Client Money Management

 

POLICY ON CLIENT MONEY MANAGEMENT

ServiceNet affirms the right of the individuals we serve to possess and use personal funds without restriction. It is the policy of ServiceNet that each client served by our programs is presumed to be capable of managing and spending his or her funds. Programs will not manage a client's funds in any way unless ServiceNet has been appointed Representative Payee (see Section 3 below on Representative Payees) or has written consent from the client or his/her legal guardian to manage all or a portion of his or her funds.

If either of the two above conditions is met, a joint money management system involving the program and the client must be implemented. This joint management must meet the requirements, and comply with the policies and procedures specified below.

GENERAL REQUIREMENTS

1. ESTABLISHMENT OF MONEY MANAGEMENT PLAN

It is the responsibility of the program to develop and implement a written plan (hereinafter referred to as the Money Management Plan, or "MMP") to assist the individual in the management and expenditure of his or her own funds. Training arrangements must be formulated using the least restrictive alternatives to meet the individual's need for assistance in everyday purchasing, saving, and consumer self-protection. The plan must include, among other guidelines, the maximum dollar amount of free cash ("spending money") the client is able to manage on a daily or weekly basis.

2. JOINT MANAGEMENT AGREEMENT

The program will develop a signed formal agreement between the program and the individual. The agreement will be individualized according to the particular needs of the client and will include the money management plan, as well as a statement that all of ServiceNet’s policies and procedures regarding management of client funds will be complied with. The agreement will be signed by the client (and client’s guardian, if applicable) and the Program Director.

3. REPRESENTATIVE PAYEES ( See Rep Payee Checking Account Bank Reconciliation Form)

A Representative Payee ("Rep Payee") is appointed by the Social Security Administration in instances where an individual receiving Social Security payments (which many of our clients do) is not capable of handling those funds. In this case, the individual's Social Security check is sent to the Rep Payee, not directly to the individual.

A client may come to ServiceNet with a Rep Payee in place (e.g. a family member). In this case that individual will continue to pay the client's bills, including client fees due to ServiceNet. ServiceNet may need to assist in managing small amounts of the client’s "spending money." If the client does not have a Rep Payee but it is determined as part of his/her treatment plan that s/he needs one, we will apply to the Social Security Administration. ServiceNet, Inc. (the corporation) should be set up as the Rep Payee, not an individual staff member.

The primary duty of the Rep Payee is to make sure that the client's basic health and safety needs are met from the social security funds (i.e. pay rent, utilities, food, clothing, medical expenses). Remaining funds can be used for client recreation or savings. The Social Security Administration publishes a pamphlet entitled "Your Duties as a Representative Payee" which can be obtained by calling the Holyoke Social Security Office at 536-3649.

CLIENT FUNDS MANAGED AT THE PROGRAM

1. ESTABLISHMENT OF A BANK ACCOUNT

Except for small amounts of daily spending money (see Section IV below), client funds must be kept in a bank account. The MMP will specify, based on the client’s ability to be involved with his/her finances, whether the account will be a joint account, requiring both client and Program Director signatures, or an account with only the Program Director as a signator. All of the policies and procedures outlined in this document (regarding record-keeping, etc.) apply equally to either type of account.

2. DEPOSITS AND WITHDRAWALS FROM MANAGED ACCOUNTS

Program Staff will strictly maintain records of every transaction involving managed accounts. In order to most effectively satisfy record-keeping requirements, and in order to further the client's experiences with non-cash transactions, a checking account will be established. This account will be established as an interest-bearing (NOW) account whenever the resources of the individual permit satisfying the minimum balance requirements of the chosen bank.

The Check Register (or, if preferred, ServiceNet’s Check Transaction Listing) must be filled out completely, and on a timely basis. All checks must be listed in numeric sequence as they are written, with the payee and purpose of the check noted.

Under no circumstances should a check be signed before the payee and amount are filled out.

Normally, checks should not be written to "Cash" or to a staff person. When the individual wishes to withdraw cash from the account, a check will be written for payment to the client by name, and the client will not endorse the check for cashing until it is presented at the bank.

Certain clients may be unable or unwilling to go to the bank to negotiate checks. If this is so, this limitation must be documented in the MMP. Only when such documentation is present, checks for client "spending money" may be made payable to "Cash" so that a program staff person can cash them. A check made payable to "Cash" will immediately (i.e. as soon as it is written) be treated as "cash" and logged into the Transaction Register as a "deposit" of client funds (see Section IV, "Holding Cash at Program Sites), with both the client and the staff person initialing the register. When the staff person returns from the bank with the funds from the cashed check, any money given to the client immediately would then be logged in the Transaction Register as a withdrawal, and the remainder would be put in the locked cash box.

Whenever withdrawals of cash other than the weekly spending amount specified in the Money Management Plan are made, the Program Director must enter a written explanation in the check register, and receipts verifying the use of the additional cash must be kept and submitted to the Fiscal Department with other paid bills.

If, according to the assessment of the Program Director and as documented in the MMP, the client is capable of managing only small amounts of cash at one time, the program staff may withdraw cash from the client's bank account and hold it for the client, disbursing the specified amount (e.g. $5.00) to the client each day. (See Section IV -- " Holding Cash at Program Sites").

If the client objects to having a checking account and prefers a savings account instead, passbook or statement savings account will be set up. For all savings accounts, a detailed record will be kept using the "Client Savings Transaction Register" (see sample following). This transaction register will be reviewed with the client each time a transaction is made, and s/he will then sign it to indicate his/her agreement that it accurately reflects the use of his/her funds. The running total on the Transaction Register must at all times agree to the balance in the savings account. All conditions established herein apply to management of client savings accounts.

