LAURENS COUNTY DISABILITIES AND SPECIAL NEEDS BOARD POLICY AND PROCEDURE MANUAL

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1 LAURENS COUNTY DISABILITIES AND SPECIAL NEEDS BOARD POLICY AND PROCEDURE MANUAL SUBJECT: REFERENCE: DATE: Financial Management and Consumer Funds SCDDSN DD, SCDDSN DD, and SCDDSN DD July 24, 1990; Jan. 1995; revised April 13, 2000; Aug. 2002; Rev. Feb. 2003; Rev. July 2004; Rev. June 2009; Rev. Jan. 2010, Rev March 2013, Rev. Aug THIS POLICY IS NOT A CONTRACT OF EMPLOYMENT FOR ANY DEFINITE PERIOD OF TIME, NOR DOES IT GUARANTEE ANY PARTICULAR POLICY OR PROCEDURE. EMPLOYMENT WITH THE LAURENS COUNTY DSN BOARD REMAINS ON AN AT-WILL BASIS. PURPOSE: To clarify costs chargeable to each consumer s personal funds. The following listing is not all-inclusive, but representative of the major areas of program costs. I. Admission Procedures A. Financial Status upon Admission 1. Each consumer or the consumer s fiscal representative is required to provide a financial statement of the person s resources upon admission. This financial statement should be updated when significant changes occur, or upon the request of the facility staff. 2. Each consumer must be informed of his/her financial rights by the staff prior to or at the time of admission to a residential program. There must be a written acknowledgement in the consumer s file that the financial rights have been explained by his/her guardian, parent, next of kin, sponsoring agency or representative when: a. The person is found by interdisciplinary team to be mentally incapable of understanding his/her rights, and this finding is documented in his/her file; or b. The person has been adjudicated in competent in accordance with state law. A copy of the order must be placed in the person s permanent file.

2 This notification shall be acknowledged in writing by the person, or the person s guardian, parents, next of kin, sponsoring agent, or representative through use of the statement of Financial Rights form. The signed Statement of Financial Rights/Authorization shall be placed in the person s permanent file. B. Custody of Funds Consumers should be requested to entrust personal funds to the LCDSNB except in one of the following cases: 1. The consumer chooses to manage his/her own funds; 2. The consumer s interdisciplinary team justified another financial management alternative; 3. Another party has been appointed representative payee by the Social Security Administration; 4. The consumer has chosen another to be his/her financial representative. A consumer may mange his or her personal financial affairs, or may designate another party to do so, or may authorize the provider to manage his/her personal financial affairs. The authorization will be documented on the Financial Rights/Authorization form. C. Collective Account (For CTH II, CRCF, and ICF/MR) The LCDSNB maintains a collective account for consumers in the CTH II s, CRCF s and ICF/MR s for personal funds. A collective account is supported by a system of records-keeping sufficient to establish a separate sub-account for each consumer having funds in the collective account and to allocate any interest earned to each sub-account within the collective account. A collective account should not prevent a consumer with appropriate financial skills identified through his/her individual Life Plan from having a personal checking account. D. Establishment of Account (For SLP I and II) A checking account and/or savings account must be established by the LCDSNB for each consumer and maintained according to the following guidelines: Page 2 of 13

3 1. This account must be separate from any other accounts of the Agency; 2. Each account will be in the consumer s name and Social Security number, or will indicate that the account is for the benefit of the consumer (ex. LCDSNB for John Doe); 3. All benefit or entitlement checks received by the consumer shall be deposited into his/her account; 4. All other funds such as wages or gifts shall be deposited unless an exception to this procedure is approved for programmatic reasons by the interdisciplinary team and documented in the consumer s financial plan. 5. All withdrawals require a co-signature of the facility or program director or his or her designee, unless the consumer s financial plan specifically waives this requirement; 6. A copy of the bank signature card should be placed in the consumer s permanent file; 7. Consumers are responsible for a bank s check charges and normal service charges for commercial bank or savings accounts. II. Financial Rights A. The LCDSNB will not charge any resident to hold, safeguard and account for personal funds. B. Current, written, individual records of all financial transactions involving a consumer s personal funds will be maintained. C. Each consumer will be provided with reasonable access to his or her own financial records and personal funds. D. Each consumer s personal funds received by the LCDSNB for holding, safeguarding and accounting will be kept separate from the operating funds of the LCDSNB. Page 3 of 13

