Policy and Procedure Manual
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FMS Policies and Procedures MN

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General Policies

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Obtain Separate Federal Employer Identification Number & Employer Agent Status

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Policy: 

F/EA obtains approval from federal authorities prior to serving as an agent of employer for consumers in the Participant Direction Program. F/EA begins issuing payments to consumers’ employees or withhold taxes from payments prior to  active authority from federal tax agencies to serve as an Employer Agent pursuant to the Fiscal Employer Agent Agreement. The F/EA is not aware of any situation whereby the IRS has denied approval. Policies and Procedures relating to filing for and obtaining approval on behalf of each participant are documented in Submit Form 2678, Employer Appointment of Agent, to the IRS. 
F/EA obtained a separate Employer Identification Number (EIN) specifically for the purpose of filing and depositing Federal Income Tax, Social Security, Medicare and FUTA taxes on behalf of consumers, under Section 3504, Rev. Proc. 70-6, Proposed Regulations REG-137036-08 of January 13, 2010 or under Revenue Procedure 2013-39. That EIN is used for all Federal tax filing, payment and remitting purposes for all consumers active in the F/EA program.
 
The August 2014 IRS Form 2678 instructions state that an agent (F/EA) is not liable for filing any federal tax returns or making any deposits or payments until it receives approval from the IRS to act as an agent for an individual.  Therefore, during the period from when the agent files the IRS Form 2678 for an individual until the agent receives IRS agent approval for that individual, F/EA includes in F/EA's contract with Program Administrator that F/EA is responsible for filing and depositing federal employment taxes and any unfulfilled federal tax obligations, including penalties and interest even before the IRS approves the IRS Form 2678. 
 
F/EA includes the above language in all contracts executed with Program clients.
 

Procedure: 

 
1.      Maintain a separate EIN specifically for the purpose of filing and depositing Federal Income Tax, Social Security, Medicare and FUTA taxes on behalf of participant, under Section 3504, Rev. Proc. 70-6, Proposed Regulations REG-137036-08 of January 13, 2010 of the Internal Revenue Code and under Revenue Procedure 2013-39.

  • F/EA obtained a separate EIN on <<Date>>.  That EIN is <<12-3456789>>.
  •  This EIN is used to file and deposit all Federal Income Tax, Social Security, Medicare and FUTA taxes on behalf of consumers in the Participant Direction Program

2.      Include IRS Form 2678 in each participant’s enrollment packet (See Policy and Procedure Chapter <<X>>)
3.      Each participant must sign a Form 2678 authorizing F/EA to be appointed the participant’s agent under Section 3504, Rev. Proc. 70-6, Proposed Regulations REG-137036-08 of January 13, 2010 of the Internal Revenue Code (See Policy and Procedure <<X>>)

  • Each Form 2678 includes F/EA’s separate agent EIN on page 2 for the EIN for the Agent of Employer.

4.      F/EA submits an executed Form 2678 to the IRS for each participant on whose behalf F/EA pays wages to the participant’s workers (see Policy and Procedure document <<X>>.
5.      F/EA receives notice LTR-1997-C authorizing F/EA to act as agent of each participant
6.      F/EA maintains these notices in each participant’s electronic file (See Policy and Procedure <<X>>)
7.      F/EA obtains Tax Information Authorization per IRS Form 8821.
8.      Each participant should sign a Form 8821 authorizing F/EA to act on behalf of the participant for purposes of obtaining prior EINs.
9.      F/EA retains an executed Form 8821 in electronic files for each participant on whose behalf F/EA pays wages to the participant’s workers(s) (see Policy and Procedure document <<X>>).  The Form 8821 is only filed in the event it is needed to obtain participant information from the IRS.
10.     Include Form SS-4 in each participant's enrollment packet.
11.     Each participant must sign a Form SS-4 allowing the F/EA to attain an EIN for the participant.
12.   The EIN is obtained by calling the IRS and referring to the participant as a "Home Health Care Service Recipient".  

Internal Controls: 

The internal controls used by F/EA to monitor this process are:
1.      The SS-4 containing F/EA’s separate Agent EIN is stored in a locked file drawer in the FEA Coordinator office until all required information is complete, all documents are scanned into electronic files which have limited access by aurhorized personnel only.
2.      All completed Forms 2678 are scanned and maintained per File Retention Policy for a minimum of 7 years
3.      All completed Forms 8821 are scanned and maintained for a minimum of 7 years
4.      All IRS Forms LTR-1997-C authorizing F/EA as agent of the employer are scanned and maintained for a minimum per File Retention Policy of 7 years.
5.     All completed Forms SS-4 are scanned and maintained per File Retention Policy for a minimum of 7 years.
 

HIPAA Policy

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Policy: 

The Health Insurance Portability and Accountability Act (HIPAA) is enforced at F/EA per F/EA’s HIPAA policy. All F/EA operations are performed in accordance with the HIPAA policy. F/EA staff must complete HIPAA training within 2 weeks of hiring a staff member.

F/EA shares their HIPAA policy with Counselors. Counselors educate consumers on F/EA’s HIPAA policy. After reviewing the policy, consumers sign the HIPAA Policy form included in the Fiscal/Employer Agent Start-Up package (See Policy and Procedure document <<X>>).
 
Per Policy and Procedure document <<X>>, F/EA’s processes each executed Receipt of Privacy Practices form. A copy of each form is maintained separately and forwarded to the F/EA <<Staff Title>> monthly.
 
Following the procedure, F/EA's HIPAA Policy is attached.
 
Procedure: 

 

  1. Counselors share the F/EA HIPAA policy during the in-take and orientation session
  2. The signed HIPAA Policy Form is returned to the  <<department>> with the Fiscal/Employer Agent Start up Package
  3. The <<Staff Title>>  follows Policy and Procedure document <<X>> to process the HIPAA Policy Form
  4. <<Staff Title>> selects the HIPAA Policy Form from Fiscal/Employer Agent Start-Up packages
  5. <<Staff Title>> forwards copies of executed forms to:
Privacy Officer’s address
  1. Privacy Officer maintains all forms for a minimum of 7 years per File Retention Policy.
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Counselors share the F/EA HIPAA policy during the in-take and orientation session.
  2. The signed HIPAA Policy Form is returned to the <<department>> with the Fiscal/Employer Agent Start-up Package.
  3. <<Staff Title>> forwards copies of executed forms to F/EA Privacy Officer.
  4. Privacy Officer maintains all forms for a minimum of 7 years per File Retention Policy.



Information Systems Security

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Policy: 

F/EA maintains a System Security Plan Template outlining the security measures enacted to protect and secure F/EA computer systems and data. The System Security Plan is updated with each change to F/EA systems or systems security. Following a change to the Plan, the Plan is reviewed and signed and dated by F/EA executive staff and F/EA officers. All changes to the Plan are tracked under the “Revisions History” section of the plan.

A suggested Plan is published below and should be revised and expanded according to F/EA operations and state regulations.
 
Procedure: 

The purpose of this written information security policy is to define the safeguards that F/EA has in place for protecting confidential information (“CI”) including:

  1. Personal Health Information (“PHI”) -- Any demographic information, medical history, test and laboratory results, insurance information and other health data which may be identified as relating to a specific individual, including any data covered by HIPAA.
  2. Personal Information (“PI”) – A person’s first name and last name or first initial and last name in combination with any one or more of the following data elements that relate to such resident: (a) Social Security number; (b) driver's license number or state-issued identification card number; or (c) financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password, that would permit access to a person’s financial account.

CI shall not include information that is lawfully obtained from publicly available information or from federal, state or local government records lawfully made available to the general public; nor shall it include any information that is excluded from protection by an agreement that F/EA has in place with another entity.

Staff Requirements

F/EA requires all staff members to adhere to the following rules regarding information security:

  1. Computers require a login password, and are set to trigger a password-protected screensaver mode after 5 minutes of inactivity
  2. All computer programs and systems used by F/EA that may contain participant or workers CI must be password-protected
  3. Passwords to web-based software that may contain CI are not cached in any browser
  4. Passwords to specific web-based systems that are likely to contain CI (including email) are required to be changed monthly
  5. Computers with the Windows operating system are required to have anti-virus software installed, and configured to update their virus definitions automatically
  6. Smartphones used to access F/EA web-based systems that are likely to contain CI (including email) must be password protected and require the password to be entered upon powering on or returning from idle 

Physical Security

Paper records (e.g., participant files) are kept in locked file cabinets and are accessible only to authorized F/EA personnel.  CI stored in this manner is accessed only to fulfill F/EA-related tasks and/or duties.

Security Checklist and Staff Requirements

Violations of this policy shall be handled on a case-by-case basis.  Discipline shall also be handled on a case-by-case basis, with potential discipline ranging from retraining to suspension and termination depending on the context of the violation.

Security Incidents

In the event F/EA discovers that unencrypted CI has been accessed by an unauthorized third party, F/EA shall notify all personnel that are impacted by the breach.

Ongoing Responsibility

<<F/EA Director>> shall have ultimate responsibility for the ongoing maintenance of and compliance with this Information Security Policy.

 

Maintain an Up-to-Date Policy and Procedure Manual

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Policy: 

The F/EA <<Quality Assurance Administrator>> is responsible for maintaining the accuracy of the Policy and Procedure Manual. Specific duties of the Quality Assurance Administrator as related to the Policy and Procedure Manual include, but are not limited to:

  1. Assist management with development of policies and procedures as required.
  2. Assist management with updating and maintaining the Fiscal/Employer Agent policies and procedures to ensure relevance and compliance with F/EA’s contractual obligation to clients.
  3. Establish an annual work plan and budget (with collaboration with <<Staff Title>>) to test compliance with all Fiscal/Employer Agent contract deliverables. This work plan must include compliance testing on Corrective Action Plans from previous audit findings. 
  4. Implement the agreed upon work plan and report in writing any non-compliance to <<Staff Title>> and <<Other Staff Titles>>.
  5. Work with Fiscal/Employer Agent staff to develop a plan to correct any areas of non-compliance, and monitor implementation of such plan.
  6. Any non-compliance will be escalated to <<Staff Title>>.
  7. Ensure that communication with department staff occurs routinely and appropriately whenever there is a policy or procedure change.
  8. Assist with retraining staff on policies and procedures for all Fiscal/Employer Agent functions and reports that are not meeting compliance.
Procedure: 

Review Policy and Procedure Manual Quarterly

On a quarterly basis, the Quality Assurance Administrator performs the processes in each Policy and Procedure sub-chapter, to “test” the sub-chapter, thereby ensuring that documented procedures accurately reflect completion of quality processes. “Dummy” tasks must be performed in instances where completing the actual task would be detrimental to F/EA operations. A control document is updated tracking review and update of the each Policy and Procedure sub-chapter.
 
The Quality Assurance Administrator compares the output produced by the procedure with the most recent output produced as part of normal processes. Any discrepancies in output are noted and researched with staff with primary responsibility for the task. Any areas of the sub-chapter that are not sufficiently documented to allow successful completion of the task are reviewed with staff with primary responsibility for the task. A corrective action plan is developed to:
 
  • Update the Policy and Procedure Manual sub-chapter
  • Train staff on updated Policies and Procedures
  • Reconcile Policy and Procedure Manual sub-chapter to contract requirements
 
After completing each process, Quality Assurance Administrator compares the sub-chapter to the relevant sections of the contract between Program Administrator and F/EA, as well as any addenda to the contract or other guidance as provided by Program Manager.  Any discrepancies between the Policy or Procedure and the contract are noted and solutions integrated into the corrective action plan. 
 
As changes to policy or procedure are implemented, the Quality Assurance Administrator will be fully informed. The Quality Assurance Administrator is in attendance at relevant meetings where policies and procedures are discussed and receives copies of applicable correspondence and documentation of policy or process changes. The Quality Assurance Administrator works with assigned staff to understand changes to the policy or process. The Quality Assurance Administrator updates the manual accordingly on an ongoing basis.
 
  1. On a quarterly basis, Quality Assurance Administrator will use each sub-chapter to perform the process described in the manual.
  2. Quality Assurance Administrator opens Policy and Procedure Manual Review Control Sheet YYYY saved at:
  • For each sub-chapter tested, Quality Assurance Administrator updates the following fields:

Sub-Chapter Number
Review Date
Reviewer Initials
Process Completed
Process Discrepancies Identified
Output Produced
Output Reviewed by Primary Staff
Output Discrepancies Identified
Compared to Contract
Contract Comparison Discrepancies Identified
Sub-Chapter Updated per Discrepancies
 
 
  1. Quality Assurance Administrator selects a sub-chapter from the manual
  2. Quality Assurance Administrator performs the process outlined in the Policy and Procedure Manual sub-chapter
  3. Quality Assurance Administrator highlights any areas that are not sufficient to perform the process
  4. After completing process, Quality Assurance Administrator compares output to the output produced by staff with primary responsibility for the task as part of normal processes
  5. Quality Assurance Administrator’s output should be identical (or appropriately similar, depending on the process) to the output produced as part of normal operations
  6. Staff with primary responsibility for the task reviews Quality Assurance Administrator’s output and notes any discrepancies
  7. Quality Assurance Administrator compares sub-chapter to relevant parts of the contract, contract addenda and other guidance issued by workers Program Manager
  8. Discrepancies are noted and reviewed with <<Staff Title>> or other assigned staff as applicable
  9. Any discrepancies in Policy and Procedure Manual sub-chapter are corrected
  10. After reviewing all Policy and Procedure sub-chapters, Quality Assurance Administrator compares reviewed sub-chapters listed in Policy and Procedure Manual Control Document to Table of Contents
  11. Quality Assurance Administrator cross references to ensure that all Policy and Procedure Manual sub-chapters have been reviewed and updated
  12. Quality Assurance Administrator prints Policy and Procedure Manual Control Document
  13. Quality Assurance Administrator signs and dates next to “Prepared By:”
  14. <<Staff Title>> reviews Policy and Procedure Manual Control Document
  15. <<Staff Title>> signs and dates next to “Reviewed By”
  16. Policy and Procedure Manual Control Document is scanned as saved to H:\Policies and Procedures\Review Control Sheets
  17. The scanned file is saved with the quarter and year in the file name
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. A control document is used to track the review and update of the Policy and Procedure Manual.
  2. Staff with primary responsibility for the task for which the sub-chapter is being tested review the output produced by the ‘test’ process to ensure it complies with output produced as part of normal operations.
  3. A corrective action plan is developed for any discrepancies or deviations from the sub-chapter.
  4. Any non-compliance is escalated to <<Staff Title>>
  5. Any continued non-compliance is escalated to the <<Staff Title>>
  6. The Quality Assurance Administrator cross-references the Policy and Procedure Manual Review Control Document with the Policy and Procedure Manual Table of Contents to ensure that all sub-chapters were reviewed.
  7. The Quality Assurance Administrator signs and dates the control document after reviewing all sub-chapters.
  8. The <<Staff Title>> signs and dates the control document after reviewing the control document.
  9. The control document is scanned and saved on the network drive for a minimum of 7 years per File Retention Policy.

Organizational Structure

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Policy: 

The organizational structure of F/EA supports the F/EA to provide excellent service to consumers, workers, vendors, families, administrators and other stakeholders.

Major organizational roles and individuals in those roles are outlined below.  Attached to this chapter is an Organizational Chart.

F/EA Director

<<insert description of role.>>

Important Role 2

<<insert description of role.>>

Important Role 3

Procedure: 

<<Leave this section blank.>>

Internal Controls: 

<<Leave this section blank.>>

Accounting

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Reconciliation of F/EA Operating Bank Account

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Policy: 

The F/EA maintains a separate operating account for each program the F/EA serves.

Each account is exclusively for depositing all reimbursements from Program Administrator for participant services and any other refunds or reimbursements received for participant services. In accordance with the terms of the contract with the F/EA's participant(s), only payments for participant services and employer-related expenses are disbursed from this account.
 
F/EA reconciles General Ledger account <<GL Account Number>>, the Program Operating Account, held with <<Bank>>, monthly. Reconciliation of this account is completed by the 10th of the month following the month for which the reconciliation is performed. This process reveals any discrepancies between F/EA’s records and the bank statement. To prove the accuracy of both records, reconciling differences and open items must be identified, aged and any necessary entries made. 
 
After performing the bank reconciliation, a bank reconciliation statement is prepared by the <<Staff Title>> verified, reviewed by <<Staff Title>>  who signs the bank statement, and stored at <<file path>>. Signed reconciliation sheets are stored for a minimum of 7 years.
Procedure: 

General description 

Each month all cash receipts and disbursements transactions booked in the general ledger account <<GL Account Number>> will be compared with the details reported on the bank statement of the program operating account.
 
Unmatched and mismatched transactions are used to reconcile the book and bank balance.
 
Data or records required to perform this reconciliation:
 
  •   The bank activities for the month including the ending bank balance on the last day of the month.
  •  The check file for all checks processed from the program operating account
  •  A copy of the detailed General ledger Account <<GL Account Number>> for the month.
 
Preparing the Bank Reconciliation
1.      Obtain monthly bank statement for program operating account
2.      Transactions will have been downloaded from bank into a csv file on a daily basis for the month and saved
3.      Sort the daily bank transactions using the <<template>>
4.    Identify and obtain transaction totals for
  •  Automatic transfers to payroll account
  • Checks cashed
  •  Funds transfers (if any) from F/EA corporate account  
  • Payments from participant 
  • Interest received 
  • Any other check deposits 
  • Bank service charges or fees
5.      <<Staff title>> prepares the journal entry to record the transfers to the workers F/EA Payroll Account and the interest earned.
6.      F/EA Accountant posts the entries to the general ledger and prints the Detailed General Ledger Account after entries are posted.
7.      Obtain the monthly check file  for all checks processed from the participant direction program perating account
8.      The check file includes the payments from account workers F/EA Operating Bank Account (Trust Account) for the month, sorted by check number and check amount.
9.      Compare the check file to the general ledger account
10.  Create list of outstanding/uncashed checks
 
Completing the Bank Reconciliation Form
 
This is the summary form for the Bank Reconciliation
 
Enter General Ledger Balance as at end of month
Enter Bank Statement Ending Balance
Enter outstanding checks amount
 
  1. Any discrepancies on the amount is researched and correctly booked  
  2. If a discrepancy is determined to be a bank error, the bank must be notified
  3. The error must be recorded on the bank balance side of the reconciliation form
  4.  If an error is found to be F/EA’s, it is recorded on the general ledger balance side of the reconciliation form with an appropriate adjusting entry in the General Ledger as needed
  •    Any debit or credit memoranda on the bank statement are identified.
  •   These charges and credits are recorded as adjustments to the general ledger of the bank reconciliation form.

  5.    The reconciliation form is printed.

  •   The <<staff title>> reviews the sheet and verifies that all entries and mathematical calculations are correct.
  •   After verifying, the <<staff title>> signs and dates the reconciliation sheet.
  •  The <<staff title>> provides the reconciliation sheet, bank statement, check file and daily bank downloads to <<Staff Title>>
  •   <<Staff Title>> reviews all documents for completeness and mathematical accuracy.
  •   After verifying, <<Staff Title>> signs and dates the reconciliation sheet.
  •  <<Staff Title>> stores this reconciliation in applicable file folder.
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA in the reconciliation of program operating account are:
 
  1. F/EA Controller or Chief Financial Officer are the only individuals within F/EA authorized to transfer funds into and out of program operating account
  • These individuals are the only check signatories on the trust account

   2.  The <<staff title>> performs the bank reconciliation.

  • The <<staff title>> verifies the supporting documents, the bank statement and check file for accuracy.
  • The <<staff title>> enters all transactions on a control document, the reconciliation sheet. This sheet is prenumbered.The <<staff title>> signs and dates the control document, the reconciliation sheet

. 3. Prior to making a posting to the General Ledger, the <<Staff Title>> reviews the reconciliation statement, including the bank statement and check file.

  • The <<Staff Title>> verifies not only completeness, but also validity.
  • The <<Staff Title>> reviews the supporting documents, the bank statement and check file, for mathematical accuracy.
  • After reviewing, the <<staff title>> signs and dates the control document, the reconciliation sheet.

  4.  All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.

Reconciliation of Service Claim Accounts Receivable

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Policy: 

F/EA reconciles the accounts receivable service claims account <<GL Account Number>> monthly. Reconciliation of this account is completed by the 10th of the month following the month for which the reconciliation is performed. 

The complete reconciliation process is the result of 6 segregated processes. A single individual does not control the entire process.
 
  1. Enter Weekly Billing to YTD Accounts Receivable, performed weekly
  2. Post Accounts Receivable to General Ledger, performed weekly
  3. Post Accruals to General Ledger, performed monthly
  4. Reconciliation of Program Payments to Billing Claims, performed weekly (or when payment is received)
  5. Post Payments to General Ledger, performed monthly
  6. Reconcile Accounts Receivable to General Ledger, performed monthly
  • Results should be escalated to Controller or CFO for stale items
These reconciliations are performed to ensure that the F/EA is appropriately submitting service claims to the participant and tracking payments and receivables. 
 
After performing the reconciliation, a reconciliation statement is prepared by the F/EA Accountant (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<file path>>. Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.
Procedure: 

Reconcile Accounts Receivable to General Ledger

Performed Monthly

Insert F/EA specific process here.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

 
  1. <<Staff Title>> reconciles supporting documents to ensure billing is submitted appropriately and payments are applied to claims appropriately.
  2. <<Staff Title>> creates journal entry templates.
    • Each journal entry template is used as a control document.
    • Each reconciliation document is prenumbered.
    • <<Staff Title>> signs and dates verifying accuracy.
  3. F/EA Accountant reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • F/EA Accountant signs and dates journal entry template.
  4. <<Staff Title>> reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • <<Staff Title>> signs and dates journal entry template.
  5. <<Staff Title>> posts journal entries.
  6. <<Staff Title>> reconciles General Ledger to appropriate supporting documents at each month.
  7. <<Staff Title>> produces reconciliation documents, verifies, signs and dates.
  8. <<Staff Title>> reviews, verifies, signs and dates reconciliation documents
  9. CFO or Controller reviews uncollectible items after <<Staff Title>> prepares and <<Staff Title>> verifies for accuracy.
  10. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.

Reconciliation of General Ledger Liability Account for FICA

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Policy: 

A reconciliation of FICA workers and employer tax is performed monthly. A reconciliation of Form 941, including FICA taxes, is performed quarterly.

These reconciliations are performed to ensure payments made for employment tasks are appropriately accounted and tracked and to ensure that the reporting agent withholds and remits payments to tax agencies accurately and timely.

After performing the reconciliation, a reconciliation statement is prepared by the <<Staff Title>> (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<file path>>. Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.

Procedure: 

 

Reconciliation of FICA Payments to General Ledger
Performed Monthly
Account <<GL Account Number>>
 
  1. F/EA Accountant reviews bank account transactions for FICA payments processed from program operating account
  2. Sum all payments made for FICA from program operating account found here: <<file path>> bank download
  3. Subtotals with description “IRS USATAXPYMT” are weekly Federal Income Tax, and Employer and Employee FICA payments
  4. Obtain report from www.eftps.gov called EFTPS Batch Provider Payment Inquiry Report
  5. Compare payments made within the month from the bank account to payments made weekly as shown on EFTPS Batch Provider Payment Inquiry Report
  6. Identify, research and resolve any discrepancies
  7. Open the reconciliation worksheet found at <<file path>>
  8. Enter sum of FICA payments from bank account on bank account transactions sheet
  9. Ending balance and sum of payments should match
  10. Research and correct any discrepancies
  11. Make necessary adjustments to general ledger if required
  12. All adjustments must be reviewed by <<Staff Title>>
  13. <<Staff Title>> signs and dates control document notating any adjustments
  14. <<Staff Title>> signs and dates reconciliation sheet
  15. <<Staff Title>> passes reconciliation sheet and supporting documents to <<Staff Title>><<Staff Title>> verifies completeness and mathematical accuracy
    1. <<Staff Title>> signs and dates reconciliation sheet
Reconciliation of FICA and Federal Withholding Returns and Payments
Performed Quarterly (See Policy and Procedure 8.1)
        1. F/EA makes deposits per deposit frequency after each payroll.
  • 941 deposit includes FICA (Social Security and Medicare tax) withheld from workers pay, FICA (Social Security and Medicare tax) paid by the employer on workers pay and Federal Income Tax withheld from workers pay
  •  Payroll Department sends a weekly payment breakdown for 941 payments to Accounting <<Staff Title>>
2.      Each quarter, Payroll Department sends a quarterly payroll summary of 941 payment
3.      Each quarter Payroll Department sends a copy of form 941, Schedule B, and Schedule R, to Accounting Department after submitting it to the IRS
4.     <<Insert reconciliation process here>>

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

 

The methods of internal control utilized by F/EA in the Reconciliation of General Ledger Liability Account for FICA are:

  • Each of the supporting documents are reviewed for mathematical accuracy by each verifier
  • Each reconciliation document is prenumbered
  • Each party initials and dates each reconciliation document displaying confirmation of their review
  • All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.
  • All adjustments require supervisory review and approval 

 

Reconciliation of General Ledger Liability Account for Unemployment Tax

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Policy: 

Monthly general ledger reconciliation is completed to ensure that State Unemployment Tax (SUTA) and Federal Unemployment Tax (FUTA) liabilities are accurately recorded in the general ledger. Quarterly these general ledger balances are reconciled to SUTA and FUTA payments made on behalf of employers.

Reconciliations of the employer Federal Unemployment Tax (FUTA) payments and State Unemployment Tax (SUTA) are performed quarterly. A reconciliation of the Federal Unemployment filing, Form 940, is performed annually.
 
These reconciliations are performed to ensure payments made for the employer-related tasks are appropriately accounted and tracked.
 
After performing the reconciliation, a reconciliation statement is prepared by the <<Staff Title>> (or assigned staff), verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<File Path>>. Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.
Procedure: 

Reconciliation of FUTA and SUTA Liabilities to General Ledger

Performed Quarterly

<<GL Account Number>>
1.      F/EA Accountant prints General Ledger balance for account <<Account Number>>
2.      F/EA Accountant (or assigned staff member) open reconciliation sheet found at <<File Path>>
3.    Enter ending balance for account
4.      Enter sum of each type of tax liability for FUTA and SUTA from F/EA payment documents
5.    Ending balance and sum of liabilities should match
6.    Research and correct any discrepancies
7.    Make necessary adjustments to general ledger
8.      <<Staff Title>> signs and dates reconciliation sheet
9.     <<Staff Title>> passes reconciliation sheet and supporting documents to <<Staff Title>>
10.      <<Staff Title>>verifies completeness and mathematical accuracy
11.  <<Staff Title>> signs and dates reconciliation sheet
 
 
Bank Reconciliation of FUTA and SUTA Payments
Performed Quarterly
Account <<GL Number>>
 
1.       F/EA Accountant (or assigned staff member) review bank account transactions for FUTA and SUTA in Program Operating Account
2.     Sum all quarterly payments made for each tax type from workers F/EA Payment Account found here: <<File Path>> bank download
3.    Create subtotals of payments for each tax type Subtotals with description “IRS USATAXPYMT” are FUTA or 941 payments.
4.    To identify FUTA payments as separate from 941 payments, compare values to EFTPS Batch Provider Payment Inquiry Report
5.     Identify FUTA payments
6.    Payroll department will send a report of the payments made on behalf of all employers with SUTA liabilities for the quarter
7.      Verify these payments have cleared the bank account
8.      After verifying payments have cleared the bank, these payments must be posted to the General Ledger
9.    Compare payments for each tax type to the sum of monthly liabilities for the quarter 
10.  Make applicable adjustments
11.     <<Staff Title>> prints reconciliation sheet and supporting documents
12.   <<Staff Title>> reviews for accuracy and signs
13.   <<Staff Title>> reviews for accuracy and signs
14.   Signed copy is stored for a minimum of 7 years per File Retention Policy
 
Reconciliation of FUTA Quarterly and Annual Returns and Payments
Performed Quarterly and Annually
1.      Per IRS Guidance (Proposed Rules REG-137036-08-1) F/EA makes one aggregate payment per quarter for Federal Unemployment Tax on behalf of all consumers represented by F/EA
  •  A report showing the FUTA liability for each participant employer is produced by the payroll department and attached to the proof of payment
2.      At year-end, form 940 is compared to sum of quarterly FUTA payments
  •   Ensure that line 3 of Form 940 matches sum of gross payment from F/EA Payroll Journal quarterly reports
3.      Obtain an EFTPS Batch Provider Payment Inquiry report for the year for F/EA’s separate F/EA EIN from EFTPS website
4.    Compare Line 13 to EFTPS Batch Provider Payment Inquiry report which shows all payments processed through EFTPS and recorded by the IRS
5.  Ensure line 13 is greater than or equal to line 12 on form 940
 
Reconciliation of SUTA Quarterly Returns and Payments
Performed Quarterly
  1. Quarterly, payroll department makes payments to tax agency for State Unemployment Tax (SUTA)
  2. Each quarter payroll department produces a Transmittal Report for showing the employer, state ID, State Unemployment tax payment, total wages, excess wages, taxable wages, tax rate, Federal ID and monthly workers counts
    • Payments reported on this report have been made to the State Unemployment Agency for SUTA for the quarter
  3. Compare the sum of payments on the Transmittal Report to the amount withdrawn from the program operating account and paid to the State Unemployment Tax Agency
  1. Compare the amount on the “Payment Check Listing” to the amount coming from bank and being paid to State Division of Unemployment Assistance or equivalent on paper check

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA in the Reconciliation of General Ledger Liability Account for Unemployment are:
  1. Each of the supporting documents are reviewed for mathematical accuracy by each verifier.
  2. Each reconciliation document is prenumbered.
  3. Each party initials and dates each reconciliation document displaying confirmation of their review.
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.
  5. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations. 
 

 

Reconciliation of General Ledger Liability Account for Federal Withholding Tax

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Policy: 

A reconciliation of workers Federal Withholding Tax is performed monthly.

A reconciliation of Forms 941, including Federal Withholding Tax taxes, is performed quarterly.
 
These reconciliations are performed to ensure payments made on behalf of employers represented by the F/EA are appropriately accounted and tracked.
 
After performing the reconciliation, a reconciliation statement is prepared by the <<Staff Title>> (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<File Path>>.  Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.
Procedure: 

Reconciliation of Federal Withholding Tax Payments to General Ledger

Performed Monthly
<<GL Account Number>>
  1. <<Staff Title>> reviews bank account transactions for Federal Withholding Tax payments process from program operating bank account
  2. Sum all payments made for Federal Withholding Tax from program operating bank account
  3. Subtotals with description “IRS USATAXPYMT” are weekly Federal Income Tax, Social Security and Medicare Tax payments
  4. Obtain report from payroll department called EFTPS Batch Provider Payment Inquiry Report
  5. Compare payments made within the month from the bank account to payments made weekly as shown on EFTPS Batch Provider Payment Inquiry Report
  6. Identify, research and resolve any discrepancies
  7. Communicate with payroll department as necessary
  8.  Direct payroll department to make adjustments to their records as necessary
  9. Print reconciliation sheet for <<GL Account Number>> found at <<File Path>>
    • Enter ending balance for account

 10. Enter sum of Federal Withholding Tax payments from bank account on bank account transactions sheet

  • Ending balance and sum of payments should match
  • Research and correct any discrepancies
  • Make necessary adjustments to general ledger if required

 11.  F/EA Accountant signs and dates reconciliation sheet

 12.  F/EA Accountant passes reconciliation sheet and supporting documents to <<Staff Title>>

 13.  <<Staff Title>> verifies completeness and mathematical accuracy

 14.  <<Staff Title>> signs and dates reconciliation sheet

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA in the Reconciliation of General Ledger Liability Account for Federal Withholding Tax are:
  1. Each of the supporting documents are reviewed for mathematical accuracy by each verifier
  2. Each reconciliation document is prenumbered
  3. Each party initials and dates each reconciliation document displaying confirmation of their review
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.

Reconciliation of General Ledger Liability Account for State Withholding Tax

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Policy: 

A reconciliation of State Withholding Tax (SWT) liability is performed monthly.

A reconciliation of SWT returns and payments is performed quarterly.
 
These reconciliations are performed to ensure payments made on behalf of employers represented by the F/EA are appropriately accounted and tracked.
 
After performing the reconciliation, a reconciliation statement is prepared by the <<Staff Title>> (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<File Path>> Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.
Procedure: 

Reconciliation of State Withholding Tax Payments to General Ledger

Performed Monthly
<<GL Account Number>>
  1. F/EA Accountant (or assigned staff member) reviews bank account transactions for State Withholding Tax (SWT) payments processed from the program operating bank account.
  2. Sum all payments made for SWT from workers F/EA Payroll Account found here: <<File Path>> Payroll download
  3. Subtotals with description “<<STATE DOR>> EFT WITH TAX” are SWT payments
  4. Obtain reports from payroll department showing state tax withholding payments on a weekly basis
    • These reports are separated by employers who remit payments weekly, monthly and quarterly (depending on the employer's individual tax deposit frequency)

  5.  Compare payments made within the month from the bank account to payments made as reported on weekly SWT tax payment reports

  6.  Identify, research and resolve any discrepancies

  7.  Communicate with payroll department as necessary

  8.   Direct payroll department to make adjustments to their records as necessar

  9.   Print reconciliation sheet for account <<GL Account Number>> found at <<File Path>>

 10.   Enter ending balance for <<GL Account Number>>

 11.   Enter sum of State Withholding Tax quarterly payments from bank account on reconciliation sheet

 12.   Ending balance and sum of payments should match

 13.   Research and correct any discrepancies

 14.   Make necessary adjustments to general ledger if required

 15.   <<Staff Title>> signs and dates reconciliation sheet

 16.  <<Staff Title>> passes reconciliation sheet and supporting documents to <<Staff Title>> (or assigned staff member)

 17.  <<Staff Title>> verifies completeness and mathematical accuracy

 18.  <<Staff Title>> signs and dates reconciliation sheet

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA in the Reconciliation of General Ledger Liability Account for FICA are:
  1. Each of the supporting documents are reviewed for mathematical accuracy by each verifier
  2. Each reconciliation document is prenumbered
  3. Each party initials and dates each reconciliation document displaying confirmation of their review
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.

Reconciliation of General Ledger Liability Account for Workers' Compensation

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Policy: 
<<Insert how Workers' Compensation is priced and paid for here.>>
 
 
After performing the reconciliation, a reconciliation statement is prepared by the F/EA Accountant (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<File Path>>. Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.
Procedure: 

Reconciliation of Workers’ Compensation Liability to General Ledger

Performed Monthly
<<Insert GL Account Number>>
  1. Obtain General Ledger ending balance for <<GL Account Number>>
  2. <<Insert Staff Title>> print reconciliation sheet for account found here: <<File Path>>
  3. Enter ending balance for account
  4. Enter sum of Workers’ Compensation liability from Payroll Journal Summary
    • Ending balance and Payroll Journal Summary should match
    • Research and correct any discrepancies
    • Make necessary adjustments to general ledger

  5.  <<Insert Staff Title>> signs and dates reconciliation sheet

  6.  <Insert Staff Title>> passes reconciliation sheet and supporting documents to <<Staff Title>>

  7.  <<Staff Title>> verifies completeness and mathematical accuracy

  8.  <<Staff Title>> signs and dates reconciliation sheet

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA in the Reconciliation of General Ledger Liability Account for Workers’ Compensation are:
  1. Each of the supporting documents are reviewed for mathematical accuracy by each verifier
  2. Each reconciliation document is prenumbered
  3. Each party initials and dates each reconciliation document displaying confirmation of their review
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.

Reconciliation of Uncashed Checks

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Policy: 

F/EA reviews uncashed checks monthly in conjunction with the monthly reconciliations. After one year, any checks that have not been cashed are removed from the bank reconciliation uncashed checks list (<<GL Account>>) and recorded in General Ledger account <<Account No,>>. F/EA follows unclaimed property procedures for the state in which employees being paid reside.

 
After performing the reconciliation, a reconciliation statement is prepared by the F/EA Accountant (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<File Path>>. Signed reconciliation sheets are stored for a minimum of 7 years.
 
Procedure: 
  1. On a monthly basis, F/EA Accountant prints ending balance for account <<GL Account Number>> (uncashed checks GL account)
  2. Enter ending balance to reconciliation sheet for applicable account found here: <<File Path>>
  3. Open F/EA Uncashed Checks spreadsheet found here: <<File Path>> 
  4. Open tab for applicable month
  5. Sum uncashed checks for the month
  6. Enter sum of uncashed checks for month on reconciliation sheet
  7. Ensure the sum of uncashed checks amount matches the ending balance
    • Any discrepancies should be researched and corrected
    • Applicable adjusting entries should be posted to account

  8.  F/EA Accountant signs and dates reconciliation sheet

  9.  F/EA Accountant passes reconciliation sheet and supporting documents to <<Staff Title>>

 10. <<Staff Title>> verifies completeness and mathematical accuracy

 11. <<Staff Title>> signs and dates reconciliation sheet

 12. Signed reconciliation sheet is scanned and saved here for at least seven years: <<File Path>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

 The methods of internal control utilized by F/EA in the Reconciliation of Uncashed Checks are:
  1. Each of the supporting documents are reviewed for mathematical accuracy by each verifier
  2. Each reconciliation document is prenumbered
  3. Each party initials and dates each reconciliation document displaying confirmation of their review
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.

Reconciliation of Administrative Claim Accounts Receivable to General Ledger

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Policy: 

This is a reconciliation of the F/EA's Accounts Receivable for claims submitted by the F/EA for the F/EA's Administrative Reimbursement.

F/EA reconciles the accounts receivable administrative account <<GL Account Number>> monthly. Reconciliation of this account is completed by the 10th of the month following the month for which the reconciliation is performed. 

The complete reconciliation process is the result of 5 segregated processes. A single individual does not control the entire process.
 
  1. Post Admin Accounts Receivable to General Ledger is done whenever a Administrative fee billing is done or at minimum monthly (See Policy and Procedure Document 21.1)
  2. Reconciliation of Administrative Payments to Billing Claims, performed whenever a payment is received
  3. Post Payments to General Ledger, performed whenever a payment is received or at minimum monthly
  4. Reconcile Accounts Receivable to General Ledger, performed monthly
  5. Results should be escalated to Controller or CFO for claims unpaid for over 90 days or reconciliations not completed within 10 days of month end 
These reconciliations are performed to ensure that the F/EA is accurately and timely submitting Administrative claims to the participant and tracking payments and receivables. 
 
After performing the reconcilation, a reconciliation statement is prepared and signed by the F/EA Accountant (or assigned staff) verified, reviewed by <<Staff Title>> (or assigned staff) who signs the reconciliation and stored at <<File Path>>. Signed reconciliation sheets are stored for a minimum of 7 years per File Retention Policy.
 
