OhioBWC - Basics: (Policy library) - File

Policy and Procedure Name:

Electronic Delivery of Funds

Policy #:

CP-04-03

Code/Rule Reference:

OAC 4123-3-10; Electronic Fund Transfers (Regulation E) 12 CFR Part 1005; and Truth in Lending (Regulation Z) 12 CFR Part 1026

Effective Date:

04/19/19

Approved:

Kevin R. Abrams, Chief Operating Officer

Origin:

Claims Policy

Supersedes:

Policy # CP-04-03, effective 12/04/14 and Procedure # CP-04-03.PR1, effective 11/14/16

History:

CP-04-03

New 12/04/14

CP-04-03.PR1

Rev. 11/14/16; New 12/04/14


 

Electronic Delivery of Funds Table of Contents

 

I. POLICY PURPOSE

II. APPLICABILITY

III. DEFINITIONS (HEADING 1 STYLE)

Automated Clearing House (ACH)

Benefit Recipient

Daywork Payment

Electronic Benefits Transfer (EBT)

Electronic Funds Transfer (EFT)

EFT Module

Pension Payment

Reclaim

Reversal

Settlement Date

IV. POLICY

A.          BWC Compensation Awards Paid via EBT or EFT

B.          EBT or EFT Participation vs Paper Warrants

C.         Benefit Recipient Enrollment in EFT

D.         Enrollment Requests

E.          Defaulting Benefit Recipient to EBT

F.          Changing EFT Direct Deposit

G.         Canceling EFT Direct Deposit

H.         Break in Compensation

V. PROCEDURES

A.          Standard Claim File Documentation

B.          EFT Direct Deposit

C.         EBT Benefit Card

D.         Identifying Payment Method

E.          Inquiries When Payment is Not Received

F.          Recoupment of Payments

G.         Reversals

H.         Reclaims (When Recipient Dies)

 

 


 

I. POLICY PURPOSE

 

The purpose of this policy is to ensure that compensation and benefit payments are made in the most timely, efficient and safe manner available.

 

II. APPLICABILITY

 

This policy applies to all claims services staff and Benefits Payable staff.

 

III. DEFINITIONS

 

Automated Clearing House (ACH): an electronic network for processing financial transactions, including direct deposits, in the United States.

 

Benefit Recipient: an injured worker or a dependent who is receiving payment from BWC.

 

Daywork Payment: compensation or benefit payment that covers current or past periods of payment but does not extend to future scheduled payments.

 

Electronic Benefits Transfer (EBT): benefit card program for the deposit of funds into an account established for the benefit recipient.

 

Electronic Funds Transfer (EFT): direct deposit of funds from BWC into the benefit recipient‘s account with a financial institution.

 

EFT Module: benefits payable system that creates and tracks EFT and EBT accounts.

 

Pension Payment: compensation payments that are scheduled to occur into the future, usually every two weeks.

 

Reclaim: act of recouping money from the benefit recipient, due to the death of the benefit recipient, from an account or benefit card to which BWC deposited benefits.

 

Reversal: act of recouping money from the benefit recipient due to a processing error from an account or benefit card to which BWC deposited benefits.

 

Settlement Date: date funds are actually available to the benefit recipient.

 

IV. POLICY

 

A.     BWC Compensation Awards Paid via EBT or EFT

 - It is the policy of BWC to pay compensation awards via EBT or EFT.

 

B.     EBT or EFT Participation vs Paper Warrants

 - It is the policy of BWC to require EBT or EFT participation and only issue paper warrants for the following reasons: 1.  It is the initial payment(s) on a claim for the benefit recipient and no previous open EFT or EBT exists.

2.   The benefit recipient does not have, or will not provide a social security number.

3.   The payment is made to honor an Authorization to Receive a Workers’ Compensation Payment (C-230).

4.   The payment is made as a miscellaneous payment on the claims management system.

5.   The payment is made to the benefit recipient in care of the employer for wage agreements.

6.   The benefit recipient has applied in writing to Benefits Payable and Benefits Payable has approved the opt-out from the EBT and EFT programs.

 

C.    Benefit Recipient Enrollment in EFT

 - The benefit recipient may enroll in EFT by:

1.   Completing the ACT Enrollment and Direct Deposit Authorization (A-12) and returning it to Benefits Payable by mail at PO Box 15429, Columbus, OH 43215 or by fax at (614) 621-1140;

2.   Completing the A-12 online at www.bwc.ohio.gov; or

3.   Calling the BWC Customer Contact Center at 1-800-644-6292.

 

D.    Enrollment Requests

 - Enrollment requests shall not be imaged to the claim because financial institution account information is confidential information.