4 III. Allowable Consumer Charges (ICF/MR only) A. Charges Inclusive in Care and Maintenance 1. Professional and Special Programs and Services Provision of services contingent upon a thorough evaluation of the needs of each consumer: a. Health Services b. Dental Services c. Training and Habilitation Services d. Dietary/Nutritional Services e. Pharmacy Services f. Physical and Occupational Therapy g. Psychological Services h. Speech and Audiology Services 2. Items/Services Necessary to the Physical Well-Being of the Consumer To the extent the Item/Service does not exceed customary costs or is approved by the consumer s ID Team to be a customary cost. a. Minor medical supplies b. Utilization of equipment and facilities c. Basic Laundry services d. Special dietary supplements e. Sheets, towels, wash cloths, diapers, soaps, and bathroom tissue f. Basic personal grooming and care articles and/or services (to include a haircut) 3. Administrative costs 4. Personal Costs 5. Physical plant maintenance 6. Bed and Board Page 4 of 13

5 B. Items/services that can be charged to Residents Personal Funds if recommended by the Interdisciplinary Team: 1. Personal Grooming and Care Articles or services of a special nature, beyond those already provided by the LCDSNB. Determination of consumer funds to be used will be completed prior to item or service purchased by consumer s ID Team. The consumer will be informed of cost associated with chosen item/service before funds are obligated. Residential staff, using the Consumer Purchase Authorization, will calculate amount of consumer funds used. This form will subtract LCDSNB s current cost for a like item from cost of the item the consumer is requesting. The consumer will only be responsible for the difference in cost. 2. Personal Recreational Items and Equipment not covered under a required activities program. Bicycles, magazine or newspaper subscriptions, aquarium plants, radios, television sets, records, books, etc. 3. Miscellaneous Items: Special food/drinks not essential to the resident s dietary needs e.g., candies, fruits, cookies, soft drinks; tobacco products and accessories e.g., cigars, cigarettes, tobacco, pipes, etc.; expenses involved in relatives visits to the facility or a resident s visit/extended stay in the home setting; postage, stationery; insurance premiums; payment of required taxes; special entertainment, recreational activities, etc. 4. Special Medical Equipment, Supplies, and Services for Convenience of Consumers and their Families: Certain purchases of medical equipment, supplies, and services that are for the convenience of consumers and their families and are not determined by the ID Team to be medical necessities may be purchased with consumer funds. This would include, but is not limited to, items such as an extra wheelchair for home visits, or certain non-essential chiropractic, podiatry and dental services. These items and services are considered to be for the convenience of consumers and their families and would not be allowable as charges to the Medicaid program. 5. Damaged Property: Consumer funds may be used to replace property owned by staff, the LCDSNB, or other consumers that the consumer has damaged, where this is consistent with the consumer s plan of care and where funds are available. Page 5 of 13

6 IV. Allowable Consumer Charges (CTH II and CRCF) A. Charges Inclusive in CTH II and CRCF Rent 1. Professional and Special Programs and Services Provision of services contingent upon a thorough evaluation of the needs of each consumer: a. Health Services b. Dental Services c. Training and Habilitation Services d. Dietary/Nutritional Services e. Pharmacy Services f. Physical and Occupational Therapy g. Psychological Services h. Speech and Audiology Services 2. Items/Services Necessary to the Physical Well-Being of the Consumer a. Minor medical supplies b. Utilization of equipment and facilities c. Basic Laundry Services d. Special Dietary supplements 3. Administrative costs 4. Personal Costs 5. Physical Plant Maintenance 6. Bed and Board B. Items/services that can be charged to Residents Personal Funds if recommended by the Interdisciplinary Team are noted in Appendix A V. Deposit Procedures (ICF/MR, CTH II, CRCF, SLP 1, SLP 2) A. All sources of income for a consumer must be deposited into his/her account unless otherwise specified in the financial plan included with the individual s Life Plan. All income must be deposited within five business days of receipt. Page 6 of 13

7 B. Where possible, Social Security, Supplemental Security Income, Veteran s Administration benefits, and other unearned income should be on the automatic deposit system to a person s bank account. VI. Withdrawal Procedures A. A financial plan for each consumer will be determined by the Interdisciplinary Team and included in the consumer s Life Plan. The financial plan should include the determination of the resident s capability in managing his own funds, and the general goals of whether to spend or save portions of the resident s funds. A maximum checking account balance should be established based on the normal cash flow needs for each individual consumer. A staff representative will be appointed by the ID Team for consumers not capable of making an adequate decision with respect to their needs. Expenditures over $ must be approved by the ID Team. Once the financial plan for each resident has been determined by the ID Team, this information should be forwarded to the Finance Office for record retention. B. Authorized Signature File Each Consumer s Bank will maintain an authorized signature file (Attachment B) to be used in verifying all withdrawals from the Client s Bank by either the staff or resident individuals. Consumer s signature shall be involved for individuals determined by the program team as capable of maintaining their own funds. Finance will maintain a file for each home showing the proper signature of the QMRP/Coordinator and/or any other staff within the home authorized to approve a Funds Draft. The file will also list the staffs that are eligible to pick up funds from the Consumer s Bank. The QMRP/Coordinator is responsible for establishing the authorized signature file and notifying the Consumer s Bank of any changes. C. Residents may request withdrawal of funds from their account. 1. All requests for payment must be to the administrative office by 12:00 on Tuesday (Collective Account only). 2. All checks for over $50 will have to be made to a vendor (not payable to the consumer). Page 7 of 13