 
Procedure: 

Reconcile Accounts Receivable to General Ledger

Performed Monthly
  1. <<Staff Title>> (or assigned staff member) opens billing system
  2. Run aging report
  3.  Copy these results into excel
  4. Sort by bill date to determine aging
  5.  Subtotal accounts receivable to show aging receivable for 0-30 days, 31-60 days, 61-90 days and more than 90 days
  6. The total of aging Accounts Receivable is the current Accounts Receivable balance
  7. Total current Accounts Receivable should match the Accounts Receivable balance in the control sheet saved here: <<File Path>>
  8. <<Staff Title>> prepares an aging report saved here <<File Path>>
  9. <<Staff Title>> provides aging report and supporting documents to <<Staff Title>> for verification
  10. <<Staff Title>> reviews for mathematical accuracy
  11. <Staff Title>> (or assigned staff member) prints ending balance for G/L Account
  12. <<Staff Title>> compares the ending balance from the General Ledger to the aging report prepared by <<Staff Title>>
  13. Any discrepancies must be researched and resolved
  14. <<Staff Title>> completes the Accounts Receivable reconciliation form for account <<GL Account Number>> saved here <<File Path>>
  15. Enter GL Ending Balance for account on reconciliation sheet
  16. Enter aging detail prepared by <<Staff Title>>
  17. The open balance in the billing system must match the ending balance in the GL Account 
  18. Any discrepancies must be researched and resolved
  19. After reconciling the GL ending balance for the month to the billing system open balance, <<Staff Title>> prints the reconciliation sheet
  20. <<Staff Title>> verifies and signs the reconciliation sheet
  21. <<Staff Title>> reviews reconciliation sheet and supporting documents for mathematical accuracy and completeness
  22. <<Staff Title>> signs and dates reconciliation sheet and returns to <<Staff Title>> for storage
  23. <<Staff Title>> identifies all open items for uncollectible claims over X months old
  24. <<Staff Title>> prepares a report of uncollectible claims and submits to F/EA Chief Financial Officer
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reconciles supporting documents to ensure billing is submitted accurately and timely and payments are applied to claims accurately and timely.
  2. <<Staff Title>> creates journal entry templates.
    • Each journal entry template is used as a control document.
    • Each reconciliation document is prenumbered
    • <<Staff Title>> signs and dates verifying accuracy
  3. <<Staff Title>> reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • F/EA Accountant signs and dates journal entry template.
  4. <<Staff Title>> reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • <<Staff Title>> signs and dates journal entry template.
  5. <<Staff Title>> reconciles General Ledger to appropriate supporting documents at each month..
  6. <<Staff Title>> produces reconciliation documents, verifies, signs and dates.
  7. <<Staff Title>> reviews, verifies, signs and dates reconciliation documents
  8. CFO or Controller reviews uncollectible items after <<Staff Title>> prepares and <<Staff Title>> verifies for accuracy.
  9. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations.
 

Reconciliation of Forms W-2

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Policy: 

F/EA reconciles the Year-End Payroll Journal Summary report for the calendar year provided by the payroll department to forms 941 for the calendar year. This reconciliation is performed between January 1 and January 31 of the year following the calendar year for which forms W-2 are produced. 

Due to the large number of workers paid by F/EA, Forms W-2 must be filed electronically with the Social Security Administration (click here for instructions from the SSA). As a result, Form W-3 is not required and a reconciliation of form W-3 is not meaningful. The reconciliation of forms W-2 to the quarterly 941 filings meets the requirement to reconcile both W-2 and W-3 information returns.
 
The complete reconciliation process is the result of 4 segregated processes. A single individual does not control the entire process.
 
  1. Enter Weekly Tax Amounts from payroll reports, performed weekly 
  2. Reconciliation of FICA and FIT Returns (941) and Payments, performed quarterly
  3. Reconciliation of FICA, FIT and SIT payment to General Ledger, performed monthly
  4. Reconciliation of Year End Payroll Journal Summary report to Forms 941 for calendar year, performed annually
 
This reconciliation is performed to ensure that the F/EA is submitting forms W-2 for the correct amount of wages, FICA, Federal Income Tax, and Earned Income Credits as reported to the IRS on form 941 and State Income Tax. This reconciliation is also performed to ensure that payments have been accurately made for income tax and FICA withheld from workers wages. 
 
After performing the reconciliation, a reconciliation statement is prepared by the <<Staff Title>> (or assigned staff). It is then verified and reviewed by <<Staff Title>> (or assigned staff) who signs the bank statement, and stored at <<File Path>> Signed reconciliation sheets are stored per Retention Policy for a minimum of 7 years.
Procedure: 

Reconcile Forms W-2 Payroll Journal Summary to Forms 941

Performed Annually between January 1 and January 31
1.      <<Staff Title>> (or assigned staff member) obtains Year End Payroll Journal Summary Report from payroll department
  •  This report shows wages, workers Social Security tax, workers Medicare tax, Federal withholding tax, Earned Income Credit, state wages and state withholding tax for each workers paid in the calendar year.
2.      <<Staff Title>> collects receipt from payroll department showing that the electronic file of forms W-2 was submitted to the Social Security Administration via Business Services Online by March 31
  •  Receipt is scanned to <<File Path>>
  •  Receipt is stored for a minimum of 7 years per File Retention Policy
3.      <<Staff Title>> collects reconciled Forms 941 for the calendar year
4.      A pre-numbered reconciliation sheet is used for this reconciliation

<<F/EA should create a reconciliation sheet that to compare 941 amounts to amounts actually paid throughout the year.  F/EA should also reconcile Form 941 to Schedule B and Schedule R.  Create a process and insert that process here.>>

5.   <<Staff Title>> prints the reconciliation sheet

6.  The <<Staff Title>> reviews the sheet and verifies that all entries and mathematical calculations are correct.

7.  After verifying, the <<Staff Title>> signs and dates the reconciliation sheet.

8.  <<Staff Title>> reviews all documents for completeness and mathematical accuracy.

9.   After verifying, <<Staff Title>> signs and dates the reconciliation sheet.

10.  <<Staff Title>> stores this reconciliation sheet by scanning it to <<File Path>>

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA are:
  1. Each of the supporting documents are reviewed for mathematical accuracy by each verifier
  2. Each reconciliation document is prenumbered
  3. Each party initials and dates each reconciliation document displaying confirmation of their review
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for account reconciliations

Write off Unpaid Claims

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Policy: 

F/EA shall prepare and review an aged trial balance of the accounts receivable as often as necessary, but at least annually at year-end, in order to determine if any delinquent receivables must be written off as bad debts.

The F/EA Accountant will send the request to the <<Staff Title>> and the Chief Financial Officer for authorization to write-off receivables as bad debts. The request shall be supported by sufficient evidence that the claims are uncollectible.

Procedure: 

 

  1. Each month, <<Staff Title>> will save an Accounts Receivable Aging Report to <<File Path>>
  2. The spreadsheet is sorted by bill_date
    • Receivable are categorized based on aging: 0-30 days, 31-60 days, 61-90 days, and over 90 days 
  3. Any receivables over 30 days old are researched
  • If the claims are denied because of eligibility or any failure by F/EA to comply with program rules and regulations, the claims will be deemed uncollectable from the participant.
  • These claims will be written-off per this procedure
  1. <<Staff Title>> prepares a spreadsheet called Write-off MMYY saved in <<File Path>>. 
  2. Each entry to be written off is entered in the spreadsheet
  3. For each claim that will be written off, the remittance advice claim number is entered into the spreadsheet for the claim
  4. <<Staff Title>> prepares a cover letter and the Write-Off report
  5. Cover letter and Write-Off report are submitted to the <<Staff Title>> and or the Chief Financial Officer for authorization to write off the claims.
  6.  <<Staff Title>> and or the Chief Financial Officer approves the write off by signing the report and returning it to the F/EA Accountant.
 
Post Bad Debt Write-Off For Reimbursement from F/EA
 
  1. <<Staff Title>> will copy the authorized Write off Report and forward it to the <<Staff Title>> to adjust the claim in the billing system.
  2. <<Staff Title>> adjusts claims in the billing system.
  3. <<Staff Title>> prepares a journal entry to record the write off and record the reimbursement due to the Cash Advance Account from F/EA
  4. The General Ledger Account receivable account <<GL Account>> is credited and the General Ledger Account # Due to/Due From Service Account <<GL Account Number>>.
  5. <<Staff Title>> signs and dates the journal entry.
  6. <<Staff Title>> forwards to <<Staff Title>> for approval
  7. <<Staff Title>> signs and date the journal entry
  8. <<Staff Title>> returns to <<Staff Title>> for posting
  9. <<Staff Title>> posts the journal entry to the General Ledger
  10. <<Staff Title>> emails Chief Financial Offcier to request reimbursement for the bad debt written off.  
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification. The methods of internal control utilized by F/EA are:

  1. An Aging Report of denied claims is produced and verified monthly
  2. Each denied claim is individually researched by the <<Staff Title>> and reviewed by the <<Staff Title>>
    1. Any claims that are deemed unrecoverable at the fault of F/EA are reported on the Write Off report
  3. The F/EA Accountant prepares, signs and dates a journal entry template and the Write Off report
  4. The <<Staff Title>> or CFO review and sign the Write Off report
  5. <<Staff Title>>  verifies that the deposit for the Write Off amount was made to the program operating account from the F/EA account

Establishment of Consumers as Employers of Workers

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General Policies for Consumer Employers

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Policy: 

This sub-chapter identifies general policies for Consumer Employers in participant-directed programs served by a Fiscal/Employer Agent.

A participant need only operate as an employer or designate a representative to serve as an employer on the participant's behalf if the participant chooses to directly hire employees.  In general, any worker who is not employed by another entity when he/she provides service to a participant and does not have a specific license to provide the service provided to the participant and who the participant directs is an employee of the participant employer.

The Internal Revenue Service generally views consumers or their representatives as common law employers of workers that the participant or representative directs as part of the participant-directed program.

<<Insert program specific policy for who can be an employer on the participant's behalf in the program>>

For purposes of acting in the official capacity as the employer of workers who provide service to the participant, the participant or someone the participant designates can act as the employer.  If the participant chooses to designate someone to act on the participant's behalf as the employer, that individual is referred to as the 'employer' or 'representative.' 

Employer tax registration and F/EA authorization forms are completed using the employer's name and identifying information.  If the participant operates as the employer, the participant's information is populated on employer tax registration and F/EA authorization forms as the "employer."  If the representative operates as the employer, the representative's information is populated on employer tax registration and F/EA authorization forms as the "employer." 

In many cases throughout this manual, the employer may be referred to as the "employer", "participant", "participant employer" or "representative" depending on the context.

In programs served by the F/EA, participant employers are considered "Household" or "Domestic" employers by the Internal Revenue Service, Department of Labor and State Departments of Labor.

Employer Start Up Packages

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Policy: 

<<Before making changes to this chapter, identify who is authorized to operate as an employer in the program.  Some programs only allow consumers to be employers while others allow the participant to authorize another person (often called a representative) to operate as the employer>>  See General Policies for Consumer Employers

The Employer Start Up Package includes important introductory forms for the participant and all required forms for the participant or his/her representative to be established with tax agencies as an employer. This package also includes forms for the participant or representative to designate tax filing and payment responsibilities for the participant's employer accounts to F/EA.

A new participant receives the Start Up package from <<the participant's Counselor only after the Counselor has received a referral from Program Administrator.>> <<This package is provided to the participant or representative by the Counselor at the intake and orientation meeting.>> The Counselor goes over each form with the participant, helping the participant to understand and complete them.

<<Insert policy for how and when Employer Start Up Packages are produced and distributed.  Insert any program specific policies about production and distribution of Start Up packages.>>
 
Employer Start Up packages are completed by consumers or consumers' representatives
 
 
 The F/EA checks for updated forms on a monthly basis. As new versions of forms are identified, the Start Up Package is updated with the new version.
 
Upon request, F/EA submits a copy of the Employer Start Up Package to Program Administrator, participant direction program Manager.
Procedure: 

<<Insert Process for how Employer Start-Up Packages are Distributed to Consumer Employers>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to distribute Consumer Orientation Packages are:
  1. A control document is used to track checking for updated forms at least monthly.
  2. Staff verifies whether there are new forms in use at relevant agency websites prior to placing a printing order for new forms (See Stay Up to Date with Forms, Rules and Regulations)
  3. <<Insert other Internal Controls related to pre-populating and distributing Employer Start-Up Packages to Consumers>>

Consumer Agreement(s)

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Policy: 

F/EA includes an agreement between the F/EA and the participant in every Employer Start-up Package.  The intent of the Consumer Agreement is to ensure that both the participant and F/EA clearly understand each other's roles in the participant direction program and both agree to their roles.  This form is included as a standard part of every employer packet produced.

The F/EA Consumer Agreement is attached here.

Form SS-4, Application for Employer Identification Number

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Policy: 

F/EA includes IRS Form SS-4, Application for Employer Identification Number, in every employer start up package.

On line 1 of Form SS-4, after listing the employer's name, "HCSR" must be written.  HCSR is the IRS' term for participant employers.  It stands for Home Care Service Recipient.  Line 1 of Form SS-4 should appear like the below:

"John Doe, HHCSR"

Otherwise, Form SS-4 should be completed per the attached example.

IRS Form 2678, Employer Appointment of Agent

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Policy: 

F/EA includes IRS Form 2678, Employer Appointment of Agent, in every Employer start up package.  F/EA completes Form 2678 per attached example.  This form is included as a standard part of every employer packet produced.

IRS Form 8821, Tax Information and Authorization

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Policy: 

F/EA includes IRS Form 8821,Tax Information and Authorization, in every employer start up package.  Form 8821 is completed per attached example.  This form is included as a standard part of every employer packet produced.

Note that an executed Form 8821 is no longer required by the IRS for Fiscal/Employer Agent services, but it is a best practice to obtain executed Forms 8821 and file them with the IRS.

State Power of Attorney for State Income Tax

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Policy: 

F/EA should update this sub-chapter per State requirements. Verify with your state if a Power of Attorney or similar form is needed for the F/EA to operate on behalf of an employer to file and pay withheld state income taxes.  If so, update this sub-chapter to reflect the appropriate policy, procedure and internal controls.

State Power of Attorney for State Unemployment Tax

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Policy: 

F/EA should update this sub-chapter per State requirements. Verify with your state if a Power of Attorney or similar form is needed for the F/EA to operate on behalf of an employer to file and pay state unemployment taxes.  If so, update this sub-chapter to reflect the appropriate policy, procedure and internal controls.

Collect and Process F/EA Start Up Packages

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Policy: 

The F/EA Start-Up Package includes all forms that a participant must complete to become an employer in the participant direction program. F/EA receives Fiscal/Employer Agent Start-Up Packages, as completed by consumers, via the Counselors. Original signatures must be on all forms, so original packages are only accepted via mail and drop-off at F/EA. All packages are quality checked within 2 business days of receipt. F/EA Start-Up Packages that are incomplete or inaccurate are returned to consumers within 2 business days of receipt.

All forms included in the F/EA Start-Up Package are required. A participant will not be established as an employer in the Worker program without satisfactorily completing all forms in the F/EA Start-Up package. For F/EA Start-Up Packages that pass a quality check without errors, F/EA obtains an Employer Identification Number (EIN) on the participant’s behalf. After successfully obtaining an EIN for the participant, the participant information can be entered into the payroll system. 
Procedure: 

Quality Check the F/EA Start-Up Package

All F/EA Start-Up Packages are quality checked by F/EA staff immediately upon receipt. <<Staff Title>> (or assigned staff member) is responsible for quality checking F/EA Start-Up packages. Forms that are not accurately or completely filled out are returned to the Counselor with an explanation of errors that must be corrected. Under no circumstances does F/EA obtain an EIN for a participant if forms are missing or are not correctly completed.
 
F/EA cannot provide tax advice for completion of any forms. If consumers or representatives have questions about the impact on their personal tax liability by completing forms, F/EA directs them to a tax professional.
 
Steps 1 through 5 below outline the general quality check procedures for the F/EA Start-Up package. Subsequent steps outline the required information for each form.
 
  1. <<Staff Title>> or assigned staff quality check F/EA Start-Up Packages
  2. Any F/EA Start-Up Packages received via the mail or drop-off are date stamped and placed in the F/EA Start-Up inbox
  3. <<Staff Title>> collects packages from F/EA Start-Up inbox daily.
  4. Upon completing review of each form, and verifying that it has been satisfactorily completed, <<Staff Title>> initials and dates the form.
  5. <<Staff Title>> tracks completion of forms in “For F/EA Use Only” sheet, the back of the third form in the package. 
  6. Write any errors on forms on “For F/EA Use Only” sheet
  7. Prior to submitting the F/EA Start-Up package to the F/EA, the Counselor completes the New Client Action Sheet and staples the Action Sheet as the first page in the package
  8. Review the Action Sheet
  9. Ensure that the following information is complete:
  • Effective Date
  • Consumer’s Name
  • Consumer’s Address
  • Sex
  • Date of Birth
  • Phone number
  • Social security number
  • Representative Information is not required, but it is preferred if the participant has a representative
  • Same preference applies if there is Legal Guardianship

10. Review the Consumer Agreement

11. Ensure that the following information is complete:

  • Printed Consumer’s name
  • Consumer’s signature
  • If the Consumer is a minor, one of the three signature options can be exercised:
  1. The person who has Power of Attorney (P.O.A.) can sign the Consumer Agreement.   If a Power of Attorney signs the Consumer Agreement, the Power of Attorney forms must be included in the package
  2. The Legal Guardian can sign the Consumer Agreement.   If a Guardian signs the Consumer Agreement, the Guardian paperwork must be included in the package

12.  Review Form SS-4, Application for Employer Identification NumberEnsure that the requisite information is complete.

  1. The person who has Power of Attorney (P.O.A.) can sign this form.  If a Power of Attorney signs the Consumer Agreement, the Power of Attorney forms must be included in the package
  2.  The Legal Guardian can sign this form.  If a Guardian signs this form, the Guardian paperwork must be included in the package
  3.  The Representative cannot sign this form, unless the representatve is listed as the employer on Line 1 of Form SS-4

13.  Review Form 2678, Employer Appointment of Agent

14.  Ensure that the requisite information is complete.

  • If the Consumer is a minor, one of the two signature options can be exercised:
  1. The person who has Power of Attorney (P.O.A.) can sign this form.  If a Power of Attorney signs the Consumer Agreement, the Power of Attorney forms must be included in the package
  2.  The Legal Guardian can sign this form.   If a Guardian signs this form, the Guardian paperwork must be included in the package
  3.  The Representative cannot sign this form, unless the representative is listed as the employer on line 1 of Form SS-4

 

17.  Review Form 8821

18.  Ensure that the requisite information is complete.

Follow-Up on Incomplete Forms
If any of the forms are not completed as described in the section above, Quality Check the F/EA Start-Up Package, action must be taken within 2 business days of F/EA receiving the forms. Use the following procedure to follow up with Counselors regarding incomplete or inaccurate F/EA Start-Up Packages.
 
1.      If any of the forms have any of the below problems, F/EA will not proceed with getting an EIN and will contact the Counselor for follow-up:
  • Any of the forms are missing from the package
  • Any forms are missing a signature
  • Any forms have inconsistent name, Social Security Number or other information
2.      If any required sections of forms are incomplete or inaccurately completed, F/EA will follow-up with the Counselor within 2 business days.
3.    After identifying forms with problems and notating the problems on the “For F/EA Use Only” control sheet, <<Staff Title>> (or assigned staff member) contacts the Counselor via e-mail
  • The <<Staff Title>> communicates which forms have problems and explains what is incomplete or inaccurate about completion of the form
  • <<Staff Title>> notifies the Counselor that they can work with the participant to complete only the form(s) with problems and mail them to F/EA
  • If the Counselor reports that they will work with the participant to fix the incomplete form and then mail the form to F/EA, print the e-mail stating that and staple to the back of the F/EA Start-Up Package
  •   <<Staff Title>> puts F/EA Start-Up Package in “Packages with Issues” sorter

               1.      Sort the package under the participant’s last name

  •  Any F/EA Start-Up Forms that are received by F/EA are date stamped and then compared to packages in the sorter

               1.      Any forms for consumers with packages in the sorter are added to those packages and quality checked

               2.      The complete F/EA Start-Up Package, with added form (s) is processed through the steps in Quality Check the F/EA Start-Up Package

  •  Every two business days, the <<Staff Title>> goes through the sorter
1.      Any packages remaining in the sorter have not had updated forms received for them
2.      For each participant with a package in the sorter, <<Staff Title>> opens their Cust. Service tab in Payroll System
3.      <<Staff Title>> checks to see if any new information about the package has been logged in the Customer Service Log
4.      <<Staff Title>> reviews the date in the Customer Service Log that F/EA first contacted the Counselor
5.      If five business days has passed since initial contact with the Counselor and corrected forms have not been received, <<Staff Title>> contacts Counselor again via e-mail to check on status
6.      Any response on status from Counselor is printed and attached to package
  • Follow steps until all completed forms are received or for 90 days
  • When a complete F/EA Start-Up Package is received, re-start process at Quality Check the F/EA Start-Up Package
 
Record Worker Information in Applicable Systems
After a F/EA Start-Up Package has cleared quality check for all forms, <<Staff Title>> or <<Staff Title>> (or assigned staff member) assigns the participant a Consumer ID and enters the participant in applicable systems.
 

 

Internal Controls: 

The internal controls used by F/EA  to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to collect and process F/EA Start-Up Packages are:
1.            All systems are password protected
  • Only staff authorized to perform certain duties are provided with password access to systems
2.            An Employer Identification Number (EIN) is not obtained on the participant’s behalf until all forms have successfully passed a quality check.
  • An EIN is required to enter a participant in the reporting agent’s payroll system.
  • This policy prevents a participant from paying a workers without an F/EA Start-Up package that successfully passes a quality check.
3.            All packages are date stamped immediately upon receipt.
  • Verification of date stamp occurs by a separate staff member than the staff member who quality checks the packages
  • This segregation of duties helps F/EA to track the time between receiving a package and quality checking it, ensuring that all packages are quality checked within 2 business days
4.            During quality check, each form is separately initialed and dated as it passes a satisfactory quality check
5.            A control sheet titled “For F/EA Use Only” is included in each F/EA Start-Up Package
  • During quality check, this control sheet is completed by the reviewer
  • The control sheet is reviewed subsequently by a second person during entry of participant information in to participant databases
6.            Each participant database is password protected.
  • Only F/EA staff authorized to update the database are provided a user ID and password.
7.            Prior to assigning a Consumer ID, the Census database is checked to ensure the Consumer ID has not already been assigned
  • This validation ensures data integrity
8.            All participant documents are scanned and saved for a minimum of 7 years per File Retention Policy.

File Registration and Authorization Forms with Tax Agencies

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Policy: 

F/EA obtains applicable employer account numbers with the Internal Revenue Service (IRS) and State Department of Revenue (DOR) on behalf of each active participant served by F/EA in the participant direction program. F/EA registers consumers with the State Department of Labor (DOL) for State Unemployment Insurance, but only after the participant has been determined liable for State Unemployment Insurance (See Register Consumer with State Department of Labor (Unemployment)).

As employers of workers in the participant direction program, consumers must be established with applicable tax agencies as employers for the purposes of withholding, depositing and filing applicable employer taxes and returns. 
 
Consumers also delegate responsibility for withholding, depositing and filing applicable employer taxes and returns to the F/EA. This document outlines the policy, procedures and internal controls used by F/EA to file these registration and authorization forms with applicable tax agencies.
 
Below, each step is outlined. The Policy associated with each step is stated beneath the step header.
Procedure: 

Create Consumer Folder

After completing the procedure in Collect and Process F/EA Start Up Packages, a folder for participant F/EA Start-Up Package paperwork is created. This process is completed by a <<Staff Title>>. New folders are created daily as packets pass quality check and all other procedures in Collect and Process F/EA Start Up Packages.
 
  1. <<Staff Title>> or assigned staff selects a blank file folder from the F/EA supply
  2. <<Staff Title>> writes participant last name, first name and <<MMIS ID>> on file folder tab
  3. Before filing participant’s F/EA Start-Up package
  1. <<Staff Title>> places all F/EA Start-Up Package forms in folder.
    • This folder will be stored in alphabetical order by participant last name in the participant file cabinets after all paperwork has been filed
    •  These file cabinets are locked for HIPAA protection (See HIPAA Policy)
  1. The folder is placed in the box labeled “Paperwork” in the Customer Service Unit

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to collect and process F/EA Start-Up Packages are:
1.            All systems are password protected
  •  Only staff authorized to perform certain duties are provided with password access to systems
2.            The New Weekly Consumer List is independently verified each week by the <<Staff Title>> to ensure paperwork is being processed timely
  • <<Staff Title>> initials and dates printed weekly participant list and stores in Payroll Department.
3.            An e-mail address is provided to State Department of Revenue (DOR) or equivalent during registration
  • If DOR cannot validate the registration, an e-mail is automatically sent to F/EA for resolution
4.            The Payroll Department submits a test to DOR monthly to verify that all employers liable for state withholding taxes are appropriately registered with DOR and that the reporting agent has accurate account numbers for consumers
5.            The Payroll Department provides an independent internal quality check of State Income Tax Account Number Registration Form when the employer is registered with DOR.
6.            The Payroll Department verifies that the reporting agent is correctly reporting an employer’s first payroll date by running a report for each employer who the reporting agent reports as liable for state withholding taxes
  • This report verifies the employer’s first payroll date
 

Apply for Employer Identification Number

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Policy: 

Applying for an Employer Identification Number (EIN) from the IRS is the first step in registering the employer with tax agencies and authorizing the F/EA to file and pay taxes on the employer’s behalf. An Employer Identification Number is required on all other employer tax forms. As of 2013, the IRS now allows Fiscal/Employer Agents to apply for EINs online.

Procedure: 
 
  1. <<Staff Title>> (or assigned staff member) removes Form SS-4 from participant’s folder for all consumers for whom EINs have not yet been applied for
  2. <<Insert process for getting the EIN>>

If applying for EIN online:

  1. Visit the IRS EIN Application site and click "Apply Online Now" button
  2. Enter the information on the completed SS-4 for each step. For the question "What type of structure is applying for an EIN?", select "View Additional Types", then click Continue.
  3. Select "Household Employer" on the following screen.
  4. Finish the application process and save the CP 575 confirmation of EIN letter PDF file for recordkeeping.

If applying for EIN via fax:

  1. Put all F/EA Start-Up package forms for Forms SS-4 faxed to IRS in a folder
  2. Label this folder with the date that Forms SS-4 were faxed to the IRS
  3. Staple the SS-4 to the front of the folder
  4. Any EIN fax confirmation forms received are placed in the above folders
  5. Review folders daily to check for EIN confirmations received
  6. If an EIN has not been received within 7 days, call the IRS at 1-800-829-4933 If EIN confirmation is received over the phone, write the EIN on Form SS-4 and attach a sheet of paper to the SS-4 with the message “IRS gave EINs over the phone on DATE. Did not get confirmation from fax.”
  7. If EIN confirmation is received via fax, attach the fax confirmation sheet to the form SS-4
  8. Write the participant’s EIN on each form in the F/EA Start-Up package
  9. Enter participant’s EIN in Payroll System 
 

 

Internal Controls: 

1. Forms SS-4 are quality checked prior to obtaining an EIN (see Collect and Process F/EA Start Up Packets)

2. After contact IRS to obtain EIN, the EIN or any issues with obtaining the EIN are recorded in the participant’s file

Register Employer with State Department of Revenue

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Policy: 

A participant is registered with the State Department of Revenue (DOR) to allow the participant to deposit and file state income taxes that are withheld from the participant’s workers(s). Registration with DOR occurs after obtaining an EIN on the participant employer's behalf.

Procedure: 

 


 

Submit Form 2678, Employer Appointment of Agent, to the IRS

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Policy: 

Filing a completed Form 2678 with the IRS authorizes F/EA to withhold, file and pay employment and Federal Withholding taxes on behalf of the participant. Form 2678 is not effective until the IRS approves F/EA to act on behalf of the participant employer. This approval is submitted to the F/EA with Notice LTR-1997C.

Because Form 2678 is not effective until the IRS approves the F/EA as an agent of the employer and therefore F/EA does not have joint liability for federal employer taxes until the IRS approves the Form 2678, F/EA includes language in each participant contract stating that F/EA is liable per the participant contract for employer taxes even before the IRS approves Form 2678.

Procedure: 

 
  1. <<Staff Title>> (or assigned staff member) separates Form 2678 from participant’s F/EA Start-Up package for those consumers for whom EINs were recently obtained
  2. Open Form 2678 letter template <<File Path>>
  • Collect up to 25 Forms 2678
  • Copy forms
  • Place copy of forms in consumers' folders and mail originals to IRS
  • No more than 25 Forms 2678 can be included in a single letter 
  • If more than 25 Forms 2678 will be submitted, prepare multiple letters
  • Review Forms 2678 for selected consumers
  • Ensure the participant’s EIN is written on Form 2678
  • Print completed 2678 Letter
  1. Mail 25 Forms 2678 and 2678 Letter to:

<<Insert address from IRS "Where to File" chart based on location of F/EA>>

  1. <<Staff Title>> opens Payroll System
  • In forms tracking module of payroll system, find participant by last name
  • Enter date Form 2678 mailed to IRS for each participant
  1. LTR-1997-C, notice from the IRS to approve F/EA to act as each participant’s agent should arrive by mail within 60 days
  • <<Staff Title>> opens Payroll System
  • In forms tracking module of payroll system
  • Find participant by last name
  • Enter date approval via LTR-1997-C received
  1. <<Staff Title>> reviews forms tracking module of payroll system weekly
  • Any consumers for whom 2678 approval has not been received within 75 days are followed-up on
  • <<Staff Title>> contacts IRS at 1-800-829-4933 and inquires about status of 2678 approval
  • Status is stored in participant’s Customer Service System
 

Submit Form 8821, Tax Information Authorization, to the IRS

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Policy: 

Filing a completed Form 8821 with the IRS authorizes officers/staff of the F/EA to discuss employer tax matters on the participant’s behalf with the IRS. 8821 Appointee status does not authorize F/EA officers to represent the participant for the IRS.  Note that an executed Form 8821 is no longer required by the IRS for Fiscal/Employer Agent services, but it is a best practice to obtain executed Forms 8821 and file them with the IRS.

Procedure: 
  1. <<Staff Title>> (or assigned staff member) separates Form 8821 from participant’s F/EA Start-Up package for those consumers for whom EINs were recently obtained
  2. Open Form 8821 letter to IRS2 from <<File Path>>
  • Collect all not submitted Forms 8821
  • Copy Forms 8821
  • Store original in participant's folder
  • Mail copies to IRS
  • Unlike Form 2678, there is not a limit to how many Forms 8821 can be submitted to the IRS in a single mailing
  • Review Forms 8821 for selected consumers
  • Ensure the participant’s EIN is written on Form 8821

 3.   Mail Forms 8821, list of officers and 8821 Letter to:

Internal Revenue Service
Memphis Accounts Management Center
Stop 8423
5333 Getwell Road
Memphis, TN 38118

4.    <<Staff Title>> opens forms tracking module in Payroll System

  • Open tab labeled “8821”
  • Find participant by last name
  •  Enter date Form 8821 mailed to IRS

5.   The IRS does not notify of 8821 approval

 

Internal Controls: 
  1. F/EA keeps a record of all forms not yet mailed to the IRS and reviews this record to ensure all forms get mailed to the IRS.
  2. When Forms 8821 are mailed to the IRS, it is recorded that they have been.
  3. Mailing records are periodically reviewed to ensure forms have not been missed.

Register Consumer with State Department of Labor (Unemployment)

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Policy: 

Employers are not registered for Unemployment Insurance (UI) with the State Department of Labor until the employer has paid at least $1000 in gross wages in a single calendar quarter. The payroll department produces the <<report>> <<weekly>> that shows any employers who do not have a UI  account number and have just crossed the $1000 per calendar quarter threshold. After reaching this limit, the employer is liable for all wages previously paid in the calendar year and all wages going forward up to the taxable wage base for each workers. 

<<Staff Title>> or assigned staff runs a ”Quarterly Report” from the payroll system to verify that $1000 in wages have been paid in a single calendar quarter and to collect wage information for prior quarters. <<Staff Title>>collects completes the state Employer Status Report form for the participant. This information is used to apply for a DUA account number for the employer through the state’s registration system. F/EA applies for a UI account number for the employer within five business days of learning that an employer has reached or crossed the $1000 in a single calendar quarter threshold.
Procedure: 
  1. Weekly the payroll department creates a <<report>> for employers without a UI Account No. and gross wages greater than $1000 in a single calendar quarter
  •  <<Staff Title>> creates the report
  • <<Staff Title>> date stamps report
  •  <<Staff Title>> assigns task to a <<Staff Title>> or other F/EA staff
  • Assigned staff completes state Employer Status Report forms <<that is what the forms are usually called, but an individual state may have a different form name or a different process>> for each participant employer using the employer name, address and FEIN information
2.      Collect Quarterly tax payroll data from the payroll system for each employer who needs a UI number
3.      <<Insert Process to collect the data>>
  • Review the data for each quarter for the participant
  • Write the applicable gross wage information on the Employer Status Report <<process may vary by state; insert where on the form to insert applicable data>>
4. Insert the following on the Employer Status Report Form for each participant as applicable <<This process will vary based on the state form requirements>> 
  • Enter the First Date of Employment, which is the first check date, on the Employer Status Report Form in “Please Enter a Valid Payroll or Employment Start Date”
  • Select “Continue”
  • In “Company Name”, enter Employer’s First and Last Name
  • In “Attention To:” enter C/O F/EA – F/EA
  • In “Legal Address” enter employer's address
  • In "Mailing Address" enter the F/EA's mailing address
  • Enter the employer's FEIN on the form as applicable
  • In “Are you liable for federal unemployment tax?”, select “Yes”
  • In “First Date of Liability”, enter first check date from Employer Status Report
  • Select the participant’s city from the drop down
  • In “Please describe the principal activity…”, enter “Household Employer”
  • In “What is the principal product or service…”, enter “None”
  • “Please enter the address of your physical location…” enter participant’s address information
  • In “Please choose the option that best describes your business” select Domestic
  • In “Please choose the option that best describes your business” select Domestic
  • In “Name”, enter Consumer’s Name
  • In “Home Address” enter Consumer’s Address
  • In “Social Security Number”, enter the participant’s SSN
  • In “Is this individual compensated for services performed for the company”, select “No”
  • In “Select the above individual’s title”, select “Owner”
  • On the next page, the participant’s DUA ID will be listed.
5.      Record in the database the date that the Employer Status Report Form is submitted to the state for each participant
6. Mail the forms to the state
7. In approximately <<X>> days, F/EA will receive each employer's UI Account No. via <<mail>>
  •        Date stamp letter upon receipt
  •        This letter contains the UI Account No. and the employer's contribution rate <<there may also be a 'surcharge rate' or disability insurance rate or other, additional rate>>
  •        Enter the new UI Account No. in the participant database for the employer
  •        This number will be used to file and pay state unemployment tax on behalf of the participant employer
  •        Enter the employer's rate in the database
8. On a monthly basis, <<Staff Title>> runs report from payroll system that shows any consumers for whom a "Date Sent" was entered for the date the Employer's Status Report was sent to the state, but a UI Account No. has not yet been received
  • This report shows any consumers that should have a UI Account No., but don't
  • <<Staff Title>> follows up with state to inquite about status of UI Account No.s for these consumers

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification. 

The methods of internal control utilized by F/EA to Register Consumer with MA DUA are:
1.      All systems are password protected
  •  Only staff authorized to perform certain duties are provided with password access to systems
2.      After payroll department creates weekly report of consumers who are newly liable for state unemployment insurance, <<Staff Title>> verifies integrity of report by running an independent report of gross wages
3.      All tracking documents are date stamped, initialed, scanned and saved for 7 years per File Retention Policy.
4.    A report is run monthly to identify any consumers for whom the F/EA has applied for a UI Account No. but the number hasn not yet been received.

Determining Whether Worker Is Employee Or Independent Contractor

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IRS Form SS-8

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Policy: 

 Test

Procedure: 

 Test

Internal Controls: 

 Test

Establishment of Workers as Employees of Consumers

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Distribute Worker Hire Package

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Policy: 

The Worker Hire Package consists of all employment forms that must be completed by the participant or representative and workers when hiring a workers. This package is only for consumers who choose to hire workers.

A new participant will receive the Worker Hire Package from the F/EA or their Counselor only after <<insert any criteria here for distributing the Hire Package; e.g. in some programs a budget has to be issued first>>.  The participant will be trained by the Counselor at the first intake meeting. The Counselor will review each form with the counsumer, helping the participant to understand and to complete them.

Existing consumers receive their supply of employment packages from their Counselor or F/EA as they request packages to hire new workers. Packages must be sent to consumers the same business day that the request is made.

 
Distribution of Updated Worker Hire packages:
 
When a new version of a form included in the package is released from the Internal Revenue Service, Department of Homeland Security or other agency, an updated Worker Hire package must made available. Forms in the Worker Hire package are updated at least annually because new versions of Forms W-4 and W-5 are released for each calendar year or if regulatory changes warrant an update.
 
Upon request, F/EA submits a copy of the Worker Hire Package to Program Administrator.
Procedure: 
Distribute Packages to Consumers at their Request
Use this process to distribute packages to consumers if they request them from F/EA. F/EA will only distribute packages to new consumers after <<insert program criteria here>>. F/EA distributes packages to approved consumers the same business day of receiving the request.
 
  1. When a participant contacts F/EA to request a package, <<Staff Title>> (or assigned staff member) records the call and request in Customer Service module of the F/EA system.
  2. <<Staff Title>> verifies in Payroll System that the participant has a <<met program criteria to be allowed to hire staff>>.
    • If the participant has <<met necessary program criteria>>, proceed with mailing Worker Hire package
    • If the participant has not <<met necessary program criteria>>, inform them that a package cannot be mailed to them until the participant <<meets necessary program criteria>>
  1. <<Staff Title>> sends out packages before the end of the day that the participant’s request is received.
  2. <<Staff Title>> prepares package to be mailed.
    • Place packages in envelope and address the envelope to the most current participant or representative mailing address.
    • Put the package in the outgoing mail box.
  3. <<Staff Title>> records in the Customer Service module that packages were sent and the date sent.
 
Distribution of Employment Packages when there is a Form Change
 
The standard, most-up-to-date Worker Hire package is distributed to Counselors and all active consumers in the program after any forms have been replaced with new versions of the form.
 
