Page 1 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE APPROVED BY BOARD OF DIRECTORS SIGNATURE (Chief Representative) DATE TITLE: Financial Management POLICY: s financial accountability and viability are achieved through the application of sound financial management practices that accord with legal and regulatory requirements. This includes, but is not limited to a strict vigilance that all Generally Accepted Accounting Principals (GAAP) are adhered to at all times.
Page 2 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Governing Body Responsibilities PROCEDURE FIN 1: Catholic Charities Board of Directors: Approves the organization s annual budget; Reviews financial summaries at least quarterly to examine the relationship of budget to expenditures and revenues; Examines fiscal policy and the recommendations of the organization s auditors; and Annually evaluates the chief executive officer s management of the organization s fiscal affairs. IMPLEMENTATION: As noted in the Budget Guidelines under GOV 6.06, the Board of Directors receives the final version of the Catholic Charities budget at its yearend meeting each year. The Board will approve the budget at that meeting. The Board of Directors: Reviews and approves all planned expenditures deviations over $10,000.00, or 5% of program budget whichever is greater, and revisions to the budget prior to implementation; and Ensures that budget-to-actual variance analyses are performed after year-end numbers are finalized. IMPLEMENTATION: The Board regularly reviews the financial condition of the agency. Updates on Financial issues, including expenditure deviations or material variances by quarter are discussed at regular Board meetings. Financial reports are a fixed item on the Board of Director s meeting agenda.
Page 3 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Internal Control Environment PROCEDURE FIN 2: Catholic Charities establishes and maintains an internal control system that includes mechanisms for: review by the Board of Directors finance/audit committee; management review by more than one individual; assurance that management directives are carried out; prevention of error, mismanagement or fraud; safeguarding and verification of assets; and segregation of duties to the extent possible. IMPLEMENTATION: Receipts CATHOLIC CHARITIES FINANCE AND ACCOUNTING (Fiscal) SERVICES INTERNAL CONTROL GUIDELINES Contributions are usually received through fund drives or special events by the Development Office of Catholic Charities. Monies identified as from a fund drive go directly to Finance/Accounting. Contributions from special events are routed first to Catholic Charities Development Office. Miscellaneous contributions are received first by the Development or Administrative staff of Catholic Charities and then forwarded to Finance/Accounting with the appropriate coding designation. Finance/Accounting staff stamps all incoming checks with a restrictive endorsement and makes a photocopy of money received and prepares a deposit slip. Finance/Accounting staff codes deposit slip with batch info and records the deposit in the general ledger. Data entry person keys information to the accounting system. Finance/Accounting staff reconciles the accounting system report to the cash receipt documentation. Disbursements
Page 4 of 22 Program Directors, Associate Director or Executive Director authorize all expenditures via a check request/request for reimbursement form. Authorization is indicated by signature on the check request. Capital expenditures over $1,000 can only be made after three competitive bids have been obtained on the item to be purchased. These bids are to be kept on file at the program. When federal monies are expended, federal guidelines must be followed and Associate Director must be notified. The Executive and Associate Directors have authority to authorize all program expenses, sign contracts and sign checks. Bank Account Reconciliations Finance/Accounting staff receives bank statements and reconciles balances to the general ledger on a monthly basis. Director of Finance/Accounting reviews all bank reconciliations, including all outstanding checks or deposits, and any unusual items. Receivables Receivables are billed out of the Finance/Accounting Office. Receivables are all billed monthly unless otherwise stated in the grant or contract. Catholic Charities Accounting has a copy of each grant or contract and is familiar with the financial requirements. Catholic Charities Accounting uses whatever billing format has been included with the grant or contract to produce a completed, timely billing with the required supporting documentation. Catholic Charities Accounting will coordinate with Agency/Program Directors for statistical or non-financial information that may be required in the billing. Accounts Payable Finance/Accounting A/P staff monitors all expenditures, comparing approved invoice to contracted amount. Finance/Accounting A/P staff also assures that invoices are properly authorized, runs checks, and delivers checks along with the proper supporting documentation to Executive or Associate Directors for signature. GAAP supported separation of duties is maintained throughout the accounts payable process. All requests for checks and payments are approved by Program Directors, and then approved by Executive/Associate Directors. Finance/Accounting staff then verifies, codes, and checks the expense for appropriateness. Fees for Service
