Penalties and Interest Project Update. Employer Advisory Committee May 9, 2012

Transcription

1 Penalties and Interest Project Update Employer Advisory Committee May 9, 2012

2 > Agenda Contribution Account Portal update Regulations update Penalty & Interest Regulations Compliance (PIRC) Questions 2

3 Contribution Account Portal (CAP): System Modifications went live May 7, 2012 Redesigned Invoice Detail Report Invoice Detail Report available to Districts Redesigned Employer Account Activity Report Best Practice data filters for the Penalty data display Late contribution penalties presented at the employee level

4 Contribution Account Portal (CAP): System Modifications went live May 7, 2012 To align the latest regulation language with the system s penalty calculations Removal of $500 minimum for late adjustments Revised due date of Cash Balance adjustments to contributions providing 60 days from notification or discovery vs. 10 working days from pay period end date Revised due dates for part-time service based on actual pay date or assumed pay date Exemption of retroactive pay increase due to written employment agreement

5 > Regulations vs. System * Worker s Comp - timeframe exemption is not automated and will require dispute processing as needed Ed Code or Regulation - timeframe exemption is not automated and will require dispute processing as needed Part-time - exemption is not fully automated for Defined Benefit using assumed pay date Retroactive pay change - due to written employment agreement is not automated for Cash Balance and will require dispute processing as needed * The regulation language is what constitutes the penalties and interest rules regardless of how those rules are automated

6 Employer Training Ongoing Contribution Account Portal (CAP): Contribution Account Portal Navigation Ongoing through end of May Regulations Refreshers Contribution Processing Penalty Assessment Analysis Dispute Processing Pilot Period Support Employer Help available to answer questions and provide CAP support Business Readiness team available to support regulation questions and penalty avoidance

7 Key Reminders for Penalty Avoidance Estimate Payment Deposit - Given how the system applies your remittances to the reporting lines, be sure to submit enough estimate payment (i.e. by the 5 th business day) contributions to cover at least 95% of your current report service and 100% of your arrears service Example: Submitting a file containing a report for 5/31/2012 for $9,000,000 in contributions. The file also contains multiple late reports for 4/30/2012 and earlier, totaling $1,000,000 in new / changes to contributions. If you submit $9.5M on 6/7/2012 and $.5M on 6/21/2012, 100% of the late reports are already due and 95% of the 5/31 report (i.e. $9,550,000) $50,000 would be late by 14 days (difference between 6/7 and 6/21) producing a $ late contribution penalty

8 Key Reminders for Penalty Avoidance Deposit Association Associate your deposits on transmission of your contribution files Supplemental Files - If your payroll cycles are such that make it difficult to avoid late reporting / remittances, make sure your system and staff are capable of supplemental contribution file processing Late timesheets Many employers have initiated enhanced communications and improved procedures related to timesheet processing. Have you implemented you plan to minimize late timesheets?

9 Key Reminders for Penalty Avoidance Reporting / Remitting as Earned Are you reporting data and remitting contributions per each employees employment agreement s entitlement of pay? (e.g. Stipend work from Nov 2012 Feb 2013, contract pays Feb 28, Contribution due 5 and 15 business days from Feb 28, and reporting due 44 calendar days from Feb 28. Contribution line indicated service period dates of Feb 1 Feb 28 as earned in the month of February.)

10 PENALTIES & INTEREST REGULATIONS and COMPLIANCE PROJECT UPDATE (PIRC)

11 April 26, 2012 F496 Integrity check & business rule modifications New CB sub-account transaction codes New CB edits F496 Mass Approval Feature Annotations on Approvals July 1, 2012 Sierra Community College (Placer County) to pilot DB Direct Reporting from districts

12 QUESTIONS? Questions about the Contribution Account Portal and PIRC: Questions about regulations / penalty avoidance: P&I@CalSTRS.com