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4.20 SCL – Individual Funds Management

Purpose

Supported Community Living will provide the supports and assistance outlined in the individuals Individual Service Plan for the ongoing management of each individual’s finances. This includes, but is not limited to, bank accounts, monthly budgets, petty cash funds, social security benefits, Medicaid benefits and food stamps.

SCL maintains that each individual will receive the level of supports and independence described in his/her ISP. Individuals will be encouraged to participate to the fullest extent possible in all aspects of financial transactions and fund management.  At all times the supports and services in the ISP will be implemented. Guidelines are established as described in this policy to ensure these funds are secure. 

Supported Community Living offers the service of the designated Payee. These services are completed by the Payee Accounts Coordinator according to the guidelines set forth in this document. The Lead Direct Support Professional will be responsible to adhere to the guidelines set forth in this document when assisting individuals who elect to remain their own payee of their benefits. Open Door adheres to the Individual Funds rule outlined in OAC 5123:2-2-07.

Training and Monitoring

All staff will be trained on individual finances with regard to this policy and the specific needs of the individuals they support. Lead staff and Program staff will receive additional training according to the policy and will be checked off on the New Employee Checklist. Program Coordinators will monitor performance in this area on a monthly basis. The Payee Rep in charge of money management must complete and pass DODD money management certification and receive annual training on individual funds policy/procedures.

Procedure

Individual funds may never be co-mingled with other funds or company funds.  Each individual must have separate file maintained for all financial documentation. It is never appropriate for one individual to provide funds to cover for any other individual for any reason.

1. Social Security Benefits

  • If determined in the individual’s person-centered ISP, SCL will make application to Social Security to become the individual’s payee for their benefits. 
  • All benefits will be directly deposited into the individual’s bank account. 
  • SCL will report earnings to the social security administration as requested
  • When SCL is the payee, as indicated in the ISP, the Payee Accounts Coordinator or designee will act as second signatory.  The individual will be the first signatory.  Copies of these records will be maintained at the SCL office.

2.         Medicaid Benefits (Includes Food Stamps)

  • If determined in the individual’s ISP, SCL will assist the individual to maintain eligibility for Medicaid benefits.  This includes accompanying the individual to the annual or quarterly re-determination meetings at the Ohio Department of Job and Family Services.
  • Information that is required to be submitted includes utility payment records, bank statements, birth certificate, employment pay stubs and the individuals’ lease agreement.  Records are obtained from the individual’s home files and a record of the re-determination is maintained at the SCL office.
  • The ODJFS will be contacted if the Medicaid card is not received by the 3rd day of each month.  Staff will follow the direction of the ODJFS to obtain the Medicaid card and file in the individual’s record book.
  • The County Board SSA and guardian (if applicable) will be kept informed of any changes in benefits as outlined in the ISP.
  • Staff will assist the individual to activate the food stamp “debit” card each month.
  • If the individual does not keep the food stamp and/or debit card on his person, it will be kept in the lock box, maintained in the home.
  • Staff will assist each individual to make application for and maintain all utility subsidy programs, such as HUD, HEAP, TAP, etc.

3.         Bank Accounts (Checking and Savings)

  • If determined in the individual’s ISP, SCL will assist the individual to open a bank account for checking and savings.  If agreed upon and stated in the ISP, benefits will be direct deposited when possible.  The individual will be counseled regarding the maintenance of his/her bank account according to his/her abilities and desires as described in the ISP.
  • All checks that are written, debits, and deposits made will immediately be recorded in the checkbook ledger and the math will be calculated to give a current balance.  This is the responsibility of the staff assisting with the transaction when the individual is unable to do so.
  • The checkbooks will be kept in the lock box, unless the individual maintains personal possession of their checkbook(s) or stated otherwise in the ISP.
  • ATM/debit cards may be utilized upon the individual’s request and if agreed upon in the ISP.  All transactions must be recorded into the ledger/checkbook.  Lead staff are responsible to ensure security of the debit card in the location.  PIN numbers should never be posted for staff. 
  • The Payee is responsible for monitoring usage of debit card and will report any suspicious activity to Incident Hotline immediately. 
  • For most banks, cancelled checks are not returned to the individual.  Check carbons serve as the cancelled check and will be filed in the home file drawer.
  • Monthly bank statements and ledgers will be stapled with purchase receipts, ATM receipts, bill statements and deposit slips which correspond to the activity on the account during the current month.  They will be filed in the Corporate Office Payee files.
  • Staff at no time will receive a disbursement, cash or gifts from a individual.
  • The memo section of the check will be utilized to indicate the nature of the purchase.
  • All fees acquired due to staff error will be logged as an incident report and will be reimbursed by SCL. 