Page 5 of 22 Fee slips/receipts are filled out by the appropriate program employee and fees are collected at the time of service. The staff person collects from the participants and notes payments on the fee slips. Fee slips and money received are sent to Finance/Accounting for processing as outlined above under Receipts. Other General Internal Control Details All accounting detail is recorded in a secure, automated accounting system. All cash receipts, disbursements, revenues and expenses are processed and recorded in a timely and accurate manner. All accounts payable are monitored regularly (weekly and monthly) to insure prompt payment of all expenditures. The Finance/Accounting staff periodically evaluate A/P, A/R and investment accounts for reasonableness The Director of Finance/Accounting monitors cash accounts and bank reconciliations for reasonableness. The Director of Finance/Accounting reviews and distributes monthly financial reports to the Program Directors, Associate Directors and Executive Director. The Director of Finance/Accounting monitors financial operations to insure the prevention of error, mismanagement of funds and fraud. Appropriate separation of duties is maintained at all times during receipt and disbursement of cash. FIN 2.01 The Board of Directors finance/audit committee: selects and meets with an independent auditor; reviews the annual audit; makes a recommendation for approval of the audit to the full Board; and reviews findings of the auditor s evaluation of the agency s internal control system. FIN 2.02 Audit committee members cannot serve as a top manager of the agency or receive compensation for professional services they provide as consultants. FIN 2.03 The Executive Director and Director of Finance and Accounting certify in writing that financial statements are accurate and fairly represent the financial condition and operations of the agency.
Page 6 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Financial Risk Assessment PROCEDURE FIN 3: The Board of Directors and management evaluate the agency s financial capacities, risks, and resources needed to provide services. IMPLEMENTATION: Refer to the minutes of the Board of Directors.
Page 7 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Stable Predictable Revenue PROCEDURE FIN 4: Catholic Charities seeks stable and predictable sources of revenue through diversification and balance in its funding streams, as appropriate to its structure, mission, and programs. IMPLEMENTATION: Catholic Charities actively considers multiple types of funding alternatives. After weighing each alternative s costs, benefits, and congruence with mission and programs, Catholic Charities seeks to balance funding from the following sources: Gifts and bequests; Grants, awards, and/or federated fundraising; Special events; Fee-for-service arrangements; Purchase-of-service contracts; Third-party reimbursement; Managed care networks; Government grants; Catholic Charities Christmas Collection; United Way donor designations; and Investment Income.
Page 8 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Financial Planning PROCEDURE FIN 5: Catholic Charities plans to the current fiscal cycle. Catholic Charities prepares a two-year strategic plan that involves key stakeholders. It is updated quarterly and then the annual budget is developed for the fiscal cycle. IMPLEMENTATION: The Executive Director assures the implementation of a longterm agency plan, which includes responsibility for the quality of services provided by Catholic Charities. Special consideration of factors for the development of a long-term plan includes but is not limited to: Priority Community needs; Matching grant availability; Total program expenditures; Current operating programs; Development of future programs; and Expertise of staff and volunteers. The Program Directors will create yearly outcome measures for their program considering the same criteria described above. Together with the long term agency plan, these outcome measures will help formulate the overall financial plan of the agency. Program Directors will be given a revenue projection sheet to fill out at the beginning of each year s budget planning cycle. This revenue projections sheet will contain total monetary awards, total time period, projected amount for upcoming year, and actual budget amount for the current year. The sheet will be completed for all contracts with governmental agencies, grants, fee for services, program service fees, contributions (both general and foundations), Catholic Charities allocation, and a list of any other revenue sources that may apply to each program. The Program Directors will compare current operational needs with future needs, expectations, and long term plans for their program, including but not limited to operational expenses and staffing pattern needs. This information will be reviewed by the Program Directors, Associate Directors and the Executive Director to formulate a financial plan and comprehensive budget for each program. The budget process is key to the financial strategy and when complete, becomes the written financial plan in terms of dollars allocated to programs in conjunction with expenses and outcome measures. Each