8 3. All check requests for over $ must have an ID Team approval before the request will be processed (excluding utilities and rent). 4. Emergency withdrawals and financial conferences with parents or guardians will be handled as they arise. D. Personal Funds Drafts and Group Withdrawal Drafts must be completed fully (Collective Account only). 1. Two signatures (one by QMRP, CTH Coordinator, Residential Director, or Assistant Residential Director). 2. Consumer s signature is required (if a mark, then a witness to the mark must sign above the mark). 3. Social Security #, Name, Residence, Purpose and Check Payable to must be completed. 4. Finance will not process if any information is incomplete, and the request will have to wait until the following Wednesday for payment. 5. When payments are picked up: Finance will complete sections Verified By, Paid By, and Check Number. 6. When payments are picked up: Finance will complete sections Received By and Date. 7. If the requests are on a Personal Funds Draft (Attachment D), then staff will have three business days from the day you pick up the money to return the receipts. 8. If the requests are on a Group Withdrawal Draft (Attachment D), staff will have until the money is depleted to return the receipts. However, staff will not be given any more funds for a house by means of Group Withdrawal until finance has received the yellow copy, receipts, receipts worksheet, monies being returned and all signatures required to finish the transaction. 9. All receipts must be returned with a Consumer Financial Worksheet (Attachment E). Receipt will not be accepted if the worksheet is not attached. 10. When returning receipts, you will need to return the original receipts, a worksheet for each receipt listing the items purchased Page 8 of 13

9 with a signature of a QMRP, CTH Coordinator, or Residential Director the yellow copy of the request and each physical receipt must be signed by a person who accompanied the consumer on the shopping trip and the consumers involved. E. Residents may receive counseling by QMRP/Coordinator concerning financial matters at their request, at the request of staff, or when the maximum checking account balance has been exceeded. F. Money is to be kept in the residence safe. G. A control mechanism (Attachment F) will be maintained for each individual and show the following: 1. Date of transaction. 2. Amount of deposit and withdrawal 3. Current balance 4. Employee s initials (QMRP/Coordinator or designee) 5. Individual s initials (if possible) 6. Attachment H. It is the consumer s option to keep his/her canteen money in his/her possession if deemed appropriate by the ID Team. I. Consumers will participate in programs and activities involving the normalized use of money. J. All provider staff having access to any funds shall be bonded. The amount of the bond shall be sufficient to cover all funds to which the staff have access. VII. Reconciliation A. A check should be written from a consumer s account to the provider to cover allowable fees for service. B. Consumer bank statements must be reconciled to the balances in the associated check registers or other ledger within ten business days of receipt. The bank s statement will be reconciled by a staff member who is NOT a co-signer for the account, and the statement, Reconciled on (Date Page 9 of 13

10 of Reconciliation) by (Reconciler s Signature), should be written on the front of the bank statement. If the account is out of balance by more than $5.00 and the problem is not identified and corrected within ten business days, the person doing the reconciliation shall notify the Finance Director. If the Finance Director has not resolved the problem within five additional business days, he/she will notify the Executive Director. C. Cancelled checks, deposit slips, and receipt of purchases must be attached to the monthly bank statement. Receipts for incidentals of a nonpermanent nature do not have to be retained. Examples of such items are snacks, video rentals, and movie tickets. Receipts for all purchases made by staff on behalf of residents should be retained. The bank reconciliation and receipts must be retained on file for at least six years, or if an audit exception if found, until resolution of the audit. In the case of an audit exception, the audit team will indicate when retention of the statements is no longer required. D. Each person must have reasonable access to his/her personal funds and financial records. Each person will receive a report of his/her account(s) at least monthly. E. All transactions for an account will be recorded in a check register or similar ledger. VIII. Accounts for Consumer Living in ICF/MR Community Residences under a management contract. This section outlines procedures that apply to personal funds of all consumers living in ICF/MR management contract residences. For these consumers, SCDDSN is responsible for establishing their Medicaid eligibility and doing the necessary reporting of financial resources to maintain their Medicaid eligibility. Funds for these consumers are managed using two accounts one a community account that functions similarly to a checking account, and one regional bank account that functions similarly to a savings account. A. Establishment of Regional Bank Accounts A regional bank account will be established at the respective regional facility for each individual in an ICF/MR management contract facility. The regional account is the individual s master checking/savings account. LCDSNB Policy on financial management of clients personal funds must be followed with respect to withdrawals from the account. Page 10 of 13

