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Policy and Procedure Name:
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Electronic Delivery of Funds
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Policy #:
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CP-04-03
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Code/Rule Reference:
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OAC 4123-3-10; Electronic Fund Transfers (Regulation E) 12
CFR Part 1005; and Truth in Lending (Regulation Z) 12 CFR Part 1026
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Effective Date:
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04/19/19
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Approved:
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Kevin R. Abrams, Chief Operating Officer
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Origin:
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Claims Policy
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Supersedes:
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Policy # CP-04-03, effective 12/04/14 and Procedure # CP-04-03.PR1,
effective 11/14/16
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History:
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CP-04-03
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New 12/04/14
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CP-04-03.PR1
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Rev. 11/14/16; New 12/04/14
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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)
The purpose of this policy is to ensure that compensation
and benefit payments are made in the most timely, efficient and safe manner
available.
This policy applies to all claims services staff and
Benefits Payable staff.
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.
- It is the policy of BWC to pay compensation awards via
EBT or EFT.
-
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.
-
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.
- Enrollment requests shall not be imaged to the claim
because financial institution account information is confidential information.
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.
- The benefit
recipient may make changes to the direct deposit information, including financial
institution changes.
- The benefit
recipient may cancel the direct deposit by agreeing to receive payments via the
EBT benefit card.
-
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.
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.
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.
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.
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.
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.
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.
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.
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.