Page 9 of 22 year, a careful review and examination of the agency s endowment funds and other sources of income are also included in the overall process to arrive at a financial plan. FIN 5.01 Catholic Charities has a written budget that serves as a plan for managing its financial resources for the fiscal year. IMPLEMENTATION: The budget planning process for Catholic Charities includes: Participation of management personnel; Participation of the Board of Directors; An assessment of the annual budget in relation to the long-term and short-term plans; A comprehensive assessment of services; Direct and indirect operation expenditures; Contractual requirements; Potentially changing costs and conditions; Anticipated funding during the program year; and The Board of Directors review and approval prior to the new fiscal year. The budget process starts with the setting of a budget preparation calendar for each budget year. The calendar consists of a list of events to occur on certain dates throughout the budget preparation period (usually from July-November) that will culminate with the creation and approval of a budget for the next year. These events are designed to be integrated with the current Board calendar, so that the final budget can be approved by the Board at its year-end meeting. Each year, the basic chronology of events is as follows: BUDGET PLANNING GUIDELINES: 1. Catholic Charities finance committee meets with independent auditors to discuss audit issues that may have arisen in the previous year. 2. Catholic Charities Board receives the current Catholic Charities audit. 3. Second Quarter Unduplicated People Served Report collected from each Program Director. 4. Salary Budget (Staffing Pattern) forms distributed to Directors from Finance/Accounting. 5. Remaining budget forms (revenue and non-salary) distributed to Directors from Finance/Accounting. 6. Second Quarter Financial Reports Received from Finance/Accounting and given to Directors so that they have a full half year s current data to utilize for planning purposes
Page 10 of 22 7. Proposed Outcome Measures for next year are developed by each Program Director. 8. Completed salary budget (Staffing Pattern) request forms sent back to Finance/Accounting from each Director. 9. Catholic Charities Finance Committee Meets to review staffing patterns, outcome measures and other budget information to date. 10. Salary Budgets (Staffing Pattern) returned by Finance/Accounting to each Program Directors & Associate Director/Executive Director. Staffing patterns are reviewed in conjunction with outcome measures and CQI data to determine staffing needs for the coming year. 11. The remainder of completed budget forms due to Finance/Accounting. These include: Non-Salary Budget expenses (operations & maintenance) Other revenue projections Projected capital expenditures Special Projects 12. First Draft of the overall budget is created by Finance/Accounting (based on the above data that has been supplies to Finance/Accounting by the Program Directors). This first draft of the overall budget (version 1) is given to each Program Director and the Associate Directors & Executive Director. Later versions are developed as additional information, projections and expense cuts are negotiated with each program. 13. A final version of the budget is presented to the Catholic Charities Board Finance Committee for their initial review. 14. Catholic Charities Board Meeting to Consider Final Budget The Program Directors work collaboratively with the Associate Directors and Executive Director and Finance/Accounting in order to produce the budget each year. Several drafts, or versions of the budget, are possible during each year s budget planning cycle. Often times, budgets may yield deficits, in which case the Program Director and the Associate Directors/Executive Director look for possible resolution to achieve a balanced budget. Examples of resolution include but are not limited to: Examination of the likelihood of securing new grants Discussion of new or augmented fund raising activities Possible program cuts in either expenses or staffing Before each new budget year it is the responsibility of the Board to review the previous years audit to make sure that the budget was followed and monies were allocated and expensed as per their approved budget. The Board appoints members to a finance committee whose job it is to meet with the independent auditor and inform the Board of any recommendations or findings from the auditor.