4.         Individual Petty Cash and Ledger

  • Each individual may have their own petty cash ledger in the lock box
  • A petty cash ledger will be maintained to keep track of the cash in the box and is located in the financial book.
  • All cash received by ATM, employment paychecks and financial gifts will be entered onto this ledger.
  • Each time a purchase is made with this money, a receipt is obtained and numbered and stapled to the ledger.
  • The individual will sign, initial or make their mark on the ledger each time money is taken out of the box.  The staff person responsible for the transaction will sign the ledger entry and, if available, a second staff will serve as a witness and will sign the ledger entry.   
  • This ledger will be balanced monthly by the Lead and/or Program staff by checking the math, checking the receipts against the entries and counting the cash to see that it is the same as the ledger.
  • If a receipt is lost, it should be re-created, stating the date of the purchase, the item(s), the total, the staff person responsible and the individual’s signature to verify this expenditure.  This “new” receipt will be stapled to the ledger.
  • All entries should be made at the time of the transaction.
  • A new ledger with the balance carried forward will be started at the 1st of every month.  Past ledgers will be filed in the home file drawer for each individual under the label “Petty Cash Ledger” and the individual’s name, if the individual is their own payee.  If CCHS is the payee, all ledgers must be submitted to the office monthly to be monitored and filed.
  • Discretionary personal spending will be identified in the ISP and indicate when receipts are not necessary.
  • Electronic ledger systems are updated the 1st of each month with carryover balance.
  • IF electronic ledger system OnSeen is utilized, all tracking will be done electronically and receipts loaded to system each expenditure. 

5.         Joint Petty Cash

  • Is maintained in the home for the purchase of a loaf of bread, carton of milk, etc.
  • All individuals must be willing to participate in the joint petty cash and must contribute the same amount to the account.
  • The money is maintained in the lock box.
  • A ledger is maintained just like the individual petty cash.
  • No purchases should be made that are jointly owned or no cash withdrawn for one individual’s personal use or activity.  All household items will be purchased and owned by only one individual.
  • Joint deposits and spending will be recorded on the Petty Cash ledger and will be witnessed and signed by the staff and individual.  Each transaction receipt needs to be stapled to the ledger.
  • Individuals may choose to utilize the Joint Petty Cash to purchase weekly groceries.  In these situations, each individual must deposit the same amount each month for all groceries consumed together.  If food stamps are utilized, it will be noted as food stamps on the ledger and serves the same as cash.  The food stamp receipt will be identified with the individual’s initials and stapled to the ledger with the grocery receipt.
  • A new ledger will be started the first of each month with a balance brought forward.
  • Monthly ledgers are filed in the home file drawer under the label “Joint Petty Cash”. 
  • Electronic ledger systems are updated the 1st of each month with carryover balance.
  • IF electronic ledger system OnSeen is utilized, all tracking will be done electronically and receipts loaded to system each expenditure. 

6.         Food Stamps and Groceries

  • Groceries can be purchased for meals or foods eaten together.  Individual groceries should be purchased separately.  The purchase of groceries should be divided evenly between the individuals and can be purchased using the food stamps, cash or checks.  All receipts for groceries purchased together (regardless of purchased by stamps, cash or check) should be placed with the appropriate source of the funds.   Copies of the grocery store receipts may be necessary. 

For groceries purchased separately:

  • There will be a ledger for each individual’s food stamp card.  It is labeled Food Stamp Ledger.  Enter the amount of the stamps on the ledger just like cash.  Use the food stamp card to purchase groceries.
  • The food stamp receipt will be attached to the ledger.
  • The grocery receipt will indicate the amount paid by cash or check and the amount paid by the food stamps and will be attached to the funding source (petty cash or checkbook).
  • If a receipt is lost, it should be re-created, stating the date of the purchase, the item(s) the total and the staff person responsible.  This “new” receipt will be stapled to the ledger.  The individual’s signature is required to verify expenditure.  Any lost receipt will be monitored.  If patterns/trends arise, there will be further audits implemented.
  • Monthly ledgers are replaced the 1st of each month and filed in the file drawer for each individual under the label “Food Stamp Ledgers”.     Electronic ledger systems are updated the 1st of each month with carryover balance.
  • IF electronic ledger system OnSeen is utilized, all tracking will be done electronically and receipts loaded to system each expenditure. 

