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Establishment of Workers as Employees of Consumers

Distribute Worker Hire Package

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

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

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

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)

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

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

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

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

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

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

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

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>>
  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.
  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

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

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.>>