11 B. Background It is necessary to maintain an amount of personal funds in the local community for individuals living in ICF/MR management contract residences in commercial banking checking accounts. This will ensure that they have reasonable access to their funds and have the opportunity to improve their money management abilities. Rather than consumer commercial checking accounts, a provider may, with approval of Central Office, maintain a collective account for individuals personal funds. A collective account must be supported by a system of records-keeping sufficient to establish a separate sub-account for each person having funds in the collective account and to allocate any interest earned to each sub-account within the collective account. All requirements of consumer check or savings accounts apply to consumer sub-accounts within a collective account. Use of a collective account should not prevent a consumer with appropriate financial skills identified by a provider through his/her Consumer Single Plan from having an individual checking account. The commercial community checking account is an extension of the consumer s regional master account, and all expenditures out of the community checking account must be posted to the regional account. This is accomplished by operating the community checking account as an imprest account. Funds required for major purchases should be accumulated and requested from the consumer s regional bank account. C. Establishing the Community Checking Account 1. The provider must make arrangements with a local bank of a consumer s choice for him/her to use; 2. Consumers are responsible for bank check charges and normal service charges. There are no charges associated with regional bank accounts. No charges will be made to consumers whose funds are maintained in a collective account. 3. Each account must be established in a consumer s name and Social Security number, or will indicate that the account is for the benefit of the consumer. 4. The maximum balance is $ Executive Directors may request approval from Regional Finance Offices of a higher maximum balance on a consumer basis when the request is support by the financial plan for the consumer as stated in his/her IPP. Page 11 of 13

12 5. The checks must be signed by the consumer and a staff person designated in the regional bank signature file to approve personal funds drafts and group withdrawals. It is recommended that two staff plus the consumer be on the commercial bank signature card, but in all cases except incapacitating illness or death, the individual must sign the check. 6. A copy of the commercial bank signature card, with the name and address of the bank and account number, is to be sent to the Regional Finance Office to be placed in the consumer s financial record. A copy is to be placed in the consumer s unit record. D. Replenishing the Checking Accounts: The Regional Facility Director will establish procedures in compliance with policy on financial management of clients personal funds, to replenish the commercial checking accounts. These procedures should ensure that supporting documentation provides enough detail to post expenditures accurately to the consumer s regional bank account. The LCDSNB Finance Director will request replenishment, as needed, but must replenish at least once each quarter in an amount equal to the funds spent. E. Maintenance of the Checking Account a. All provisions for community accounts outlined (previously, in Sec. IV-A and B) shall apply to the community accounts for individuals in management contract ICF/MR s (except for previous B (2), (3), and (4)). b. All income shall be deposited into the regional bank account. Each region will establish procedures to accomplish this. c. All provider fees shall be paid from the regional bank account. d. One of the major goals in maintaining the community checking account is money management training. Therefore, the checking account activity (expenditures) should be reviewed as a minimum at the consumer s annual program plan meeting. e. Monthly statements from the regional bank of the consumer s account shall be produced and forwarded to the provider. These statements shall be filed along with the commercial bank account statements. Page 12 of 13

13 F. Discharges/Transfers: Closing Community Checking Accounts a. Transfers within the provider facilities will only require transferring the checkbook registers, checks, and bank statements to the new Community Residence Director. The bank signature card must be updated and copies placed in accordance with policy about establishing the community checking account. b. Transfers and discharges outside of a consumer s current provider s facilities will require that the present account be closed and a new account be established by the new provider. DDSN will establish local procedures to ensure receipt of and reviews of all checking accounts supporting documentation to include the checkbook registers, checkbooks, unused checks, and bank statements. Closed account records will be filed at the regional finance office for six years. c. The time lines outlined in policy (previous Section VIII) shall apply to both the community account and the regional bank account. Regional staff assigned to monitor standards shall review selected cases during the annual standards review and monitor other cases as indicated. Community checking account activity will be monitored by the regional Finance Office and is subject to various state and federal audits. Page 13 of 13

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