GSA SmartPay® - Guidance on the Charge Card Freeze

GSA SmartPay Smart Bulletin No. 040

UPDATE:

Effective Date

Mar 7, 2025, and shall remain in force until modified or rescinded.

Business Line(s) Affected

Purchase, Travel, and Integrated

Introduction

This Smart Bulletin provides clarifying information and responses to questions that GSA’s Center for Charge Card Management (CCCM) has received as it relates to the February 26, 2025, Executive Order (EO) titled Implementing the President’s “Department of Government Efficiency” Cost Efficiency Initiative, particularly section 2(f), and the Memorandum issued by the Acting Administrator of General Services on February 23, 2025, titled “Additional Card Program Changes.” Agencies should confer with internal agency officials, including Offices of the General Counsel as to how the EO specifically affects the operations of their own agencies.

Summary

Which Agencies does the EO apply to?

For the purposes of applicability of the EO, section 2 defines “Agency” as having “the meaning given to that term in section 3502 of title 44, United States Code, except that such term does not include the Executive Office of the President or any components thereof.”

Pursuant to 44 U.S.C. 3502:

(1) the term “agency” means any executive department, military department, Government corporation, Government controlled corporation, or other establishment in the executive branch of the Government (including the Executive Office of the President), or any independent regulatory agency, but does not include—

(A) the Government Accountability Office;
(B) Federal Election Commission;
(C) the governments of the District of Columbia and of the territories and possessions of the United States, and their various subdivisions; or
(D) Government-owned contractor-operated facilities, including laboratories engaged in national defense research and production activities;

(5) the term “independent regulatory agency” means the Board of Governors of the Federal Reserve System, the Commodity Futures Trading Commission, the Consumer Product Safety Commission, the Federal Communications Commission, the Federal Deposit Insurance Corporation, the Federal Energy Regulatory Commission, the Federal Housing Finance Agency, the Federal Maritime Commission, the Federal Trade Commission, the Interstate Commerce Commission, the Mine Enforcement Safety and Health Review Commission, the National Labor Relations Board, the Nuclear Regulatory Commission, the Occupational Safety and Health Review Commission, the Postal Regulatory Commission, the Securities and Exchange Commission, the Bureau of Consumer Financial Protection, the Office of Financial Research, Office of the Comptroller of the Currency, and any other similar agency designated by statute as a Federal independent regulatory agency or commission;

Please use the information above to make a determination as to whether or not the EO applies to your agency/organization. Two caveats - please note that as indicated in the EO, the Executive Office of the President is specifically excluded from the EO, despite it being included in the definition of “agency” pursuant to 44 U.S.C. 3502(1). In addition, GSA has confirmed that this EO does not apply to tribal governments, legislative branch agencies, or judicial branch agencies.

Does the EO apply to Centrally Billed Accounts?

Yes, the EO applies to both Centrally Billed Accounts (CBAs) and Individually Billed Accounts (IBAs).

Does the EO apply to Fleet Cards?

No, the EO does not apply to Fleet Cards.

Does the EO apply to debit or charge cards outside of the GSA SmartPay® program?

Please reach out to the agency that oversees each of these programs for further guidance.

My agency received a Memorandum from GSA’s Acting Administrator asking to reduce spending limits and card accounts. Does the EO supersede the memorandum my agency received?

The Executive Order may be read in concert with the Acting Administrator of General Services memorandum, if your agency has received a memorandum. The EO requires agencies as defined in 44 USC § 3502(5) to cease spending on card accounts for 30 days unless your agency has an exception.

How does my agency handle any exceptions to the EO?

Exceptions should be coordinated internally with your Agency Head and DOGE POCs.

What exception information needs to be reported to GSA?

By COB each Friday, beginning on Friday, March 14, 2025, your designated agency POC should submit any exceptions to purchase and travel card use to GSA. In order to facilitate an orderly submission process, GSA has developed a report template to be used for submissions. The template is attached in the email that also contains these FAQs. Submissions should be sent to spaccountincreases@gsa.gov. If your agency prefers to submit exceptions using a secure process, please use the email above to provide a point of contact and GSA will reach out to better understand your agency’s needs.

Note: GSA will continue to track card and spend reductions for the agencies that received the Acting Administrator’s Memorandum. This information is coming to GSA from the contractor banks so there is no action needed from agencies to provide this information.

Does my agency need to inform card holders of the actions being taken?

Yes, Agency/Organizations Program Coordinators (A/OPCs) should notify their cardholders immediately of the EO directive to freeze use of GSA SmartPay charge cards to the maximum extent possible and provide cardholders with any internal exception request process information.

My agency received the Memorandum from the Acting Administrator of General Services asking to add GSA as a “consignor” to my agency’s task order. What does this mean?

GSA is asking agencies to add a member of GSA’s Center for Charge Card Management (CCCM) as a Contracting Officer’s Representative (COR) to your agency’s task order. For the purposes of this memorandum, the term “consignor” is being defined as a Contracting Officer’s Representative (COR).

Agencies that participate in the GSA Pool task order do not need to take this action as there is already a GSA/CCCM COR assigned to this task order.

Agencies that tag onto GSA’s task order or another agency’s task order do not need to take action, as the lead agency will work with GSA to add the GSA/CCCM COR.

Separate guidance will be provided to the Department of Defense whose task orders are already managed by GSA’s Center for Charge Card Management (CCCM).

Who should my agency assign “consignor” authority to in GSA?

The “consignor” should be added by name to your agency’s GSA SmartPay task order. This individual is also your GSA SmartPay CCCM point of contact. If you do not know who your GSA SmartPay point of contact is, please email gsa_smartpay@gsa.gov for the information. Once you have the name of the CCCM POC for your task order, please work directly with that individual to obtain any additional information needed by your agency to process the modification.

What is the period of time for GSA to be named as the “consignor” on the agency’s task order?

The period of time is from the date of signature to November 29, 2031–the end date of the current GSA SmartPay 3 contract if all options are exercised.

Must a contracting officer add GSA to the task order as a “consignor”?

Yes, a warranted contracting officer from each agency must be the individual who adds the GSA/CCCM POC as a “consignor” (COR) to the agency’s task order.

Is there specific language that should be used when adding the CCCM COR as the “consignor” to the task order?

It is recommended that the agency task order be modified in any existing applicable section or clauses where contracting officer’s representative authority is denoted to add the following:

“In addition to the agency contracting officer’s representative identified in this task order, contracting officer representatives within the GSA, FAS, PSHC, Center for Charge Card Management, acting within the scope of their COR authority, are empowered to provide technical monitoring for this task order, as well as any administration duties as assigned.”

Will GSA also be taking over the A/OPC role(s) for my agency?

At this time, A/OPC roles will remain with each agency.

If GSA takes over the A/OPC role(s), how will GSA know who should have a card within my agency or if funds are available to approve/make a purchase or allow for travel?

At this time, GSA does not anticipate taking the A/OPC roles under an agency’s task order.

If an agency needs to be exempt from having GSA as a “consignor”, what is the process for requesting the exemption?

Work through your Agency Head(s) to develop an exemption document and provide it to spaccountincreases@gsa.gov.