 

E.     Defaulting Benefit Recipient to EBT

 

1.   If the benefit recipient does not enroll in EFT, it is the policy of BWC to default to the EBT program.

2.   It is the policy of BWC to provide disclosures to benefit recipients for EBT, pursuant to Electronic Fund Transfers (Regulation E) 12 CFR Part 1005; and Truth in Lending (Regulation Z) 12 CFR Part 1026.

 

F.     Changing EFT Direct Deposit

 - The benefit recipient may make changes to the direct deposit information, including financial institution changes.

 

G.    Canceling EFT Direct Deposit

 - The benefit recipient may cancel the direct deposit by agreeing to receive payments via the EBT benefit card.

 

H.    Break in Compensation

 - If there is a break in compensation, payments may resume electronically depending on the following circumstances:

1.   EFT

a.   Payment will be made by EFT if the benefit recipient has an open EFT account within the preceding 12 months, including an EFT account in a different claim.

b.   If a payment has not been made within 12 months, the EFT is closed and the benefit recipient receives a paper warrant until the benefit recipient enrolls in either EFT or defaults to EBT.

2.   EBT - If six months or more has passed from the last EBT payment to a benefit recipient, the benefit recipient shall receive a notice at the time payment is issued to the EBT. The notice includes notification of deposit and instructions for replacing the card, if needed.

 

V. PROCEDURES

 

A.     Standard Claim File Documentation

1.     BWC staff shall refer to the Standard Claim File Documentation and Altered Documents policy and procedure for claim note requirements; and

2.     Shall follow any other specific instructions for claim notes included in this procedure.

 

B.     EFT Direct Deposit

1.   Enrolling in EFT Direct Deposit - If the benefit recipient has not previously received payment by direct deposit in any claim:

a.   BWC shall send up to three (3) consecutive payments (i.e., initial award and two additional payments) via paper warrant to the benefit recipient, unless the benefit recipient signs up for EFT direct deposit;

b.   A warrant remittance will go out automatically with each payment to the benefit recipient; and

c.   Claims service staff will send out the A-12 to the benefit recipient, only after claim service staff receives a direct request for the A-12.

2.   Verifying Caller Information

a.   The BWC Customer Contact Center or Benefits Payable has the authority to take personal financial institution information over the phone. Financial institution information should never be obtained by claim service staff.

b.   Claim service staff shall ensure that the claim is in an allowed status and coded as lost time before financial institution information is obtained or processed.

c.   The Customer Contact Center shall verify the caller is the benefit recipient or the authorized individual to establish EFT direct deposit for a claim. Verification includes having the caller provide the following:

i.    Name;

ii.   Claim number;

iii.   Social security number;

iv.  Date of birth;

v.   Date of injury; and

vi.  Address, including phone number. If address is not current:

a)   Verify previous address; and

b)   Obtain and update current address.

3.   Staff shall ensure the caller answers all questions correctly in order to proceed with the voice authorization.

4.   The Customer Contact Center shall complete the A-12 online and read the authorization agreement to the recipient. Staff shall forward the caller to Benefits Payable if the caller:

a.   Would like to sign-up for EBT; or

b.   Cannot verify information; or

c.   Resides in a foreign country and does not have a U.S. financial institution account; or

d.   Does not agree or understand the agreement.

5.   Benefits Payable will verify the financial institution information input into the EFT module to ensure its accuracy.

a.   If there is an error in the input or on the A-12, those entries shall be returned to the Customer Contact Center, where claim service staff will correct the error within the same day and resubmit.

b.   Error entries are “removed/closed” by Benefits Payable when claim service staff does not correct the error entry within the same day (i.e., especially in cases where the payment has been released) from the EFT module.

6.   Changing EFT Direct Deposit - The benefit recipient may change information by:

a.   Completing the Direct Deposit ACT Bank Change (A-35) and returning it to Benefits Payable by mail at PO Box 15429, Columbus, OH 43215 or by fax at 614-621-1140;

b.   Completing the A-35 online at www.bwc.ohio.gov; or,

c.   Calling the BWC Customer Contact Center 1-800-644-6292. The Customer Contact Center will:

i.    Complete the Voice Authorization for Direct Deposit (A-42) form and read the authorization agreement to the recipient; and

ii.   Enter financial institution information into the EFT module and fax the completed A-42 to Benefits Payable at 614-621-1140.