  1. After identifying that a new version of a form will be implemented, <<Staff Title>> (or assigned staff member) prints two copies of the updated form and a copy of the instructions. Completes a copy of the form as a sample for consumers to follow. Both the Blank updated form and the completed sample form placed   in the Forms Control Binder stored at Customer Service Unit
  2. <<Staff Title>> updates the Employee Packet Control Sheet to record the date the form is updated.
  3. Copy front and back of all forms which were changed in Worker Hire package and or F/EA Start up Package, including samples and instructions.
  4. The <<Staff Title>> determines how many copies are required.
  5. <<Staff Title>>, or assigned staff member, writes a detailed letter to each Counselor and participant to accompany the  updated forms
  6. This letter includes:
  •  Descriptions of any changes on the forms
  •  Step by step instructions to complete the forms
  •  Instructions to use these new forms for any new workers that will be hired
  •  Notification of the implementation date of any new forms with instructions to only use new packages as of the implementation date
  • A template for this letter is saved here: <<File Path>>
  1.  The <<Staff Title>> reviews a single sample package to be sent for completeness and accuracy.
  2. <<Staff Title>> mails updated packages and a letter from the <<Staff Title>> to each Counselor and active participant
  • Counselors use packages in trainings and when a participant requests Worker Hire packages from the Counselor.
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to distribute Worker Hire packages are:
  1. A control document is used to track checking for updated forms at least monthly.
    • Staff verifies that new forms have been looked for at relevant agency websites at least monthly
  2. The <<Staff Title>> reviews the updated Employee Packet prior to sending it to consumers or counselors.

Employee Agreement

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Policy: 

This form includes policies to which the workers must agree to provide service in the program.

<<Worker agreement will be different for each program.>>

<<Common language in workers agreement addressess:

  1. Worker rate of pay
  2. If overtime is ever authorized
  3. Process for issuing approval for overtime
  4. If participant authorizes workers to work in excess of participant's individual budget, F/EA is not responsible for payment to the workers
  5. Requirements for timesheet to be considered "properly completed"
  6. F/EA is not responsible for payment for improperly completed timesheets
Procedure: 

This form is automatically included in every Worker Hire Package.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

Employee Information Sheet

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Policy: 

This document is included in every Worker Hire Package.

The front of this form is used to collect workers, participant and representative biographical information, including whether the workers has a family relationship with the employer that causes the workers to qualify for an employment tax exemption.

The back of this form provides information on which forms must be completed by the Worker and which forms are optional. This page also includes some helpful tips for completing the forms.

This form is reviewed by <<Staff Title>> <<enter periodicty>> for accuracy and completeness. If changes are made to the standard form, the changes are reviewed by <<Staff Title>>.  See Stay Up to Date with Forms, Rules and Regulations

Procedure: 

This form is automatically included in every Worker Hire Package.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

Federal Form W-4 and Instructions

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Policy: 

This form is used to collect Federal Income Tax withholding information from the workers.

Workers must complete this form prior to employment.  If a workers provides service before completing this form and must be paid for that service, F/EA pays workers as if the workers's Federal Form W-4 was completed as "Single" with "0 Allowances."  Completion of the W-4 in this manner ensures the highest withholding for Federal Income Tax occurs.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

State Version of Form W-4 and Instructions (if applicable)

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Policy: 

This form is used to collect State Income Tax withholding information from the workers.

Not all states have or require completion of a State Form W-4.

Internal Controls: 
The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.
  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

USCIS Form I-9 and Instructions

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Policy: 

This form is for the employer to verify and record employment eligibility information for their workers.  This form is included in every workers packet by default.

This completed form must be received by the F/EA prior to issuing payment to a workers.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

Authorization Agreement for Direct Deposit and Instructions

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Policy: 

This form is used to collect bank account information for employees electing to have their pay directly deposited into their bank account.

This form is only completed if an employee desires to have direct deposit.  Completion of this form is not required for payment.  Employees who do not complete this form will receive payment via paper check.

Procedure: 

This form is automatically included in all employee hire packages.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

Medicaid Provider Agreement

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Policy: 

 

As required by the F/EA’s contract with the Medicaid Agency, the F/EA obtains an executed Medicaid Provider Agreement from every worker.  The Medicaid Provider Agreement is stored in the F/EA’s files per File Retention Policy.

 

Collect and Process Worker Hire Package

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Policy: 

Payment will not be issued to workers by F/EA without a completed Worker Hire Package.

All Worker Hire packages received by fax, mail or hand delivered must be date stamped immediately upon receipt and placed in the Worker Package In-Box located in the Payroll Department.
 
The Worker Hire Package includes all forms that a workers and participant or representative must complete prior to a workers beginning work. The Worker Hire Package is collected from consumers, workers or Counselors via fax, mail or drop-off. All packets are quality checked within 2 business days of receipt. All incomplete or out of date Worker Packages are returned to consumers, counselors or workers within 2 business days of receipt for correction. Data from Worker Hire Packages that meet a quality check without errors are entered into F/EA's payroll system.
 
All consumers must have an approved budget (or authorization) and an Employer Identification Number (EIN) before they can hire a workers. If a Worker Hire Package is received for a participant that does not yet have an approved budget (or authorization) or EIN, F/EA will hold the Hire Package for <<insert number>> days. If a budget (or authorization) or EIN is not received for the participant after <<insert number>> days, the Hire Package is returned to the participant's counselor.
 
F/EA cannot provide tax advice for completion of any forms. If consumers, representatives or workers have questions about the impact on their personal tax liability by completing forms, F/EA will suggest that workers contact the Internal Revenue Service or a tax professional.
Procedure: 

Required Forms

These forms must be accurately completed and submitted to the F/EA prior to a workers beginning work. Any forms not listed in this section but included in the Worker Hire Package are optional and are applicable only if the workers meets the criteria outlined for the forms.
 
 
  1. Employee Agreement
  2. Employee Information Sheet
  3. Federal Form W-4 and Instructions (F/EA prefers to receive this completed form, but if form is not submitted, F/EA will withhold Federal Income Tax at the highest rate of Single with 0 Allowances)
  4. USCIS Form I-9
 
 
Quality Check for the Worker Hire Package
 
All Worker Hire Packages are quality checked immediately upon receipt. Forms that are not accurately or completely filled out are <<Insert F/EA's process for following up with workers/consumers>>. Under no circumstances does F/EA issue payment to a Worker if forms listed in the “Required Forms” section above are incomplete.
 
<<Staff Title>> are responsible for the quality checks for all forms in the Worker Hire Package. Staff complete a Quality Checklist to document which forms have been received and correctly completed. This form is used as an internal control to guide by the F/EA for documenting the quality checks and receipt of forms in the Worker Hire Packages.
 
Review of Worker Hire Package
 
  1. Check for the "Date Received" stamp.
  2. Find the Worker Hire Package Forms Checklist
  • Compare each form received against the boxes checked as completed and submitted by the participant.
  • At the bottom of the Quality Check form write in:
  • -the participant #
  • -F/EA staff name and date, and
  • -applicable information regarding each form
  1. Continue with verification process.
  2. Review the first form
  • Ensure that the following information is complete:

<<Insert requirements for quality check here>>

                                                            

 

  1. Review Form W-4
  2. Ensure that the following information is complete:
  •  Box 1, First Name, Last Name (of Worker) and address
  •  Box 2, Social Security Number
  •  Marital Status
  •  Last name different to name on the social security Card
  •  Number # of Allowances
  •  Additional (deduction) amount requested
  •  Exemptions claimed
  •  Employee’s signature “certifying that the information is true, correct and complete” and the date
  •  Employer’s Name
  • If Line 3 and 5 are not completed the IRS guidelines states that the workers should be taxed as “single, 0”.
  • If line 3 is not completed and line 5 has a number, the employer will be taxed as “single, and the # of allowances”.
  • If line 3 is completed as “married” and line 5 is left blank. The workers will be taxed as “married, 0”.
  • Check the appropriate box on the Worker Hire package Forms Checklist; if the form was completed correctly. If information is missing, note briefly next to the form name, the missing information.
Note: F/EA cannot provide tax advice for completion of any forms. If consumers, representatives or workers have questions about the impact on their personal tax liability by completing forms, F/EA will suggest that workers contact the Internal Revenue Service or a tax professional.
 
 

8.  Review Form I-9

**This form must be verified with extraordinary attention to detail.
**Any mistakes or incompletion require that the form is returned to the participant immediately.
9.  Ensure that the following information is complete:
  • Section 1- Worker Last, First Name and Middle Initial
  • Worker Address
  • Worker Date of Birth
  • Worker City
  • Worker State
  • Worker Zip Code
  • Worker Social Security #
  • Worker MUST complete one of the three check boxes under “I attest, under penalty of perjury, that I am (check one of the following).   If either of the bottom two check boxes are checked, dates and Alien or Admission #s must be complete
  • Section 2 must be complete
  •  Per I-9 instructions, all applicable information from documents must be completed in Section 2.
  • - For example, if a drivers’ license is shown under ‘List B’ the drivers’ license number, expiration date and name of licensed driver MUST be shown on the lines
  • -If any of the above are missing, Section 2 is incomplete
  • Verify that appropriate documents from each list are shown
  • Compare the provided documents to the list of acceptable documents on Page 2 of Form I-9
  • -If a List A document is provided, only one document is required
  • -If List B or C documents are provided, the workers must show one document from each list for a total of two documents
  • ‘Certification’ section must be complete 
  • Employer must enter the month/day/year that they reviewed and certified the workers’s documents
  • The Employer must Sign, Print their Name and Date the Certification section
  • The Employer must enter their address
  • The ‘Title’ field is not required to be completed by the employer
  • Section 3 is only required if the employer is updating or recertifying the workers’s work authorization status 
  • It is the duty of the employer to track when a workers must be recertified
  • F/EA does not track workers work authorization status
  • -Neither the workers nor employer should submit copies of identification documents to F/EA:
  • It is the employer’s responsibility to review documents and record them on Form I-9
  • F/EA will appropriately destroy any identification documents which are received with copies of Form I-9
                                                           

10.  Review the Authorization Agreement for Direct Deposits.

  • This form is not required unless the workers elects to have their payment directly deposited to their bank account

11. If the workers has completed this form, ensure the following fields are complete:

  • Bank Name
  • Bank Address
  • Depositor Account No.
  • Type of Account
  • Transit Routing Number
  • Account Number Information
  • Worker Name
  • Date
  • Worker Signature
  • Employer Name
  • A voided check (not a deposit slip) must be submitted with this completed form
12. If the worker has completed this form, ensure the following fields are complete:
  • Print or Type Full Name (Worker Name)
  • Social Security Number (Worker SSN)
  • Line 1 Check Box (Yes or No)
  • Line 2 Check Box (Yes or No)
  • Line 3 Check Box (Yes or No)
  • Signature (Worker Signature)
  • Date
                                                        
 
 
Follow-Up on Incomplete Forms
If any of the forms are not completed as described in the section above action must be taken within <<X>> business days of F/EA receiving the forms. Use the following procedure to follow up with consumers regarding incomplete or inaccurate Worker Hire Packages.
 
1.      If any required sections of forms are incomplete or inaccurately completed, F/EA will follow-up with participant within 2 business days
2.    After identifying forms with problems and notating the problems on the control sheet, <<Staff Title>>, <<Staff Title>> (or assigned staff member) contacts via phone the workers’s participant.
  • Tell the consumer the forms with problems and explain what is incomplete or inaccurate about completion of the form
  • Notify the participant that they can complete only the form(s) with problems and fax it to F/EA
  • Notify participant that F/EA will hold the packet for 2 business days awaiting their faxed, corrected form(s) 
  • Notify participant that if the corrected form(s) are not received by F/EA within 2 business days, the entire Worker Package will be returned to the participant.
  • F/EA cannot enroll the participant’s workers until a fully complete Worker Hire Package is received.
  • If the participant prefers, F/EA can return the entire package to the participant immediately and the participant and workers can correct forms with issues and return the entire package to F/EA
  • Log all communication with the participant, including the deadline provided to the participant to fax a corrected form, in the Customer Service Module of the F/EA system
  • <<Staff Title>> or <<Staff Title>> (or assigned staff member) puts Worker Hire Package in a sorter for packages requiring follow up
  • Sort the package under the participant’s last name
  • Any Worker Hire Forms (as separate from a complete Worker Hire Package) that are received by F/EA are date stamped and then compared to packages in the sorter.
  • Any forms for consumers with packages in the sorter are added to those packages and quality checked
  • Customer Service Module of F/EA system is updated stating that the form (s) has/have been received, when forms are received
  • Every two business days, the <<Staff Title>> goes through the sorter.
  • Identify any packages remaining in the sorter that have not had updated forms received for them
  • For each participant with a package in the sorter, <Staff Title>> opens the Consumer's log in the Customer Service Module of the F/EA System
  • <<Staff Title>> checks to see the date in the Customer Service Log file by which any additional faxed forms would be accepted by F/EA (the deadline for faxing in corrected forms as provided to the participant)
  • If the deadline provided to the participant is today or before today, <<Staff Title>> contacts participant
  •  <<Staff Title>> notifies participant that because a completed form has not been received by F/EA by the deadline, F/EA is returning the package to the participant
  •  <<Staff Title>> urges participant to utilize sample documents in the back of the Worker Hire Package for assistance completing forms
  • <<Staff Title>> notifies participant to contact F/EA or Counselors for additional assistance completing forms
  •  <<Staff Title>> logs contact with participant in Customer Service Log for participant
  • <<Insert process for how F/EA resolves missing forms situation for workers and participant>>
  • When a complete Worker Hire Package is received, re-start process at Quality Check the Worker Hire Package
 
Record Worker Information in Applicable Systems
After a Worker Hire Package has cleared quality check for all forms, <<Staff Title>> or <<Staff Title>> (or assigned staff member) enters Worker information in applicable payroll systems, including the F/EA's payroll system.
  1. <<Insert process for entering workers and tax information into payroll system, including any workers FICA tax exemptions.  Insert process for connecting workers to participant in systems.  Insert process for recording workers mailing address>>

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to collect and process Worker Hire Packages are:
1.            Worker Information is not entered into the payroll system until the Worker Hire Package has satisfactorily passed a quality check.
  • This ensures that workers with incomplete packages are not paid.
2.            All packages are date stamped immediately upon receipt.
  • Verification of date stamp occurs by a separate staff member when packages are entered in Payroll System
3.            During quality check, each form is separately initialed and dated as it passes a satisfactory quality check.
4.            A control sheet is used to Quality Check each packet.
  • During quality check, this control sheet is completed by the reviewer
  • The control sheet is reviewed secondarily during entry of workers information in to the payroll system

Collecting, Recording and Processing Information for Family Employer and Employee Tax Exemptions

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Policy: 

Using the Employee Information Form, F/EA collects information on a workers's familial relationship to his/her employer.  Based on certain familial relationships, workers and their employers are exempt from certain taxes.  When a workers is exempt from taxes with an employer contribution, the employer is also exempt from paying the employer tax.

The F/EA processes all Employee Information Forms upon receipt.  The F/EA uses current Federal and State regulation information to record exemptions based on familial relationships.

F/EA uses the following criteria from IRS Publication Circular E:

  1. If workers is under 21 and the workers is employed by his/her parent, the workers is exempt from FICA (Social Security and Medicare) and FUTA (and probably SUTA, but check state laws) until workers is age 21.  The workers is not exempt from Federal Income Tax withholding.
  2. If the workers is over age 21 and the workers is employed by his/her parent, the workers is NOT exempt from any Federal taxes.
  3. If the workers is employed by his/her child, the workers is exempt from FICA (Social Security and Medicare) and FUTA (and probably SUTA, but check state laws).  The workers is not exempt from Federal Income Tax withholding.
  4. If the workers is employed by his/her spouse, the workers is exempt from FICA (Social Security and Medicare) and FUTA (and probably SUTA, but check state laws).  The workers is not exempt from Federal Income Tax withholding.
Procedure: 
  1. Upon receipt of Worker Hire Packages, <<Staff Title>> quality checks all forms, including the Employee Information Form, the form which records employer/workers familial relationships.
  2. <<Staff Title>> review Employee Information Form and identifies if information provided indicates that workers has a Family Relationship tax exemption.
  3. For any workers with Family Relationship tax exemptions, <<Staff Title>> enters applicable information in Payroll System so that payroll system does not withhold taxes from workers wages for which workers is exempt.  Payroll System also will not calculate employer taxes for which workers is exempt.
  4. <<Insert Process to enter data in payroll system>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to collect, record and process information for family employer and workers tax exemptions are:
 
1. Worker Information is not entered into the payroll system until the Worker Hire Package has satisfactorily passed a quality check.
  •  This ensures that workers with incomplete packages are not paid.

2. All packages are date stamped immediately upon receipt.

  •  Verification of date stamp occurs by a separate staff member when packages are entered in Payroll System

3. During quality check, each form is separately initialed and dated as it passes a satisfactory quality check.

4. F/EA stays up to date with any changes to Family Tax Exemptions using Stay Up to Date with Forms, Rules and Regulations

5. A control sheet is used to Quality Check each packet.

  • During quality check, this control sheet is completed by the reviewer
  • The control sheet is reviewed secondarily during entry of workers information in to the payroll system

Report New Hires

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Policy: 

State law requires that all newly hired employees are reported to the <<Insert Agency Name>> by employers within <<Insert No. of Days>> days of the employee’s first day on the job. 

F/EA tracks all newly hired employees and ensures that they are appropriately reported on the new hire report that the F/EA submits to <<Insert Agency Name>> weekly.  Confirmation of a new hire report being submitted to <<Insert Agency Name>> is tracked in a control document stored at F/EA.

Procedure: 

 

1.      As Worker Hire Packages are completed, quality checked and entered into the payroll system the <<insert how F/EA tracks new hires>>
  • See <<File Path>> Hire list
2.      Once a week, the <<Staff Title>> (or assigned staff) creates a New Hire Report in the format required by <<Insert Agency Name>>
<<Insert how to create this report>>
3.      This report lists all employees that were hired by consumers in the last 7
  •  <<Staff Title>> (or assigned staff) opens <<File Path>> New Hire Report
  •  <<Staff Title>> (or assigned staff) sorts New Hire Report by Employer
  • Using the “New Hire Reporting” report provided by the reporting agent, <<Staff Title>> (or assigned staff) identifies each workers listed on the report in the Worker Package Hire List
  •   <<Staff Title>> tracks in Payroll System the date that the each workers was submitted on the New Hire Report
<<Insert Process to submit New Hire Report to the correct agency>>
<<Insert Process to show how you make sure this is regularly happening...a report to check for any employees who haven't had a New Hire Report date entered for them in the system?>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification. 

The methods of internal control utilized by F/EA to distribute timesheets are:
  1. The payroll system is used to track that all employees are reported via the New Hire process.
  2. The control document is reviewed monthly to ensure that all employees have been reported via the new hire reporting process.
    • Any discrepancies are researched and resolved.

Verify Worker Social Security Numbers with the Social Security Administration

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Policy: 

Verifying Worker Social Security Numbers (SSN) with the Social Security Administration (SSA) and resolving any errors prior to filing Forms W-2 with the Social Security Administration is a key to accurate and timely annual wage report submission. Submitting Forms W-2 to the SSA with accurate SSNs helps to ensure that workers earnings records are properly credited with wage information. This is important information for determining their Social Security benefits in the future.

Verifying Worker SSNs with the SSA and resolving any errors prior to filing Forms W-2 reduces the number of forms W-2c necessary, thereby increasing accuracy of Forms W-2 for employees, reducing confusion and minimizing cost. Verifying SSNs with the SSA reduces the number of Forms W-2C produced by the F/EA. The SSA submits “no match” letters to employers and agents if at least 10 of every 2000 Forms W-2 are submitted with SSNs that do not match workers names. Agents or employers must use reasonable means to correct SSN errors as listed in the “no match” letter. Agents may be fined if too large a percentage of forms W-2 have unresolved SSN errors.
 
Verification of workers SSNs prior to W-2 submission also allows F/EA to verify that the F/EA has correct Social Security Numbers for Workers in their payroll system. This process itself is an internal control used to verify the data integrity of Worker Social Security Numbers recorded in F/EA systems. 
 
Prior to providing services in the F/EA program, each workers completes a Worker Hire Package. F/EA obtains workers self-reported SSNs on forms W-4, USCIS I-9 and <<State Form W-4>>. While the workers certifies with his or her signature that the SSN reported on the aforementioned forms are correct, F/EA verifies the SSN with the Social Security Administration’s Business Services Online (BSO) Social Security Number Verification Service to ensure accurate W-2 reporting and to avoid “no-match” letters.
 
F/EA verifies Worker SSNs with the Social Security Number Verification Service by September of each calendar year. F/EA Customer Service follows up with any workers with SSN errors and corrects them in applicable payroll systems prior to issuing Forms W-2 to workers before January 31.
Procedure: 

 

  1. <<Staff Title>> or assigned staff obtains electronic list of all active workers names, Social Security Numbers and birth dates from payroll system  <<Insert process onhow to do this>>
    • This list is formatted per current Social Security Number Verification System specifications (http://www.ssa.gov/employer/ssnvs_handbk.htm#subfileformat)
  2. <<Staff Title>> logs onto the SSA’s Business Services Online
  3. Follow instructions to upload SSN Verification File
  4. Go to https://s044a90.ssa.gov/acu/BSOIRESEAI/login
  5. Select ‘I Accept’
  6. Enter user PIN and Password. 
  7. User develops a Password per BSO password requirements, including any required characters
  8. BSO provides a PIN
  9. Per BSO, password must be updated at least once annually
  10. F/EA updates password quarterly for added protection
  11. Select ‘Submit an Electronic File for SSN Verification’
  12. Select ‘I Accept’
  13. Select ‘Continue’
  14. Enter the F/EA Agent EIN in ‘Employer’s EIN’ box
  15. Enter Select ‘Browse’ and browse for the SSN Verification text file
  16. Select ‘Submit’
  17. Print Confirmation Sheet
  18. Initial and date confirmation sheet
  19. Provide Confirmation Sheet to <<Staff Title>> for review
  •  <<Staff Title>> reviews, initials and dates \
  • Confirmation sheet and copy of submitted file are stored in “Social Security Number Verification” binder in Payroll Department

20.  Log in to SSNVS the next business day to check to see if a return file has been produced

21.  If a return file has been produced, download the file

23.  Open the file in Excel

24.  Sort the spreadsheet by the 9 column

  • This is the error column
  • Any records with an error code of 1, 5 or 6 must be followed up on
  • Error 1 means that the SSN provided for the workers was not ever issued by the SSA, so it cannot be a valid SSN
  • Error 5 means that the name submitted for the SSN does not match the name on record for the SSN
  • Error 6 means that the SSN did not verify for another reason. This is usually if the SSN has nonnumeric characters or is not 9 digits in length

25.  For any SSNs with error codes 1, 5 or 6, the F/EA must verify that the SSN provided in the Worker Hire Package was the SSN submitted to the SSA for verification

  • A typo at any point in the process could cause an error in the Social Security Number Verification System
  • Comparing the SSN with an error in the return file to the SSN in the Worker Hire Package resolves the majority of errors

26.  Print the Excel sheet showing errors

  • <<Staff Title>> initials and dates Excel sheet print out, to show that errors were collected and the date errors were collected
  • <<Staff Title>> initials and dates Excel sheet print out
  •  Excel sheet print out is stored in “Social Security Number Verification” binder in Payroll Department

27.  Locate the Worker’s Hire Package saved in the participant’s scan file on the X drive

28.  Review each form in the Worker Hire Package

29.  Compare the SSN listed on each form to the SSN listed for the provider in the return file

  • Is the SSN the same?
  • If the SSN in the Worker Hire Package is different than the SSN return file, it is likely that the SSN in the Worker Hire Package is correct.

30.  Go to https://s044a90.ssa.gov/acu/BSOIRESEAI/login

31.  Select ‘I Accept’

32.  Enter user PIN and Password. User develops a Password, BSO provides a PIN

33.  Password must be updated at least once annually

34 . Select ‘Submit an Electronic File for SSN Verification’

35.  Select ‘I Accept’

36.  Select ‘Continue’

37.  Select “Verify up to 10 SSNs Online”

38.  Enter the Worker’s name and the SSN found on the Worker Hire Package

39.  Select “Submit”

40.  The next screen will report whether the name and SSN match the SSA’s records

41.  If they do, update the Worker’s SSN with the correct SSN in all systems

42.  If the name and SSN found on the Worker Package do not match the SSA’s records, or if the SSN on the Worker Package is the same as the SSN submitted to the SSA originally, F/EA customer service must contact the workers’s participant to attempt to resolve the SSN error

43.  <<Staff Title>> (or assigned staff member) places an outbound call to the participant and notifies them of a problem verifying their workers’s Social Security Number

44.  This call is documented in the Customer Service module in F/EA System

45. Rather than verify the SSN with an outbound call to the Consumer, the <<Staff Title>> identifies him or herself as a representative of the F/EA, leaves his or her name and number for the participant to call back.

  • This process is used so that the participant can verify that the phone number provided is indeed F/EA’s and is not a fraudulent caller

46.  A <<Staff Title>> verifies the previously provided SSN and Date of Birth (DOB) with the participant when he or she returns the call 

47.  If the SSN or DOB on file with F/EA does not match that provided during the call by the provider, record the corrected SSN in all applicable systems

48.  Follow steps to verify the SSN with the Social Security Administration

49.  If the SSN or DOB on file matches that provided by the workers, the <<Staff Title>> encourages the participant or workers to contact the Social Security Administration’s local branch to correct or verify their SSN or Date of Birth

50.  The <<Staff Title>> provides the workers with a local number to reach the Social Security Administration

51.  Contact information for the Social Security Field Office near the workers or Consumer can be located by entering the workers or participant’s zip code at this website: https://secure.ssa.gov/apps6z/FOLO/fo001.jsp

52.  All contact with the participant is recorded in the Customer Service Module

 
Internal Controls: 

This process itself is an internal control used to verify the data integrity of Worker Social Security Numbers recorded in F/EA systems. By using this method to verify Social Security Numbers of workers, F/EA improves the accuracy of data on Forms W-2 provided to workers, State Department of Revenue or equivalent, the Social Security Administration and the IRS. Performing this process at least annually improves F/EA data integrity.

F/EA uses the following internal controls to monitor this process:
  1. <<Staff Title>> prints, reviews, initials and dates a confirmation sheet showing that a Social Security Number Verification file was submitted to the Social Security Administration.
  2. <<Staff Title>> reviews, initials and dates a confirmation sheet showing that a Social Security Number Verification file was submitted to the Social Security Administration.
    • Confirmation Sheet is stored in Payroll Department for a minimum of 7 years per File Retention Policy.
  3. <<Staff Title>> prints, reviews, initials and dates a print out of Social Security Numbers with errors.
  4. <<Staff Title>> reviews, initials and dates of Social Security Numbers with errors.
    • Print out of Social Security Numbers with errors is stored in Payroll Department for a minimum of 7 years, per File Retention Policy
  5. Documentation of follow-up with consumers on Worker Social Security Numbers deemed incorrect is stored in the Customer Service tab of Payroll System.

Update Worker Contact Information

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Policy: 

F/EA can only make changes to employee contact information when the employee, participant or representative requests a change.  <<Does the program require that requests come in writing?  If so, add it here.>>

Three times a year in February, July and October, F/EA mails a bulk mailing to all active participants and their workers.   This mailing includes a Contact Information Verification Form to verify both participant and workers mailing address, phone number and e-mail address.  <<Only include this if you actually do it>>
 
Contact Information Verification Form is pre-populated with the participant number, participant name and participant contact information on file.  This form is mailed to the participant or representative for confirmation/ correction.
 
The workers contact Information is pre-populated with the participant number, participant name and the employee mailing address, phone number and e-mail address. This form is mailed to the employee for confirmation/correction.
 
Additionally employees or participants can contact the F/EA at any time to update their addresses over the phone or in writing.
 
F/EA stores all requests for change of contact information in the Customer Service module.
Procedure: 

Update Worker Contact Information

<<Insert process to update contact information in your systems>>

Internal Controls: 

 

  1. All systems are password protected
    1. Only staff authorized to perform certain duties are provided with password access to systems
  2. F/EA only changes contact information for a workers if the request <<is made in writing.>>
  3. When the written request is received, F/EA staff verifies the sender and match the name with records on file.
  4. All requests for changes in contact information are scanned and saved electronically for seven years.

Process Background Checks on Workers

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Policy: 

<<Depending on the rules of the program, certain background checks may be required to be performed on workers before they are permitted to provide service.  The program may only require background checks for workers performing certain types of service.  For example, a workers performing "Respite Care" must have a background check, but a workers installing a ramp does not have to have a background check performed.

The program may require one or many types of background checks.  Some possible types of background checks are a criminal background check (state or FBI), a child abuse registry check, an adult/edler abuse registry check, or a sexual offender registry check.

Some programs may disallow a workers to provide service in the program if they have any offenses in their background check.  Others will only prohibit the workers providing service in the program if the workers has been convicted of certain kinds of offenses.  Still others require that if a workers has a offenses on his/her background check, that the participant complete an informed consent form, certifying that the participant is aware of the workers's offenses and still chooses to hire the workers.

The policy section of this document should set forth for what types of workers background checks are required, by when they must be performed, who performs them, and what occurs if a workers has offenses on his/her background check.  This section may also include how the payment for the background check is funded (e.g. by the F/EA, from the participant's budget or another approach.>>

Procedure: 
  1. <<Staff Title>> obtains consent forms to have a background check performed from each prospective workers's employment package.
  2. <<Staff Title>> reviews the consent form for completion.
  3. <<Staff Title>> tracks that the consent form was recieved <<insert how that is tracked>> and submits the background check for processing.
  4. <<Insert to what entity and how the background check is submitted>>
  5. <<Staff Title>> tracks that background check was submitted for processing.
  6. Results are obtained from background check within X days of submitting request for background check.
  7. <<Staff Title>> reviews results.
  8. <<Insert process for reviewing results, including what should happen if offenses exist on a background check.>>
  9. <<Insert process for tracking that a background check was performed so that workers is approved to be paid.>>
  10. <<Insert any process for informing the participant or workers of workers's status in program (e.g. able to be paid or not).>>
Internal Controls: 
  1. <<Insert control that tracks that a consent form for a background check was received.>>
  2. <<Insert control that tracks that a background check was submitted to entity to check background.>>
  3. <<Insert control that ensures that a workers is not paid until satisfactory background check results are received, or informed consent from the participant is received.>>

Establishment of Vendors as Goods/Service Providers for Consumers

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Prepare and Distribute a Goods & Services Vendor Package

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Policy: 

The Goods and Services Vendor Package consists of all forms that must be completed by the vendor and participant or the designated representative, when procuring goods or services from a vendor for the  program.

Consumers will receive the Goods & Services package from their <<counselor>>.  <<The counselor>> will review each form with the participant, helping the participant to understand the purpose and how to complete each form in the package. Each participant will receive a blank Goods and Services Vendor Package with their Welcome Package.

Throughout the program consumers will receive their supply of Goods and Services vendor packages from F/EA as they request packages to hire vendors. 

F/EA is responsible for updating the Goods and Services vendor packages as applicable.  F/EA will check on a monthly basis for updates on forms.  As forms are updated, changes will be made to the vendor package.   Packages that include updated forms are sent to consumers when they request vendor packages.
 

Note that individual workers are rarely considered "Goods and Services Vendors."  A "Goods and Services" vendor is usually an agency, corporation, licensed non-profit or other independent contractor.

Procedure: 
  1. A blank Goods and Services Vendor package is included in each participant's Welcome Package.
  2. Each blank Goods and Services Vendor package includes the following documents:
  3. Information on F/EA operations and policies is provided for the Goods and Services Vendor in the package, including a payment schedule, contact information and roles and resposibilities of of the F/EA
  4. Vendor agreement
  5. A payment request form is included in each package 
  • This form is used for goods and services vendor to propose services that they will provide to submit to F/EA to receive approval for payment

  6.  Vendor Enrollment Information Form

  • This form collects all of the relevant information in order for vendors to be issued payments in the program.

  7.  IRS Form W-9: Request for Taxpayer Identification Number and Certification, and Instructions for Qualified Independent Contractors Providing Approved Goods and Services

  8.  This form is provided to collect vendors Taxpayer Identification Numbers (TINs), in order for their invoices to be processed.

  • This information is needed in order for IRS Form 1099 to be processed for vendors at year end.

  9.  Medicaid Provider Agreement, as applicable

  10.  Direct Deposit Form

 
 

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to distribute Worker Hire packages are:
  1. A control document is used to track checking for updated forms at least monthly.
    • Staff verifies that new forms have been looked for at relevant agency websites at least monthly
  2. The <<Staff Title>> reviews the updated Goods and Services Vendors Package prior to sending it to consumers or counselors.

Establish Goods/Services Vendor in Payroll System

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Policy: 

Prior to paying a Goods & Services vendor, the F/EA must receive a completed Goods & Services Vendor Package.  The F/EA utilizes this information to establish the vendor as such in the F/EA's payroll system.  This procedure ensures that payments to the vendor go where intended, but also that the F/EA has required information to send tax returns to the vendors at year-end.  Form W-9 is required for all Goods and Services vendors prior to payment is issued.

F/EA will process vendor payments on a bi-weekly basis completed, valid payment request forms (PRFs) are received.

The payment request forms are distributed to all consumers when they join the program, in the Goods & Services Vendor Enrollment Package.  Consumers or vendors can request PRF’s by calling F/EA’s toll-free customer service line or the form can be accessed online. 

The PRF allows the participant to inform F/EA of what vendor is to be paid, in what amount and from what line in the participant’s budget to use allocated funds. 
 

Procedure: 
  1. <<Insert process to quality check vendor package.>>
  2. Ensure that the vendor has completed Form W-9, regardless of the vendor's status as a corporation, non-profit, sole proprietor, or Limited Liability Corporation.
  3. <<Enter vendor data, including vendor TIN, name and address into payroll system.>>
  4. <<As applicable, associate vendor with consumers who will pay vendor.>>
  5. <<If vendor has submitted direct deposit paperwork, establish vendor for direct deposit.>>
  6. <<Store vendor paperwork in participant file for a minimum of 7 years per File Retention Policy.>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

The methods of internal control utilized by F/EA to collect and process Goods & Services Vendor Packages are:
1.            Vendor Information is not entered into the payroll system until the Goods & Services Vendor Package has satisfactorily passed a quality check.
  • This ensures that vendors with incomplete packages are not paid.
2.            All packages are date stamped immediately upon receipt.
  • Verification of date stamp occurs by a separate staff member when packages are entered in payroll system and Goods & Services Vendor Packages
3.            During quality check, each form is separately initialed and dated as it passes a satisfactory quality check.
4.            A control sheet is used to Quality Check each packet.
  • During quality check, this control sheet is completed by the reviewer
  • The control sheet is reviewed secondarily during entry of vendor information in to the payroll system

Individual Budgets

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Validate Budgets for Accuracy

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Policy: 

Payment to a workers cannot be made without an active budget for the participant receiving service. The budget must cover the workers’s work date and the service type provided.  Any timesheets received that are not covered by a budget are denied.

F/EA receives budget data from the program administrator or counselors.  Each budget must be approved by <<X>> and <<Y>>.  Upon receipt, F/EA verifies that each budget is accurately calculated and includes appropriate start and end dates. Each valid budget is entered into F/EA’s Payroll System <<and billing system>>>.  A valid budget must be received by the F/EA for a participant before the participant is approved to receive service.
 
Budgets are processed by the <<Staff Title>> daily.
 
<<Insert how budgets are received by F/EA.  Are they paper forms?  Are they electronic submissions?>>
Procedure: 

Validate Each Individual Budget for Accuracy

F/EA receives individual budgets from Program Administrator or Counselors. Upon receipt, F/EA verifies that each budget is accurately calculated and includes appropriate start and end dates. Follow this process to validate the accuracy of a budget when it is received for a new participant, an existing participant or if the budget is an extension.
1.      Budgets are received daily via <<mail and fax>>
2.      When received, budgets are placed in assigned <<Staff Title>>’s inbox
3.      <<Staff Title>> collects budgets from inbox each day
4.      <<Staff Title>> identifies participant name on budget
5.      Open payroll system
6.      Press <<>> to find the participant in the system by last name.  Ensure the participant listed on the budget is in the system.
7.      Review the budget
8.      Identify the budget expiration date
9.      Verify that the budget expiration date is after the budget start date
10.  If the budget expiration date is not after the budget start date, the budget must be corrected (Go to Request Correction to Budgets as Needed below)
11.  Review the first line of the budget
12.  <<Insert what to check for>>
13. <<Insert everything that needs to be checked.  Pay special attention to make sure sufficient funds have been authorized to cover employer taxes and workers' compensation costs>>
14.  After verifying the budget for accuracy, <<Staff Title>> initials and dates the budget.

 

Request Correction to Individual Budgets As Needed
If there are any discrepancies found in the above process, Validate Each Individual Budget for Accuracy, a correction to the budget is requested of the <<the Program Administrator>>. Requests for corrections to budgets are made the same business day that the discrepancy is identified.
1.      After identifying a discrepancy on the budget, <<Staff Title>> requests a correction to the budget
2.      <<Staff Title>> logs in to Payroll System by double clicking on the icon on the computer desktop
3.      Enter user name and password
4.      Search for the participant by the participant number written on the budget
5.      Click on Notes tab
6.      Select “Add Note”
7.    Write “Waiting on budget correction”
8.    Select “Save”
9.      Prepare a Fax Cover sheet
10.  On fax cover, describe discrepancies on budget
11.  Request that budget be corrected as soon as possible
12.  Provide contact information for <<Staff Title>> in case Program Administrator has additional questions
13.  Fax Cover Sheet and budget to Program Administrator
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
    • Only staff with direct responsibility for certain Prior Authorization duties have password access to systems
  2. Each budget is verified for accuracy
    • The budget is verified for mathematical accuracy
    • The budget is verified for date accuracy
  3. After validating the budget, the <<Staff Title>> initials and date stamps the budget
  4. Program Administrator is notified in writing of budgets requiring corrections
  5. <<The budget is scanned to the participant file and saved for a minimum of 7 years>>

 

Process Budgets for Consumers Never Served by F/EA

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Policy: 

F/EA ensures that consumers are not established in F/EA’s payroll system until a budget has been received. This is an internal control to ensure that payments are never made on a participant's behalf until the budget is received.  After a budget has been received for a participant and verified by the <<Staff Title>>, the <<Staff Title>> is notified to continue establishment of the participant with state tax agencies and in applicable payroll systems. Any timesheets received that are not covered by a budget are denied.

Budgets are processed by the <<Staff Title>> daily. Customer Service Unit is notified daily of consumers who do not yet have state tax ID numbers, but for whom a budget has been received.
 
Use this procedure for any consumers who are not yet in the payroll system when a budget is received.
Procedure: 
  1. Upon receipt of the budget, <<Staff Title>> looks for participant in payroll system.
  2. If participant is not found, <<Staff Title>> uses this process.
  3. Place budget in inbox called "Establish Consumer in Systems"
  4. Each day, <<Staff Title>> takes all budgets in "Establish Consumer in Systemss" inbox to process paperwork for the participant to obtain the appropriate Tax ID numbers
  5. <<Staff Title>> obtains quality checked paperwork for all consumers in the inbox
  6. <<Staff Title>> provides start-up paperwork and list to <<Payroll Department>> to set-up
  7. <<Payroll Department>> enters into the payroll systems all consumers who have an EIN and completed start-up paperwork
  8. After setting up all consumers in the payroll system, <<Staff Title>> uses applicable policy and procedure manual to enter budget in the systems and issue a welcome package to the participant.