Some programs prefer to use a combined form that includes a record of both "Cash on Hand" transactions and banking transactions (checking or savings account). This is also acceptable as long as the form is filled out completely. 

See Monthly Financial Transaction Sheet.

Under no circumstances should program staff keep client checkbooks or bank books with them. Except when a savings passbook is taken to the bank for updating, all client bank books should remain at the program in a secure location.

3. REVIEW AND RECORD-KEEPING OF MANAGED CLIENT FUNDS

The Program Director is responsible for immediately notifying the Chief Financial Officer of the establishment of any jointly managed account or of the appointment of ServiceNet as Rep Payee. The Program Director is also responsible for forwarding to the Chief Financial Officer, or his/her designee, a copy of the Joint Management Agreement, including the Money Management Plan, as well as the Social Security Determination Letter, "Shared and Delegated" letter, guardianship agreement, or other document(s) authorizing ServiceNet to manage the individual’s money.

In any instance where program staff are managing client bank accounts and funds, whether or not ServiceNet is the client’s Rep Payee, appropriate records must be kept of all transactions. This record-keeping is the responsibility of the Program Director, and will be reviewed monthly by the Fiscal Department. The level of the client's involvement in financial record-keeping will be determined by program staff, based on the client's capability.

As indicated above, a written record will be made of every transaction made on a client's account. If the client's funds are kept in a checking account, this will be done on the checkbook register or, if preferred, ServiceNet’s alternate check Register form. If the funds are in a passbook savings account, a Client Funds Transaction Register will be maintained. The record will indicate in each case the amount, date, check number (if a checking account) and purpose of the transaction, and will be supported by bills and receipts.

The "reporting period" for submitting documents will be determined by the type of bank account. For a Checking Account, documents must be submitted within 10 days of the cutoff date of the bank statement; for a Savings Account, within 10 days of the close of the calendar month.

At the end of the reporting period, the Program Director will forward the following documents to the Fiscal Department after making copies for the program as appropriate:

A) For a Checking Account:

1) The original bank statement, which has been reconciled to the checkbook register (or ServiceNet Checking Transaction Register), initialed by the Program Director. Reconciliation must be done on the ServiceNet Bank Reconciliation form (copy attached).

2) A copy of the checkbook register (or ServiceNet Checking Transaction Register) for the month,

3) All original bills and receipts for the month

4) Copie(s) of the Transaction Register(s) for any client cash/"spending money" which has been held at the program, including a copy of the "excess funds" transaction register, if applicable. (See Section IV "Holding Cash at Program Sites".)

B) For a Passbook Savings Account:

1) Savings Transaction Register for the month, initialed by the Program Director

2) A copy of the last page of the savings passbook, updated by the bank as of the end of the month

3) All original bills and receipts for the month

4) Copie(s) of the Transaction Register(s) for any client cash/"spending money" which has been held at the program, including a copy of the "excess funds" transaction register, if applicable. (See Section IV "Holding Cash at Program Sites".)

A member of the Fiscal Staff, as assigned by the Chief Financial Officer, will review the bank statements and transaction registers each month and will initial them, documenting his/her review. Any records submitted with incomplete documentation, or incorrectly completed, may be returned to the Program Director for correction. After the records are reviewed (and any necessary corrections made), the Fiscal Department will keep them in an active file for one year, after which they will be archived and kept on file for seven years after the client has been discharged from service.

If the Program Director or other staff person assigned to manage client funds needs assistance in the proper procedures for reconciling bank accounts, s/he should contact the Chief Financial Officer, who will arrange for training.

4. HOLDING CASH AT PROGRAM SITES

If the client’s MMP requires that the program hold cash for him/her on site, the following procedures apply:

Normally, no more than $200 total of client cash (for all clients of a program) may be held by a program at any one time (see below for approval of exceptions to this limit). Under no circumstances will the program hold or be responsible for cash for staff.

The cash will be held in a locked, secure site to which only designated staff have access.

Cash being held for any individual will be clearly identified and will be kept separate from all other cash.

All deposits or withdrawals of cash must be recorded on a "Client Funds Transaction Register". The date of the transaction and the signature of both the client for whom the cash is being held and the signature of the staff who receives or disburses the cash must be recorded.

The Program Director is responsible for reconciling the transaction records with available cash on a weekly basis.

There may be situations in which, due to the financial circumstances or clinical needs of particular clients or the number of clients in the program , it would be either impossible or very impractical to limit the client cash-on-hand to the standard amount. If it is necessary to hold a larger amount of client funds, the following procedures must be followed:

1) The Program Director must document the extenuating circumstances in a memo, which must then be reviewed and approved (in writing) by the Division Director and the Chief Financial Officer.

2) The excess funds must be kept in a separate safe, to which only the Program Director has access.

3) A separate "Cash Transaction Register" must be kept for the excess funds. When cash is transferred out from the excess funds into the regular client cash fund, it should be signed out of this transaction register by the Program Director and entered into the regular transaction register. A copy of this "excess funds" Transaction Register must be submitted each month to the Fiscal Department with client records of any client for whom excess funds are held in a separate safe.

If at any time client funds are discovered to be missing, the following steps should be taken:

1) The incident should immediately be reported to the Division Director and the Chief Financial Officer.

2) The Program Director must prepare a written report to the CFO (with a copy to the Division Director) documenting the circumstances surrounding the incident and the steps to be taken to improve security of client funds in the future.

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intranet Intranet,
Jun 17, 2008, 10:43 AM
ĉ
intranet Intranet,
Jun 17, 2008, 10:45 AM
ĉ
intranet Intranet,
Jun 17, 2008, 10:45 AM
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