Page 11 of 22 FIN 5.02 The budget planning process includes participation of management personnel and the Board of Directors and is based on: Assessment of the annual budget in relation to the long-term and short-term planning Performance improvement data; A comprehensive assessment of the organization s services; Direct and indirect operating expenditures; Contractual requirements; Potentially changing costs and conditions; and Anticipated funding during the program year. IMPLEMENTATION: Each year, the Executive Director and The Associate Directors assess the annual budget in relation to the long-term plan and outcome measures for the agency. They also assess all services in relation to community needs, mission statement and core values. All direct expenditures are calculated by the Program Directors and based on staffing patterns, assigned costs, extra costs, etc. All indirect expenditures are administrative in nature and are compiled in a cost pool which is then allocated to the programs according to a percentage of use. It is the responsibility of the Associate Directors to monitor contractual agreements. Once a contract is executed, all the fiscal requirements of the contract are maintained by Finance/Accounting. Finance/Accounting insures that regular and required billings are completed accurately and in a timely fashion. Finance/Accounting will note any change in costs or conditions throughout the agency. Monthly reports are created by Finance/Accounting and reviewed by the Director of Finance/Accounting as well as the Program Directors, the Associate Directors and the Executive Director. Any changes to anticipated funding streams will also be communicated by Finance/Accounting to the Associate Directors and Executive Director. FIN 5.03 According to a mutually agreed upon schedule, the Executive Director provides written, comprehensive reports on the organization s finances to the Board of Directors that address: Present financial status and anticipated problems, as required by organizational policy; and Financial planning and funding alternatives.
Page 12 of 22 FIN 5.04 Financial information is routinely analyzed and the information includes: a monthly analysis of financial performance against pre-established financial thresholds, such as projected timelines of expenses in relation to revenues; service revenues and actual service delivery costs; and Catholic Charities conducts an annual inventory of significant assets, including securities, and compares them with permanent records. IMPLEMENTATION: Finance/Accounting will create monthly reports to be reviewed by all administrative and management personnel. Variations in expenses or revenues are compared against the pre-established and approved budget for the agency. Asset inventories will take place in conjunction with the annual depreciation schedule. Each program will be sent a list of assets currently recorded for their program for review and acknowledgement that these assets still exist, have been deleted, or new assets added. Additionally, inventories of all computer equipment and other capital equipment will be updated annually. FIN 5.05 Catholic Charities conducts cost analyses of its various services and can identify: the fixed and variable costs of each unit of service at each program and service delivery site; the average costs or charges of treatment for identified groups of consumers; and the contribution of services to the overall revenue base. IMPLEMENTATION: Catholic Charities monitors each program s cost per unit (for services delivered) on a regular basis. Cost per unit analysis is derived from predetermined formulae which compare program expenses with unduplicated numbers of person served within each service category. FIN 5.06 At least annually, Catholic Charities analyzes the unit costs of each of its services and uses the information to: Analyze operational effectiveness and efficiency; Monitor trends and current experiences and changes in costs; Contract, bill, and charge fees for its services; and Budget for the current fiscal cycle. IMPLEMENTATION: Cost per unit analysis are performed and considered as part of the budgeting process for each year. Each program maintains cost per unit information
Page 13 of 22 based on pre-determined formulae based on expenses and unduplicated persons served statistics.
Page 14 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Financial Accountability PROCEDURE FIN 6: Catholic Charities is accountable to its Board of Directors, community, and, when applicable, regulatory bodies with regard to prudent fiscal management. FIN 6.01 Catholic Charities makes available an annual report of fiscal, statistical, and service data that includes summary information regarding its financial position. FIN 6.02 Catholic Charities undergoes an audit of its financial statements. An A-133 audit is also performed when required by federal regulations. The audit is performed under the following guidelines: Within 180 days of the end of its fiscal year; Prior to July 1 st ; Kept in file for last 10 years; and By an independent, certified public accountant who is approved by the Board of Directors. FIN 6.03 If Catholic Charities revenue falls below $500,000 and is not otherwise required to file an audit, the agency will undergo a comprehensive review (performed by an independent CPA as approved by the Board) of its financial statements at the end of each fiscal year. The Board will meet with the independent CPA and make that review available for public inspection. FIN 6.04 Catholic Charities Board of Directors: Delegates the Finance Committee to meet with the independent auditor to review the audit findings, the auditor s report, the accompanying financial statements, and any management letter that may accompany the audit and report to the Board of Directors; Delegates the Finance Committee to review and formally recommends accepting the auditor s report to the Board within 180 days of the close of the fiscal year;
Page 15 of 22 Delegates the Finance Committee to report the findings of the audit at the next official meeting of the Board of Directors; and Discloses any transactions involving Board members, staff, or their immediate families. Promptly ensures that management acts on the recommendations of a management letter, if any; Makes the report available for public inspection by sending it to the Washington State Charitable Contribution system; and Reports the information on IRS form #990.