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
  2. Only staff with direct responsibility for certain budget duties have password access to systems
  3. Budget information cannot be entered in to Payroll System to permit payment of timesheets unless participant has been entered in Payroll System
  4. Customer Service reviews when a participant has completed applicable paperwork to permit the participant to be entered in to Payroll System
    • This process ensures that payroll department does not add budget to F/EA systems until Customer Service has ensured that the participant has completed all necessary paperwork
    • By not entering the budget in the Payroll system, payment of timesheets is not possible
    • This ensures that timesheets are not paid for a participant until all required information has been received

Enter Budget Information in Applicable Systems

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Policy: 

F/EA ensures that consumers are not established in F/EA’s payroll system until a budget has been received (See Policy and Procedure document 4.4). This is an internal control to ensure that payments are not made on a participant's behalf until an approved budget has been received.

After a budget has been received for a participant and verified by <<Staff Title>>, and the Customer Service Unit has verified that all requirements have been met for the participant to begin paying workers (See Policy and Procedures <<>>), the <<Staff Title>> enters budget in the Payroll System. The <<Staff Title>> performs these tasks daily. 
 
A separate process exists for entering budget information for complete budgets and for budget extensions. Both processes are described below.
Procedure: 

Enter Budgets (Not Extensions) in Payroll System

Use this process when a new budget for a participant has been received. Do not use the process when an extension of an existing budget has been received.
 
1.      <<Staff Title>> logs in to Payroll System by double clicking on the icon on the computer desktop
2.      Enter user name and password
3.      Search for the participant by the participant number written on the budget
4.      Select “Individual Budget” tab
  •  <<Insert Process to enter individual budget data into the payroll system and any checks or calculations that need to be made as part of the process.>>

 

 
Enter Budget Extensions or Amendments in Payroll System
In some cases, Program Administrator will issue a budget extension for a participant because their current budget has expired, but a new budget has not yet been issued. Extensions of budgets  are usually made for 1 month or less, but this is not a requirement. <<Staff Title>> enters extension information in the current budget portion of Payroll System.
 
Alternatively, an amendment to an existing budget may be submitted by Program Administrator.  Amendments are adjusted in the current budget portion of the Payroll System.
  1. Review PA extension
  2. <<Insert Process to enter Extensions/Amendments into Payroll System.  Include any necessary checks or calculations and/or people that should be notified of the change.>>
 
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
  2. Only staff with direct responsibility for certain budget duties have password access to systems
  3. Budget information cannot be entered in to Payroll System to permit payment of timesheets unless participant has been entered in Payroll System
  • Customer Service reviews when a participant has completed applicable paperwork to permit the participant to be entered in to Payroll System
    • This process ensures that <<Staff Title>> does not add budget to F/EA systems until Customer Service has ensured that the participant has completed all necessary paperwork
    • By not entering the budget in the Payroll system, payment of timesheets is not possible
    • This ensures that timesheets are not paid for a participant until all required information has been received
  1. <<Staff Title>> signs and dates each budget after entering in to Payroll System
  2. All Prior Authorization documents are stored for a minimum of 7 years, per F/EA file retention policy

 

Issue Welcome Package to Consumer

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Policy: 

After a participant’s budget is received by F/EA, validated for accuracy and entered into Payroll System, a Welcome Package is sent to the participant. Welcome Packages are only sent to consumers after their first budget is received by F/EA. A Welcome Package is sent to the participant within 3 business days of entering the budget in the Payroll System. 

 

The Welcome Package is issued when the participant is totally ready to receive and direct service in the program.  This means that the Welcome Package is issued after all employer paperwork has been received by the F/EA and verified as correct and an authorized budget for the participant has been received by the F/EA.  The Welcome Package alerts the participant that they can now hire staff, purchase goods and receive services.  The Welcome Package also provides the participant with other information and documents that they will use in the management of their program.

Usually, the Welcome Package is only sent when the participant starts their program and it is not sent again.

The <<Staff Title>> issues the Welcome Package.
Procedure: 
  1. After entering budget information in Payroll System, <<Staff Title>> prepares Welcome Package to be sent to participant
  2. The Welcome Package is only issued to the participant after F/EA receives the participant’s first budget and all employment paperwork has been deemed complete.  Welcome Packets are not sent to the participant following receipt of subsequent budgets.
  3.  <<Staff Title>> is provided a list of new consumers for whom Welcome Packages should be issues.
  4. Budgets for these consumers are entered in to applicable systems (See previous chapter) and issued Welcome Packages
  5. <<Staff Title>> obtains Welcome Letter template from <<Insert File Path>>
  6. On Welcome Letter, <<Staff Title>> enters today’s date in “Date”
  7. On the blank line following “Your Consumer ID is ______”, enter participant ID
  8. Enter participant first and last name in appropriate place on Welcome Letter
  9. <<Staff Title>> obtains a complete Welcome Package from <<file path or physical storage>>
  10. Each Welcome Package includes the following documents
  • Overview of F/EA's services, operations and key roles and responsibilities
  • F/EA hours of operation and key contact information
  • Timesheets
  • -These are used for workers and consumers to report service provided by the workers
  •   Invoices
  • -These are used for non-workers goods and services requisitions
  • Termination Form
  • -The participant completes this form and submits it to F/EA when they terminate a workers
  •  Change and Request Form
  • -This form is used for the participant to request changes to their or their workers’s address, telephone number or other contact information
  • Notification of Reinstatement of Worker
  • -This form is used for a participant to notify F/EA that they are re-hiring a workers
  •  Policies
  • -<<Insert Policies that F/EA wishes to share with participant>>
  • Fraud and Abuse Policy
  • <<Staff Title>> obtains manila envelope from shipping supplies storage area
  • Obtain participant or representative mailing address
  • Mail envelope to participant or representative

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
    • Only staff with direct responsibility for certain budget duties have password access to systems
  2. All Welcome Package documents are maintained in a secure location within F/EA Department
  3. When a Welcome Package document is updated all copies of previous form versions are discarded from Welcome Package document storage location
    • This ensures that only the most up to date versions of documents are included in Welcome Packages
  4. Issuing Welcome Packages is the responsibility of <<Staff Title>>. Customer Service and Payroll staff are not authorized to issue Welcome Packages.
  5. Only F/EA Department staff have access to Welcome Package contents
    • Envelopes are sealed prior to delivering to F/EA front desk staff who stamp and mail Welcome Package

Operate as a Medicaid Enrolled Provider (when applicable)

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Policy: 

If the F/EA is operating as such in a Medicaid program, the F/EA must be a Medicaid enrolled provider.  <<Adjust this per program rules.>>  In Medicaid programs, the F/EA must be an enrolled Medicaid provider prior to receiving participant budget funds, making payments on consumers' behalves or submitting service claims for payment.

<<Insert policy for F/EA to be a Medicaid enrolled provider for the program.>>

<<Insert policy for how F/EA maintains status as Medicaid enrolled provider.>>

Procedure: 

<<Insert procedure to apply for and receive a approval to be a Medicaid enrolled provider, as applicable.>>

Internal Controls: 

<<Insert any internal controls related to operating as a Medicaid enrolled provider.

Issuing Payments to Workers & Vendors

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Collect and Date Stamp Timesheets & Invoices

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Policy: 

Timesheets are submitted to F/EA by consumers on a bi-weekly basis according to the payroll calendar schedule. All timesheets must be received by at the Fiscal/Employer Agent Office by <<4:00 PM on the Monday>> after the payroll period ends.

Timesheets are accepted via <<drop-off, mail, fax, and/or online>>. A separate timesheet must be completed for each employee.
 
Each timesheet must include the following:
Time in and time out for each day worked
Employer Signature
Employee Signature
Service Code for the Service performed by the workers
Procedure: 

Faxed Timesheets

  1. Consumers are encouraged to fax timesheets to the F/EA as stated in the timesheet instructions in the Start-Up Package
  2. The timesheet fax number is <<XXX-XXX-XXXX>>
  3. Timesheets faxed to the timesheet fax number go directly to the <<verifier system>>
    • Timesheets faxed to the timesheet fax number are automatically date stamped by the system as they are picked up by the system
  4. Timesheets are processed via the standard process
Mailed and Dropped Off Timesheets
  1. Consumers can mail timesheets to F/EA or drop them off at the F/EA at <<insert address here>>.
  2. Timesheets that are mailed to F/EA are opened and processed daily
  3. Timesheets that are dropped off at the F/EA drop box by 3PM daily, are collected daily from the drop-off box and processed
  4. Payroll Representative collects all dropped off or mailed timesheets each day at 3:15 PM
  5. Payroll Representative takes timesheets to date stamp machine and date stamps the timesheet
  6. <<Where do timesheets go for the next phase of processing?>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, document procedures and ensure independent internal verification. 

  1. Only F/EA Personnel are authorized to pick up timesheets and other Fiscal/Employer Agent paperwork the F/EA Drop-Off box.
  2. All timesheets are date stamped immediately upon receipt.
  3. <<Staff Title>> verifies that each scanned batch is accepted by the system.

Review Each Timesheet for Accuracy and Completeness

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Policy: 

Timesheets are verified for accuracy and completeness either manually or with software called <<Insert if you have software that supports timesheet validation>>. Each timesheet is reviewed to ensure the following fields are correctly completed: 

  1. Signatures by both the workers and employer are on the timesheet (Note: see section listed in procedure for specific policy if a participant/employer passes away during a payroll period in which a workers has worked)
  2. Start and end dates of the payroll cycle
  3. Time in and time out for each day worked
  4. AM and PM completion for each day worked
  5. Consumer Number
  6. Employer signature
  7. Employee signature
  8. Total hours worked for each week
Any fields that are not correctly and accurately completed are either corrected by F/EA Payroll Department or are submitted to F/EA Customer Service Unit. Customer Service Unit contacts participant to correct timesheets as applicable.
Procedure: 

Verify Timesheets for Accuracy and Completeness

The review of the timesheets for accuracy and completeness is performed by <<Staff Title>> and assigned staff.
  1. <<Staff Title>> or assigned staff double clicks on Teleform icon on desktop
  2. <<Insert process used to verify timesheet accuracy>>
  3. Verify that the participant has completed all necessary paperwork prior to the timesheet being processed
  4. <<Insert the process used to verify that all program requirements have been met>>
  5. Verify that the participant number on the timesheet exists in the Payroll System and pull up the participant name associated with the participant number for verification
  •  The participant’s name and number require verification.
                                      

6.  Verify that the Employee ID number on the timesheet exists in the Payroll System and pull up the workers name associated with the Employee ID for verification

  • The workers’s name and number require verification.
7.  If it doesn’t, <<Staff Title>> or assigned staff logs in to Payroll System and looks up the workers by the last name written on the timesheet
8.  Verify that the workers has completed all necessary paperwork and met all requirements prior to the timesheet being processed
9.  Verify that the Signature <<insert the program requirements for Signature verification.>>
10. Verify that the dates on the timesheet coincide with the payroll cycle
11. If the begin and end dates are not within 3 days of the pay cycle dates, go to step 10.
  •  If the dates on the timesheet are for future dates, the timesheet should not be processed

12. Verify that the total hours worked each day match the difference between the in and out times on the timesheet.

  •  <<Insert what to do if hours don't match>>

Verify that the total hours worked for the week match the sum of the daily totals for each week.

  • Identify the weekly totals that do not match the sum of daily totals for each week.
  • Update the weekly totals to match the sum of daily totals

13.  For any timesheet verification errors that cannot be resolved, do the following:

  • Print image of timesheet (if verifying electronic timesheet)
  • Write <<the batch number>> on the timesheet and the problem with the timesheet
  • Give the timesheets with problems to <<Staff Title>>
  • Customer Service Unit will contact consumers as applicable
  • After verifying all timesheets in a batch, <<Staff Title>> or assigned staff will be assigned another batch to verify
  • Each Batch is saved as the verification is completed, the batch status will change to “Ready to be committed”
  • This completes the review of the timesheets for completeness and accuracy. 

Commit Timesheets for Payment

  • Processing of the timesheets for payment is the responsibility of the Payroll Department staff only. Payroll staff are the only personnel authorized to perform the steps below.
  1. For any batches with a status of “Ready to be committed” <<adjust process per software system below>>
  2. Select “Commit"
  3. A message displaying, “Do you want to commit the batch?” will display
  4. Select “Yes”
  5. The batch status will change to “Batch is Complete”
  6. These batches will be picked up by Payroll System
  7. Identify any batches that have a number greater than zero in the “Nonforms” column     

Process to Sign Timesheet if a Consumer Passes Away in Payroll Period

  • Timesheets are required to be signed by a participant or representative. The procedure below outlines the process to execute the timesheet in the event the participant passes away during a payroll period in which a workers has worked. In no instance are Counselor staff authorized to sign a participant’s timesheet.
  1. If the participant has a representative or legal guardian, the representative or legal guardian should sign the timesheet
  2. If the participant does not have a representative, then a relative or caretaker who is not the workers is authorized to sign the timesheet
    • The relative or caretaker must submit with the timesheet a letter stating the date that the participant passed away
    • This date is compared to the last date worked on the timesheet and no time worked after the participant’s date of death are paid

3.  If none of the above are available, the <<Staff Title>> or <<Staff Title>> will sign the timesheet.

 

Internal Controls: 

 The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
    • Only staff with direct responsibility for certain payroll duties have password access to systems’ functions
  2. The <<>> system automatically compares the participant number written on a timesheet to participant numbers in the Payroll System
    • This systematic process ensures that timesheets are not paid for consumers who have not successfully completed all F/EA Start-Up paperwork.
  3. The <<>> system automatically validates mathematical calculations.
  4. The <<>> system automatically identifies timesheets with future dates.
  5. The <<>> system automatically identifies any timesheets missing workers or participant signatures.
  6. Verification of timesheet accuracy and follow-up with consumers are segregated duties within F/EA.
    • The Payroll Department is responsible for verifying timesheets for accuracy.
    • The Customer Service Unit is responsible for contacting consumers to correct timesheets as applicable.
  7. Any timesheets that are manually verified are initialed and dated by the <<Staff Title>> or assigned staff who manually checks them.
  8. All timesheets are stored in <<>> for a minimum of 7 years per File Retention Policy.

Review Timesheet for Compliance with Budget and Program Rules

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Policy: 

Timesheets are checked for completion in accordance with Program rules. The process to verify timesheets in accordance with program rules occurs using <<F/EA’s Payroll System.>>  <<Program rules will vary by program.  Some sample program rules are here.>>

The Payroll system includes a database containing all budget data, including the participant name, budget number,budget start date, budget end date and approved hours/units for each service and workers/vendor. <<Include approved rate information?>> The database also contains all workers data. 
 
This system is programmed to perform automated data validation. Each timesheet is checked against database data per program rules and any discrepancy is flagged for follow-up.
 
Timesheets are entered into this system either manually or via an import from the <<Optical Character Recognition>> system. Timesheets are verified in the payroll system <<Monday through Thursday >> of each payroll week.
Program Rules
 
<<List the program payment rules here.  Below are some examples.>>
-A participant cannot receive service from more than one workers simultaneously
-A workers cannot provide service to more than one participant simultaneously
-Workers who get paid for transportation must show proof of a valid drivers' license
-Workers must pass a criminal background check before they can be paid for service
-A participant's budget must include an authorized service before a workers or vendor can be paid for providing that service
-A participant must have sufficient funds in the budget line item before a workers or vendor can be paid for the service
Procedure: 
Import and Verify Timesheet Data
 
1.      <<Staff Title>> <<insert process to import and verify timesheet data>>
  •  <<this might be a combination of importing OCR timesheets and manually entering timesheet data>>
 Manual Entry of Timesheets
<<For any timesheets that required manual verification from any non-forms or any timesheets with a typo in the workers’s Social Security Number, follow this process to manually enter the timesheets in to Payroll System.>>
 
Error and Discrepancy Resolution
<<Enter the process used to identify Program Rule errors and discrepancies and the process to resolve them, when possible>>  <<Information on following up with consumers, counselors and families can be found in the chapter dedicated to that process>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. The Payroll system performs a second validation to ensure the participant number written on a timesheet is in Payroll System
    • This systematic process ensures that timesheets are not paid for consumers who have not successfully completed all F/EA Start-Up paperwork.
  2. The Payroll system automatically compares hours on a timesheet to the remaining balance in the participant’s budget
    • Users are notified when the participant’s budget does not have a balance to cover hours on the timesheet
    • The timesheet will not be paid unless the <<Staff Title>> directs the timesheet to be paid
  3. The Payroll system automatically identifies timesheets with a workers that is not connected the participant listed on the timesheet
    • This triggers the <<Staff Title>> to verify that the workers has completed all necessary paperwork and is approved to provide service to the participant
  4. The Payroll System automatically verifies that a duplicate timesheet is not being paid.
    • This ensures that workers are not paid twice for the same service even if they submit a timesheet twice for the same service.
  5. Verification of timesheet accuracy and follow-up with consumers are segregated duties within F/EA
    • The Payroll Department is responsible for verifying timesheets for accuracy.
    • The Customer Service Unit is responsible for contacting consumers to correct timesheets as applicable.
  6. All payroll systems are password protected.
    • Only those F/EA staff with responsibility for certain payroll activities have passwords for applicable payroll systems.

Pay Worker in Accordance with Applicable Rate for Each Approved Service Code

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Policy: 
<<How rates are determined varies greatly by program.  Insert the policy for rate determination here and the procedure for paying in accordance with rates below.>>
 
Most programs use one of the following models to determine payable rates:
 
-Rates are set by the service code.  Each service code is associated with a rate and every workers is paid that rate when they perform the service.
-Rates are set by the participant, but cannot be higher than a certain maximum.  Rate maximums exist for each service.  The minimum is minimum wage.
-Rates are set by the participant, and there is not a maximum.  The minimum is minimum wage.
-Rates are tiered and workers get paid based on experience or qualification.
-Workers qualify for the companionship exemption and are not required to be paid minimum wage.
 
In many cases, the workers agrees to the rate in the employment agreement.  <<If that is the case, insert that the workers agrees to his/her rate in the employment agreement, when the employment agreement is executed and where it is stored.>>

 

Procedure: 

<<Insert procedure for paying in accordance with rates.  In most cases, the rates are pre-determined and are stored in the participant's budget on the line item for the individual workers.>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

Submit Payments to Workers

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Policy: 
  1.  F/EA pays workers, withholds and calculates applicable workers and employer taxes and files and deposits taxes with applicable government agencies.
  2. F/EA ensures that all workers have been properly paid by performing a weekly reconciliation of the payroll edit register.
  3. F/EA pays workers and vendors via one of two methods: by paper check mailed to the <<workers or vendor>> or by direct deposit into the workers or vendor's authorized bank account.
  4. Each check includes the F/EA Chief Financial Officer’s (CFO) signature on the check. The Chief Financial Officer is one of two signatories on the program bank account, with the <<Staff Title>>. The F/EA maintains the CFO signature block image in a password protected, secured location within the F/EA's check writing software. Only authorized F/EA staff have access to the signature block image.
  5. A remittance advice is submitted with every payment.  If the workers or vendor is paid by paper check, the remittance advice is included in the envelope with the paper check.  If the workers or vendor is paid by direct deposit, the remittance advice is <<mailed or emailed>> to the workers or vendor separately.  Each remittance advice includes the following information:
  • Consumer who received services
  • Gross wages this pay period
  • Gross wages year-to-date
  • Net wages this pay period
  • Net wages year-to-date
  • Federal income tax withheld this pay period
  • Federal income tax withheld year-to-date
  • Social Security tax withheld this pay period
  • Social Security tax withheld year-to-date
  • Medicare tax withheld this pay period
  • Medicare tax withheld year-to-date
  • Earned Income Credit this pay period
  • Earned Income Credit year-to-date
  • Other deductions (itemized) this pay period
  • Other deductions (itemized) year-to-date
Procedure: 

<<Insert Process to do the following>>

-Print checks with the applicable check date

-Get signature on checks

-Print remittance advices with checks

-Verify addresses on checks/envelopes

-Stuff checks/remittance advices in envelopes

-Mail checks with postage date on or before published pay day

-Create electronic funds bank file for direct deposits

-Upload electronic funds file to F/EA bank

-Manage "pre-notes" as needed

-Get confirmation that direct deposits have been accepted

-Mail/email remittance advices for direct deposits

-Store check information

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Insert internal controls depending on process>>
  2. F/EA Payroll Department reconciles payroll account to ensure that accurate payments are debited from the account
  3. Chief Financial Officer is one of two signatories on the program bank account (with Executive Director)
    • F/EA maintains Chief Financial Officer signature block for checks in a password protected, secure location
    • Only authorized staff have access to Chief Financial Officer signature block
  4. On a quarterly basis Quality Assurance Coordinator contacts a random sample of 25 workers/vendors to inquire if they regularly received a remittance advice with their payments
    • F/EA Quality Assurance Coordinator completes a findings control document and submits to <<Staff Title>> for review and signature
    • Corrective action plan developed and implemented based on findings

Budget & Utilization Research

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Policy: 

Budget and utilization research is performed when a participant’s budget balance is zero before the end of the approval period. This could be the result of the participant over-utilizing authorized units or there could be an error in the budget. This research is performed to identify the problem, communicate it to the participant and counselor as applicable, and resolve any issues or discrepancies.

This process is performed by the <<Staff Title>> at the end of each weekly pay cycle. Upon processing payroll using the Payroll System, an error may display stating that insufficient <<hours, units, dollars>> are remaining in the participant’s budget balance to cover the timesheet.  These timesheets are preliminarily researched during processing and a <<Research form>> is completed for them. <<At the end of the pay cycle, the <<Staff Title>> collects the Research forms and performs the below process to research them.>> 
Procedure: 

 

  1. <<Staff Title>> collects all Research forms at the end of each pay cycle
    • Research forms are stored in the Timesheets for Research folder in the Payroll Department
  2. Select the first Research form in the folder
  3. <<Staff Title>> requests Billing History report for the participant from Billing Department
  4. Verify that the research was not already performed and the timesheet paid
    • Go to <<File Path>>
    • Within this folder, a folder exists for each participant for whom research has been performed in the past
    • Search for a folder named for the participant
  1. If you locate a folder named for participant, review the research spreadsheet within the folder and perform the following steps
  2. Compare the research to the “Needs Research” sheet and complete any missing information on the “Needs Research” sheet
  3. Verify that the research was completed accurately by double checking the calculations and data
  4. Print the research page for the participant
  5. Attach the research page to the back of the timesheet that could not be paid for insufficient hours
  6. <<Insert process to research a participant's budget utilization>>
  7. <<The point of this process is to ensure that the participant actually has spent all of his/her budget and his/her timesheet should not be paid.>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
    1. Only staff with direct responsibility for certain payroll duties have password access to systems
  2. Programmed system controls track participant spending and prevent payment of a timesheet if the budget balance will be less than zero following payment
  3. Payment data that facilitates research is maintained in F/EA payroll systems for 7 years per File Retention Policy
  4. A control document of payroll payment research is maintained
  5. Staff preparing the research document sign and date the control document
  6. The control document and all supporting documents are maintained for a minimum of 7 years per File Retention Policy
  7. All communication with the participant is logged and maintained for a minimum of 7 years per File Retention Policy
  8. Staff who communicate with consumers regarding utilization are separate from staff who perform utilization research

Adjust Payments Issued in Error

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Policy: 

F/EA strives to issue all payments correctly when they are initially issued.  However, in some rare cases, checks may be issued in error.  Some possible errors include:

  1. Worker or vendor is paid for a different number of hours or units of service than were actually provided.
  2. The incorrect amount of tax is withheld from an workers paycheck.
  3. The check is issued to the incorrect payee.

Immediately upon identifying an error in payment, the error is researched by appropriate staff and corrective action is taken.  Corrective action may include:

  1. Issuing a supplemental check or direct deposit to correct an underpayment.
  2. Voiding a payment.
  3. Voiding and re-issuing a payment.
Procedure: 

 <<Insert procedure based on F/EA's operations>>

Internal Controls: 

 <<Insert internal controls based on F/EA's operations>>

Issue Stop Payments and Replacement Checks for Checks Reported Lost or Stolen

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Policy: 
If a check is reported to F/EA Customer Service as lost or stolen, F/EA stops payment on the original check and issues a replacement check within 5 days of receiving <<written notification>> from the participant.
Procedure: 

Customer Service Receives Notification

F/EA’s Customer Service Unit first receives notification from the participant or representative that a check has been lost or stolen. Customer Service verifies the check mailing address and that the check was sent. Customer Service updates the participant address as applicable. <<Customer Service requests that participant submits to F/EA a stop payment request in writing.>>
 
  1. When Customer Service receives a call that a check should be reissued, the <<Staff Title>> must first ask the caller to identify himself or herself.
  2. <<The <<Staff Title>> must verify that the caller is the participant or representative>>
  3. If it is, continue to step 5
  4. << If the caller is not the participant or representative, <<Staff Title>> informs the caller to ask the participant or representative to contact F/EA>>
  5. <<Staff Title>> verifies in the payroll system whether the check in question was paid
  6. <<Insert process to check this in payroll system>>
  7. <<Staff Title>> verifies check delivery address
  8. <<Insert process to check mailing address in system>>                                                         
  9. Notify the caller of the check number that was originally issued
  10. <<Request from the participant a “Stop Payment” letter containing the following information:
    • Consumer and Worker Name
    • Payroll period paid on the check
    • Check number
    • Explanation of why a replacement check is required
    • Consumer or representative’s signature>>

11.  Remind the caller that if they do receive the original check, they must contact F/EA to inquire if it can be cashed prior to cashing it

12.  Log description of call in Customer Service tab of Payroll System

13.  Use code to denote the type of call being logged

14.  Open the Stop Payment Requests Form at <<File Path>>

15.  Complete the form including the following information on the Stop Payment Request Form:

  • Caller’s name
  • Date of Call
  • Consumer Number
  • Consumer Name
  • Worker Name
  • Consumer/Representative Phone Number
  • Payroll Period
  • Check number
  • <<Staff Title>> name
  • Reason for Stop Payment
  • A note that the address was verified
  • A note that if the address was incorrect, the correct address is now in the payroll system

16.  Attach copy of check stub to Stop Payment Request Form

17.  <<Keep this package of documents until the written request for stop payment is received from the participant or representative>>

18.  <<Staff Title>> stores the request in “Stop Payment Requests” folder

19.  <<Once the written request for stop payment is received, log that it has been received in the Consumer’s Customer Service tab in Payroll System>>

20.  <<Attach written request for stop payment to copies of check stub and P/R Delivery Address page and Stop Payment Request Form>>

21.  Provide entire package to  <<Staff Title>>  to issue stop payment and replacement check

 
Payroll Department Process Stop Payment and Replacement Check
F/EA’s Payroll Department receives a package of Stop Payment documents from the Customer Service Unit after <<the participant has issued a written request,>> the delivery address has been verified and Customer Service has verified that a check was actually mailed. After receiving applicable documents, <<Staff Title>> verifies with the bank that the original check has not yet been cashed.   If it has not, a stop payment and a replacement check are issued.
 
  1. <<Staff Title>> or designated officer verifies with the bank online if the check was cashed (See Processing Online Stop Payment below)
  2. If the check was not cashed, process a stop payment requisition with the bank using the online process (See Processing Online Stop Payment below)
  3. Print a copy of the online transaction
  4. <<Staff Title>> or designated officer must sign and date check print out information (in stop payment package received from Customer Service)
    • Attach a copy of the online transaction to this stop payment package
  5.  <<Staff Title>> or <<Staff Title>> completes a A/P Check Requisition including:<<update this process per the process actually used by the F/EA>>
    • In Vendor Name, complete with workers Name and Address
    • In Description, enter “Reference: Consumer Name and Number”
    • In Description, enter the reason a manual check is requested
    • Specify the account number to be affected
    • Specify the amount for which the check should be paid
    • Check boxes in the lower right corner can be completed to denote where to mail the check
    • Complete the “Date Submitted”
    • Complete the “Submitted By”
    • The requisition is always submitted by <<Staff Title>> or F/EA CFO
  1. The person listed in “Submitted By” must sign the form
  2. <<Staff Title>> scans signed check print out information and A/P Check Requisition form
    • <<Staff Title>> or Lead <<Staff Title>> attaches scanned image of signed check print out information and e-mails to F/EA Accounts Payable Department with a subject “Check Requisition”
    • Upon receipt of this requisition, F/EA Accounts Payable Department issues a replacement check dated the day of the authorized request
    • After printing the check, F/EA Accounts Payable Department submits an image of check to F/EA Payroll Department
  3. <<Staff Title>> or <<Staff Title>> attaches all documents after verifying that all data is correct
  4. Record voided check information in Void and Reissue log
    • Open Void and Reissue log spreadsheet found here: <<File Path>>
    • Enter the following information in the Void and Reissue log.  Information is found on the documents developed as part of the stop payment process
  • Consumer name
  • Worker/vendor name
  • Check number for stop payment
  • Check amount
  • Date participant or representative reported the missing check
  • Reason for stop payment
  • Date stop payment was made with the bank
  • Payroll staff member’s signature on check print out (payroll staff who authorized the stop payment)
  • F/EA staff name who received call from participant or representative of missing check
  • Name of caller
  • Confirmation of check delivery address
  • FI explanation of issue (why original check was not received by participant)
  • Replacement check number
  • Replacement check date
  • Initials of payroll staff monitoring this transaction
  1. After recording this information, place participant’s stop payment package of documents in the “Void and Reissue” binder for storage
 
Issue a Stop Payment Online
The <<Staff Title>> or designated officer can issue a stop payment with F/EA’s bank online. Only the <<Staff Title>> and designated officers have log in and password access to the online bank site.
  1. <<Staff Title>> or designated officer goes to bank website: <<insert bank website>>
  2. Enter Company ID: (This will be assigned as needed)
  3. Enter Company password: (This will be assigned as needed)
  4. Enter User ID: (This will be assigned as needed)
  5. Enter User password : ( This will be assigned as needed)
  6. Select “Submit”
  7. Verify if check was cashed
  8. Go to “Balance Reporting” on menu
  9. Select “Account Summary”
  10. Select <<insert bank account name>>
  11. In “From” date, enter the check date
  12. In “To” date, enter today’s date
  13. Select “Submit”
  14. Sort report by field by which you wish to search
  15. Attempt to identify check in question
  16. If check cannot be found, the check has not been cashed.  Go to Step 18.
  17. If check is found, the check has been cashed
  • Obtain the Check Stub print out
  • Write on print out that check was cashed and the date check was cashed
  • If check was cashed in a prior month, obtain check image in bank statement from F/EA Accountant
  • Provide this information to Customer Service
  • Customer Service will contact the participant

18.  Select “Account Services”

19.  Select “Stop Payment”

20.  Select “Add Stop Payment”

21.  Select “Account Number”

22.  Select “Reason for stop Payment”

23.  Enter Check Number; Check Amount; Issue date and Payee.

24.  Select “Add”  

25.  Verify the accuracy of the data.

26.  Select “Process”  

27.  The screen will change to confirm. 

28.  Print Confirmation page

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All systems are password protected
    • Only staff with direct responsibility for certain payroll duties have password access to systems
  2. Customer Service Unit verifies mailing address with participant or representative to ensure that F/EA is mailing to the appropriate address
  3. <<F/EA requires stop payment request in writing>>
  4. Only the <<Staff Title>> or designated officer is authorized to issue stop payments with the bank
    • Only these individuals have bank log in information to authorize stop payments
  5. <<Staff Title>> or designated officer review and sign stop payment package prior to providing to Lead <<Staff Title>>
  6. Lead <<Staff Title>> verifies that <<Staff Title>> or designated officer has signed stop payment package prior to faxing request for replacement check to reporting agent
  7. An A/P Check Requisition form is completed, dated and signed by <<Staff Title>>
    • <<Staff Title>> reviews A/P Check Requisition form and supporting documents
    • <<Staff Title>> signs A/P Check Requisition form prior to submitting to F/EA Accounts Payable Department
    • F/EA Accounts Payable Department will not re-issue a check without <<Staff Title>> signature on A/P Check Requisition form
  8. After reissuing a check, the F/EA Accounts Payable Department submits an image of the check to Payroll Department
    • Payroll Department uses this image as proof that the check was printed and issued to the workers
  9. All voided checks are recorded in a log, including information on F/EA staff who authorized the stop payment and reissue

Monthly and Quarterly Reconciliation of Payroll Payments

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Policy: 

<<This process is contingent on the F/EA's payroll and accounting processes>>

Procedure: 

Monthly Reconciliation of Payroll Payments

  1. At end of each month, <<Staff Title>>, or assigned staff, obtain the monthly Payroll Journal Summary from the payroll system
  2. The report includes the following:
    • Payments for <<X program>> Consumers
    • Payments for <<Y program>> Consumers
    • Adjustments for <<X program> Consumers
    • Adjustments for <<Y program>> Consumers
    • Adjustments for Transfers
  3. This report must be matched to the weekly reconciliations
    • Open spreadsheet called
    • Create a new tab in the spreadsheet and name it “Month End”
  4. A tab exists in the spreadsheet for each payroll week
    • These tabs include summary amounts for each day payroll was cut for the payroll week as well as weekly sums
    • Copy the weekly summary amount to the month end tab
    • Do this for each week in the month
  5. <<Staff Title>> creates a spreadsheet and merges every expense report for the month
  6. Using the monthly Payroll Journal Summary from the payroll department enter the following values separated by program, transfers and adjustments
    • Day Hrs
    • Day wages
    • OT hours
    • OT wages
    • Holiday hours
    • Holiday wages
    • Other hours
    • Oth wages
    • Night hours
    • Night wages
    • Total hours
    • Total wages
    • Federal Income Tax Withheld
    • State Income Tax Withheld
    • Employee Social Security
    • Employee Medicare
    • EIC
    • Misc Deductions
    • Net
    • Employer Social Security
    • Employer Medicare
    • Employer FUTA
    • Employer SUI
    • Total Liab
    • Workers' Compensation
  7. In column S, insert calculations that sum each of the rows listed above for each program
  8. In column T, the difference between the payroll system month end report and the sum of weekly payroll amounts is shown
    • Research and resolve any discrepancies
  9. Journal Entries and Posting to General Ledger is performed using Policy and Procedure <<insert link>>
Quarterly Reconciliation of Payroll Payments
 
  1. At end of each quarter, <<Staff Title>>, or assigned staff, obtain the quarterly Payroll Journal Summary from the payroll system
  2. The report includes the following:
    • Payments for <<X program>> Consumers
    • Payments for <<Y program>>Consumers
    • Adjustments for <<X program>> Consumers
    • Adjustments for <<Y program>> Consumers
    • Adjustments for Transfers
  3. This report must be matched to the sum of the monthly reconciliations in the quarter
    • <<Staff Title>> opens spreadsheet called Quarterly Reconciliations YYYY from <<File Path>>
  4. On the first tab (Jan-Dec YYYY), a summary of each quarter exists
    • The quarterly values are automatically pulled from the reconciled monthly values called Month YYYY at <<File Path>>
    • The summary contains data for each program
  5. Open the tab on the spreadsheet called “TRANS X Qtr”
    • This tab shows all transfer amounts in and out of the F/EA by hours, dollars and tax
    • Enter the transfer amount from the tab called “TRANS X Qtr” to the Transfer column on the Jan-Dec YYYY tab
  6. Enter the data from the quarterly Payroll Journal Summary Report
  7. Insert calculations to compare the quarterly Payroll Journal Summary Report from the payroll system to the calculations on the summary tab called (Jan-Dec YYYY)
  8. The amounts on the quarterly Payroll Journal Summary Report should match the quarter sums on the summary tab of the spreadsheet called (Jan-Dec YYYY)
  9. Any discrepancies must be researched and resolved
  10. A note is made in the green box at the bottom of the spreadsheet to outline any discrepancies and how they are resolved
  11. After resolving any discrepancies, print Quarterly Reconciliation document for the quarter
  12. Print the Transfers tab for the quarter
  13. Attach the quarterly Payroll Journal Summary report for the quarter
  14. Attach any supporting documents showing resolution of discrepancies
  15. <<Staff Title>> reviews reconciliation and supporting documents
  16. <<Staff Title>> signs and dates on the Prepared By: line
  17. <<Staff Title>> reviews reconciliation and supporting documents
  18. <<Staff Title>> signs and dates on the Approved By line
  19. Scan signed reconciliation and supporting documents to <<File Path>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Reconciliations are performed monthly using weekly reconciled data
  2. A control document is used to perform monthly reconciliation
    • <<Staff Title>> and <<Staff Title>> review monthly reconciliation
    • <<Staff Title>> and <<Staff Title>> sign and date monthly reconciliation
  3. Monthly reconciliation control document is scanned and stored for a minimum of 7 years per File Retention Policy
  4. A quarterly reconciliation is performed using aggregated monthly data
  5. A control document is used to perform quarterly reconciliation
    • <<Staff Title>> and <<Staff Title>> review quarterly reconciliation
    • <<Staff Title>> and <<Staff Title>> sign and date quarterly reconciliation
  6. Quarterly reconciliation control document is scanned and stored for a minimum of 7 years per File Retention Policy

Post Payroll Journal Entries to General Ledger

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Policy: 

On a weekly basis, Payroll Department produces journal entries for payroll expenses and liabilities. Payroll Department provides journal entries and supporting documents to F/EA Accountant. At month end, F/EA Accountant reviews each journal entry and supporting documents. The journal entry template is stored in: <<File Path>>. F/EA Accountant posts payroll expenses and liabilities to the General Ledger.   The F/EA Accountant signs and dates each journal entry and <<Staff Title>> authorizes by signing each journal entry. All journal entries are saved here: <<File Path>>

Procedure: 

Post Payroll Tax Liability to General Ledger

Performed Monthly
  1. On monthly basis, <<Staff Title>> produces Payroll Journal Summary report.
  2. F/EA Accountant or assigned staff reviews journal entry and supporting documents for completeness and mathematical accuracy.
  3. F/EA Accountant posts the Tax liability to the following General Ledger accounts.
    • Account # <<>> Employee Federal Income Tax withheld
    • Account # <<>> Employee and Employer FICA Tax
    • Account # <<>> Employee State Income Tax withheld
    • Account # <<>> Accrued State Unemployment Taxes
    • Account # <<>> Accrued Federal Unemployment Taxes
4.      All journal entry templates are scanned and saved here: <<File Path>>
5.      All journal entry templates are stored for a minimum of 7 years per File Retention Policy
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> produces journal summary report from reconciled data
  2. <<Staff Title>> signs and dates journal summary report
  3. F/EA Accountant reviews and verifies data prior to posting entries to General Ledger
  4. F/EA Accountant signs and dates journal entry after posting to General Ledger
  5. The <<Staff Title>> authorizes the entries by signing and dating the  payroll journal entries.
  6. All reconciliation templates are pre-numbered
  7. All signed and dated journal entry templates are stored for a minimum of 7 years per File Retention Policy

Pay Workers in Accordance with Overtime, Wage, Hour and Pay Day Rules

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Policy: 

Consumers' employees must be paid in accordance with applicable state and federal overtime and wage and hour rules and regulations and in accordance with state pay day rules.