7.         Utility Bills

  • All bills are reviewed by the Lead or the Payee Accounts Coordinator.  Bills are paid by the due date.
  • The total amount should be divided by the total number of the individuals in the home.  Each individual will then write a check for his or her portion of the bill (usually 1/3 or 1/2).  All three checks can be mailed to the utility company together.
  •  Each individual is responsible for his or her own long distance phone calls.  Cable line, internet or caller ID utilized by only one individual should be paid by that individual.
  • Keep all stubs (statements) from all utility bills and any other kind of payment made.  Utility stubs will be filed in the home file drawer under the label “Utilities”.  All other statements will be placed with the receipt and placed with the appropriate funding source, i.e. petty cash, joint petty cash, monthly bank statements.  (See above.)
  • Any fees acquired due to staff error will be reimbursed by SCL.

8.         Location’s Financial Lock Box

  • As requested by the individuals, the checkbooks, savings pass books, petty cash, joint petty cash and food stamps may be kept in the locations’ lock box.
  • The Lead will have a key.
  • The second key will be kept in a confidential location in the home and the Administrator On-Call will have knowledge of the whereabouts to ensure accessibility to the individual.
  • Each individual will have access to his or her funds upon request at all times.
  • The Lead will make provisions for accessibility to funds during their time off.

9.         Debit Cards/Debit Card ledgers

  • All individuals’ accounts have been issued bank debit cards.  The cards are set up so that no cash withdrawals without prior approval.  Bank cards and pin numbers are stored securely in the payee office. 
  • Debit Cards are used for instances that require individual’s to have card, such as vacation, online purchases and those who have programs to learn to use the cards to achieve increased independence.  All receipts must be signed by individual, including online purchases. 
  • Debit cards are to be tracked using the petty cash procedures listed above, including, tracking on ledger, reconciliations, audit by external party, etc.

10.      Stable Accounts

  • Payee can assist with STABLE account set up, transactions, maintenance and storage of records, and statement review for individuals per regulations set forth by State of Ohio.
  • A STABLE account helps supplement current benefits with a way to save for qualified expenses. If receiving Supplemental Security Income (SSI), individual can have up to $100,000 in the account without it counting towards the $2,000 asset limit.
  • The money in STABLE account will not affect your eligibility for Medicaid benefits.
  • The money in your account can be used for everyday expenses. Qualified expenses are geared toward improving health, independence, and quality of life, and include: Living expenses, Education, Housing, Transportation, Employment, training, and support, Assistive technology, Personal support services, Health, prevention, and wellness, Financial management, Administrative services, Legal fees, Oversight and monitoring, Funeral and burial costs, etc.

11. Monitoring of Finances

  • Will be completed, utilizing the House Ledgers, Program Staff, Payee Accounts Coordinator and Accounting department with second audit by designated person who is not the person responsible for the fund management.
  • Financial audits and reconciliations will be completed every 30 days by Payee Rep.
  • Stable account transaction reviews will occur monthly during bank statement reconciliations.
  • Formal Stable account reconciliations will occur when statements are received (generally quarterly).
  • Payee will monitor assets and financial accounts to ensure that individual does not exceed allowable resources. Payee will provide notice to team when individual resources have potential to reach maximum allowable limits per regulation and ensure proper measures are taken to prevent loss of benefits or eligibility for services.
  • The Program Manager will track completion of the monitoring requirements and will initiate special and random audits.
  • As requested, CCHS will file annual taxes for the individual.
  • For employee reimbursement for individual outings, please refer to P&P 2.05.
  • Staff failing to follow the policy and procedures for individual finances will be subject to CCHS disciplinary process. (Refer to P&P 2.15)
  • Any financial discrepancies noted will be reported to Incident Hotline, incident report written with details, and any missing money will be replenished within 24 hours. 

Signed by:

Rebecca Sharp Porter
Chief Executive Director

Last Revised: 4/16/2024

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