Page 16 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Financial Management System PROCEDURE FIN 7: Catholic Charities receives, disburses, and accounts for its funds according to sound financial practices and Generally Accepted Accounting Principles (GAAP). FIN 7.01 Catholic Charities annual financial statements are prepared in accordance with Generally Accepted Accounting Principles. IMPLEMENTATION: Each year, Finance/Accounting creates financial statements and reports that are prepared in accordance with GAAP. Any financial reporting that is not done in accordance with GAAP is discussed in annual audit findings when appropriate. FIN 7.02 Catholic Charities financial reporting system is capable of providing information that: is useful in making business and economic decisions; is understandable and will aid in predicting future cash flows; and includes data about the agency s economic resources, claims to those resources (obligations), and the effects of transactions, events, and circumstances that change resources and claims to resources. FIN 7.03 Catholic Charities acts in accordance with an internal accounting control system that addresses: Prevention of error, mismanagement, or fraud; An inclusive and descriptive chart of accounts; Prompt and accurate recording of revenues and expenses; Prompt payment of expenditures; and Information on all funds, including each fund s source and pertinent regulations governing each fund. Safeguarding and verifying assets; Separation of duties to the extent possible; and
Page 17 of 22 Disbursement and receipt of monies. IMPLEMENTATION: Refer to FIN 2 for Catholic Charities Finance/Accounting Internal Control Guidelines. The Finance/Accounting Office has written procedures and job descriptions that address separation of duties to the extent possible. Within Finance/Accounting, there is a strict adherence to GAAP and internal controls. This adherence to GAAP and other internal controls is monitored yearly by external auditors and results are reported to Catholic Charities. FIN 7.04 Catholic Charities seeks to conserve its fiscal resources by: Taking advantage of benefits allowed tax-exempt organizations, where applicable; Maintaining sound policies regarding purchasing and inventory control; Coordinating the purchase of goods or services among internal programs; and Using competitive bidding, when applicable, according to Board of Directors policy and law regulation. IMPLEMENTATION: PURCHASING AND INVENTORY CONTROL All Program Directors have the authority to expend monies designated in the annual budget to maintain and operate their respective Programs. Program Directors may expend up to $500.00 on any material purchase at their discretion. Any material purchase over $500.00 must be approved by the Associate Directors All material purchases are monitored by Finance/Accounting for reasonableness. Annually each Program Director will receive from Finance/Accounting an inventory sheet to check for accuracy and return to Finance/Accounting for the purpose of depreciation scheduling. All programs are held under the tax-exempt status of the agency. The Associate Directors work with Finance/Accounting to insure that all tax-exempt benefits are taken advantage of and that tax-exempt status is maintained. All programs work collaboratively to coordinate the purchase of goods and services. Economies of scale and cost savings are encouraged to be realized between programs when goods and services can be purchased by several programs under one contract at a reduced rate. FIN 7.05 Accounting records are kept up-to-date and balanced on a monthly basis, as demonstrated by: Reconciliation of the bank statement to the general ledger;
Page 18 of 22 Reconciliation of subsidiary records to the general ledger; Up-to-date posting of cash receipts and disbursements; Monthly updating of the general ledger; and Review of the bank reconciliation by at least two personnel, periodically one of whom is not involved in maintaining the accounting records. IMPLEMENTATION: Refer to FIN 2 for guidelines related to the above points. FIN 7.06 Catholic Charities uses the accrual method of accounting. FIN 7.07 Oversight and management of Catholic Charities accounting system requires that: The Director of Finance/Accounting is responsible for maintaining the Finance/Accounting Department. The Director has C.P.A. credentials. The Department provides accounting, budgeting, human resource processing, payroll, donor and special events records, capital campaigns, and contract oversight. The financial computer software system has been a multiyear installation plan. Trainings are provided on a regular basis. Internal control systems are managed by the Finance/Accounting Director, Executive Director and the audit firm. Internal controls are also monitored and reviewed by the Catholic Charities Executive Director and Associate Directors. The software system assures secure access, controlled by user IDs, passwords and permissible logon times. FIN 7.08 As required by law, Catholic Charities makes timely payments to, or provides proof of exemption from, the following taxing authorities: The Internal Revenue Service; State and local employment tax bodies; Social Security Administration; Property tax assessors. FIN 7.09 Catholic Charities Partners Program assumes fiduciary responsibility for client funds or disburses non-fee-for-service funds, such as maintenance or allowance funds for persons served, and has operational procedures that ensure: Segregation of funds; Organizational accountability; The protection of consumer assets; and