Consumers' employees must be paid the prevailing minimum wage per hour, whether that be the state or federal minimum wage*.  Consumers' employees also must be paid at least an hourly rate of time and a half the workers's regular hourly rate of pay for any hours worked over 40*.

Consumers' employees also must be paid per state pay day rule.  A pay day rule states within how many days an workers who submits a satisfactory timesheet must be paid by his/her workers.  Consumers' employees are paid within applicable state pay day rules.

 

*This policy does not apply if the workers is working as a "companion" for the participant.  "Companions" may qualify to be exempted from Federal minimum wage and overtime rules per the Fair Labor Standards Act's Companionship Exemption. The companionship exemption may not be taken if a FLSA joint third party employer relationship exists--i.e., the state and/or the F/EA is considered a joint employer by the US Department of Labor.

Procedure: 

<<Insert information on how the F/EA complies with this policy.>>

Internal Controls: 

<<Insert internal controls.  Some suggested internal controls are listed below.>>

  1. F/EA's payroll system automatically calculates when a workers submits a timesheet with more than 40 hours per week on it.  The payroll system automatically flags the timesheet as eligible for overtime.
  2. F/EA's payroll system includes a system control that prevents any hourly pay rate to be paid if the rate is less than <<$X>>, the minimum wage.
  3. <<Staff Title>> reviews all unpaid timesheets on a weekly basis to ensure that all timesheets are paid per the state pay day rule, which requires employees to be paid within <<X>> days of submitting a satisfactory timesheet.

Process Payments for Goods & Services Vendors

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Policy: 

F/EA processes vendor payments on a bi-weekly basis when completed, valid payment request forms (PRFs) are received.

The payment request forms are distributed to all consumers when they join the program, in the Goods & Services Vendor Enrollment Package.  Consumers or vendors can request PRF’s by calling F/EA’s toll-free customer service line or the form can be accessed online. 

The PRF allows the participant to inform F/EA of what vendor is to be paid, in what amount and from what line in the participant’s budget to use allocated funds. 
 

Procedure: 
  1. Payment Request Forms are distributed to all consumers in the  program in their initial Goods & Services Vendor Enrollment Packages
  2. Consumers can print out more PRF’s from the F/EA website
  3. Consumers can call F/EA toll free line to request more forms by mail
  4. On at least a quarterly basis, F/EA should conduct a mail merge, sending out fresh, blank PRF’s to consumers 
  5. Once consumers receive notice from their counselor that their budget has been approved, they may begin to spend the funds from it (both on workers services and non-workers goods and services) 
  6. Consumers will complete a PRF for each non-workers good or service for which they wish to use their budget funds
  7. Even if the good or service will be regularly purchased on the participant’s behalf, a valid PRF for each pay period must be submitted for each payment to be made
  8. It is mandatory that each PRF be accompanied with a valid invoice for the good or service being purchased
  9. Consumers can fax or mail the PRF’s to the number or address on the form
  10. The payment schedule has a due date by which the PRF will need to be received in order for a check to be cut in that pay-cycle.
  11. If the PRF is received after the cut-off date that is specified on the payment schedule then it will be paid in the following check run
  12. Each pay period, appropriate staff alphabetize each PRF by the participant’s last name and then by vendor
  13. All PRF’s are date stamped as they are received
  14. Alphabetized, date stamped, accurately completed PRF’s with a valid invoice attached are placed in a “to-be-paid” folder
  15. The invoice is stapled behind the PRF
  16. If the PRF is not filled out completely or there is not an invoice attached, the PRF is placed in a separate folder
  17. The F/EA Customer Service team will follow up on all incomplete PRFs with the goal of resolving any issues so that payments can be made in the current check run
  18. Any unresolved issues will be processed in a future check run, after requirements have been met
  19. If applicable vendors are not already in the payment processing system, they must be added
  20. After entering the vendor into the system, the vendor ID is written on the form
  21. In the invoice processing location of the accounting system:
  22. Create a new line item for each PRF by filling in the participant field, vendor field, service code field and the payment amount
  23. There may be two errors that occur while following the above steps:
  24. The service code is not in the participant’s budget; or
  25. Sufficient funds do not exist in the budget line item to cover the invoice
  26. For any consumers with issues on their PRF, F/EA staff report the issue to the participant’s counselor
  27. The counselor and participant determine whether and how to adjust the budget to make the payment
  28. Any PRFs that cannot be processed are placed in a file folder of PRFs with issues
  29. On the check run date, checks are cut and mailed to each vendor for which PRF’s were processed
  30. Consumers and their counselors receive spending reports on a monthly basis, so that they can see what they have spent and what they have left to spend out of their budgets. 
     

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Insert internal controls depending on process>>
  2. F/EA Payroll Department reconciles payroll account to ensure that accurate payments are debited from the account
  3. Chief Financial Officer is one of two signatories on the program bank account
    • F/EA maintains Chief Financial Officer signature block for checks in a password protected, secure location
    • Only authorized staff have access to Chief Financial Officer signature block
  4. On a quarterly basis Quality Assurance Coordinator contacts a random sample of 25 workers/vendors to inquire if they regularly received a remittance advice with their payments
    • F/EA Quality Assurance Coordinator completes a findings control document and submits to <<Staff Title>> for review and signature
    • Corrective action plan developed and implemented based on findings

Withhold Taxes from Employee Pay and Calculate Employer's Taxes

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Policy: 

When the F/EA pays consumers' employees, certain taxes are withheld from each employee's paycheck.

For those employees who are not FICA exempt (see Collecting, Recording and Processing Information for Family Employer and Employee Tax Exemptions), Social Security and Medicare taxes are withheld from employee pay up to the Social Security Contribution and Benefit Base.  Social Security Tax is withheld from employee gross wages at a rate of 6.2%.  Medicare Tax is withheld from employee gross wages at a rate of 1.45%.  The combination of Social Security Tax and Medicare Tax is called "FICA", so the total FICA amount withheld from an employee's paycheck is 7.65%.

The employer also owes FICA taxes on employee wages.  For Social Security and Medicare taxable wages paid to an employee,, the employee's employer owes 7.65% of the wages.  The employer and the employee share of FICA are both deposited to the IRS by the employer (see IRS Form 941: Employer's Quarterly Federal Tax Return and Payments).

Federal Income Tax should be withheld from employee pay.  The amount withheld will depend on what the employee has recorded on their IRS Form W-4 and what the employee's tax rate is, based on their income bracket (see page 39 of Publication 15, Circular E).

In most states, State Income Tax must be withheld from employee pay.  The rate of state income tax withheld depends on state requirements.

State Unemployment Tax is required in all states and usually paid in whole by the employer.  State Unemployment Tax exemption and liability rules usually mirror FUTA rules, but this varies by state.  In some states, employees may be responsible for a portion of State Unemployment Tax or disability insurance tax.  In those states, the employee tax should be withheld from employee pay per state rules.

For those employees who are not exempt from Federal Unemployment Tax (FUTA) (see Collecting, Recording and Processing Information for Family Employer and Employee Tax Exemptions) AND whose employers are liable for FUTA tax*, the employer FUTA tax must be calculated and eventually paid on gross wages paid to an employee up to the FUTA Taxable Wage base.  If State Unemployment Tax is paid timely and in full by the employer, then the FUTA tax owed is .6% of FUTA taxable wages, except if a FUTA credit reduction is in effect in F/EA's state of operations for that calendar year.  If State Unemployment Tax is NOT paid timely or in full, then the FUTA tax rate is 6% of FUTA taxable wages.

The F/EA ensures that all employee taxes are appropriately withheld and that all employer taxes are appropriately calculated so that all taxes can also be correctly paid and filed.

*Employers are liable for FUTA tax if they have paid $1000 or more in gross wages in a single calendar quarter.  It doesn't matter how many employees the employer pays; all that matters is if the employer has ever paid $1000 of wages out in a single quarter. If they have, that employer is liable for FUTA on wages paid to his/her employees.

Procedure: 
  1. The F/EA's payroll system is programmed with the most current tax withholding tables to ensure that taxes are correctly withheld and calculated for every employee paycheck processed.
  2. <<Insert information on how and when tax tables in payroll system are updated.>>
  3. <<Insert information on how individual employer tax rate information (e.g. for State Unemployment Tax) is stored in the payroll system for each employer and how that calculates the taxes owed.
Internal Controls: 
  1. <<Insert how tax tables are kept up to date>>
  2. <<Insert how payroll system is periodically tested to ensure that tax calculations are operating correctly.>>
  3. <<Insert any other information on how paycheck withholings are quality checked or any other information on payroll system controls.>>

Pay and File Taxes on Behalf of Consumers

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IRS Form 941: Employer's Quarterly Federal Tax Return and Payments

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Policy: 

In accordance with Section 3504 of the Internal Revenue Code, Revenue Procedure 70-6 and Proposed Regulations REG-137036-08 (January 13, 2010) and Revenue Procedure 2013-39, F/EA files Form 941 quarterly in aggregate, on behalf of all participants in the Program. F/EA uses its separate agent Employer Identification Number (EIN) to file Form 941 and to deposit workers Federal Withholding Tax, workers FICA and employer FICA. Federal Withholding Tax and employee and employer FICA are deposited by the F/EA with the IRS on within 24 business hours of each payroll. 

As applicable, F/EA submits Schedule B for Form 941 with Form 941.  Schedule B shows F/EA liability if F/EA deposits more often than monthly per deposit requirements.  Deposit requirements are determined based on F/EA aggregate liability, not on individual employer liability.  Most F/EAs must deposit more often than monthly and therefore must submit Schedule B for Form 941 with Form 941.
 
F/EA must submit Schedule R for Form 941 with Form 941 .
 
F/EA utilizes reconciliation processes to ensure 941 taxes are paid accurately, timely and in accordance with existing regulation. On a monthly basis, F/EA reconciles 941 payments to debits for 941 payments from Program Operating Account (See Reconciliation of General Ledger Liability Account for FICA and Reconciliation of General Ledger Liability Account for Federal Withholding Tax). Quarterly, F/EA Accountant ensures sum of quarterly debits from Program Operating Account for 941 payments matches payments reported on Form 941.
 
Documentation showing payments of FICA and Federal Withholding Tax made on behalf of consumers is made available to Program Administrator and consumers upon request.
Procedure: 
  1. F/EA makes 941 deposit on each day payroll checks are cut with a check date for that day
  2. 941 deposit includes FICA (Social Security and Medicare tax) withheld from workers pay, FICA (Social Security and Medicare tax)  paid by the employer on workers pay and Federal Income Tax withheld from workers pay
  3. F/EA makes all deposits using IRS online payment system, EFTPS.gov.
  4. On a weekly basis, <<Staff Title>> produces and prints a report called the EFTPS Batch Provider Payment Inquiry.  This report shows all deposits made for the F/EA's separate FEIN for the prior week.
  • The EFTPS Batch Provider Payment Inquiry shows each 941 deposit made on behalf of F/EA, the date the deposit was made and the settlement date
 5.  <<Staff Title>> reviews EFTPS Batch Provider Payment Inquiry and compares it to the week's Payroll Registers to ensure that the report accurately reflects 941 liabilities for the week.
 6.  Any discrepancies are researched and resolved.
 7.  After resolving any discrepancies, EFTPS Batch Provider Payment Inquiry is provided to F/EA Accountant.
 8.  Upon receiving EFTPS Batch Provider Payment Inquiry, F/EA Accountant logs into Bank website
 9.  Verify that a payment for the amount listed on the EFTPS Batch Provider Payment Inquiry was made from the bank account
10. Ensure the payment date shown by Bank matches Settlement Date on EFTPS Batch Provider Payment Inquiry
11. F/EA Accountant writes on EFTPS Batch Provider Payment Inquiry: “verified with bank on <<date>>” and initials
12. These weekly breakdowns are stored in F/EA Accountant’s applicable file until quarter end
13. At quarter end, <<Staff Title> produces a quarterly payroll summary of 941 payment from the EFTPS website.  This report is called EFTPS Batch Provider Payment Inquiry Report
14. Form 941 is completed per attached example.
15. F/EA Accountant verifies Form 941 to ensure that Payroll Department accurately reported wages paid, federal withholding tax and employer and workers FICA
16. Reconcile payments
17. Sum all payments made for FICA from Worker F/EA Payroll Account found here: <<File Path>> Payroll download
18. Locate spreadsheet for each of the three months in the quarter
19. Sort by transaction and description
20. Sub total ‘Amount’ by transaction
  • This provides subtotals of payments for each tax type

21. Subtotals with description “IRS USATAXPYMT” are weekly Federal Income Tax, and Employer and Employee FICA payments

22. Add the subtotals with description “IRS USATAXPYMT” for each month in the quarter

23. This creates monthly totals of payments

24. Compare this to the liability amounts on Schedule B to ensure that payments for each month are equal to or greater than liabilities

  • Voids may cause payments to be greater than liabilities in a month
  • If a payment in a previous month is greater than a liability, the liability in a later month can be greater than the payments for that month by the exact amount that was overpaid in a previous month

25. Complete lines 17, 18 and 19 on Quarterly Reconciliation Document

26. Compare the liability on each date on Form 941 Schedule B to the amount for each “Settlement Date” on the EFTPS Batch Provider Inquiry

27. Ensure that the amount on Form 941 Schedule B is less than or equal to the amount on the EFTPS Batch Provider Inquiry for the settlement date

28. Ensure that the settlement date and the date on Schedule B match in each case

  • Report any discrepancies to reporting agent
  • Reporting agent will file form 941-X as necessary

29. Compare the sum of payments for all three months from bank account to “Total liability for the quarter” on schedule B

30. Ensure sum of payments is greater than or equal to “Total liability for the quarter” on Schedule B
31. Compare the sum of payments for the quarter as debited from the bank account to Line 11 on Form 941

32. If a discrepancy exists, review prior quarter’s 941 Box 13 to see if an overpayment was made

33. Ensure that the discrepancy equals the difference between Line 11 941 and sum of debits from bank account


34. Compare Schedule B 941 Deposits to debits from bank account

35. Ensure all values on dates match

36. Ensure monthly totals match

37. <<Staff Title>> reviews Form 941, Schedules B and R and all supporting documents.
 
38. After <<Staff Title>> signs off on Form 941, mail Form 941 to applicable IRS office via UPS
 
39. Obtain UPS Tracking number
 
40. Enter date shipped on Quarterly Tax Reconciliation document
  • Quarter 1 is due by April 30
  • Quarter 2 is due by July 31
  • Quarter 3 is due by October 31
  • Quarter 4 is due by January 31

41. <<Staff Title>> scans all documents and stores them at <<File Path>>

42. Signed reconciliation sheets are stored for a minimum of 7 years.


 
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. On a monthly basis, F/EA independently reconciles 941 payments to debits for 941 payments from Program Operating Account.
    • This ensures that payments are reconciled monthly prior to being reconciled again when the quarterly return is filed with the IRS
  2. The F/EA Accountant performs the quarterly 941 and payment reconciliation
    • The F/EA Accountant verifies the supporting documents, the bank statement and 941 return for accuracy
    • The F/EA Accountant enters all transactions on a control document, the Quarterly Tax Reconciliation sheet. This sheet is pre-numbered.
    • After performing the reconciliation, the F/EA Accountant signs and dates the control document.
  3. The <<Staff Title>> reviews the reconciliation statement and the supporting documents for accuracy
    • The <<Staff Title>> verifies not only completeness, but also validity.
    • The <<Staff Title>> reviews all documents for mathematical accuracy.
    • After reviewing, the <<Staff Title>> Signs and dates the reconciliation sheet.
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for reconciliations.
  5. The reconciliation and supporting documents are scanned and saved for a minimum of 7 years per the File Retention Policy.

Producing F/EA Schedule B for Form 941

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Policy: 

<<Insert policy for completing Schedule B of Form 941>>

Procedure: 

<<Insert procedure for completing Schedule B of Form 941>>

Internal Controls: 

<<Insert internal controls for completing Schedule B of Form 941>>

Producing F/EA Schedule R for Form 941

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Policy: 

F/EAs must file Schedule R with their Forms 941. Vendor Fiscal/Employer Agents that operate in Self-Directed (also known as Participant-Directed and Consumer-Directed) programs operate under Section 3504 of the Internal Revenue Code and must file a Schedule R with their aggregate Form 941.

Schedule R (Form 941) is used to allocate the aggregate information reported on Form 941 to each participant employer.  For purposes of Schedule R (Form 941), the Internal Revenue Service refers to employers represented by agents as their 'clients'.  

When the F/EA serves 15 or more employer clients, complete as many Continuation Sheets for Schedule R as necessary.  Attached Schedule R (Form 941) and any Continuation Sheets to the aggregate Form 941.  F/EA should file Schedule R and Form 941 together with the Internal Revenue Service.

Schedule R is due with Form 941 for each quarter that an agent files an aggregate Form 941, beginning with Quarter 1, 2010.

Procedure: 

<<Insert procedure to produce Schedule R for Form 941>>

Internal Controls: 

<<Insert internal controls to produce Schedule R for Form 941>>

State Unemployment Tax Returns and Payments

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Policy: 

In accordance with State regulation, consumers must file and pay State Unemployment Tax, as calculated on workers gross wages, individually using the individual participant’s account number designated for this purpose.  Payments and returns are made and filed per regulation on a quarterly basis.

Each participant employer has his/her own experience rate for State Unemployment Tax.  This means that each individual employer may pay a different tax rate for State Unemployment Tax.  In most states, new employers are designated a standard "New Employer Rate".  New employers usually maintain the "New Employer Rate" for some uniform time period.

Each state maintains a taxable wage base.  The taxable wage base is the amount of gross wages paid to an workers in a calendar year that are taxable for State Unemployment Purposes.  Any wages paid to the workers in excess of the taxable wage base are considered "Excess Wages" and are not taxable for State Unemployment Purposes.

 
F/EA utilizes the employer tax cost allocation in the participant's budget to pay State Unemployment Tax.
 
F/EA utilizes a reconciliation process to ensure that payments are made and returns filed on behalf of consumers accurately, timely and in accordance with existing regulation. This reconciliation is performed by the F/EA Accountant quarterly.
 
On a quarterly basis, F/EA Quality Assurance Administrator audits filings and deposits for State Unemployment Insurance. Quality Assurance Administrator collects a random sample of payments and compares payments rates and thresholds on report to payroll edit registers and rate notices.
 
Additional policies, for each portion of the process, are presented below prior to the procedure outlined for each process.
 
Documentation showing payments of State Unemployment Tax made on behalf of consumers is made available to Program Administrator and consumers upon request.
Procedure: 

Filing and Payment

  1.  At quarter end, <<Staff Title>> within Payroll Department uses Payroll System to produce State Unemployment Tax report for each employer
  2. Each report shows <<insert per state requirements>>:
  • Employer gross wages paid in the quarter
  • Employer Unemployment Tax Rate
  • Taxable wages
  • Excess wages
  • Unemployment tax liability
  • Employee name and Social Security Numbers paid this quarter
  • Gross wages by workers
  • Taxable wages by workers
  • Excess wages by workers
  1. Using Payroll System, <<Staff Title>> produces payments to accompany State Unemployment Tax reports <<payments may be paper checks or an Electronic Funds Transfer file>>
  2. <<Staff Title>> selects sample of 10% of employers represented by agent for the quarter
  3. <<Staff Title>> selects Unemployment Insurance Tax reports and corresponding payments for 10% of participants for quality check
  4. <<Insert process used to Quality Check data>>
  5. After reports and payments have successfully passed the Quality Check process, <<Staff Title>> submits reports and payments to State Department of Labor
  6. <<Insert process to submit reports and payments.  May be electronic or on paper.  Process will vary depending on state.>>

Reconciliation of Unemployment Return and Payment

On a quarterly basis, within 30 days of the unemployment return and payment due date (30 days to allow time for payments to clear the bank), the F/EA Accountant reconciles unemployment returns to debits from the program operating bank account. F/EA performs a quarterly audit of returns and payments to ensure that the payroll system is accurately producing unemployment reporting and payment data, including filing state unemployment in accordance with each employer’s unemployment insurance rate, wages and wage base threshold.
  1. Each quarter F/EA sends a Transmittal Report for e-filing showing the employer, state ID, State Unemployment tax payment, total wages, excess wages, taxable wages, tax rate, Federal ID and monthly workers counts
  2. F/EA Accountant collects Transmittal Report and copy of Division of Unemployment Assistance check from applicable file folder
  3. F/EA Accountant opens spreadsheet called Quarterly Tax Reconciliation CYYY saved at <<File Path>>
    1. Open the tab labeled for SUTA and the quarter in question
    2. Complete the Quarterly Tax Reconciliation by entering values next to the labels using the <<Transmittal Report>> and payments to State Department of Labor
  4. Compare the sum of payments on the <<Transmittal Report>> to the amounts debited for State Unemployment Tax from program operating account <<insert detail>>
  5. Identify any discrepancies
  6. Any discrepancies must be researched and resolved
  7. Report discrepancies to Payroll Department as applicable
  8. Payroll Department will file amended returns as applicable
  9. If no discrepancies identified, F/EA Accountant prints Quarterly Tax Reconciliation document
  10. F/EA Accountant signs and dates Quarterly Tax Reconciliation document next to “Prepared By”
  11. F/EA Accountant provides Quarterly Tax Reconciliation document and supporting documents to <<Staff Title>>
  12. <<Staff Title>> signs and dates Quarterly Tax Reconciliation document next to “Verified By”
  1. <<Staff Title>> scans all documents and stores them at <<File Path>> 
  2. Signed reconciliation sheets are stored for a minimum of 7 years.
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. On a monthly basis, F/EA reconciles State Unemployment Insurance (SUTA) payments to debits for such payments from Program Operating Account (See Reconciliation of General Ledger Liability Account for Unemployment Tax)
    • This verifies that payments are actually made
  2. Payroll Department submits a UPS shipping receipt showing the date the paper returns and payments are mailed to State Department of Labor
    • F/EA Accountant reviews UPS shipping receipt to ensure that paper returns are mailed on or before due date
  3. Payroll Department submits a transmittal receipt showing the date the electronic returns are submitted to State Department of Labor
    • F/EA Accountant reviews transmittal receipt to ensure that paper returns are mailed on or before due date
  4. The F/EA Accountant performs the quarterly SUTA return and payment reconciliation
    • The F/EA Accountant compares values on relevant documents for accuracy
    • The F/EA Accountant enters all transactions on a control document, the Quarterly Tax Reconciliation sheet. This sheet is prenumbered.
    • After performing the reconciliation, the F/EA Accountant signs and dates the control document.
  5. The <<Staff Title>> reviews the reconciliation statement and the supporting documents for accuracy
    • The <<Staff Title>> verifies not only completeness, but also validity.
    • The <<Staff Title>> reviews all documents for mathematical accuracy.
    • After reviewing, the <<Staff Title>> signs and dates the control document, the reconciliation sheet.
  6. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for reconciliations.
  7. The reconciliation and supporting documents are scanned and saved for a minimum of 7 years per the File Retention Policy.

State Withholding Tax Returns and Payments

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Policy: 

Per the contract with Program Administrator, F/EA must file and remit State Withholding Tax (SWT) withheld from consumers’ workers on behalf of consumers. The State Department of Revenue requires returns to be filed and payments to be remitted individually using the participant’s individual account number designated for this purpose. Payments of State Withholding Tax withheld from workers pay must be made per each employer’s required deposit schedule. The deposit schedule is set by the State Department of Revenue or equivalent based on the employer’s quarterly liability.

F/EA utilizes a reconciliation process to ensure that the reporting agent is making payments and filing returns on behalf of consumers accurately, timely and in accordance with existing regulation. This reconciliation is performed by the F/EA Accountant and <<Staff Title>> (or assigned staff) quarterly, within 10 days of the reporting agent completing the quarterly filing and payment.
 
Documentation showing payments of State Withholding Tax made on behalf of consumers is made available to Program Administrator and consumers upon request.
 
Additional policies, as they apply to each portion of the process, are stated below prior to each procedure.
Procedure: 

Reconciliation of State Withholding Tax Return and Payment

The reporting agent deposits withheld State Withholding Tax on behalf of employers per each employer’s individual deposit schedule. Payments may be made on behalf of an employer weekly, monthly or quarterly. 
 
On a quarterly basis, the reporting agent files returns for State Withholding Tax to the State Department of Revenue or equivalent on behalf of individual consumers. Returns are filed quarterly regardless of the participant’s deposit schedule. Within 10 days of the State Withholding Tax return due date, the F/EA Accountant reconciles reports and payments made by the reporting agent (see process below). On a quarterly basis within 30 days of the quarterly State Withholding Tax deposit due date (30 days to allow time for payments to clear the bank), the F/EA Accountant reconciles State Withholding Tax returns as provided by the Payroll Department to debits from the service funds bank account for State Withholding Tax (See Policy and Procedure <<X>>). The combination of these two reconciliations serve for F/EA to ensure that State Withholding Tax returns and payments are made timely and that payment have been made in accordance with each return. F/EA performs a quarterly audit of returns and payments to ensure that the reporting agent is accurately paying and filing State Withholding Tax in accordance with each participant’s wages and deposit schedule and employees’ allowances.
  1. Payroll Staff sends State EFT – ACH Transaction Audit report with each deposit, whether it be weekly, monthly or quarterly
  2. F/EA Accountant stores these reports until quarter end
  3. Quarterly, F/EA Accountant collects all State EFT –ACH Transaction Audit reports and F/EA Payroll Journal Summary report for the quarter
    • Note that prior to being used for reconciliation to State Withholding data, F/EA Payroll Journal Summary is reconciled to Payroll System Register and sum of weekly F/EA Payroll Journal reports (see Policy and Procedure <<X>>)
  4. F/EA Accountant reconciles sum of deposits from State EFT – ACH Transaction Audit report to F/EA Payroll Journal Summary report
  5. F/EA Accountant opens spreadsheet called Quarterly Tax Reconciliation CYYY saved at <<File Path>>
  6. For each State EFT – ACH Transaction audit report, enter the date paid and the total amount paid under State EFT – ACH Transaction Report on line 1 through 24 of Quarterly Tax Reconciliation
  • The amount paid for each Transaction Audit Report will automatically total on line 25
  • On line 25 under Amount on F/EA Payroll Journal Summary Report enter the total State Withholding Tax

  7.  Reporting Agent also sends an excel report called F/EA DOR Payment Reconciliation quarterly

  • This shows quarterly payments, monthly payments, weekly payments vs. the liability for each employer
  • This report also shows the difference between payments and liability

  8.  As an additional verification, F/EA DOR Payment Reconciliation quarterly is compared to F/EA Payroll Journal reports for the quarter

  • A variance may occur because participant transferred to another F/EA mid-quarter and all liabilities for that participant are shown on the F/EA DOR Payment Reconciliation report

  9.  Obtain UPS Tracking number used to ship paper returns for employers who became liable for state withholding tax this quarter to DOR from reporting agent

10.  Go to www.ups.com , enter tracking number

11.  Verify that shipment date for DOR shipment occurred on or before the Return Due Date

12.  Enter date shipped on Quarterly Tax Reconciliation document

  • Quarter 1 is due by April 30
  • Quarter 2 is due by July 31
  • Quarter 3 is due by October 31
  • Quarter 4 is due by January 31

13.  Obtain receipt from electronic transmittal of state withholding tax returns from reporting agent

14.  Verify that the transmittal date occurred on or before the Return Due Date

15.  Enter transmittal date on Quarterly Tax Reconciliation document

  • Quarter 1 is due by April 30
  • Quarter 2 is due by July 31
  • Quarter 3 is due by October 31
  • Quarter 4 is due by January 31

16.  F/EA Accountant reviews variance and accounts for transfers

17.  Any discrepancies are identified and resolved

18.  Adjustments are made as required on the F/EA DOR Payment Reconciliation

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. On a monthly basis, F/EA reconciles State Withholding Tax payments made by reporting agent to debits for such payments from Service Funds F/EA Operating Account (See Policy and Procedure <<X>>)
    • This ensures that payments that the reporting agent reports as making are actually made
  2. The reporting agent submits a UPS shipping receipt showing the date the paper returns and payments are mailed to DOR
    • F/EA Accountant reviews UPS shipping receipt to ensure that paper returns are mailed on or before due date
  3. The reporting agent submits a transmittal receipt showing the date the electronic returns are submitted to DOR
  4. The F/EA Accountant performs the quarterly State Withholding Tax return and payment reconciliation
    • The F/EA Accountant verifies compares values on relevant documents for accuracy
    • The F/EA Accountant enters all transactions on a control document, the Quarterly Tax Reconciliation sheet. This sheet is prenumbered.
    • After performing the reconciliation, the F/EA Accountant signs and dates the control document.
  5. The <<Staff Title>> reviews the reconciliation statement and the supporting documents for accuracy
    • The <<Staff Title>> verifies not only completeness, but also validity.
    • The <<Staff Title>> reviews all documents for mathematical accuracy.
    • After reviewing, the <<Staff Title>> signs and dates the control document, the reconciliation sheet.
  6. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for reconciliations.
  7. The reconciliation and supporting documents are scanned and saved for a minimum of 7 years per the File Retention Policy.
 

IRS Form 940: Employer's Annual Federal Unemployment (FUTA) Tax Return and Payment

Policy: 

In accordance with Section 3504 of the Internal Revenue Code, Revenue Procedure 70-6 as modified by Proposed regulations REG-137036-08-1 and in accordance with Revenue Procedure 2013-39, F/EA Files Form 940 annually and in aggregate on behalf of all consumers in the participant direction program. F/EA uses their separate agent Employer Identification Number (EIN) to file Form 940.  Per IRS regulation, F/EA deposits employer Federal Unemployment Tax quarterly on behalf of all consumers. 

F/EA Accountant utilizes reconciliation processes to ensure that the Payroll Department filed and paid estimated, quarterly 940 taxes accurately, timely and in accordance with existing regulation. On a monthly basis, F/EA reconciles 940 reports to debits for 940 payments from Program Operating Account.
 
Documentation showing payments of Federal Unemployment Tax made on behalf of consumers is made available to Program Administrator and consumers upon request.


 
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Procedure: 

Reconcile and Verify 940, Employer’s Annual Federal Unemployment (FUTA) Tax Return, Payment

Performed Quarterly
 
Federal Unemployment Tax (FUTA) payments are made quarterly by the Payroll Department. F/EA Accountant (or assigned staff) verifies that payments were made timely and accurately using the below process.
 
  1.  Per IRS Guidance, the Payroll Department makes one aggregate payment per quarter for Federal Unemployment Tax on behalf of all consumers represented by F/EA
  2. <<Insert Process Used to determine estimate FUTA deposit amounts by employer and then deposit FUTA in aggregate using the F/EA's separate FEIN).
  3. A breakdown of the quarterly payment, the EFTPS Batch Provider Payment Inquiry, is submitted to F/EA Accountant by the Payroll Department after payment to IRS is completed
  4. F/EA Accountant (or assigned staff) collects EFTPS Batch Provider Payment Inquiry
  5. Open “Quarterly Tax Reconciliation” saved at <<File Path>>
  6. Complete the Quarterly Tax Reconciliation by entering values next to the labels for each document
  7.  Insert FUTA liability amount from Payroll Department Report
  8.  Enter amount on Line 1 of Quarterly Reconciliation document
  9. Review payment amount on EFTPS Batch Provider Payment Inquiry
  10. Enter amount on Line 1 of Quarterly Reconciliation document
  11. Review “Settlement Date” on EFTPS Payment Batch Inquiry
  12. Verify that “Settlement Date” for 940 Payment occurred on or before the 940 Payment Due Date
  13. Enter Settlement Date on Quarterly Tax Reconciliation document
  • Quarter 1 is due by April 30
  • Quarter 2 is due by July 31
  • Quarter 3 is due by October 31
  • Quarter 4 is due by January 31

 14.  Review the “Variance” column of the Quarterly Tax Reconciliation document

  • Any value greater than or less than “0” in the “Variance” column indicates discrepancy
  • Any discrepancies must be researched and resolved
  • Report discrepancies to reporting agent as applicable
  • Payroll Department will make a supplemental payment or adjust an overpayment as necessary

 15.  If no discrepancies identified, F/EA Accountant prints Quarterly Tax Reconciliation document

 16.  F/EA Accountant signs and dates Quarterly Tax Reconciliation document next to “Prepared By” 

 17.  F/EA Accountant provides Quarterly Tax Reconciliation document and supporting documents to <<Staff Title>>

 18.  <<Staff Title>> signs and dates Quarterly Tax Reconciliation document next to “Verified By”

 19.  <<Staff Title>> scans all documents and stores them at <<File Path>>

 20.  Signed reconciliation sheets are stored for a minimum of 7 years.

 
Reconcile and Verify 940, Employer’s Annual Federal Unemployment (FUTA) Tax Return, Payment
Performed Annually
 
Per IRS Regulation, Form 940, Employer’s Annual Federal Unemployment (FUTA) Tax Return, is filed annually and in aggregate on behalf of all consumers represented by F/EA. Annually when Form 940 is filed with the IRS by the reporting agent, F/EA Accountant verifies form 940 for accuracy and to ensure it was filed timely.
 
  1. <<Insert process to collect applicable payroll data and complete Form 940 per Sample>>     
  2. At year-end, form 940 is compared to FUTA payments and liabilities for the calendar year  <<Insert process to verify and reconcile Form 940>>
  3. Review the “Variance” column of the Quarterly Tax Reconciliation document
  • Any value greater than or less than “0” in the “Variance” column indicates discrepancy
  • Any discrepancies must be researched and resolved
  • Report discrepancies to Payroll Department as applicable
  • Payroll Department files Form 940C as necessary

  4.  Obtain UPS Tracking number used to ship Form 940 to IRS from Payroll Department

  5.  Go to www.ups.com , enter tracking number

  6.  Verify that shipment date for 940 shipment occurred on or before the 940 Due Date

  7.  Enter date shipped on Quarterly Tax Reconciliation document

  • Form 940 is due by January 31

  8.  If no discrepancies identified, F/EA Accountant prints Quarterly Tax Reconciliation document

  9.  F/EA Accountant signs and dates Quarterly Tax Reconciliation document next to “Prepared By”

10.  F/EA Accountant provides Quarterly Tax Reconciliation document and supporting documents to <<Staff Title>>

11.  <<Staff Title>> signs and dates Quarterly Tax Reconciliation document next to “Verified By”

12.  <<Staff Title>> scans all documents and stores them at <<File Path>>

13.  Signed reconciliation sheets are stored for a minimum of 7 years.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. On a quarterly basis, F/EA reconciles 940 payments to EFTPS Batch Provider Payment Inquiry
    • This ensures that payments are reconciled quarterly prior to being reconciled again when the annual return is filed with the IRS
  2. Quarterly, 940 payments are reconciled as part of the standard bank reconciliation process
  3. The F/EA Accountant performs the quarterly 940 payment reconciliation
    • The F/EA Accountant verifies the supporting documents, the bank statement and 940 return for accuracy
    • The F/EA Accountant enters all transactions on a control document, the Quarterly Tax Reconciliation sheet. This sheet is prenumbered.
    • After performing the reconciliation, the F/EA Accountant signs and dates the control document.
  4. The F/EA Accountant performs the annual 940 return reconciliation
    • The F/EA Accountant verifies the supporting documents, the bank statement and 940 return for accuracy
    • The F/EA Accountant enters all transactions on a control document, the Quarterly Tax Reconciliation sheet. This sheet is prenumbered.
    • After performing the reconciliation, the F/EA Accountant signs and dates the control document.
  5. The <<Staff Title>> reviews the reconciliation statement and the supporting documents, the bank statement and 940 return for accuracy
    • The <<Staff Title>> verifies not only completeness, but also validity.
    • The <<Staff Title>> reviews all documents for mathematical accuracy.
    • After reviewing, the <<Staff Title>> signs and dates the control document, the reconciliation sheet.
  6. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for reconciliations.
  7. The reconciliation and supporting documents are scanned and saved for a minimum of 7 years per the File Retention Policy.
Policy and Procedures: 
FUTA
940
form 940

Non-Resident Tax Returns and Payments

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Policy: 

When consumers employ workers who live in a state other than the state the participant lives in, "non-resident" workers state income and state unemployment taxes must be managed.  Each state has different rules and regulations for how non-resident taxes must be handled.  Some states have reciprocal agreements with other border states.  If two states have a reciprocal agreement and an individual lives in one of those states and works in the other, the individual will only be subject to the income tax in the state where he lives. All states with reciprocal agreements have provisions that exempt an workers from having the tax withheld for the state where he works, but employers are not required to withhold the tax for the state where the workers lives.

The F/EA manages non-resident tax responsibilites on behalf of any participant employers who have employees who live in a state other than the participant's state of residence.

Procedure: 
  1. <<insert the procedure for determining an workers's state of residence.>>
  2. <<Insert the procedure for determining if an workers is non-resident.>>
  3. <<Insert the procedure for managing non-resident workers taxes.>>
Internal Controls: 
  1. <<Insert internal controls for ensuring that non-resident employees are identified.>>
  2. <<Insert internal controls for ensuring that non-resident workers taxes are appropriately filed and paid.>>

Producing F/EA Schedule R for Form 940

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Policy: 

F/EAs must file Schedule R with their Forms 940. Vendor Fiscal/Employer Agents that operate in Self-Directed (also known as Participant-Directed and Consumer-Directed) programs operate under Section 3504 of the Internal Revenue Code and must file a Schedule R with their aggregate Form 940.

Schedule R (Form 940) is used to allocate the aggregate information reported on Form 940 to each participant employer.  For purposes of Schedule R (Form 940), the Internal Revenue Service refers to employers represented by agents as their 'clients'.  

When the F/EA serves 15 or more employer clients, complete as many Continuation Sheets for Schedule R as necessary.  Attached Schedule R (Form 940) and any Continuation Sheets to the aggregate Form 940. F/EA should file Schedule R and Form 940 together with the Internal Revenue Service. 

Year-End Tasks

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Issue Forms W-2

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Policy: 

By January 31 of each calendar year, F/EA submits Forms W-2 to consumers’ employees for wages earned in the previous calendar year. A employee receives an individual form W-2 for each employer for whom they work, as a distinct employer/employee relationship exists for each employer/employee relationship. 

