                of cardholders and historical behaviors. 
                Notwithstanding any other provision of law, 
                such evaluation shall include an assessment of 
                an individual's consumer report from a consumer 
                reporting agency as those terms are defined in 
                section 603 of the Fair Credit Reporting Act.
                  (G) Each executive agency utilizes 
                technologies to prevent or identify fraudulent 
                purchases.
                  (H) Each executive agency ensures that the 
                travel charge card of each employee who ceases 
                to be employed by the agency is invalidated 
                immediately upon termination of the employment 
                of the employee.
                  (I) Each executive agency utilizes, where 
                appropriate, direct payment to the holder of 
                the travel card contract.
          (2) Guidance on management of travel charge cards.--
        The Director of the Office of Management and Budget 
        shall prescribe guidance governing the implementation 
        of the safeguards and internal controls in paragraph 
        (1) by executive agencies.
          (3) Penalties for violations.--
                  (A) In general.--The regulations prescribed 
                under paragraph (2) shall provide for 
                appropriate adverse personnel actions or other 
                punishment to be imposed in cases in which 
                employees of an executive agency violate such 
                regulations or are negligent or engage in 
                misuse, abuse, or fraud with respect to a 
                travel charge card, including removal in 
                appropriate cases.
                  (B) Reports on violations.--The regulations 
                prescribed under paragraph (2) shall require 
                each head of an executive agency, and each 
                Inspector General of an executive agency, on a 
                semi-annual basis, to submit to the Director of 
                the Office of Management and Budget a report on 
                violations or other actions covered by 
                paragraph (1) by employees of such executive 
                agency. At a minimum, the report shall set 
                forth the following:
                          (i) A description of each violation 
                        or other action covered by the report.
                          (ii) A description of any adverse 
                        personnel action, punishment, or other 
                        action taken against the employee for 
                        such violation or other action.
          (4) Assessments.--The Inspector General of each 
        executive agency shall--
                  (A) periodically conduct risk assessments of 
                the agency travel card program and associated 
                internal controls and analyze identified 
                weaknesses and the frequency of improper 
                activity in order to develop a plan for using 
                such risk assessments to determine the scope, 
                frequency, and number of periodic audits of 
                travel cardholders;
                  (B) perform periodic audits of travel card 
                purchases designed to identify potentially 
                fraudulent, improper, and abusive uses of 
                travel cards;
                  (C) report to the head of the executive 
                agency concerned on the results of such audits; 
                and
                  (D) report to the Director of the Office of 
                Management and Budget and the Comptroller 
                General on the implementation of 
                recommendations made to the head of the 
                executive agency to address findings during 
                audits of travel cardholders.
          (5) Definitions.--In this subsection:
                  (A) The term `executive agency' means an 
                agency as that term is defined in section 5701 
                of title 5, United States Code, except that it 
                is in the executive branch.
                  (B) The term `travel charge card' means the 
                Federal contractor-issued travel charge card 
                that is individually billed to each cardholder.