7.   Canceling EFT Direct Deposit

a.   The benefit recipient may cancel by:

i.    Completing the Electronic Benefit Card Enrollment Application (A-21) and returning it to Benefits Payable by mail at PO Box 15429, Columbus, OH 43215 or by fax at 614-621-1140;

ii.   Completing the A-21 online at www.bwc.ohio.gov; or,

iii.   Calling the BWC Customer Contact Center at 1-800-644-6292.

b.   Canceling direct deposit or choosing not to enroll in EBT is not ordinarily an option for a benefit recipient. 

i.    If the benefit recipient believes extenuating circumstances exist to justify opting out from receiving electronic payments, the benefit recipient can contact Benefits Payable to make the request.

ii.   Benefits Payable will make the final decision on approving or denying a benefit recipient’s request to opt out of direct deposit or not to enroll in EBT.

8.   Claims services staff may refer to Direct Deposit Verification & Authorization Policy and Procedure Manual on the Benefits Payable division page for additional information.

 

C.    EBT Benefit Card

1.   Enrollment in EBT may only be completed by Benefits Payable. Benefits Payable shall:

a.   Automatically enroll benefit recipients in the EBT program, after three 14-day (bi-weekly) payments, when personal financial institution information is not provided.

b.   Not automatically enroll benefit recipients in EBT if there is an EFT returned because the financial institution account is closed. Benefits Payable will attempt to contact the benefit recipient by phone to update financial institution information.

2.   Benefit recipients may:

a.   Enroll for the EBT benefit card by contacting Benefits Payable or signing up online at www.bwc.ohio.gov.

b.   Select the EBT card if they do not want EFT.

 

D.    Identifying Payment Method

1.   Claims services staff shall check the claims management system to identify the payment method. 

2.   Staff shall review the Financials, Indemnity Payment, View Reconciliation where the system displays Payment Reference Number to determine method of delivery.

a.   EFT and EBT payments begin with an alphanumeric code in the warrant number field. For example, “A123456” will display.

b.   Paper warrants are numeric with 7 digits in the warrant number field. For example, “1234567” will display.

 

E.     Inquiries When Payment is Not Received

1.   Claims services staff shall check the payment history to verify whether the payment was made electronically or by mail.

2.   If the payment was made by EFT or EBT, claims services staff shall refer the benefit recipient to Benefits Payable by email at EFTGROUP@bwc.state.oh.us

3.   If the payment was via paper warrant, claims services staff shall complete the Warrant Status Change (C-170) requesting a stop payment and fax to 614-621-1140 or email the C-170 to Benefits Payable at EFTGROUP@bwc.state.oh.us.

 

F.     Recoupment of Payments

1.   Benefits Payable will process attempts to reverse and/or reclaim payments.

2.   Benefits Payable may reverse or reclaim payments, when appropriate, because all written authorizations are signed by the benefit recipient or because verbal authorization has been given to BWC at the time of enrollment. Benefit recipients are given notice at the time of enrollment that BWC can withdraw payment(s) made in error.

3.   Benefits Payable shall change the payment status at the time of reversal or reclaim.

 

G.    Reversals

1.   Claims services staff shall make reversal requests for payments that have not yet released EFT/EBT as a “Pull Request” and not adjust the impacted compensation until the results of pull request have been updated in the claims management system.

2.   Claims services staff shall adjust payments in the claims management system prior to requesting reversal for all payments that have released EFT/EBT. The overpayment must be equal to or greater than the amount of the reversal.

3.   Claims services staff shall complete the C-170 to request reversal of payment already transferred for each payment processed in error and fax to 614-621-1140 or email to Benefits Payable at EFTGROUP@bwc.state.oh.us.

a.   Reversal requests shall be no more than five (5) days after the settlement date of erroneous entry, based on the National Automated Clearing House Association (NACHA) rules and guidelines for reversing entries.

b.   The claims management system accounts for the warrant date and it is the settlement date. 

4.   Additional and more specific information regarding overpayments and adjustments can be found in the Overpayment of Compensation policy and the Adjustment of Overpaid Compensation policy.

 

H.    Reclaims (When Recipient Dies)

1.   Claims services staff shall:

a.   Verify the date of death (DOD); and

b.   Determine method of payment:

i.    For electronic delivery, modify any payment plans to end including the date of death in the claims management system.

ii.   For paper warrants, reduce the payment plan to the last scheduled payment prior to the date of death. Place a stop payment on any outstanding warrants.

c.   When the plan is reduced, the IW’s claim may reflect an overpayment.

2.   Benefits Payable shall receive a report the next day showing the DOD entry. Benefits Payable shall stop and attempt to reclaim any payments made electronically after DOD.

3.   Results of full, partial or unsuccessful reclaims shall be posted to the claims Financials Transactions window.

4.   Additional and more specific information regarding payment of accrued compensation, overpayments and adjustments due to death can be found in the Accrued Compensation policy, Overpayment of Compensation policy, and the Adjustment of Overpaid Compensation policy.