Forms W-2 are produced per Internal Revenue Code Section 3504, Revenue Procedure 70-6 and Revenue Procedure 2013-39. Each Form W-2 shows Federal and State taxable wages earned in the calendar year by the employee from the employer.

By March 31 of each calendar year, F/EA or the reporting agent submits Forms W-2 to the Social Security Administration electronically per specifications published by the Social Security Administration in Publication EFW2, Specifications for Filing Forms W-2 Electronically. Forms W-2 are submitted to State Department of Revenue by <<March 31>> of each calendar year per <<State>> Electronic W-2 specifications (<<or via paper, depending on the state process>>.
 
<<Three times annually (see Policy and Procedure document 3.5), F/EA submits Change Request Forms to consumers to collect updated contact information for workers. This information is important for completion of year-end responsibilities to ensure that employees receive forms W-2 and that those who qualify receive any FICA refund checks>>.
 
A reconciliation of Forms W-2 is performed using  separate processes as outlined in separate Policy and Procedure documents:
 
  1. Reconciliation of FICA and FIT Returns (941) and Payments, performed quarterly
  2. Reconciliation of FICA, FIT and SIT payment to General Ledger, performed monthly
  3. Reconciliation of W-2 report to Forms 941 for calendar year, performed annually (see Policy and Procedure document <<X>>).
 
Procedure: 

 

  1. Prior to December 31 of each calendar year, F/EA staff update workers address information per received Change Request Forms.  Address updates are made in the Payroll System for each affected workers.
  2. F/EA balances and reconciles Form W-2 reports to State Withholding Tax returns and Forms 941
  3. <<Insert process to do this>>
  4. <<Control Sheets are used for reconcilations>>
  5. <<Insert who reviews and signs off on control sheets before Forms W-2 are mailed to workers>>
  6. Prior to January 31 of each calendar year, F/EA mails Forms W-2 to each workers to whom wages were paid as part of the program in the preceding calendar year
  7. Forms W-2 are populated as follows (with applicable tax and wage information for each workers)
  8. After mailing forms W-2 to consumers, <<Payroll Staff Title>>  e-mails <<Customer Service Staff Title>> to notify that Forms W-2 have been mailed to consumers
  • Customer Service Unit staff are notified because workers and consumers may begin calling with questions about Forms W-2

  9.  Prior to March 31, F/EA submits an electronic file of Forms W-2 to the Social Security Administration via their Business Services Online portal

  10.  A file of electronic Forms W-2 is produced per Social Security Administration publication EFW2

  11.  The file is uploaded to the Social Security Administration

  12.  After uploading the file, the F/EA receives a Transmittal Confirmation receipt

  13.  <<Staff Title>> saves Transmittal Receipt confirmation to <<File Path>>

  14.  Transmittal Receipt confirmation is saved for a minimum of 7 years per File Retention Policy

  15.  Also prior to March 31, reporting agent submits an electronic file of Forms W-2 to the State Department of Revenue in the required format

  16.  After submitting the file, a Transmittal Confirmation receipt is received

  17.  <<Staff Title>> saves Transmittal Receipt confirmation to <<File Path>>

  18.  Transmittal Receipt confirmation is saved for a minimum of 7 years per File Retention Policy

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification. The methods of internal control utilized by F/EA in are:

  1. Separate reconciliations are performed throughout the year to ensure that values reported on Forms W-2 are correct.
  2. Pre-numbered Control Sheets are used to perform W-2 Reconciliation processes prior to issuing Forms W-2 to workers.
  3. Prior to mailing Forms W-2, <<Staff Title>> and <<Staff Title>> review, sign and date Control Sheets.
  4. Control Sheets are stored for a minimum of 7 years per File Retention Policy.
  5. Transmittal Confirmation receipts for electronic files of Forms W-2 submitted to the IRS/SSA and State DOR or equivalent are provided by the reporting agent to the <<Staff Title>>
    • <<Staff Title>> stores e-mail Transmittal Confirmation receipts for a minimum of 7 years per File Retention Policy.

Issue Form W-2c as Required

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Policy: 

F/EA issues Form W-2c for any Forms W-2 that were previously issued and must be corrected.  Common reasons for issuing a Form W-2c include:

  1. Incorrect workers Social Security Number
  2. Incorrect workers name
  3. Incorrect wages
  4. Incorrect withholdings

Forms W-2c must be submitted to the workers listed on the Form W-2.  Corrected data, as shown on the Form W-2c, must be submitted to the Social Security Administration and the State Department of Revenue.

Whether or not the corrected W-2 data is submitted to the Social Security Administration and State Department of Revenue using the applicable W-2c process depends on when the error on the original W-2 is identified and the corrected W-2 issued.  If the original W-2 data has not yet been submitted to the Social Secutiy Administration or the State Department of Revenue when the error is identified and the W-2c provided to the workers, the F/EA does not need to use the Social Security Administration or State Department of Revenue W-2c process.  Rather, the F/EA can correct the data and submit corrected data to the Social Security Administration and State Department of Revenue with the F/EA's initial submission of W-2 data.  This approach to correcting data is usually used after Forms W-2 have been issued to workers but before W-2 data has been submitted to the SSA or State.

If W-2 data has already been submitted to the Social Security Administration or State Department of Revenue when the error is identified, the F/EA uses the Social Security Administration's W-2c filing process and the State Department of Revenue's filing process.

In 2016, Forms W-2c can be effectively filed using the Social Security Administration's Business Services Online portal and following onscreen steps to submit W-2c data.

Each state has an approach to accepting W-2c data.

Procedure: 

<<Insert F/EA Process>>

Internal Controls: 

<<Insert F/EA Internal Controls>>

Refund Over-Collected FICA to Workers and Employers (or the State Client)

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Policy: 

Per IRS regulation, household employees are only liable to pay Social Security and Medicare taxes (commonly referred to as FICA) if they earn wages from a single employer over a certain amount in the calendar year. Per IRS Publication 15, Circular E, in 2019, that amount is $2,100. 

F/EA must withhold the employee’s portion and calculate the employer’s portion of Social Security and Medicare from every paycheck made because F/EA will not know in advance if the employee will meet the threshold to be liable for FICA taxes for the calendar year. At year-end, prior to issuing forms W-2 and filing the fourth quarter Form 941, F/EA reviews employer/employee wages for the calendar year. Any employees who earned less than the FICA threshold in gross wages from a single employer are identified. 
 

All adjustments for refunded FICA must be made using Form 941-X.  A separate Form 941-X must be filed for each quarter in which FICA was withheld that is ultimately refunded.  A Schedule R for Form 941 must accompany each Form 941-X showing the corrected wages and taxes only for those employers impacted by FICA refunding for the quarter.

Procedure: 

 

  1. Immediately after the final payroll of a calendar year, F/EA identifies any employees who earned less than the FICA threshold for the calendar year in any employer/workers relationship
  2. Remember that the FICA threshold must be tested for each employer for which an workers works
  3. <<Insert process to create this report>>
  4. Run a report of gross wages paid by employer to each workers for the calendar year working for an employer in a calendar year
  5. For those employees who earned less than the FICA threshhold for a single employer, run a detailed payroll report showing their gross wages and FICA liabilities by quarter
  6. Collect the information for affected employees for Quarter 1
  7. Complete Form 941-X as follows:

Date discovered errors: 12/31/YYYY
Part 1, check Box 1 to apply the overdeposit to a future return (fastest way to get money)
Check Box 2 to get a check from the US Treasury (slow way to get money)
        If you choose this method, F/EA can only correct overreported amounts on this 941-X and F/EA must complete a     separate 941-X if F/EA is also correcting overreported amounts.
Part 2, check Box 3 and 3.a
Column 1 = F/EA's originally filed Form 941 less amounts for employees impacted by FICA Refunding

Column 2 = the amount originally filed on Form 941 for the quarter

Line 6: F/EA gross wages stay the same.  The workers were still paid.  It’s the Social Security and Medicare wages that will be adjusted.  Yes, workers were paid, but the wages were not Social Security or Medicare Taxable.
Column 3 = the difference.  This will also be F/EA's total amount for employees impacted by FICA refunding.
Line 8 – take it through like the other lines. 

Column 4 is the sum of F/EA total workers and employer refunded SS tax for the quarter

Line 10 – take it through like the other lines. 

Column 4 will also be the sum of F/EA total workers and employer refunded Medicare tax for the quarter
Lines 10 – 18 follow the remaining instructions on Form
The amount in line 18 is the amount of FICA refunded for the quarter
Half of this amount will be sent as a refund to the individual employees (their share of FICA)
Half of this amount will be refunded to the employer (almost always, this means refunding to the state)

Complete Section 21 to explain how you find the errors. 

  1. <<Staff Title>> makes appropriate corrections in payroll system for each employer/workers budget and in  F/EA general ledger.
  2. Participant budgets may be affected for the employer portion of FICA.
  3. This complete 941-X process is completed for each quarter in the calendar year.

 

Also complete a Schedule R to accompany each Form 941-X.  The Schedule R should include ONLY those employers affected by refunded FICA in the quarter for which the Form 941-X is filed.  

  1. List each employer that had an employee for whom refunded FICA applies for the quarter.
  2. The Schedule R should list the employer's EIN and the wages paid and tax liabilities assuming FICA refunding has already taken place - that is show the wages and taxes on the Schedule R as though the employer did not pay the wages or have the liability for the taxes for which a FICA refund is now do.
  3. Attach the Schedule R to the 941-X for the quarter and submit to the IRS.

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. This process is performed by the F/EA Accounting department. Payroll Department staff are not authorized to record FICA refund values.
  2. Using a detailed report, the F/EA Accountant records employer and workers FICA refund amounts in <<control document>>
    1. These values are used to reconcile to the applicable tax forms
  3. The F/EA Accountant reconciles FICA refund payments that are sent to workers per the normal bank reconciliation process
    1. Any uncashed checks are processed per the uncashed check process
  4. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for reconciliations.
  5. The reconciliation and supporting documents are scanned and saved for a minimum of 7 years per the File Retention Policy.

Report Abandoned Property to State Division of Abandoned Property

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Policy: 

F/EA reviews uncashed checks monthly. After <<one year>>, any checks that have not been cashed are removed from the bank reconciliation uncashed checks list (Account <<99999>>) and accounted for in General Ledger Account <<99999>> (See Policy and Procedure X.X).

F/EA conducts a due diligence process to try to connect uncashed checks with payees prior to submitting them to the Division of Abandoned Property.  For all payees with uncashed checks at least one year old are sent a notice by first-class mail to the payee's last known address at least <<60>> days prior to filing a report and turning over assets to the Division of Abandoned Property.  Each notice includes a voucher that the payee is asked to complete, sign and return to the F/EA.  The voucher asks the payee to certify that they never received the check in question and requests that the payee specify an address where a replacement check should be sent.  Each voucher includes identifying information so that the F/EA can match the signed voucher to the uncashed check(s) and payee.  The voucher must be signed by the payee for the F/EA to process it.  F/EA only re-issues checks for returned, signed vouchers. 
 
If after <<60>> days the payee has not contacted the F/EA to claim the uncashed check, F/EA submits each uncashed check value to the State Division of Abandoned Property in the payee's name using the Division's specified process.
 
This process is regulated by <<Insert State Statute or Reference to Regs>>
Procedure: 

 

  1. Each month when F/EA Accountant performs Program Operating Account Bank Reconciliation any uncashed checks <<180 days or older>> get moved to GL Account <<99999>>
  2. For any check <<180 days or older>>, F/EA attempts to contact the payee
  3. <<Note: Customer Service Unit is not authorized to have contact with workers. For this reason, the F/EA accounting unit handles all communication with workers regarding uncashed checks>>
  4. F/EA Accountant isolates all checks written to workers that are <<180 days old or older>>
  5. F/EA Accountant copies and pastes/imports this check data to spreadsheet at <<File Path>>
  6. F/EA Accountant verifies each payee’s address in the Payroll System and <<enters address information into the spreadsheet>>
  7. F/EA Accountant opens letter template saved here <<File Path>>
  8. Complete mail merge from Uncashed ck issue spreadsheet for uncashed ck letter for each workers with a check outstanding for 180 days or more
  9. This process will populate each letter with:
  • Consumer number
  • Check Date
  • Type of Check (Payroll check, refund check etc.)
  • Worker Address
  • Today’s date
  • Worker Name
  • Uncashed Check Number
  • Uncashed check amount
<<Insert image of letter template.  Letter template may include a 'voucher' that can be returned with a payee signature saying that the original check was never received and should be re-issued to X address.>>

10.  All letters are mailed to workers

11.  Some letters will be returned as “undeliverable”

12.  After undeliverable letters are received, F/EA Accountant or <<Staff Title>> try to contact workers by phone to verify their addresses

13.  Verify mailing address with each workers

14.  Record that call is made in <<Customer Service System>>

15.  pdate address in Payroll System

16.  After verifying or updating address with each workers, send each workers the uncashed check letter

17.  When vouchers are returned to F/EA, F/EA Accountant logs the date the voucher was returned in the Outstanding Check Issue spreadsheet

18.  For all workers in the spreadsheet for whom a voucher has been received, F/EA Accountant approves re-issuance of the check value by completing the "Re-Issued Check Requisition Form"

19.  For each returned, signed voucher, collect the voucher and the Re-Issued Check Requisition form

20.  Provide these forms to <<Staff Title>> for review

21.  Each check gets one form with the Check Requisition and the Letter

22.  <<Staff Title>> reviews all supporting documents and Check Requisition form

23.  <<Staff Title>> initials and dates Check Requisition form in lower right corner

24.  <<Staff Title>> reviews letter and Check Requisition form

25.  If errors do not exist, <<Staff Title>> signs and dates the Check Requisition form

26.  F/EA Accountant interoffice mails the Check Requisition forms to Accounts Payable Department

27.  F/EA Accounts Payable Department issues checks

28.  Issued checks are submitted to F/EA Accountant

29.  F/EA Accountant reviews checks received from Accounts Payable Department

30.  F/EA Accountant enters “Reissued” in column <<B>> of the Check Issue spreadsheet at <<File Path>>

31.  F/EA Accountant enters the reissued check number in column <<R>>

32.  Filter spreadsheet by column B = “Reissued”

33.  Copy all lines with “Reissued” in column B

34.  Paste results to bottom section of spreadsheet where reissued checks are stored

35.  <<Staff Title>> puts checks in envelopes

36.  Seals envelopes

37.  Delivers checks to outgoing mail box

38.  Checks are mailed

39.  By November of the calendar year, uncashed checks are reported to abandoned property for checks that are 3 years old or older

40.  F/EA Accountant provides report of uncashed checks 3 years or older to F/EA Controller for reporting

41.  F/EA Controller completes <<State Issued Report of Abandoned Property>>

42.  If any payment is due to transfer the unclaimed property to the Division, F/EA Controller will make payment and submit original report and payment to Division of Abandoned Property

43.  Copies of payment and <<State Issued Report of Abandoned Property>> are provided to <<Staff Title>>

44.  Copies of payment and <<State Issued Report of Abandoned Property>> are scanned and saved to <<File Path>> for a minimum of 7 years per File Retention Policy

45.  <<Insert process to appropriately update General Ledger and reconciliation documents>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. On a monthly basis, as part of the Bank Reconciliation process, uncashed checks are reviewed and flagged
  2. <<The Customer Service Unit is not permitted to contact workers. The unit is only permitted to talk to consumers and representatives per program rule>>
    • For this reason, the F/EA Billing Department performs all communication with workers regarding uncashed checks.
  3. All vouchers requesting a re-issuance of a previously uncashed check must be signed by the payee.
  4. <<Staff Title>> reviews all signed voucher and Check Requisition form prior to re-issuing a previously uncashed check
    • <<Staff Title>> initials and dates Check Requisition form in lower right corner
  5. The <<Staff Title>> reviews supporting documents and signs the Check Requisition Form prior to F/EA Accounts Payable Department issuing replacement checks
  6. All control documents are password protected and access is restricted to F/EA Assigned staff with responsibility for reconciliations.
  7. The reconciliation and supporting documents are scanned and saved for a minimum of 7 years per the File Retention Policy.

Issue Forms 1099-MISC

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Policy: 

Independent contractors that are used in the participant-directed program must be issued Forms 1099-MISC when they meet certain criteria.  The F/EA issues Forms 1099-MISC to contractors and submits copies of the Forms 1099 and Form 1096 (or electronic equivalent) to the IRS.  Copies of Forms 1099 and Form 1096 (or electronic equivalent) are submitted to the state Department of Revenue (or equivelent) depending on state rules.

Forms 1099-MISC should be filed per instructions and rules for the form, which can change from year to year.

Not withstanding other Form 1099-MISC instructions, Forms 1099-MISC will generally be issued to independent contractors by the F/EA under the following circumstances:

  • the participant uses the services of a self-employed individual and the individual is paid $600 or more per year by the participant (or consumers) for those services.
  • the participant uses the services of a nonprofit or government organization and that entity is paid $600 or more per year by the participant (or consumers) for those services.
  • the participant purchases health or medical services from any organization, including a corporation.  Qualifying health and medical services include services provided by physical & occupational therapists and nurses.

Forms 1099-MISC generally must be submitted to payees by January 31 of the year following the tax year reported on Form 1099-MISC.

The F/EA submits to the IRS copies of all Forms 1099-MISC and a completed Form 1096 by February 28 of the year following the tax year reported on Form 1099-MISC.  If the F/EA issues 250 or more Forms 1099-MISC, Forms 1099 must be filed electronically by the IRS.  In this case, a Form 1096 is not required.  Electronic Forms 1099-MISC are due to the IRS by March 31

Procedure: 
  1. <<Insert procedure to determine which payments/contractors qualify to receive a Form 1099-MISC and how that is tracked.>>
  2. <<Insert procedure to produce paper Forms 1099-MISC>>
  3. <Insert procedure to mail Forms 1099-MISC to payees>>
  4. <<Insert procedure to either create the electronic form 1099 for the IRS, or to create the 1096 MISC.>>
  5. <<Insert procedure to submit Forms 1099 and Form 1096 (or electronic equivalent) to the IRS.>>
  6. <<Insert procedure to create Form 1099 info per state requirements and to submit to the state.>>
Internal Controls: 
  1. <<Insert internal controls to track which payees get Forms 1099.>>
  2. <<Insert internal controls to ensure that data on Forms 1099 is correct.>>
  3. <<Insert internal controls to ensure that Forms 1099 are submitted to payees by January 31 and to the IRS and State by applicable due dates.>>

Other Tax Responsibilities

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Respond to Unemployment Claim Forms

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Policy: 

When an employee files for unemployment compensation from the State Department of Labor, the State Department of Labor sends an Unemployment Insurance Request for Information form to the employer at F/EA’s address. The form requests information to be verified or completed and returned to the State Department of Labor by the due date listed. The due date is usually within 12 days of the form’s mailing date. 

The F/EA <<Staff Title>> reviews the form, collects requested information, verifies listed information, copies and returns the form to the State Department of Labor by the due date. The <<Staff Title>> contacts the participant or representative to collect any information requested on the notification form that F/EA does not have.
 
Due to tight deadlines required by the Unemployment Insurance Request for Information form, F/EA staff process forms daily.
Procedure: 

 

  1. All Unemployment Insurance Request for Information forms are date stamped upon receipt
  2. <<Staff Title>> (or assigned staff) collects  Unemployment Insurance Request for Information forms from <<Insert location where forms are stored as they are received>>
  3. Staff logs in to Payroll System
    • Enter username and password
  4. First verify that the workers listed in section 2 of the Unemployment Insurance Request for Information is actually working for the participant
    • Search for the employer listed on the form by last name in Payroll System
    • After identifying the employer, write the participant’s company number on the Request for Information form
  5. See if the participant has submitted a Termination Form for any workers
    • If so, identify the Termination Form for the workers listed on the Unemployment Insurance Request form
    • Review the Termination Form for the workers to collect information for the Unemployment Insurance Request Form
    • Fill in the appropriate reason for the reason that the workers is no longer working for the participant
    • If there is not a Termination Form or the information is not provided on the Termination Form, go to the next step
    • Call the participant or representative and ask the participant or representative why the workers is no longer working for the participant and what the workers’s last date of work was
    • Record the information the Termination information in the Payroll System
    • Complete the Request for Information form with the information collected from the participant or representative
    • If the participant or representative cannot be reached, complete the section on why the workers was terminated with “quit”
  1. If a Termination Form has not been entered into Payroll System, the participant did not notify F/EA upon terminating the workers
    • This is common
  2. Verify that the workers works for the participant and the dates the workers worked for the participant by going to the Payroll System
  • All timesheets for the participant will be listed with the workers’s name

  8.  Find the workers listed in Section 2 of Request for Information form and their first start date

  9.  Enter the first start date in the appropriate section on the form

 10. Find that workers’s last end date worked

 11. Enter the last end date in the appropriate section on the form

 12. Verify the workers’s wages for the appropriate section of the Request for Information form

  • <<Enter process to run a report from the Payroll System to get this data as necessary>>
  • Verify that the wage amounts for the workers match those listed on the Request for Information report
  • Perform this process for each quarter
  • If any corrections are required, enter the correct amount on the Request for Information report
  • Scan the completed report to the participant’s file
  • The report is saved for a minimum of 7 years per File Retention Policy

  13. Fax the completed report to the fax number listed on the form

 14. Within a few weeks, F/EA will get a letter stating that the workers has or has not been granted Unemployment Compensation

 15. <<Staff Title>> or assigned staff sends a copy of the letter to the participant

 16. Scan a copy of the letter to the participant’s file on the X drive

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All State Deparment of Labor Unemployment Insurance Request for Information forms are date stamped upon receipt
  2. The <<Staff Title>>, who is not responsible for payroll duties nor for communicating with consumers, representatives or workers as part of normal duties, is responsible for collecting and verifying information for the Unemployment Insurance Request for Information
  3. The <<Staff Title>> verifies all information requested by Request for Information form in F/EA payroll systems
  4. All systems are password protected
    • Only staff with responsibility for certain payroll responsibilities have password access to systems
  5. The Determination of Unemployment Compensation letter is scanned and saved for a minimum of 7 years per the File Retention Policy.

Respond to Social Security Request for Information Forms

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Policy: 

Periodically, Social Security Administration Field Offices will request wage information about workers who work for consumers. These requests are mailed to the participant’s attention at the F/EA address. F/EA is responsible for completing all information and returning completed forms to the Social Security Administration Field Office in the postage paid envelope. 

The F/EA <<Staff Title>> reviews the form, collects requested information, copies and returns the form in the postage paid enveloped addressed to the applicable Social Security Administration Field Office. The F/EA <<Staff Title>> contacts the participant or representative to collect any information requested on the notification form that F/EA does not have.
Procedure: 

 

  1. All Social Security Information Request forms are date stamped upon receipt
  2. <<Staff Title>> (or assigned staff) collects Social Security Information Request forms
  3. Staff logs in to Payroll System
  4. Enter username and password
  5. First verify that the workers listed actually worked for the employer listed
  6. Search for the employer listed on the form by last name in Payroll System
  7. After identifying the participant, write the participant’s ID number on the form
  8. Click on Cust. Service tab for the participant in Payroll System
  9. Review the files to see if any Termination Forms have been submitted for the participant
  10. If a “T” is entered on a note on the Cust. Service tab, the participant has submitted termination information for a workers, including the last date of work and the reason the workers is no longer working
  11. Review any notes with a “T”
  12. See if the note is for the workers listed on the form
  13.  If so, complete “Is the individual named above still employed…” with “Yes”
  14. Enter the last date worked in Section 1 of the form for “Last Date Worked”
  15. Enter the pay date for the corresponding work date for “Last Date Paid”
  16. If there is not a note with a “T” on the Cust. Service tab notes, call the participant or representative to inquire if the workers is still working for the participant
  17. If the workers is no longer working for the participant, record the information, coded with a capital “T” in the Customer Service notes tab
  18. Complete section 1 of the Request for Information form with the information collected from the participant or representative
  19. If the participant or representative cannot be reached, complete “Is the individual named above still employed…” with “No” and leave the “Last Date Worked” and “Last Date Paid” sections blank
  20. If “No” was checked in “Is the individual named above still employed…”, complete the rest of Section 1 of the form
  21. In “Current Rate of Pay”, enter the current workers Program day rate per hour
  22. Verify that the workers works for the participant and the dates the workers worked for the participant by reviewing timesheets
  23. Select “Search”
  24. Sort timesheet results by start date
  25. All timesheets for the participant will be listed with the workers’s name
  26. Find the workers listed on form and their last end date
  27. Enter the last end date after “Date Last Paid” on form
  28. After “How often paid” on form, write “biweekly”
  29. After “Rate of overtime pay” write current participant direction program overtime rate
  30. After “Average overtime pay per pay period” enter “0” <<unless overtime is permitted in the program, in which case enter the average overtime pay per pay period>>
  31. Leave “Please describe any changes you expect in any of the information shown above:” blank
  32. In Section 2, “Prior Wages”, collect the wages paid to the workers in each month
  33. <<Enter process to get this information>>
  34. After completing Section 2, add any additional information about the workers’s employment in Section 3: Additional Information
  35. <<Staff Title>> signs, dates and writes his/her title in Section 4
  36. <<Staff Title>> completes “Employer Name”, “Telephone” and “Fax” with contact information for the participant or representative
  37. The <<Staff Title>> scans the completed report and files it the participant file on <<File Path>>
  38. The <<Staff Title>> mails the completed report in the postage paid and addressed envelope provided with the form
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. The <<Staff Title>>, who is not responsible for payroll duties as part of normal duties, is responsible for collecting and verifying information for the Social Security Income Information Request Form
  2. The <<Staff Title>> verifies all information requested by Social Security Income Information Request Form in F/EA payroll systems
  3. All systems are password protected
    • Only staff with responsibility for certain payroll responsibilities have password access to systems
  4. The employer’s contact information is provided on the form.
    • The Social Security Administration verifies information with the employer as required

Process Garnishments, Levies and Holds for Workers

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Policy: 

As garnishments, levies and holds are received by F/EA on behalf of participant employers, F/EA Payroll Department staff review the garnishment to ensure that the employer and workers are active in the program.

After verifying that the employer and workers on the garnishment are active in the program, Payroll Department staff copy applicable documents, maintain originals in a locked file drawer at F/EA and submit garnishment documents to reporting agent.
 
F/EA deducts garnishment amounts from applicable workers per garnishment instructions and state and federal garnishment laws. After deducting garnishment amounts from workers pay, F/EA creates checks payable to the garnishing agency. 
 
F/EA sends checks payable to garnishing agencies Payroll Department. Payroll Department reconciles checks to Payment Check Listing, completes garnishment vouchers, prints garnishment check pay stub and mails check and vouchers to garnishing agency per garnishment instructions.
 
All garnishment, levy and holds checks are mailed to the garnishing agency within one business day of the pay date on which the garnishment is processed.
Procedure: 

 

  1. When garnishment, levy or hold notices (hereafter referred to generally as “garnishments”) are received via mail, the notices are immediately date stamped and delivered to the Payroll Department
  2. <<Staff Title>> reviews each garnishment and confirms all information
  3. <<Staff Title>> first checks to see if the workers listed on the garnishment is still working for the participant
  4. Log in to Payroll System
  5. Enter user name and password
  6. Search for employer by last name listed for employer on garnishment, levy or hold
  7. After identifying participant in Payroll System, write participant number on garnishment form
  8. Check to see if the workers listed on the garnishment has been terminated
  9. If the workers has been terminated:
  10. Review the termination reason and date
  11. If the workers listed on the garnishment has been terminated, complete the garnishment request with a statement that the workers has been terminated and the date of termination
  12. Copy the garnishment
  13. Store a copy of the garnishment in the <<insert where completed garnishments are stored>>
  14. Mail the original garnishment to the garnishing agency with the statement that the workers has been terminated
  15. If the workers listed on the garnishment form has not been terminated, make a copy of the garnishment form
  16. Place the original garnishment in the locked <<insert where garnishments are stored>>
  17. Provide the copy of the garnishment to <<Staff Title>>
  18. <<Staff Title>> sets up deductions for workers per garnishment instructions and garnishment regulations in Payroll System
  • The garnishment notice states the amount to deduct from the workers’s pay and for how long

 19.  <<Insert Process to enter garnishment info into the Payroll System>>

 20.  Each time the workers in question is paid, the system makes a deduction per the garnishment set-up

 21.  Each day that payroll is processed, garnishment checks are cut for all deducted amounts

 22.  Each garnishment check is made payable to the agency as stated on the garnishment form

 23.  <<Staff Title>> reviews all printed garnishment checks to ensure all checks were received as appropriate

 24.  <<Insert process for <<Staff Title>> to ensure all garnishment checks were cut>>

 25.  <<Staff Title>> verifies that the name and amount on each garnishment check is correct

 26.  After verifying checks, <<Staff Title>> provides checks to <<Staff Title>>

 27.  <<Staff Title>> obtains the garnishment voucher for each check from the locked <<location>> file drawer

 28.  Copy voucher

 29.  <<Staff Title>> copies check to save with copy of voucher

 30.  <<Staff Title>> completes voucher with check information

 31.  <<Staff Title>> copies completed voucher and printed pay stub

 32.  Copy of voucher and pay stub are stored in workers folder in locked <<location>> file drawer

 33.  <<Staff Title>> mails completed voucher and original check to address on voucher

 34.  When a garnishment has been completely paid and no further payments are required, scan entire workers garnishment file and save to participant folder

 35.  Checks and vouchers are stored for a minimum of 7 years per File Retention Policy

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Lead <<Staff Title>> reviews information on garnishment and compares it to information in payroll systems to ensure workers is working for participant
  2. Original garnishment is saved in locked F/EA  file drawer for a minimum of 7 years per File Retention Policy
  3. <<Staff Title>> verifies garnishment checks to verify accuracy of garnishment check
  4. <<Staff Title>> copies completed voucher and places voucher copy and pay stub in workers’s file folder in locked “Child Support and Levy” file drawer

Garnishment checks and vouchers are scanned and stored to a participant's scan file for a minimum of 7 yeras per File Retention Policy.

Stay Up to Date with Forms, Rules and Regulations

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Policy: 

The <<Staff Title>> (or assigned staff member) checks each tax and other agencies for updated employee, employer and independent contract and forms at least monthly. New versions of the forms are integrated into the Employee Hire, Independent Contractor and Employer Start-Up packages and updated packages are distributed to Counselors and consumers as applicable.  Records are maintained showing that new forms were checked for; the record is saved in a control document and reviewed by <<Staff Title>>.

The <<Staff Title>> reviews and updates all tax forms, instructions and manuals related to Vendor Fiscal/Employer Agent services, household employers and domestic service workers.  The <<Staff Title>> seeks information on preparing, filing and depositing taxes on behalf of individual household employers at all relevant tax websites.

The <<F/EA Project Manager>> maintains contact with Program Administrator. The <<Staff Title>> is notified of any Program form, rule or regulations changes.  <<F/EA Project Manager>> is responsible to ensure that any new program form, rule or regulation changes are appropriately integrated into F/EA's policies, procedures and communication.
 
Each month, by the tenth day of the month, <<Staff Title>> reviews applicable tax agency websites for new employer reporting or other requirements. Policies and Procedures are adjusted per new regulatory requirements.
 
When new forms, rules or regulations are identified that will impact consumers, workers, independent contractors or Counselors, <<Staff Title>> integrates guidance about new policies and procedures into quarterly training conducted for Counselors. As applicable, Counselors, consumers and workers are notified in writing of changes to policies and procedures.
 
Policy and Procedure documents are updated per new forms, rules and regulations.
Procedure: 

 

  1. At least monthly, the <<Staff Title>> (or assigned staff member) goes to the website for the agency that produces each tax form in the workers hire, independent contractor and employer start-up packages.
  2. <<Staff Title>> (or assigned staff member) opens control document called Form_Verify saved here: <<File Path>>
  3. <<Staff Title>> obtains a copy of the current workers hire package, independent contractor package and employer start-up package from the Forms Control Binder. 
  • This is the current version of this package sent to consumers and the counselors.
Worker Hire Package
 
  1. IRS Form W-4
  2. Go to: http:// www.irs.gov/pub/irs-pdf/fw4.pdf
  3. Print a blank IRS Form W-4
  4. Compare the review date noted on the bottom right corner of the form printed from the website to the date printed on the form in the package.
  5. If date is different, replace the IRS Form W-4 in the package with the form printed from the website.
  • If the date is the same no change is required.
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Form_Verify describing any changes to the form or “No change”
  1. USCIS Form I-9
  2. Go to: http:// www.uscis.gov/files/form/i-9.pdf
  3. Print a blank Form I-9
  4. Compare the review date noted on the top right corner of the form printed from the website to the date printed on the form in the package.
  5. If date is different, replace the Form I-9 in the package with the form printed from the website.
  6. If the date is the same no change is required.
  7. Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  8. Enter comments in Form_Verify describing any changes to the form or “No change”
  9. State Form W-4
  10. Go to http://
  11. Print a blank Form W-4
  12. Compare the review date noted on the top right corner of the form printed from the website to the date printed on the form in the package.
  13. If date is different, replace the Form W-4 in the package with the form printed from the website.
  • If the date is the same no change is required.
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Form_Verify describing any changes to the form or “No change”

 19.  IRS Form W-5

 20.  Go to: http:// www.irs.gov/pub/irs-pdf/fw5.pdf

 21.  Print a blank Form IRS W-5

 22.  Compare the review date noted on the top left corner page 2 of the form printed from the website to the date printed on page 2 of the form in the package.

 23.  If date is different, replace the Form IRS W-5 in the package with the form printed from the website

  • If the date is the same no change is required
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Form_Verify describing any changes to the form or “No change”

 24.  All forms in the Employee Hire Package have now been updated as applicable per tax agency websites

 25.  Print Form_Verify control document

 26.  Provide updated Employee Hire Package and completed Form_Verify control document to <<Staff Title>>

 27.  <<Staff Title>> reviews updated Employee Hire Package and Form_Verify control document for accuracy

 28.  If documents are deemed as accurate, <<Staff Title>> signs and dates Form_Verify control document

 29.  Make a copy of the updated Employee Hire package. 

 30.  File copy in the Forms control Forms Binder. 

 31.  Ensure updated Employee Hire Package is distributed to applicable websites, counselors, consumers and workers as needed.

 
F/EA Start-Up Package
  1. IRS Form SS-4
  2. Go to: http:// www.irs.gov/pub/irs-pdf/fss4.pdf
  3. Print a blank IRS Form SS-4.
  4. Compare the review date noted on the top left corner of the form printed from the website to the date printed on the form in the package
  5. If date is different, replace the IRS Form SS-4 in the package with the form printed from the website
  • If the date is the same no change is required
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Updated_Form_Verify describing any changes to the form or “No change”

   6.  IRS Form 2678

   7.  Go to: http:// www.irs.gov/pub/irs-pdf/f2678.pdf 

   8.  Print a blank IRS Form 2678

   9.  Compare the review date noted on the top left corner of the form printed from the website to the date printed on the form in the package.

 10.  If date is different, replace the IRS Form 2678 in the package with the form printed from the website.

 11.  If the date is the same no change is required.

 12.  Enter date in Form_Verify control document that F/EA  staff verified if there are any updates to the form

 13.  Enter comments in Form_Verify describing any changes to the form or “No change”

 14.  IRS Form 8821

 15.  Go to: http:// www.irs.gov/pub/irs-pdf/f8821.pdf

 16. Print a blank IRS Form 8821

 17. Compare the review date noted on the top left corner of the form printed from the website to the date printed on the form in the package.

 18. If date is different, replace the IRS Form 8821 in the package with the form printed from the website.

  • If the date is the same no change is required.
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Form_Verify describing any changes to the form or “No change”

 19.  State Department of Labor, Employer Status Report

 20.  Go to: http://

 21.  Print a blank Employer Status Report Form

 22.  Compare the review date noted on the bottom left corner of the form printed from the website to the date printed on the form in the package

 23.  If date is different, replace the Employer Status Report Form in the package with the form printed from the website.

  • If the date is the same no change is required.
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Form_Verify describing any changes to the form or “No change"

 24.  State Department of Revenue Application for Registration

 25.  Go to: http://

 26.  Print a blank Employer Status Report Form

 27.  Compare the review date noted on the bottom left corner of the form printed from the website to the date printed on the form in the package

 28.  If date is different, replace the Employer Status Report Form in the package with the form printed from the website.

  • If the date is the same no change is required.
  • Enter date in Form_Verify control document that F/EA staff verified if there are any updates to the form
  • Enter comments in Form_Verify describing any changes to the form or “No change”

<<Insert process to check all forms in Employer Start-Up Package for program and state>>

  1. Make a copy of the updated Employee Hire package. 
  2. File copy in the Forms control Forms Binder. 
  3. Ensure updated Employee Hire Package is distributed to applicable websites, counselors, consumers and workers as needed.

<<Insert Process to check forms in Independent Contractor Package>>

 
Review Tax Agency Websites for Updated Payroll Rules and Regulations
  1. On a quarterly basis, <<Staff Title>> reviews applicable tax agency websites for updates to reporting rules and regulations that impact Household employers or payroll agents
  2. <<Staff Title>> reviews the following websites quarterly:
    • Internal Revenue Service: www.irs.gov
    • US Department of Labor:www.dol.gov
    • State Department of Labor (or equivalent):
    • State Department of Revenue (or equivalent):
  3. Quarterly, the <<Staff Title>> reviews the IRS and Social Security Administration’s newsletter for small businesses: The SSA/IRS Reporter
    • The SSA/IRS Reporter is mailed to the F/EA quarterly
    • <<Staff Title>> can also review the SSA/IRS Reporter online at: http://www.irs.gov/businesses/small/article/0,,id=109886,00.html
  4. Quarterly, the <<Staff Title>> reviews the applicable website to review the state's New Hire Reporting rules and to ensure the F/EA is up to date with all rules.
  5. Quarterly, the <<Staff Title>> reviews the applicable website to review the state's Workers' Compensation rules and to ensure the F/EA is up to date with all rules.
  6. After reviewing each website, the <<Staff Title>> updates a record describing any changes to the form or tax, or the <<Staff Title>> denotes "no change."
    • <<Staff Title>> reports any updates to <<Staff Title>> and <<Staff Title>>
  7. Print the form control document
    • Provide updated F/EA Start Up Package and completed control document to <<Staff Title>>
  8. <<Staff Title>> reviews updated F/EA Start Up Package and Form_Verify control document for accuracy
    • <<Staff Title>> works with applicable F/EA departments to implement any required changes
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reviews forms for updates on tax agency websites quarterly.
  2. <<Staff Title>> reviews tax agency websites for updates to other rules and regulations.
  3. Updates are recorded in a control document.
  4. <<Staff Title>> reviews control document to ensure updates were checked for and forms updated timely and accurately.
  5. Customer Service Unit distributes updated forms to Counselors
  6. <<Staff Title>> trains Counselors on changes to forms, rules and regulations on a quarterly basis

Process and Respond to Tax Notices

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Policy: 

F/EA processes, records and responds to notices from Federal, State and Local tax agencies that are received on behalf of employers. All notices are date stamped immediately upon receipt. 