Page 19 of 22 Compliance with applicable legislative, regulatory, judicial, and governmental requirements. IMPLEMENTATION: Catholic Charities follows WAC codes concerning client funds. In brief, client funds are handled under the following guidelines: Always obtain written consent from the client, the client s guardian or legal representative A client s funds will not be combined with other agency funds A financial management plan is required for the client The individual financial plan (IFP) is reviewed at least annually by staff and client A copy of the IFP will be sent to the guardian or legal representative and the Client s case resource manager upon request The plan will include: o Type of accounts to be used o A budget process o Asset management o Cash management o Money management instruction o An explanation of which purchases require receipts o A contingency plan for expenditures Client s money will be tracked separately and tracking efforts will be kept current Staff will reconcile client s account to bank statement monthly Staff will make deposits to client s account within one week Staff will prevent the client s account from being overdrawn Staff will insure that individual cash funds do not exceed seventy-five dollars Staff will retain receipts for purchases of over twenty-five dollars. FIN 7.10 Catholic Charities establishes safeguards against over-and-under billing that include: an accurate account of units of service provided; timely submission of invoices and required documents; and compliance with applicable regulations. IMPLEMENTATION: All Billing information is kept on file at Finance/Accounting as well as with the Associate Director. Changes to billing procedures for any grant or contract are communicated to Finance/Accounting immediately by the Associate Director. All files or correspondence from funding sources related to billing procedures are kept current and up to date.
Page 20 of 22 FIN 7.11 Catholic Charities determines the basis for any denial of coverage or payment under insurance or contractual arrangements and follows up with timely appeals and communication with the person served, if applicable. IMPLEMENTATION: Denial of payments will be handled as appropriate by either the Finance/Accounting personnel or the Program Directors. This will be determined by the billing process. If the billings go through Finance/Accounting they will be alerted to any denial of payment and will initiate contact with the appropriate consumer, agency, or company to resolve the problem. If the billing is Program directed any denial of payment will be sent back to the Program who initiated the billing and the Program Director will initiate the necessary follow-up procedures to resolve the problem.
Page 21 of 22 APPROVED BY EXECUTIVE DIRECTOR SIGNATURE DATE TITLE: Payroll PROCEDURE FIN 8: Catholic Charities payroll practices comply with federal and state wage and hour laws. FIN 8.01 Catholic Charities: Reviews and approves payroll expenditures; Documents changes in time and overtime records; Authorizes payment for new hires and severance for terminations; Oversees mandatory deductions and rates of pay; and Ensures separation of payroll funds. IMPLEMENTATION: Payroll Payroll approval forms listing each employee and pertinent salary/payroll information, for each program are sent electronically to the respective Program Director for processing and are signed off by the Associate Director or Executive Director. Two signatures are required for proper approval, one from the Program Director and the second from the Associate Director or Executive Director. Timecards are signed by program employees and the Program Director and accompany signed payroll approvals to Finance/Accounting. Payroll is prepared by Finance/Accounting. After timecards are received by Finance/Accounting staff and any questions are resolved relating to hours worked or pay rates, an entry worksheet is prepared for input to an outsourced payroll service provider. Two different Finance/Accounting staff members share the payroll input duties to insure checks and balances. One staff verifies the direct deposit vouchers and prepares reports from the outsourced payroll service provider. Payroll checks are written by the outsourced payroll service provider, and the transfer of funds to that provider is authorized by the Associate Director or Executive Director. Paychecks are signed by the same authorized individuals listed above; check signers refer to a payroll approval sheet which includes employee names, current pay rates based on Grade and Step, etc.
Page 22 of 22 Directors sign for the paychecks for their department, and distribute on payday to staff. Absent employee paychecks are returned to Finance/Accounting and kept by Program Directors until the employee returns and signs for it. FIN 8.02 Catholic Charities assures annual reconciliation of gross pay, FICA withheld, and employer FICA with Federal Forms W-2.