I applaud comments made in the Feb. 22 editorial on state purchasing cards ("Bosses MIA on state p-card spree," @issue).

Used in virtually every industry and government, p-cards can be an effective tool for small purchases. They make the purchasing process much more effective. In fact, numerous studies have determined that the p-cards can eliminate a large part of the administrative effort exerted to purchase business items. Normally, a requisition is required, and a purchase order is then generated to a vendor to purchase a good or service. A separate invoice is then received, proper approvals are gained, and a separate check is cut to each vendor and then mailed out.

These administrative costs add up quickly, especially when you consider the 1.1 million p-card transactions conducted by Georgia agencies this past year.

While most purchasing studies estimate this savings to exceed $100 per transaction, Georgia estimates, conservatively, that it saves $65 each time a p-card is used, thus saving taxpayers $70 million annually.

Additionally, numerous p-card program attributes can prevent fraudulent purchases, such as limiting the use of p-cards at certain merchant types or restricting the transaction limits on each card. In reality, an effective p-card program provides a superior alternative to cash advances for purchases, petty cash funds and even employee reimbursement through expense reports. They allow full visibility into what has been purchased to ensure that the purchases are for legitimate business needs. Georgia's Department of Administrative Services administers the state's p-card program. We have safeguards in place to monitor the purchases.

A state audit of seven state agencies and universities uncovered the initial instances of questionable p-card usage. The Board of Regents conducted its own systemwide audit of nearly 600,000 p-card transactions.

Working alongside the GBI and the State Inspector General's office, two criminal investigations have concluded and been sent to the state attorney general for prosecution. Another major investigation is under way, with the GBI, working alongside the local district attorney, to investigate yet another incident. Federal agents have been called to investigate the latest incidents at Georgia Tech. And we continue to review other such incidents to determine subsequent investigations and possible criminal proceedings. We met last week to gain further insight into the ongoing university system audits.

The state is aggressively pursuing these scofflaws, as we consider these transgressions to be serious and egregious at all levels.

The state has moved aggressively to put programs in place to educate state staffers on proper management techniques for the p-card program. No fewer than four levels of p-card training courses have been developed and are being administered to p-card holders, their supervisors and p-card program administrators. P-card holders are trained on proper use of the cards, what constitutes valid business purchases, which purchases are not allowed, and how to properly submit invoices to support the monthly p-card bill.

Supervisors are trained on how to properly review p-card expenses submitted by subordinates. Training tips include looking for weekend purchase activity, questioning purchases without proper documentation or receipts, and defining restricted purchases. P-card administrators in each agency are trained in the state's comprehensive p-card policy as well as on how to conduct self-audits of their agency's p-card transactions. Additionally, a team of p-card program compliance auditors now regularly audits state p-card transactions on a rotating basis.

Accordingly, in the past few months, more than 1,200 cards were terminated, 1,000 more p-card holders had their transaction and/or credit limits reduced, and thousands of state staffers have been trained. Enhanced p-card policies are in place, and p-card holders and their supervisors are being held jointly accountable for any violations.

New legislation is being proposed by our agency to make it a felony to utilize state funds for personal gain, where today the charge is only a misdemeanor.

This problem is not about p-cards being used as a payment method for state purchases. This issue is one of employee ethics and inadequate supervision at the agency and university level. It doesn't matter whether a fraudulent purchase is made with a p-card, a purchase order or an employee's personal credit card submitted on an expense report. Fraudulent activity and the abuse of the public's trust is not to be tolerated.

> Brad Douglas is commissioner of the Georgia Department of Administrative Services.