Notices that may be received by F/EA on behalf of a participant include notices from State Department of Revenue (DOR), State Department of Labor (DOL) or the Internal Revenue Service notifying the participant of: a missing employer tax return, a missing employer tax payment, an insufficient employer tax payment, a tax payment in excess of tax due, a penalty for a late return or payment, or an incorrectly file tax return.
 
Each notice is researched on behalf of the employer. Often, the tax notice is issued in error.   Documentation supporting that the notice was issued in error must be collected and submitted to the tax agency to resolve the notice. The notice is logged in <<where is data stored>> and the data is used for reporting purposes as applicable.
 
If payments are required to resolve notices, requests for payment are submitted to the Payroll Department.  Payment is submitted to the agency that issued the notice with a copy of the notice. Copies of checks cut as payment to resolve notices are stored with notices. 
 
If payment is required to resolve a penalty assessed as a result of F/EA’s negligence, F/EA pays the penalty on behalf of employer from the F/EA's bank account that is not connected with program funds.
 
All notices and corresponding resolution information are scanned into the file. Scanned documents are stored for a minimum of 7 years per File Retention Policy.
Procedure: 

 

  1. Immediately upon receipt, tax notice is date stamped with the date the notice is received by F/EA
  2. Notices are delivered to <<Staff Title>>
  3.  <<Staff Title>> reviews notices within 1 business day and prioritizes notices with the nearest due date
  4. Within 5 days of receipt, <<Staff Title>> processes all received notices
  5. <<Staff Title>> finds participant no. for employer listed on notice
    1. <<Staff Title>> logs into Payroll System
  1. <<Staff Title>> obtains last check date for participant
  2. Write the last Payroll Check Date on the front of notice
  3. Run the report for the period listed on the notice
  4. Research if participant is no longer in the program
  5. <<Insert process to do this>>
  6. Search Customer Service and Payroll System to identify if notice was already processed and if a payment submitted (if applicable).
  7. Go to the <<File Path>>
  8. Open respective folder for notices (IRS, DOL, DOR)
  9. Open spreadsheet containing this notices
  10. Search for participant and notice and see if it was already processed.
  11. If already processed, confirm with respective agency to make sure the notice was sent in error, and/or disregard notice.
  12. If not processed yet, process notice.
  13. <<Insert process to research and respond to notices of each type>>
  14. Record notice information
  15. Open spreadsheet called <<>>saved at: <<File Path>>
  16. Record the following information from the notice:
  • Date notice received
  • Consumer number
  • Consumer name
  • Issue (on notice)
  • Period Due
  • Check date
  • Check number
  • Resolution
  • Amount of payment (if any)

 22.  Payroll Department issues checks and/or returns to applicable tax agency with copies of notices

 23.  Copies of checks and/or returns are submitted to <<Staff Title>>

 24.  Copies of checks and/or returns are attached to notices

 25.  Notices, checks and/or returns are scanned to participant scan file and saved for a minimum of 7 years per File Retention Policy

 26.  Any notices received for consumers who did not have payroll during the period on the notice:

 27.  Must have zero returns (as applicable per notice) completed by <<Staff Title>> or

 28.  Must have account numbers terminated (See chapter on Retiring and Revoking Account Numbers and Authorization)

 29.  If it is determined that the participant transferred to another F/EA, additional research is required

  • The F/EA to which the participant transferred is contacted as necessary
  • Notices and returns (as applicable) are scanned to participant scan file and saved for a minimum of 7 years per File Retention Policy

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All notices are date stamped immediately upon receipt.
  2. <<Staff Title>> reviews notices within a single business day and prioritizes those with the nearest due dates.
  3. Each notice is researched individually.
  4. All notice information is recorded in a spreadsheet for reporting and documentation purposes.
  5. All notices and corresponding resolution documents (payments, returns, applicable research) are scanned to the participant’s scan file and stored for a minimum of 7 years.

Renew Tax Forms

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Policy: 

Certain employer tax forms expire and must be renewed periodically.

F/EA renews IRS Form 8821, Tax Information Authorization, every 3 years.

F/EA renews any state Forms Power of Attorney as required by state rules.

Procedure: 

Renew IRS Form 8821

  1. When employers complete the employer start up package, they complete IRS Form 8821 (see Employer Start Up Packages).
  2. Form 8821 is completed then with an expiration date three years from when the Form is signed.
  3. F/EA records when Form 8821 expires when the original Form 8821 is completed.
  4. Annually prior to December 31, F/EA reviews expiration dates for all Forms 8821 and identifies those employers with Form 8821 that are expiring in the current calendar year.
  5. F/EA pre-populates IRS Forms 8821 for those employers.
  6. F/EA mails the pre-populated Forms 8821 with a letter explaining that the Form is expiring and must be signed by the employer and returned to the F/EA.
  7. F/EA tracks when Forms are sent and tracks that Forms are returned to the F/EA.
  8. F/EA tracks the expiration date of newly received Forms.
  9. Completed, renewed Forms 8821 are submitted to the IRS.
  10. F/EA follows up with any employers that do not return completed Forms 8821 to the F/EA.

Renew IRS Form 2848 <<include a procedure for this if you use Form 2848>>

  1. When employers complete the employer start up package, they complete IRS Form 2848 (see Employer Start Up Packages).
  2. Form 2848 is completed then with an expiration date one year from when the Form is signed.
  3. F/EA records when Form 2848 expires when the original Form 2848 is completed.
  4. Annually prior to December 31, F/EA reviews expiration dates for all Forms 2848 and identifies those employers with Form 2848 that are expiring in the current calendar year.
  5. F/EA pre-populates IRS Forms 2848 for those employers.
  6. F/EA mails the pre-populated Forms 2848 with a letter explaining that the Form is expiring and must be signed by the employer and returned to the F/EA.
  7. F/EA tracks when Forms are sent and tracks that Forms are returned to the F/EA.
  8. F/EA tracks the expiration date of newly received Forms.
  9. Completed, renewed Forms 2848 are submitted to the IRS.
  10. F/EA follows up with any employers that do not return completed Forms 2848 to the F/EA.

Renew State Forms <<include a procedure for this if you use state forms that expire>>

  1. When employers complete the employer start up package, they complete <<State Form>> (see Employer Start Up Packages).
  2. <<State Form>> is completed then with an expiration date one year from when the Form is signed.
  3. F/EA records when <<State Form>> expires when the original <<State Form>> is completed.
  4. Annually prior to December 31, F/EA reviews expiration dates for all <<State Form>> and identifies those employers with <<State Form>> that are expiring in the current calendar year.
  5. F/EA pre-populates <<State Forms>> for those employers.
  6. F/EA mails the pre-populated <<State Form>> with a letter explaining that the Form is expiring and must be signed by the employer and returned to the F/EA.
  7. F/EA tracks when Forms are sent and tracks that Forms are returned to the F/EA.
  8. F/EA tracks the expiration date of newly received Forms.
  9. Completed, renewed <<State Forms>> are submitted to the state.
  10. F/EA follows up with any employers that do not return completed <<State Forms>> to the F/EA.

 

Internal Controls: 
  1. <<Insert internal controls for tracking when a Form expires.>>
  2. <<Insert internal controls for identifying those forms that are expiring this calendar year.>>
  3. <<Insert internal controls for tracking that a form that must be renewed is received back from the employer.>>
  4. <<Insert internal controls for tracking that a renewal form is submitted to the IRS, or applicable state tax agency.>>

Workers' Compensation

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Purchase Workers' Compensation Insurance in each Consumer's Name (as applicable per State and Program rules)

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Policy: 

F/EA is responsible for purchasing, on behalf of each employer and in the employer’s name, a Workers’ Compensation policy covering all of the employer’s workers.  <<Insert individual State or Program policy>>

F/EA submits documentation of Workers’ Compensation policies procured on behalf of employers to Program Administrator upon request. Reporting workers’ compensation premiums paid on behalf of consumers is performed as part of the annual Individual Budget reconciliation report.  F/EA also reports premium payments to Program Administrator as part of the monthly program account reporting process.
 
 
Procedure: 

 

<<Workers' Compensation Procedure will vary by program and state>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Depends on procedures>>

Comply with Annual Workers' Compensation Audit & if a Claim is Submitted

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Policy: 

Annually, Workers’ Compensation Agent requests Workers’ Compensation audit data for the previous contract year. F/EA provides requested data to Workers’ Compensation agent within <<10>> business days of receipt of audit request.

Audit data is used to reconcile the estimated payroll data and policy cost to the actual payroll data. The total premiums due or refunded are adjusted per payroll data provided.
 
By comparing the premium deposit to the premium deposit earned, F/EA and the insurance agent determine if a Workers’ Compensation premium is due from or a refund owed to F/EA.
 
If F/EA owes an additional workers’ compensation premium, F/EA Accounts Payable Department cuts a check and mails it to insurance agent. If a refund is owed to F/EA, insurance agent cuts check and mails it to F/EA.
 
If an employee submits a Workers' Compensation claim, the Workers' Compensation underwriter may also request this, or other, information.  The F/EA always complies with Workers' Compensation information requests from policy underwriters and brokers.
Procedure: 

 <<Audit Process will vary depending on Program, State and Agent>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> collects annual payroll data from Expense Reports that are independently reconciled monthly
    • <<Staff Title>> initials and dates annual payroll data report
  2. <<Staff Title>> reviews annual payroll data
    • <<Staff Title>> compares annual payroll data report to individual budget amounts
  3. <<Staff Title>> compares the deposited premium shown on the letter from the insurance agent to the payments made on participant's behalf
  4. F/EA A/P Check Requisition document is prepared by <<Staff Title>>, as applicable
  5. <<Staff Title>> reviews F/EA A/P Check Requisition document as compared to invoice
    • <<Staff Title>> signs and dates F/EA A/P Check Requisition document
    • Accounts Payable Department will not cut check without <<Staff Title>> signature on F/EA A/P Check Requisition document
  6. Accounts Payable Department cuts check payable to agent as applicable
  7. F/EA Department scans invoice and check and saves for a minimum of 7 years per File Retention Policy
  8. <<Insert internal controls for receiving a payment from Workers' Compensation Agent if F/EA overpaid on behalf of a participant>>

Reporting

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Monthly Bank Statement

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Policy: 

Monthly, F/EA Accountant performs the bank reconciliations for the F/EA Program Bank Account.  During the process, the <<Staff Title>> reviews the bank statements and account reconciliation supporting documents for accuracy.

After monthly bank reconciliations have been performed, reviewed and finalized, <<Staff Title>> submits copies of bank statements to State Program Administrator via secure file delivery.
Procedure: 

 

  1. After F/EA Accountant reconciles Program Operating Bank Account
  2. F/EA Accountant provides reconciled bank statements and control documents to <<Staff Title>>
    • <<Staff Title>> zips and password protects statements so that they can be securely e-mailed
  3. <<Staff Title>> e-mails copies of the monthly bank statements for the program to Program Administrator
    • Copies of the monthly bank statements are submitted via e-mail by the 30th of each month for the previous month
    • <<Staff Title>> leaves a voicemail message for the Program Manager stating the password to be used to open the files
  4. After e-mailing documents, <<Staff Title>> scans documents and saves electronic copies of documents and e-mail to <<File Path>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. F/EA Accountant reconciles the monthly bank statements
  2. <<Staff Title>> reviews bank statements and supporting documents for accuracy
    • <<Staff Title>> signs and dates bank reconciliation control documents and supporting documents after reviewing
  3. All documents are scanned and saved for a minimum of 7 years per File Retention Policy
  4. <<Staff Title>> zips and password protects bank statement files prior to e-mailing them to State Program Administrator.
  5. <<Staff Title>> saves a copy of the e-mail submitted to Program Administrator program manager with supporting documents for a minimum of 7 years per File Retention Policy

Monthly Consumer and Worker Data Report

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Policy: 

Monthly, F/EA reports on the following data:

  • Number of new consumers enrolled with F/EA during the month
  • The total number of consumers enrolled with F/EA for whom an administrative fee was billed
  • The total number of consumers enrolled with the F/EA for whom an administrative fee was not billed
  • The total number of workers who were paid during the month
   
This information is reported to Program Administrator by the <<Staff Title>>. Information is gathered by F/EA Accountant and reviewed for accuracy by the <<Staff Title>>. <<Staff Title>> certifies information and submits to Program Administrator per the monthly reporting process.
Procedure: 

<<Insert Process to Collect Data from F/EA Systems>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. After producing the report, the report is reviewed and quality check by <<insert staff title.>>
  2. <<Insert staff title>> identifies any discrepancies and resolves them.
  3. After report has been verified as accurate, <<insert staff title>> initials and dates a copy of the report.
  4. Initialed and dated copy of the report is filed <<insert an appropriate place to keep this quality check document.>>

Consumer Complaints Report

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Policy: 

On January 15 and July 15 of each year, F/EA provides a summary report of the number and types of complaints and grievances filed by or on behalf of consumers. F/EA also reports how each grievance and complaint has been resolved.

The Consumer Complaints Report is produced by the <<Staff Title>> and verified and submitted to Program Administrator by the <<Staff Title>> 

Procedure: 
  1.  Review complaint log (see Assess, Categorize and Maintain a Log of Complaints and Grievances)
  2. Produce report showing all complaints, the date of the complain and the resolution (if any) for the period being reported
  3. Provide report to <<insert staff title>> for review
  4. <<insert staff title>> compares report to complain log to check for accuracy
  5. Any discrepancies are identified and resolved
  6. <<insert staff title>> dates and initials a copy of the report after it is verified accurate
  7. The quality checked copy of the report is stored <<insert an appropriate place to store the report>>
  8. Original report is submitted to program administrator via <<insert the process used to submit the report to program administrator, such as fax, email or mail.>>
  9. <<insert email address, fax number or mailing address to which report is submitted>>
  10. Program administrator provides feedback on submitted report
  11. <<insert staff title>>develops corrective action plan for any feedback provided by program administrator
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All complaints and grievances are electronically recorded in F/EA’s secure payroll and customer service system immediately upon receipt
    • Formal complaints and grievances are recorded with code “X"
  2. Semi-annually, <<Staff Title>> runs report on formal complaints
    • <<Staff Title>> reviews results of report, resolving discrepancies as necessary
    • <<Staff Title>> signs and dates report
  3. <<Staff Title>> reviews report for accuracy
    • <<Staff Title>> signs and dates report
  4. Report is stored electronically for 7 year per File Retention Policy

Consumer Spending Reports

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Policy: 

F/EA issues spending reports to consumers and counselors on a <<monthly>> basis.  Each participant spending report includes:

  • Funds allocated for the participant for the reporting period
  • Funds allocated by service
  • Funds spent for the participant for the reporting period
  • Funds spent by service
  • Remaining funds

 

Consumer Spending Reports are quality checked by <<Staff Title>>.  After quality check, Consumer Spending Reports are issued by mail and <<email>> to consumers.  All reports are issued by the <<10th business day>> following the reporting period.

Procedure: 

<<Insert Process to produce, quality check and sign off on Consumer Spending Reports>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

Retire and Revoke Account Numbers and Authorization

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Retire Account Numbers When an Employer is Deceased

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Policy: 

When an employer who was active in the F/EA program passes away, the employer's EIN and State Tax (State Income Tax and State Unemployment Tax) Account Numbers must be retired.

Quarterly, after all taxes for an employer have been filed, the assigned <<Staff Title>> revokes deceased employers' Employer Identification Numbers with the IRS.
 
Quarterly, after all taxes for an employer have been filed, the <<Staff Title>> revokes deceased employers’ State Tax (State Income Tax and State Unemployment Tax) Account Numbers.
 
Notice from tax agencies confirming revocation is tracked in the Customer Service System.
 
Note that these account numbers should only be retired when the employer is deceased.  If a participant passes away, but the participant had designated someone else to act as the employer for the participant's program, do not retire these account numbers.  Doing so will prevent the living employer from ever utilizing their EIN and State Account Numbers.  The IRS issues only one EIN for a sole proprietor per lifetime.
Procedure: 

Retire Employer Identification Number for Deceased Employers

  1. Quarterly, after all quarterly taxes for the employer have been filed and paid, <<Staff Title>> submits a letter to the Internal Revenue Service notifying of EINs that should be retired because the employer has passed away
  2. <<Staff Title>> opens letter template for "Retire Forms SS-4"
  3. Letter template states:

Dear Sir or Madam,

The following employers are deceased as of <<Insert Today's Date.>> Please retire the employers' Employer Identification Numbers.

<<List Employer Name>> <<List EIN for Employer Name>>

<<List as many employer names as needed.>>

Please contact <<Staff Name at number during available hours>> with any questions.

Sincerely,

<<Staff Name>> (can be any staff person)

<<Staff Title>>

4. Copy letter

5. Store copy of letter for each deceased employer in participant's file 

6. Submit letter to IRS office where F/EA's Aggregate Forms 941 are filed

7. For each deceased employer, record date letter was sent to IRS office in Customer Service System

8. The Internal Revenue Service will NOT issue a notice to the F/EA that the EIN has been retired.

 
Retire State Department of Labor Account Number

<<Insert Process to Retire State Department of Labor Account Number for Deceased Employers>>

 

 
Retire State Department of Revenue Account Number

<<Insert Process to Retire State Department of Revenue Account Number for Deceased Employers>>

 

 
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Dates that request to retire account number are sent are tracked in the Customer Service System
  2. Dates that revocation notices are received are tracked in the Customer Service System
  3. All revocations are sent via Certified Mail
    • Certified Mail receipts are stored with copies of letters for a minimum of 7 years per File Retention Policy
  4. All revocation letters, confirmation sheets and revoked forms are scanned and stored in each participant’s scan file for a minimum of 7 years per File Retention Policy

Revoke Forms 2678, 8821 and State Power of Attorney Forms

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Policy: 

When a participant transfers to another F/EA or stops using the program for any reason, certain tax authorization granted to F/EA must be revoked. Heretofore, these consumers will be referred to as "closed employers."

Quarterly, after all taxes for a closed employer have been filed, <<Staff Title>>, revokes F/EA’s authorization assigned by the IRS per Forms 8821 and 2678 and any State Power of Attorney Forms for all closed consumers. All revocations are performed per current IRS and State instructions and Stay Up to Date with Forms, Rules and Regulations.
 
 
Notice from tax agencies confirming revocation is tracked in the Customer Service System.
Procedure: 


  1. Quarterly, after all taxes for an employer have been filed, <<Staff Title>> (or assigned staff) revokes Forms 8821, 2678 and State Forms Power of Attorney for closed consumers
  2. Open Payroll System
  3. Identify any closed employers <<Insert process to identify closed consumers>>

Revoke Form 2678

  1. F/EA revokes Form 2678 for any closed consumers after all quarterly tax payments and returns have been completed
  2. For each closed participant, F/EA completes Form 2678
  3. In Part 1, F/EA enters the following information for the participant or representative employer
  • Check box for "Revoke an Existing Appointment"

In Part 2, enter the following:

  • Enter Employer Name (this will be either the participant or the participant's appointed employer)
  • Enter Employer's Address associated with employer's EIN
  • On Line 5, check the first box for "ALL Employees"
  • The employer is NOT required to sign in Part 1 to REVOKE the Form 2678

In Part 3, enter the following

  • Enter F/EA's Aggregate EIN
  • Enter F/EA's address associated with Aggregate EIN
  • Check box for "Check here if the employer is a disabled individual or other welfare recipient receiving home-care services through a state or local program."
  • Authorized signatory for F/EA signs and dates Form 2678 in Part 3
  1. <<Staff Title>> stores copy of Revoked Form 2678 in participant file
  2. <<Staff Title>> records in Customer Service System that Form 2678 was revoked and the date on which it was mailed to the IRS
  3. <<Staff Title>> mails revoked Form 2678 to Internal Revenue Service using "Where to File" chart in insructions for Form 2678
  4. Internal Revenue Service will submit notifcation of Form 2678 revocation with 120 days.  The notice sent by the IRS is IRS LTR 4228C.
  5. When IRS LTR 4228C is received, <<Staff Title>> tracks the date received in Customer Service System
  6. Store IRS LTR 4228C in participant file

Revoke Form 8821

1.  F/EA revokes Form 2678 for any closed consumers after all quarterly tax payments and returns have been completed

2. For each closed participant, locate participant's original Form 8821 in participant file

3. Write “Closed” and the participant’s close date on the top of Form 8821

4. Copy all revoked Forms 8821 for consumers

5. Place original forms back in participant file

6. Mail copies of revoked Forms 8821 to IRS address where original Forms 8821 were submitted

7.  <<Staff Title>> records in Customer Service System that Form 2678 was revoked and the date on which it was mailed to the IRS

8. Internal Revenue Service will NOT submit notifcation of Form 8821 revocation

Revoke Form State Power of Attorney Forms

<<Insert Process to Revoke State Power of Attorney Forms>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Dates that revocations are sent are tracked in the Customer Service System
  2. Dates that revocation notices are received are tracked in the Customer Service System
  3. All revocations are sent via Certified Mail
    • Certified Mail receipts are stored with copies of letters for a minimum of 7 years per File Retention Policy
  4. All revocation letters and revoked forms are scanned and stored in each participant’s scan file for a minimum of 7 years per File Retention Policy

Customer Service

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General Policies for Inbound and Outbound Calls

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Policy: 

In implementation of Fiscal/Employer Agent services for the participant direction program, F/EA seeks to empower consumers to manage their services. 

F/EA <<Customer Service Representatives>> are available at the toll-free phone number to respond to <<participant, representative and workers>> inquiries from <<9AM to 5PM>> on all non-state Holiday business days.
 
<<Staff Title>> communicate only with consumers or representatives.>>  <<Staff Title>>s do not provide information to or respond to inquiries from workers or other participant stakeholders. All written and verbal communication performed by <<Staff Title>>s is conducted with consumers or representatives.>>
 
Policies and procedures in this document are general in nature.  Specific policies and procedures apply to certain other Customer Service responsibilities and can be found in other Policy and Procedure documents. All non-routine inbound and outbound calls are logged in Customer Service System per Policies and Procedures. Specific policies and procedures apply to resolving timesheet discrepancies as documented in <<>>. Written communication with consumers is documented in Policy and Procedure document <<>>. 
Procedure: 

Inbound Calls

  1. <<Staff Title>> (or assigned staff) answers inbound call to F/EA toll-free number
  2. <<Staff Title>> states:
  •   “Thank you for calling <<F/EA>>. How can I help you?”

  3.  <<Staff Title>> listens to brief description of nature of call

  4. <<Staff Title>> asks the caller if they are the participant or representative.>>

  5. <<The below section may not apply if program does not have restrictions on F/EA speaking with stakeholders other than consumers and representatives>>

  6. << If the caller says “no”, <<Staff Title>> explains that F/EA can only speak to the participant or representative about Fiscal/Employer Agent matters>>

  7. <<If necessary, <<Staff Title>> explains that F/EA is not the employer of the workers, but rather that the participant or representative is>>

  8.  <<Staff Title>> reminds the caller to contact the participant or representative with any questions, and if necessary, the participant or representative can contact F/EA>>

  9.  If the caller states that they are the participant, <<Staff Title>> asks the caller for his/her name

 10. Verify that the participant exists in the program

 11. Log into Customer Service System

 12. Search for participant by name

 13. If participant exists, open participant record

 14. Record information about call per in Customer Service System for Consumer Record

 15. If participant does not exist in Payroll System, get more information from caller about why they are contacting F/EA

 16. <<If the caller states that they are the representative, ask the caller his/her name

 17. Ask the caller the name of the participant for whom they are the representative

 18. If the representative name matches F/EA records for participant, proceed with call>>

 19. <<If the representative name does not match, inform the caller that they are not listed as the representative and that F/EA can only communicate with representatives and consumers

 20. Inform the caller to contact the representative or participant

 21. If necessary, provide the caller with the name of the representative listed

 22. Do not provide additional information to the caller who is neither the representative nor representative>>

 23. <<Staff Title>> proceeds with call.

 24. Information is provided as applicable

 25. If additional research is required, <<Staff Title>> provides caller with an estimated time when <<Staff Title>> will contact caller with research

 26. For specific types of calls, see “Respond to Consumer Inquiries” Policy and Procedure document

 27. Document caller issue, caller name, and resolution in Customer Service System per Policy and Procedure X.X

 
Outbound Calls
  1. Prior to making an outbound call, <<Staff Title>> verifies if the participant has a representative
    • <<Staff Title>> Opens Customer Service System
    • After finding participant in system, scroll and review the representative contact information
    • Contact the representative at the phone number listed
    • If a representative name is not listed, contact the participant at the phone number listed

  2.  Collect all applicable information and place call

  3.  If phone is answered, state: “This is <<name>> from F/EA. Is <<participant or representative>> available?”

  4.  If participant or representative is available, discuss issue

  5.  If participant or representative is not available, ask to leave a message with the person who answered the phone

  • Request that the participant or representative contact F/EA at <<toll-free number>>
  • Do not provide additional information on the issue as data and information is confidential

  6.  If a voicemail system is reached, state:

  • “This is <<name>> from F/EA calling for <<participant or representative>>. Please call us  at <<toll-free number>>.

  7.  Record the communication in Customer Service System

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All communication with callers is recorded in Customer Service System per Policy and Procedure document X.X
  2. Prior to providing any information during an inbound call, <<Staff Title>>s verify that caller is participant or representative
    • <<Staff Title>> matches caller’s name to participant or representative name in Customer Service System
    • If names do not match, <<Staff Title>>s request that caller contact participant or representative
    • <<Staff Title>>s do not provide information to callers who are not consumers or representatives
  1. Prior to placing an outbound call, <<Staff Title>> verifies if participant has a representative
    • If participant has a representative, <<Staff Title>> requests to speak with representative
    • If participant does not have a representative, <<Staff Title>> requests to speak with participant  

Contact Consumer to Resolve Discrepancies with Timesheet or Invoice

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Policy: 

On a daily basis, F/EA Payroll Department identifies discrepancies or errors on timesheets and invoices using applicable systems and manual verification. All timesheets with discrepancies or errors are printed and the problem is noted on the timesheet. 

Daily, Payroll Department provides timesheets with discrepancies or errors to the <<Staff Title>> (or assigned staff). Within the business day that timesheets are provided to <<Staff Title>>, <<Staff Title>> assigns <<Staff Title>>(s) to resolve timesheet or invoice discrepancies or errors with participant/representative. 
 
<<Staff Title>>(s) contact participant/representative within 1 business day and record all communication in Customer Service System. Consumers/representatives are asked to correct errors and re-submit corrected timesheets to F/EA or provide information over the phone to correct information. Daily, <<Staff Title>>s checks to see if timesheets with errors or discrepancies have been paid.
 
Procedure: 

 

  1. During the payroll process (See Policy and Procedure X.X) Payroll Department identifies timesheet discrepancies requiring follow-up with participant or representative
    • Each day, timesheet discrepancies are provided to <<Staff Title>> by Payroll Department staff
  2. <<Staff Title>> reviews and follows up on timesheet discrepancies each day
  3. <<Staff Title>> reviews each timesheet for the following errors:
    • Dates on the timesheet do not match the pay period start and end dates
    • Timesheet is submitted for wrong payroll cycle
    • Timesheet is missing signatures of participant/representative or workers
    • A day with hours recorded is missing in time or out time
    • “AM” or “PM” designation is missing from a timesheet line
    • The timesheet includes time recorded for a date that has not yet occurred
    • Faxed timesheet image was compromised
    • Timesheet is illegible
  4. If timesheet contains any of the above discrepancies, <<Staff Title>> contacts participant or representative via phone
    • Using participant name on timesheet, <<Staff Title>> looks up participant in Customer Service System
    • Open new outbound call note log for participant
                                                          
  1. <<Staff Title>> places an outbound call to the participant or representative using the phone number listed for participant on the timesheet
  2. In note log, <<Staff Title>> documents:
  • The phone number and staff person who placed call
  • The reason for the call
  • Who the <<Staff Title>> talked to, or if a voicemail message was left
  • Verification that participant/representative was told that the timesheet must be corrected and re-faxed in order to be processed <<if applicable; information may be able to be collected over the phone, in which case that information should be recorded>>
  • When the participant/representative estimates they will re-fax the timesheet
  •  << Notify participant/representative to call F/EA within 5 minutes of re-faxing a timesheet so they can verify that the timesheet was received and will be processed>>
  •  <<Notify that if timesheet isn’t received within the business day, it will be paid on the following Friday>>
  • Document the resolution of the issue in Customer Service notes log

 7.  Two attempts to contact the participant by phone must be made within the day the discrepancy is identified by Customer Service

  • If the participant/representative or a voicemail system cannot be reached after two attempts within the business day that the discrepancy is identified by Customer Service, timesheet must be mailed to participant/representative within the business day

 8.  <<Staff Title>> completes a “Not Paid” template letter from the F/EA Master Copy File

 9.  All timesheets for which calls have been made or timesheets that have been mailed are placed in a timesheet discrepancy sorter in Customer Service Unit

10.  Sorter is reviewed each Tuesday afternoon, Wednesday afternoon and Friday morning

11.  <<Staff Title>> opens sorter

12.  For each timesheet in sorter, <<Staff Title>> goes to Payroll System to see if the timesheet has been paid yet

13.  If timesheet has not yet been paid, keep timesheet in sorter so that it can be verified the next time the sorter is reviewed

                                                          
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Payroll Department identifies all discrepancies and Customer Service Department contacts consumers/representatives to resolve discrepancies
  2. All contact with participant/representative is recorded electronically
    • The number of timesheet errors for a participant is tracked, thereby allowing F/EA to track consumers who may need additional skills training or help
  3. Customer Service Department proactively verifies if timesheets with errors have been received and paid
    • This helps to prevent timesheets with errors from being overlooked and allows F/EA to provide the most up-to-date information to callers regarding payment

Respond to Stakeholder Inquiries

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Policy: 

Robust and accurate Customer Service is the crux of F/EA’s services. Customer Service staff answer the F/EA toll-free phone number from <<9A.M to 5PM>> on all State business days. Mail is reviewed daily (See Policy and Procedure document). F/EA Customer Service makes every effort to respond accurately to all participant inquiries either via phone or in writing. 

During hours that Customer Service staff does not answer the F/EA toll-free phone number, a voicemail messaging system collects messages left by callers. Customer Service staff retrieve messages each business day. All calls are returned within 1 business day of receipt.
Procedure: 

Incoming Calls

  1. <<Staff Title>>s, or assigned staff, answer all incoming calls to toll-free phone number
  2. <<After verifying that caller is a participant or representative>> (see Policy and Procedure document), <<Staff Title>> answers caller’s inquiry
  3.  If minor research is necessary to accurately respond to participant inquiry, <<Staff Title>> performs research while caller is on phone
  4. If significant research is required to respond to caller’s inquiry, <<Staff Title>> tells caller by when they can expect a return call with an answer after additional research is performed
  5. Call is logged in Customer Service System
  6. Perform research and return call by date and time indicated
Incoming Mail
  1. <<Staff Title>>s process incoming mail daily (See Policy and Procedure document)
  2. Any mail from a participant or representative with an inquiry is identified
  3. <<Staff Title>> reviews inquiries and provides mail documents to <<Staff Title>> for follow-up
  4. <<Staff Title>> research each inquiry
  5. <<Staff Title>> respond to each inquiry by mail or telephone as applicable
    • If inquiry is responded to by telephone, response is recorded in Customer Service System
    • If inquiry is responded to by mail, copies of documents sent are scanned and saved to participant’s scan file folder for 7 years per File Retention Policy
 
Voicemail Messages
  1. Before 9:15 AM each morning, <<Staff Title>> retrieves all voicemail messages from answering system
  2. <<Staff Title>> records all calls
  3. <<Staff Title>> records:
  • Date Message Retrieved
  • Date message left
  • Caller
  • Consumer in question (if applicable)
  • Payee in question (if applicable)
  • Return phone number

  4.  After retrieving all messages, <<Staff Title>> assigns Customer Service staff to research and respond to each call within the business day

  • <<Staff Title>> types <<Staff Title>> name in “Assigned To” column for message

 5.  <<Staff Title>> auto-filters by “Date Message Retrieved” equal to today’s date and by “Assigned To” to each staff member

  • <<Staff Title>> prints each <<Staff Title>>s message assignments for the day
  • <<Staff Title>> provides assignments to each <<Staff Title>> and instructs them to return all calls within the business day

 6.  After making each call, <<Staff Title>> records resolution in Customer Service System (See Policy and Procedure document)

  • <<Staff Title>> initials recorded message on print out provided by <<Staff Title>>
  • If an action besides returning the call is required, <<Staff Title>> notes that on the print out
  1. At 4PM each day, <<Staff Title>> collects print out from each <<Staff Title>>
    • <<Staff Title>> verifies that each recorded message row has been initialed
    • <<Staff Title>> initials and dates each print out of messages
  2. <<Staff Title>> provides initialed print out of messages to <<Staff Title>>
  3. <<Staff Title>> reviews each print out to verify that all calls were initialed as responded to within the business day
    • <<Staff Title>> signs and dates print outs
  4. <<Staff Title>> stores verified print outs in “Messages” file folder in Customer Service File Cabinet
    • Print outs are stored for 90 days
    • After 90 days, print outs are shredded
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All incoming and outgoing calls are recorded in Customer Service System
  2. Customer Service staff verify that caller is a participant or representative prior to providing information
  3. Copies of any written responses to participant inquiries are stored in participant’s scan file for a minimum of 7 years per File Retention Policy
  4. <<Staff Title>> retrieves messages each day by 9:15 AM
  5. As each message is returned or acted upon, <<Staff Title>>s initial message print out document
  6. At 4PM each day, <<Staff Title>> collects print out from each <<Staff Title>>
    • <<Staff Title>> verifies that each recorded message row has been initialed
  7. <<Staff Title>> reviews each print out to verify that all calls were initialed as responded to within the business day
    • <<Staff Title>> signs and dates print outs
  8. <<Staff Title>> stores verified print outs in “Messages” file folder in Customer Service File Cabinet
    • Print outs are stored for 90 days
    • After 90 days, print outs are shredded

Offer Communication in Consumer's Primary Language or Alternative Format

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Policy: 

F/EA makes every effort to communicate with consumers in their primary language or language of choice. Spoken languages accommodated by F/EA include English, <<Insert Languages>>.

 
F/EA has a contract with <<Insert>> to provide TTY phone services. If the caller would benefit from a TTY call, F/EA <<Staff Title>> places call to <<Insert>> and conferences in the caller.
Procedure: 

Outgoing Calls

  1. F/EA stores a participant’s primary language in the Customer Service System
  2. Prior to making an outbound call, the <<Staff Title>> reviews the participant’s primary language
  3. If the participant’s primary language is not spoken by the <<Staff Title>> who is about to make the call, the <<Staff Title>> reviews F/EA Languages Matrix
  4. <<Staff Title>> reviews language column
  5. If F/EA staff member who speaks participant’s primary language is identified, <<Staff Title>> asks the staff member to contact the participant
  •  <<Staff Title>> briefs staff member on the participant’s situation and provides information to be communicated to participant
  • Staff member calls participant
  • <<Staff Title>> stays with caller during call in case any additional information must be translated

 6.  If F/EA staff member who speaks participant’s primary language is not identified <<insert process>>

 7.  If the participant would benefit from a TTY call, <<Staff Title>> contacts TTY Contractor

  • Dial
  • Provide the operator with the participant or representative’s area code and phone number
  • Speak directly to the operator at a moderate speed
  • The operator will type everything he or she hears
  • After each statement, say “Go ahead”
  • After hearing “Go ahead”, operator will relay TTY message to participant or representative
  • When call is complete, say “good-bye”

 8.  Resolution of call is documented in Payroll System

 
Incoming Calls
  1. If upon answering an incoming call, <<Staff Title>> determines that the participant speaks a language not spoken by the <<Staff Title>>, the <<Staff Title>> reviews F/EA Languages matrix
  2. <<Staff Title>> reviews language column
  3. If F/EA staff member who speaks caller’s primary language is identified, <<Staff Title>> asks the staff member to take the call
  • Call is transferred to staff member who speaks caller’s primary language
  • <<Staff Title>> stays with staff member during call in case any additional information must be translated

 4.  If F/EA staff member who speaks participant’s primary language is not identified <<insert process>>

 

 5.  If the participant is contacting F/EA via the TTY number provided on F/EA communications, <<Staff Title>> will hear the TTY operator say “This is TTY Operator, Opr5xxxxx with a relay call. Do you know how to use relay?”

  • <<Staff Title>> responds, “Yes”.
  • The operator will relay spoken TTY messages received from the caller to the <<Staff Title>>
  • To respond, speak directly to the operator at a moderate speed
  • The operator will type everything he or she hears
  • After each statement, say “Go ahead”
  • After hearing “Go ahead”, operator will relay TTY message to participant or representative
  • When call is complete, say “good-bye”

 6.  Resolution of call is documented in Customer Service System

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All incoming and outgoing calls are recorded in Customer Service System.
  2. Consumer’s primary language is stored in the Customer Service System.
  3. Customer Service Staff review primary language field prior to contacting participant.
  4. Languages spoken by F/EA staff are published on F/EA Langages matrix.
    • F/EA Languages matrix is posted at each <<Staff Title>>’s desk.
  5. <<Staff Title>> familiar with participant’s situation stays with staff member who communicates with caller during phone call.

Record All Communication with Consumers and Representatives

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Policy: 

F/EA maintains a log of all communication with consumers and representatives in the Customer Service system. Each call is denoted with a code denoting the nature of the call. Each <<Staff Title>> receives training on the use of phone call log codes.  A phone call log codes chart, with code and description, is posted at each <<Staff Title>>’s work area.

Every non-routine inbound and outbound call is recorded in Customer Service System with an applicable code and sub-code. Any walk-in visits to F/EA are also recorded in Customer Service System using the same codes as are used for phone communication, but with a different sub-category code. Logs are reviewed by staff and management as applicable.
 
Information recorded in log includes:
  • Consumer’s name
  • Date of Communication
  • Type of Communication
  • Issue
  • Resolution
  • Person with whom communication occurred 
Procedure: 

 

  1. <<Staff Title>>, and any other F/EA staff who make or receive calls, record calls in Customer Service System with an applicable phone call log code
  2. All non-routine communication is recorded
  3. Non-routine communication includes:
  • Verification of F/EA’s phone or fax number
  • Verification of F/EA’s address
  • Communication with a workers or other stakeholder to whom Customer Service is not permitted to talk

 4.  All other communication with consumers or representatives is recorded

 5.  Upon making an outbound call or receiving an inbound call, log in to Customer Service System

 6.  Enter username and password

 7.  Select a participant by number or name

 8.  Go to Customer Service Tab and start logging the call.

 9.  Enter one of the following codes in the “Caller” field for the applicable description covered by the communication being recorded: 

 

Code
Description
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   
   

10. In the “Notes” field, first enter a sub-category code:

11. Enter “OG” for an outgoing call

12. Enter “IC” for an inbound call

13. Enter “VM” for a voice message

14. Enter “WI” for a walk-in communication

15. After entering the sub-category code in the “Notes” field, enter as much of the following information as possible:

16. Enter at least the first name of the person with whom communication occurred

17. Enter the nature of the issue

18. Enter the resolution to the issue as applicable

  •  If any non-standard information was provided or exceptions to standard protocol made, enter that information

19. Save the note

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Standard codes are used to record all phone communication in the Payroll system
  2. Information logged includes:
    • Consumer
    • Date of Communication
    • Type of Communication
    • Issue
    • Resolution
    • Person with whom communication occurred
  3. F/EA staff are trained on what constitutes a non-routine call
  4. All systems are password protected
    • Only staff with direct responsibility for applicable duties are granted access to systems
  5. Phone call log codes are published and posted at <<Staff Title>>’s work areas

Tax Advice Restrictions

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Policy: 

F/EA staff never provides tax advice to participants, representatives, workers or other stakeholders. All staff are trained, within 15 days of hire, to not ever provide tax advice to any stakeholders with whom F/EA staff communicate.

Any staff member overheard or reported as providing tax advice to participants, representatives, workers or other stakeholders is reported to their supervisor. Supervisor will issue a verbal warning to the staff member to desist from this action. In addition, <<Staff Title>> sends an e-mail reminder to all staff not to provide tax advice. In certain cases, staff receives a written warning for providing unauthorized tax advice.
 
F/EA staff offer stakeholders seeking tax advice contact information for tax agencies and other resources.
Procedure: 

 

  1. If a caller requests tax advice, inform them that F/EA staff cannot provide tax advice.
  2. Commonly requested tax advice regards:
  • Earned Income Credit information 
  • How many allowances to use on form W-4
  • Impact of completing form SS-4 on personal tax situation

 3.  Advise the caller to contact their tax professional or seek information from one of the following resources:

  • IRS: www.irs.gov
  • IRS: 1-800-829-1040 
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All staff are trained, within 15 days hire, to never provide tax advice to consumers, surrogates, workers or other stakeholders
  2. Any staffs overheard or reported as providing tax advice receive an e-mail reminder not to provider tax advice from the <<Staff Title>>. 
  3. In certain cases, staff receives a written warning for providing unauthorized tax advice.

Inform Consumers in Writing of Policy Changes

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Policy: 

If at any time, F/EA changes a policy that will impact a participant, representative, workers or vendor, consumers/representatives must be informed in writing as soon as the F/EA receives notification of a change in policy or at least 30 days in advance of the implementation date. Consumers need not be informed about policy changes that do not impact their interaction with F/EA, Counselors or their workers and vendors. Written communication regarding a policy change is created and submitted to consumers or representatives by the <<Staff Title>>. All written communication must describe the policy change and it must include an effective date and instructions for complying with the policy.

Procedure: 

 

  1. <<Staff Title>> issues a written notification of policy change to all stakeholders at least 30 days in advance of policy change
  2. Written communication documents:
    • The change in policy
    • Instructions for complying with the new policy
    • An effective date of the policy
  3. <<Staff Title>> assigns staff to create a mail merge to all consumers/representatives
  4. Staff creates a mail merge of envelopes or labels using addresses in the payroll system
  5. Envelopes are stuffed with written communication and sealed
  6. Envelopes are mailed to participant/representative address
  7. Electronic copy of written communication is stored in an applicable file location for a minimum of 7 years per File Retention Policy
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> issues all written communication of a policy change
  2. Written communication includes:
    • The change in policy
    • Instructions for complying with the new policy
    • An effective date of the policy
  3. A mail merge, using the most up-to-date participant/representative address information is used to produce envelopes for the mailing
  4. Electronic copy of written communication is stored in an applicable file location for a minimum of 7 years per File Retention Policy.

Process and Distribute Incoming Mail

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Policy: 

Mail is delivered to F/EA at <<address>> each day that federal mail is delivered. F/EA receptionist sorts mail. <<Staff Title>> is notified when mail has been sorted and is ready for Customer Service to pick up. <<Staff Title>> assigns staff to pick up F/EA mail from receptionist. 

<<Staff Title>> (or assigned staff) opens all mail immediately upon receipt. Mail is immediately date stamped. F/EA mail is sorted into categories and placed in applicable inboxes within 3 hours of delivery. Staff assigned to each inbox review and process mail by the close of each business day.
Procedure: 

 

  1. Each day when mail is delivered to F/EA the F/EA receptionist identifies and sorts F/EA mail
  2. All opened mail is immediately date stamped
  3. After date stamping each piece of mail, documents are sorted by type and placed in applicable inboxes
    • Any time sensitive mail is identified and flagged for immediate follow up, if necessary
  4. Sort mail per the following:
    • Individual Budgets go to:
    • Timesheets go to:
    • Employee Hire Packages go to:
    • Worker Terminations go to:
    • Direct Deposit forms go to:
    • Change of Address forms go to:
    • Employer Start-Up Packages go to:
    • 2678, 8821, EIN Confirmation Notices from IRS go to:
    • State DOL and DOR notices go to:
    • Employment Verification and Social Security Wage Information Requests go to:
  5. Staff assigned to each inbox review and process mail in their inbox by the close of each business day
    • Any time sensitive mail is identified and flagged for immediate follow up, if necessary
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All mail is opened immediately upon receipt
    • This ensures that all time sensitive mail is identified as soon as it is delivered to F/EA
  2. Inboxes are pre-determined and staff are assigned to each inbox
  3. Staff process mail in the inbox(es) to which they are assigned by close of business each day
    • All mail is processed the day it is received
    • Any time sensitive mail is identified and flagged for immediate follow up, if necessary

Consumer Complaints and Grievances

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Publish Complaint and Grievance Policy

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Policy: 

F/EA includes the Complaint and Grievance Policy in each Consumer Welcome Package and the Policy is distributed by Counselors. The F/EA Complaint and Grievance Policy is published so that consumers understand that they have a right to express grievances and that F/EA welcomes reporting of grievances. The Policy outlines the process by which consumers should report complaints and grievances to F/EA and the steps F/EA will take to resolve the complaint or grievance. 

The Complaint and Grievance Policy is updated by the <<Staff Title>> as needed. Upon request, F/EA’s Complaint and Grievance Policy and applicable Policy and Procedure documents are submitted to Program Administrator.
 
Copies of the Complaint and Grievance Policy are stored on the Welcome Package forms shelf within the F/EA Payroll Department.
 
 

 

Procedure: 

The Complaint and Grievance Policy is included in the Consumer Welcome Package distributed to consumers

  1. As the Complaint and Grievance Policy is updated, the most updated version is included in the Welcome Package.
  2. The Complaint and Grievance Policy includes the following information:

 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. The Complaint and Grievance Policy is reviewed for accuracy as part of the quarterly review of the Consumer Welcome Package
  2. <<Counselors review the Complaint and Grievance Policy with consumersas applciable>>
    • This ensures that consumers have an opportunity to ask questions, thereby supporting that consumers fully understand their rights to reports complaints and grievances and the process to do so

Assess, Categorize and Maintain a Log of Complaints and Grievances

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Policy: 

Upon receiving communication from participants or representatives, whether via phone, in person or in writing, F/EA <<Staff Title>> determine if the communication must be classified as a complaint or grievance. Staff is trained, within 15 days of employment as a F/EA <<Staff Title>>, on handling complaints and grievances. 

Any communication that should be categorized as a complaint is recorded as such with applicable details. Complaint records are maintained for a minimum of 7 years per File Retention Policy.
Procedure: 

Assess Communication and Determine if it is a Complaint or Grievance

  1. As calls and mail are received, F/EA staff must assess whether the communication from a participant should be categorized as a complaint or grievance
  2. Some communication is clearly categorized as a complaint or grievance:
    • The participant states over the phone or in writing that they are reporting a complaint
    • The participant requests to speak with a manager or supervisor to report an unresolved issue
    • A grievance is reported in writing
  3. Some communication is more difficult to classify as a complaint or grievance and requires follow-up questions:
    • The participant is clearly upset, speaking loudly or with strong language
    • The participant accuses F/EA of negligence
    • The participant reports a negative impact that action or lack of action by F/EA has had on his/her life
  4. When communication is not clearly a complaint, Customer Service staff will ask the caller if they would like to lodge a complaint
    • If the caller responds in the affirmative, the issue should be logged as a complaint
    • If the caller declines the opportunity to lodge a complaint, the issue should not be logged as a complaint
  5. In general, issues of the following nature are not deemed complaints, unless they are also characterized by complaint criteria identified in step 2 and step 4:
    • A participant reports that a check that was expected has not yet been received
    • A participant reports that the check received was for a different amount than expected
    • A participant reports trouble faxing a timesheet to F/EA
    • A participant reports trouble completing participant or Worker start-up packages
    • A participant reports receiving an over-usage letter and questions the validity of the letter
 
Record Complaints or Grievances
  1. Once communication, either received via phone or mail, has been classified as a complaint or grievance, it must be logged
  2. <<Staff Title>> log the complaint or grievance in Payroll System per the process outlined in Policy and Procedure document
  3. The following information must always be recorded:
    • Code <<X>> in the “Caller” field for complaint
    • The participant’s name
    • The date of communication
    • The time of communication
    • The complaint or grievance
    • The method by which communication was received (phone, voicemail, writing, in person)
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Policies and Procedures document how to classify communication as a complaint or grievance
  2. Staff are trained on handling complaints and grievances within 15 days of employment as a <<Staff Title>>
  3. Complaints and grievances are coded as such and recorded in detail in the Customer Service System
  4. Recorded complaint and grievance data is stored for a minimum of 7 years per File Retention Policy

Develop Corrective Action Plan for Complaint or Grievance

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Policy: 

After recording a complaint, F/EA develops a corrective action plan and responds to the individual submitting the complaint within <<X>> business day(s). 

<<Staff Title>> reports complaints to the <<Staff Title>> immediately upon receipt. The <<Staff Title>> investigate the complaint and perform initial fact gathering. After fact gathering, <<Staff Title>> notifies <<Staff Title>> and <<Staff Title>> that a complaint was received.
 
Within one business day of receiving a complaint, <<Staff Title>>, <<Staff Title>>, <<Staff Title>> and any other applicable Customer Service, Billing or Payroll staff meet to review the situation and develop a corrective action plan.
 
Within one business day of receiving the complaint, <<Staff Title>> (or <<Staff Title>> or <<Staff Title>>, when appropriate) contact the participant or representative who placed the complaint and report F/EA’s corrective action plan for his/her complaint. The corrective action plan is submitted to the participant in writing on the same day that verbal communication of the corrective action plan is performed. Corrective action plans are submitted in writing for all complaints, regardless of if complaint was received via phone, mail or in person.
 
If implementation of the corrective action plan is not sufficient to resolve the participant’s complaint, F/EA arranges for a hearing with the participant, including the presence of a neutral party in accordance with the American Board of Arbitration guidelines.
 
All communication is recorded. All written documentation is scanned to the participant’s scan folder and maintained for a minimum of 7 years per File Retention Policy.
Procedure: 

 

  1. After recording a complaint or grievance <<Staff Title>> notifies <<Staff Title>> verbally or via e-mail that a complaint has been received
  2. <<Staff Title>> works with <<Staff Title>> to find as many facts about the situation as possible
  3. Facts sought vary by issue, but facts often sought are:
  • Check date of payment in question
  • Check number of payment in question
  • Worker/vendor associated with payment in question
  • Timesheet(s)/invoice(s) associated with payment in question
  • Date timesheet(s)/invoice(s) faxed or mailed
  • Individual budget details associated with payment in question

 4.  After fact-seeking, and on the same day that the complaint is received, <<Staff Title>> notifies <<Staff Title>> and <<Staff Title>>, verbally or in writing, that a complaint has been received

 5.  <<Staff Title>> schedules meeting with <<Staff Title>>, <<Staff Title>> and applicable Customer Service, Payroll or Billing staff to occur on or within one day of receiving complaint

 6.  During meeting, all parties review facts as presented by <<Staff Title>> and seek additional facts as necessary

 7.  After collecting relevant facts, meeting attendees develop a corrective action plan to resolve the participant or representative’s complaint or grievance while maintaining compliance with program rules and regulations

 8.  <<Staff Title>> drafts a letter that outlines the corrective action plan

 9.  Corrective action plan must include expected dates of completion for each element in plan

10.  <<Staff Title>> calls participant or representative

11. <<Staff Title>> shares with participant or representative F/EA’s corrective action plan to resolve the complaint or grievance

12. <<Staff Title>> records communication in Payroll System per Policy and Procedure document

13. <<Staff Title>> submits written corrective action plan to participant or representative

14. <<Staff Title>> records in Customer Service System per Policy and Procedure that written corrective action plan was submitted to participant

15. Written corrective action plan and fact-seeking document are scanned to participant’s scan folder and maintained for a minimum of 7 years per File Retention Policy

16. If the participant or representative is not satisfied with the corrective action plan, he/she will contact F/EA within 3 business days of receiving the plan in writing

17. <<Staff Title>> will schedule a hearing with a mediator in an effort to resolve the issue to both partys' satisfaction

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All complaints and grievances are coded and recorded in Payroll System
  2. All complaints and grievances are reported to the <<Staff Title>> for review immediately upon receipt
  3. All complaints and grievances are reported to the <<Staff Title>> and <<Staff Title>> on the same business day as they are received
  4. All facts pertaining to complaint or grievance are sought and documented within 1 business day of receipt of complaint
  5. A corrective action plan is submitted to the participant in writing
  6. The corrective action plan and fact seeking document are scanned to the participant’s scan folder and maintained for a minimum of 7 years per File Retention Policy

Perform Internal Review of Complaints and Grievances

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Policy: 

On a monthly basis, <<Staff Title>> reviews complaints received for the month. <<Staff Title>> and other F/EA staff members determine if processes can be improved to minimize complaints and improve services to program stakeholders. Processes that can be improved are reviewed with <<Staff Title>> and Chief Financial Officer as applicable and process changes are implemented. 

As applicable, Counselors and consumers are notified of any changes to policies or procedures.
Procedure: 

 

  1. On a monthly basis, <<Staff Title>> reviews complaints and resolutions for the month that just ended
  2. <<Staff Title>> double clicks on Shortcut to Note Viewer icon on desktop
  3. <<Staff Title>> identifies any themes of complaints
  4. Where possible, <<Staff Title>> identifies opportunities to adjust processes to increase participant satisfaction and minimize complaints
  5. <<Staff Title>> reports suggested process improvements to <<Staff Title>> Per <<Staff Title>> approval, <<Staff Title>> works with applicable staff and Chief Financial Officer to implement process changes.
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All complaints and grievances are coded and recorded in Payroll System
  2. Complaints are recorded by Customer Service staff and independently reviewed by <<Staff Title>>
  3. <<Staff Title>> and Chief Financial Officer work with staff to implement changes to F/EA processes

Fair Labor Standards Act

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Policy: 

F/EA will comply with the Fair Labor Standards Act Home Care Rule announced by the Department of Labor on October 1, 2013 and effective October 13, 2015.  The Home Care Rule narrows and clarifies circumstances under which the companionship exemption from minimum wage and overtime may be taken and the live-in exemption from overtime may be taken. In addition, the Rule clarifies the Department's position on joint employment as determined using the economic realities test. The Rule also contains guidance on shared living scenarios.

The guidance on joint employment in particular holds profound implications for self direction programs. If a third party joint employer is found to exist in an employment relationship, the third party joint employer cannot use the companionship exemption nor the live-in exemption.

Due to DOL's joint employment guidance, third party overtime and travel time may have to be paid when a worker is employed by multiple participants in a program, depending on whether a joint employer (e.g., an FMS provider, state, or managed care organization) exists. If so, all hours worked over 40 per work week must be paid at time and a half, with overtime not paid from any participant's budget but by the third party joint employer if the participant was not personally responsible for overtime. For example, Employee Z works for Participant A for 20 hours per week and Employee Z works for Participant B for 25 hours in the same work week. Employee Z travels from one shift for Participant A to another shift for Participant B.  5 hours of overtime must be paid to Employee Z, but not from Participant A or B's budgets.  In addition, travel time from Participant A to Participant B must be compensated by the third party joint employer as wages.

Despite not being employers per the IRS's common law test, Fiscal/Employer Agents can be joint employers per DOL's economic realities test.

Procedure: 

Procedures are not included at this time because each program's policies and procedures depend on their individual program design and state's response to FLSA compliance.

Policy and Procedures: 
FLSA
Home Care Rule
home care
companionship exemption
joint employment
live-in exemption

Transfer Consumers

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Submit Consumer Records, Worker/Vendor Records, Tax Documents and Individual Budget Records to New F/EA

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Policy: 

 

When a participant transfers to a new Fiscal/Employer Agent (F/EA), F/EA must provide the new F/EA with all Consumer Records, Worker/Vendor Records, Tax Documents and Individual Budget Records to New F/EA and other documentation relating to the participant within <<10 days>> of notification that the participant is transferring.
 
Forms and documentation are collected from the participant’s electronic files. All forms and documentation are submitted to the F/EA to which the participant is transferring.
 
The Individual Budget balance is provided to the F/EA to which the participant is transferring. An Individual Budget balance report showing all allocation amounts issued for the participant, the start and end date of the budget, the approved amount, the spent amount and the amount remaining is produced, verified and submitted to the new F/EA.
Procedure: 

<<Insert Process to Collect, Verify and Transfer Applicable Records>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. Per Policy and Procedures, documents are scanned to a participant’s scan folder and stored for a minimum of 7 years per File Retention Policy.
    • These electronic files are collected, printed and submitted to the new F/EA when a participant transfers
    • The scan folder is moved to a transferred consumers location on the network so that it is not confused with active participant folders
  2. Consumer’s records are printed and submitted to the transferring F/EA.

Manage Taxes for Transferring Consumers

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Policy: 

When a participant transfers from F/EA to a new Fiscal/Employer Agent (F/EA), F/EA submits certain tax information to the new F/EA within 10 days of the participant transferring to the new F/EA. 

F/EA submits a final Payroll Summary to the new F/EA for transfers that occur within a calendar year and for those that occur at calendar year end.
 
For transfers that occur at calendar year end, special handling of Social Security and Medicare taxes (FICA), Federal Withholding Tax (FWT) and Federal Unemployment Tax (FUTA) is not required. For transfers that occur within a calendar year, (but not within a quarter) however, special procedures apply.   Consumers are never permitted to transfer from one F/EA to another within a calendar quarter.
 
The transition for state income tax unemployment tax can happen in a straightforward manner since generally these taxes are filed and paid under the participant employers’ separate EIN.  However, the current F/EA must make sure to retire any state Power of Attorney or Authorization it might have for the particular individual/representative-employer once all state taxes are filed and paid for the period in which the current F/EA served the employer (See Retire and Revoke Account Numbers and Authorization).  Upon transitioning from an old F/EA to new F/EA, the old F/EA must provide the new F/EA with reports showing all State Income Tax and State Unemployment Tax liabilities and deposits to date for the calendar year.
 
The process to manage Federal Employment taxes for an employer who transitions between F/EAs in a calendar year is tenuous and is described in detail in the below procedure.
 
Procedure: 

Process to Transfer State Tax Data when a Consumer Transfers from one F/EA to Another within a Calendar Year

  1. When F/EA is notified that a participant is transferring to another F/EA within a calendar year <<Staff Title>> records that the participant is transferring and the effective date
  2. <<Staff Title>> produces a Tax Report from the Payroll System
    • Report shows paid and yet unpaid taxes due to state tax agencies on the participant’s behalf
    • <<Staff Title>> verifies the report for mathematical accuracy
  3. <<Staff Title>> submits State Tax report to new F/EA for the participant
  4. New F/EA is responsible for filing State Income and Unemployment Taxes on behalf of participant for all future quarters.

Process to Transfer Federal Tax Data when a Consumer Transfers from one F/EA to Another within a Calendar Year

1.    F/EA 1 makes deposits to IRS for any FICA withheld throughout year.

2.    For any employer-employer who transfers from F/EA 1, F/EA 1 provides F/EA 2 with all information on wages paid to the employer’s workers(s) and federal employer and workers FICA taxes withheld and deposited.

  • At the time of transfer, F/EA 1 DOES NOT refund any FICA to transferring employer-employers and their applicable workers who did not earn wages equal to or in excess of the FICA wage threshold nor does the F/EA issue IRS Forms W-2 for the support service workers at this time. 

3.    F/EA 2 records wages paid to the employer-employer’s workers(s) by F/EA 1.  F/EA 2 will include wages paid by F/EA 1 when determining if a employer-employer and his/her workers are eligible for a refund of over collected FICA at the end of the calendar tax year.

  • F/EA 2 takes particular note of any employer-employer’s workers who have not yet been paid wages equal to or in excess of the FICA wage threshold.  These employer-employers and workers may qualify for a refund of over collected FICA if one or more workers do not earn wages equal to or in excess of the FICA wage threshold after F/EA 2 finishes paying wages to the applicable workers on behalf of the employer-employer at the end of the calendar tax year.

4.    By November 1st each year, F/EA 2 provides F/EA 1 with a report of wages it has paid and taxes it has deposited for all transferred employer-employers and their workers.

  • Based on what each F/EA has paid transferred employer-employers’ workers and the information each F/EA receives from the other about what the wages they have paid to these workers, F/EA 1 and 2 determine which employer-employers and workers are likely to be eligible to receive a refund of over collected FICA for the particular calendar tax year.
  • Each F/EA verifies each applicable workers’s address using the standard address verification process.
  • At year end, refunds of over collected FICA (employer and workers portions) are issued only to eligible employer-employers (most likely the state) and workers (i.e., workers who have been paid wages less than FICA wage threshold) and whose addresses has been verified.

5.    After the last payroll in the calendar tax year, F/EA 2 determines if any additional workers transferred from F/EA 1 have been paid wages by F/EA 1 and 2 equal to or in excess of the FICA wage threshold for that calendar tax year or not.

  • F/EA 2 provides wage information for applicable workers to F/EA 1.

6.    For each workers that has not earned wages equal to or in excess of the FICA wage threshold in the calendar tax year for services provided to their employer-employer, both F/EA 1 and 2 determine the total employer and workers share of FICA that was over-collected by each F/EA and that is to be refunded by each F/EA.

  • Both F/EAs deduct the amount of over collected FICA that is to be refunded from one or more final federal tax deposit(s) in the last quarter of the calendar tax year.
  • If the deposit(s) in the last quarter of the calendar tax year are not sufficiently large enough to cover the total amount of over collected FICA to be refunded, the F/EA may do the following:
  • The F/EA reports balance of the over collected FICA amount not deducted from the last deposit(s), on Box 15 of the 4th quarter IRS Form 941 for the calendar tax year and checks the box for “Send a Refund.” The 4th quarter IRS Form 941 is submitted to the IRS on or before January 31st.  The F/EA usually will receive the over collected FICA funds for distribution on or after April 15th. 
  • The F/EA should process all FICA refund checks for the workers portion of FICA to the applicable workers prior to issuing IRS Forms W-2.
  • The State may require the F/EA to refund the employer portion of FICA either to the employer-employer or the State (the majority of states currently choose to receive these funds).    If the F/EA can not obtain sufficient funds from withholding FICA from the last deposit(s) to cover the over collected FICA amount, the F/EA should refund the workers’ for over collected FICA first and then refund either the State or employer-employers for the employer portion of over collected FICA once the F/EA receives the FICA refund from the IRS, which is usually on or after April 15th.  The State must determine whether the State or the employer-employer will receive the employer portion of over collected FICA, the procedure for doing so (see footnote 3) and inform the F/EA.

7.    If the F/EA will operate as an agent in the next calendar year, it has another option for obtaining a refund of over collected FICA that was not deducted from the deposit(s) in the last quarter of the calendar tax year.  The F/EA can report the balance of over collected FICA (not obtained from deposit(s) in the last quarter of the calendar tax year) in Box 15 and check the box for “Apply to Next Return” on the 4th quarter IRS Form 941 submitted to the IRS on or before January 31st.

  • Then the F/EA deducts the amount included in Box 15 from a deposit made for wages paid in the first quarter of the next calendar year.
  • On the 1st quarter IRS Form 941 filed by the F/EA on or before April 30th, the F/EA includes that amount in the amount in Box 11 on the Form.

Once the balance of over collected FICA is received by the F/EA, the F/EA then issues the refund of over collected FICA to the applicable employer-employer or State based on the instructions provided by the State self-directed program agency.

8.    There may be a case where all IRS Forms 941 have been filed and all FICA has been deposited for employer-employers and workers for a particular calendar tax year, but over collected FICA has not been withheld for refunding.  In this case an F/EA must request a refund from the IRS of over collected FICA so it can refund FICA to eligible employer-employer(s) and support service workers.  To obtain a refund of over collected FICA, the F/EA can file an IRS Form 941X per IRS Form instructions.

  • Over-collected FICA reported on an IRS Form 941X will be sent to the F/EA by the IRS on or after April 15th.
  • It should be noted that when any adjustment is made to an IRS Form 941 after the form has been filed with the IRS (due to over collected FICA or other reasons), the F/EA must complete an IRS Form 941X for that quarter, showing any adjustments or corrections on the IRS Form 941X.

9.  Any FICA refund checks that are returned to the F/EA should be reported
per the state’s unclaimed or abandoned property law.

10.    When a workers does not receive wages equal to or in excess of the FICA wage threshold, they still can receive an IRS Form W-2.  In the case where a employer-employer transfers F/EA in a calendar tax year, the support service workers will receive an IRS Form W-2 from F/EA 1 and F/EA 2.  Both F/EAs should report FICA wages paid to the workers on the IRS Form W-2 they prepare and issue, completing the rest of the Form per IRS instructions for agents. 

However, it should be noted that currently the Social Security Administration (SSA) will not allow an F/EA to electronically file an IRS Form W-2 if the Form reports FICA wages greater than zero but below the FICA wage threshold.  However, F/EAs that file 250 or more Forms W-2 must file electronically or be penalized $50 per Form filed in hardcopy.  Discussions currently are underway with IRS to see if SSA will adjust their Form W-2 e-filing rules so as to allow F/EAs to electronically file IRS Forms W-2 that report FICA wages that are greater than zero but below the FICA wage threshold.
 

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification. 

  1. <<Staff Title>> reviews tax report received from reporting agent for mathematical accuracy.
  2. A control document is used to track each transfer requirement for a participant and the dates that each transfer requirement was met.

Service Claims

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Enter Consumers in Billing System

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Policy: 

These policies, procedures and internal controls depend on the F/EA's billing processes.

Submit Service Claims to <<MMIS, State, Other>>

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Policy: 

On a weekly basis, <<Staff Title>> produces a claim file for all payrolls processed in the most recent payroll cycle and any claims that were put on hold from a previous payroll cycle. Claims are produced per the format for electronic submission as specified by State/MMIS Provider. 

Each claim is verified for accuracy, completeness and compliance with program rules and regulation prior to submission. Claim file submissions are recorded in a control sheet.
 
After submitting a claim, a journal entry template is created and a posting made to the General Ledger.
Procedure: 

Process will vary based on program rules and F/EA systems.

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. System access is restricted to those staff who have direct responsibility for service claim production
  2. Before completing the current payroll cycle’s billing, values in the billing system are reviewed to ensure that the billing from the last cycle was completed
  3. Each daily bill file is reconciled to the daily payroll report
    • Discrepancies are researched and resolved prior to proceeding
  4. Adjustments are made using control documents provided by the Payroll Department
    • All adjustments are stored for reconciliation purposes
  5. <<Staff Title>> reconciles supporting documents to ensure billing is submitted appropriately and payments are applied to claims appropriately.
  6. <<Staff Title>> creates journal entry templates.
    • Each journal entry template is used as a control document.
    • Each reconciliation document is prenumbered
    • <<Staff Title>> signs and dates verifying accuracy
  7. F/EA Accountant reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • F/EA Accountant signs and dates journal entry template.
  8. <<Staff Title>> reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • <<Staff Title>> signs and dates journal entry template.
  9. F/EA Accountant posts journal entries.
  10. F/EA Accountant reconciles General Ledger to appropriate supporting documents at year-end.
  11. F/EA Accountant produces reconciliation documents, verifies, signs and dates.
  12. <<Staff Title>> reviews, verifies, signs and dates reconciliation documents

Process Service Claim Payments

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Policy: 

Claims submitted to <<MMIS/State>> for payments made on behalf of consumers for tax purposes are referred to as service claims. 

On a weekly basis, or as payments for service claims are received by F/EA, <<Staff Title>> loads the electronic payment remittance file to Billing System. The payment is reconciled to open claims in Billing System. Any denied claims are noted, accounted for and researched.
 
Open claims in the ETS billing system are reconciled to the Accounts Receivable on the Wash Claim billing control sheet. After reconciling and resolving any discrepancies, <<Staff Title>> creates a journal entry template to post the service claim payments to the General Ledger.
 
After reviewing the journal entry template and supporting documents, the <<Staff Title>> and F/EA Accountant sign and date the journal entry template. The F/EA Accountant posts payments to the General Ledger (See Policy and Procedure 20.5).
 
After posting payments, a reconciliation of the General Ledger account to ETS Accounts Receivable is performed (See Policy and Procedure 2.15).
Procedure: 

Post Service Payment to Billing System

<<Process will vary depending on State payment process and F/EA billing system and processes>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reconciles Cash Account Transactions-Batch Control report to Remittance Advice to the electronic payment file to ensure payment file has been received appropriately.
  2. <<Staff Title>> reconciles payment file that has been applied to open service claims to remittance advice to ensure payment claims were not misapplied to open claims.
  3. <<Staff Title>> enters all values in a billing control document.
  4. <<Staff Title>> reconciles the Accounts Receivable report to billing control document to ensure that all payments and denials have been correctly accounted for.
  5. Paper and electronic copies of all documents are maintained for a minimum of 7 years per File Retention Policy.

Process Denied Service Claims

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Policy: 

Service Claim Denials are processed within 10 days of an Service Claim payment being posted. The <<Staff Title>> researches each denied claim. Where applicable, the <<Staff Title>> adjusts the claim and resubmits it. The Service Claim Accounts Receivable is updated per denials and resubmissions.

Procedure: 

 

  1. After a payment is posted for an service claim submission  <<Staff Title>> completes denial process within 10 days
  2. <<Staff Title>> goes to <<File Path>>
  3. <<Process will vary depending on state and F/EA procedures>>
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> researches each denial and corrects denials as appropriate.
  2. <<Staff Title>> reconciles denied and rebilled amounts from claim to billing system.
  3. A Billing Control sheet is completed showing denied and re-billed claims.
  4. The year-to-date accounts receivable balance for service claims in the billing system is reconciled to the Accounts Receivable balance in the F/EA Billing Control sheet.
  5. A Tracking Number confirmation receipt is printed after submitting rebilled denials to State submission website.
  6. F/EA Accountant posts journal entries.
  7. F/EA Accountant reconciles General Ledger to appropriate supporting documents at month end.
  8. F/EA Accountant produces reconciliation documents, verifies, signs and dates.
  9. <<Staff Title>> reviews, verifies, signs and dates reconciliation documents

Post Service Claims and Payments to General Ledger

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Policy: 

After successfully submitting a valid service claim file, the <<Staff Title>> reconciles the recently submitted claim to the Accounts Receivable balance in the billing sub-system. The <<Staff Title>> updates the Billing Control form with the applicable Accounts Receivable values and creates a journal entry template. 

After reviewing the journal entry template and researching and resolving any discrepancies, the F/EA Accountant posts applicable entries to the General Ledger. A reconciliation process is performed monthly and is reviewed by the F/EA Accountant and <<Staff Title>> (See Policy and Procedure).
 
After receiving a payment for a previously submitted claim, <<Staff Title>> applies the payment to open claims in the Billing System and tracks denied claims. The <<Staff Title>> updates the Billing Control form and reconciles the payment to the Accounts Receivable balance in the billing system. The <<Staff Title>> creates a journal entry template.
 
After reviewing the journal entry template and researching and resolving any discrepancies, the F/EA Accountant posts applicable entries to the General Ledger. A reconciliation process is performed monthly and is reviewed by the F/EA Accountant and <<Staff Title>> (See Policy and Procedure 2.15).
Procedure: 

Post Service Billing to General Ledger

Performed Monthly
Account <<99999>>
  1. <<Insert Process>>

Post Accruals to General Ledger

Performed Monthly
Account <<99999>>
  1. An accrual is the amount that has been put on hold, meaning it has not yet been submitted as a claim to the Program, but must be counted in Accounts Receivable
  2. <<Insert Process>>
 
Post Payments to General Ledger
Performed Monthly
Account <<99999>>
 

<<Insert Process>>

Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. <<Staff Title>> reconciles supporting documents to ensure billing is submitted appropriately and payments are applied to claims appropriately.
  2. <<Staff Title>> creates journal entry templates.
    • Each journal entry template is used as a control document.
    • Each reconciliation document is prenumbered
    • <<Staff Title>> signs and dates verifying accuracy
  3. F/EA Accountant reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • F/EA Accountant signs and dates journal entry template.
  4. <<Staff Title>> reviews supporting documents and journal entry template for completeness and mathematical accuracy.
    • <<Staff Title>> signs and dates journal entry template.
  5. F/EA Accountant posts journal entries.
  6. F/EA Accountant reconciles General Ledger to appropriate supporting documents at year-end.
  7. F/EA Accountant produces reconciliation documents, verifies, signs and dates.
  8. <<Staff Title>> reviews, verifies, signs and dates reconciliation documents

Administrative Task Claims

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Policy: 

Administrative Task Claims are bills submitted by the F/EA to the program for the work that the F/EA does.  Billing for Administrative Tasks varies significantly by state.  Policies, procedures and internal controls vary and should be updated accordingly for each state and program.

Submit Administrative Task Claim to Program Payer

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Policy: 

 On a <<monthly>> basis, the F/EA submits claims to the program adminstration agency to be reimbursed for the F/EA's work in the program.  This is referred to as the "administrative claim."  The administrative claim must be submitted by the <<15th day>> of the month following the month being invoiced.  <<insert any other policy information for your administrative claim process.>>

Procedure: 

<<insert the appropriate procedures for the F/EA's unique administrative claiming process into each of the sections below, or create different sections.>>

Prepare and Validate Administrative Billing Claim 

 
Prepare Final Administrative Claim File for Submission to Program Administrator
 

 

 
Upload Administrative Claim File to Program Administrator
 

 

 
Enter Monthly Admin Billing to YTD Accounts Receivable
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

<<insert internal controls based on the F/EA's procedure>>

Process Administrative Task Claim Payments

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Policy: 

 The program administration agency pays administrative claims submitted by the F/EA.  <<Insert the policy for that here.>>

Procedure: 

 <<Insert the procedure for collecting administrative claim payments from the payor.>>

Internal Controls: 

 <<Insert internal controls based on the procedure.>>

Post Administrative Task Claims and Payments to General Ledger

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Policy: 

 <<Insert the F/EA's policy for posting administrative claim payments to the F/EA's General Ledger.>>

Procedure: 

  <<Insert the F/EA's procedure for posting administrative claim payments to the F/EA's General Ledger.>>

Internal Controls: 

   <<Insert the F/EA's internal controls, based on the procedure, for posting administrative claim payments to the F/EA's General Ledger.>>

Process Denied Administrative Task Claims

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Policy: 

 <<In some cases, an administrative claim may be denied and never receivable and an F/EA will post that never receivable claim to the general ledger in a particular way.  Enter the policy for determining if a claim will not ever be receivable and for entering the claim into the General Ledger.>>

Procedure: 

<<Insert the procedures for determining if a claim will not ever be receivable and for entering the claim into the General Ledger.>>

Internal Controls: 

 <<Insert the internal controls based on the procedure.>>

Fraud

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Report Alleged Fraud to Program Administrator

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Policy: 

F/EA notifies Program Administrator in writing within ten calendar days of suspecting a potentially fraudulent situation as defined under 42 CFR 455.2. In addition to F/EA suspecting fraud, F/EA will notify Program Administrator in writing upon receiving a report of alleged fraud from a Counselor, participant, worker or other stakeholder. 

F/EA cooperates fully with the Office of the Attorney General’s Medicaid Fraud Control Unit (MFCU).   F/EA makes every effort to provide any requested information and documentation within 3 business days of request. 
 
F/EA maintains confidentiality of any investigations performed by Program Administrator, MFCU or other agency.
Procedure: 

  1. F/EA <<Staff Title>> (or assigned staff) completes a fraud report form under the following circumstances:
    • F/EA staff suspect fraud as defined under 42 CFR 455.2
    • A Counselor reports fraud or submits a form to F/EA
    • A participant, workers or other stakeholder reports fraud to F/EA either via phone, in writing or in person
  2. When fraud is suspected or reported, record issue in Customer Service System
  3. Collect and log all applicable information including:
  • Who is reporting suspected fraud
  • Description of suspected fraud
  • Parties involved with suspected fraud
  • When suspected fraud occurred
  • Where suspected fraud occurred

 4.  Open applicable fraud report form from <<File Path>>

 5.  Complete fraud report form with applicable information

 6.  In “Subject” check the box for the person that is suspected of fraud

 7.  In Consumer Information section, enter all applicable information for participant

 8.  Obtain participant demographic information from Payroll System

 9.  Obtain Individual Budget information from Payroll System

10. If workers is checked under Subject, enter applicable workers information

11. Worker information can be obtained from Payroll System

12. In Complainant section, enter all information pertaining to person who reported suspected fraud

13. Data can be obtained from entry made for issue in Customer Service System

14. Answer each of the three questions listed on the bottom of the form

15. <<Staff Title>> (or assigned staff) completes Person Completing This Report Section

16. For whatever period reported in the allegation, <<Staff Title>> runs report of participant's payroll history for the same period from Payroll System

  1. Mail fraud report to <<insert where report is mailed>>
    • Mail copy to participant’s Counselor
  2. Program Administrator will take corrective action and contact F/EA to request additional information or to direct F/EA to take additional action
Internal Controls: 

The internal controls used by F/EA to monitor this process establish responsibility, segregate duties, document procedures and ensure independent internal verification.

  1. All information related to report of alleged fraud is recorded in Customer Service System
  2. <<Staff Title>> reviews completed fraud report and supporting documents prior to submission to Program Administrator
  3. <<Staff Title>> signs completed fraud report and supporting documents prior to submission to Program Administrator
  4. Fraud report and supporting documents are submitted to participant’s Counselor at the same time that they are submitted to Program Administrator
  5. Fraud report and supporting documents are maintained at F/EA
    • Documents are scanned and maintained for a minimum of 7 years per File Retention Policy