Association for Barry S Bay, Ontario K0J 1B0

Madawaska Valley 19491 Opeongo Line, P.O. Box 1178, Association for Barry’s Bay, Ontario K0J 1B0 Community Living Tel: (613) 756-3817 Fax: (613) 756-0616 www.mvacl.ca

Personal Funds Policy

Policy Statement

Where a person receiving supports has requested assistance with the management of their day- to-day finances or the assistance is identified in the person’s individual support plan a separate book of accounts and financial records is prepared and maintained for each person with a developmental disability who receives assistance with the management of their day-to-day finances.

Procedures Annual Financial Planning:

Each person receiving support from MVACL will complete, with assistance as needed, an Annual Financial Plan, and Personal Budget. (see attached Appendix a & b) These will be reviewed on an annual basis.

Banking Procedures to Open Accounts for Organization at a bank branch Document requirements:

Prior to opening the account, the bank is required to obtain documentation to indicate that the Agency has the right to operate and manage an account on behalf of the individual. The following documents are required:

1. An “Indemnity Agreement” signed by the Agency (see attached Appendix c) 2. A Letter of Direction from the Agency to open the account, designating their appointed Co-signer as the POA for the Supported Person. (see attached Appendix d)

Opening up and account:

Both the Supported Person and the designated co-signer are to visit a branch together to open the account and present a copy of the POA document, a signed “letter of direction” and “Indemnity” agreement from the corporate client.

 MVACL should contact the Bank with the information such as the client name and make an appointment at the branch.  The Supported Person and the Co-signer must present two (2) pieces of identification. It is mandatory that one piece must be from among those set out in Type A. Also, the Social Insurance Number Card (SIN Card) of the Supported Person must be used as one (1) form of identification 1 2 Identification Type A Type B Driver’s License issued in Canada X Canadian Passport X Foreign Passport X Certificate of Canadian Citizenship X Certificate of Naturalization in the form of a paper document or card, but not a X commemorative issue Permanent Resident Card X Citizenship and Immigration Form IMM1000 (prior to June 28th, 2002) X Citizenship and Immigration Form IMM1442 X Citizenship and Immigration Form IMM5292 X Birth Certificate issued in Canada X SIN Card issued by the Government of Canada X Old Age Security card issued by the Government of Canada X As of January 1st, 2008, Old Age Security cards will be issued without reference numbers Certificate of Indian Status issued by the Government of Canada X Provincial Health Insurance Card as permitted to be used for identification purposes X under provincial law *not permitted if issued in PEI, Manitoba or Ontario A document or card, bearing the individual’s photograph and signature, issued by any of the following authorities or their successors: a) Insurance Corporation of British Columbia b) Alberta Registries c) Saskatchewan Government Insurance d) Department of Service Nova Scotia and Municipal Relations X e) Department of Transportation and Public Works of the Province of Prince Edward Island f) Service New Brunswick g) Department of Government Services and Lands of the Province of Newfoundland and Labrador h) Department of Transportation of the Northwest Territories i) Department of Community Government and Transportation of the Territory of Nunavut Provincially Issued ID Card with Photo (in lieu of Driver’s License) X US Driver’s License X US Birth Certificate X Employee identity card, issued by a well-known employer, bearing the individual’s X photograph A signed automated teller machine (ATM) card or client card bearing the name and signature of the cardholder, issued by a member of the Canadian Payments Association. X (i.e. RBC Client Card) Credit card, issued by a member of the Canadian Payments Association in the name of, X or bearing the name of, the individual and bearing the individual’s signature. Canadian National Institute for the Blind (CNIB) client card bearing the individual’s X photograph and signature Credit Card issued by a known retailer (e.g. Sears, Canadian Tire, etc.). X Senior Citizens privilege card X Identification Type A Type B Introduction letter from previous bank with signature X Sponsor, personally known by RBC client or community member. (Identity of the individual confirmed by a client in good standing with RBC Financial Group or by an X individual of good standing in the community where the bank is situated.) 3 Canadian University or College Student Card with Photo X Diplomatic ID issued by Foreign Affairs X Changing the Caregiver on the account

When there is a change in Co signer on the Supported Person’s account, the Corporate Client must provide the bank with a “Notice of Change” (see attached Appendix e) document and a new Indemnity Agreement before any account maintenance can be performed. The letter must indicate the former Co signer and the appointment of a new Co- signer on the existing account. Only the new Co-signer needs to attend the branch and present two (2) forms of identification as mentioned above.

Co-signed Bank Accounts

A co-signed account is an account in the name of the Supported Person by the agency that requires a second signature to permit funds to be removed from the account.

A co-signed account is usually put into place for one or all of the following reasons:

 As a last resort for people supported who have been identified as unable to demonstrate responsible control over their finances, putting at risk their health & safety. For example their ability to pay for food and or shelter. When this type of situation occurs it is necessary to ensure the Supported Person is provided with due process. As a measure to ensure that respect of the Supported Person’s rights is being exercised.

 It is required by the financial institution, as the financial institution has determined the person is not responsible and requests a co-signer for accountability.

 It is required by the person being supported as they have self-identified the need for assistance (i.e. excessive spending is depleting their savings and they wish to save for something specific or temporarily request assistance to regain control of their finances.)

Access

Bank accounts will be established for Supported Persons at a bank that is reasonably close to their residence. All Supported Person bank account statements will be printed off monthly by the Finance Department. The statement will include a monthly date and a list of all transactions.

Access to Supported Person financial records is restricted to the Supported Person, primary Support Worker, appropriate Manager, and the Finance Department. If the primary Support Worker is absent, the Manager will reassign caseload duties and responsibility for managing the Supported Person’s finances. Each Supported Person will be encouraged to apply for direct deposit as this is a much more effective way to manage the account. Staff will assist the individual in making application for direct deposit.

Where a Supported Person receives banking support from staff, the Manager must approve any purchases over $50 using a Purchase Order.

A family who takes on financial responsibility would be expected to participate in the creation of the Personal Budget and Financial Plan.

4 Any monies forwarded from the family for services received and for the personal use of a Supported Person will be administered according to MVACL’s Personal Funds Policy. Receipts will be forwarded in a timely fashion.

All exceptional arrangements with families who take responsibility for managing Supported Person finances will be reviewed annually when the Personal Budget Plan is updated.

Personal Needs Allowance (PNA)

The following applies to all persons who receive O.D.S.P. and their cheque indicates Personal Needs Allowance. Personal Needs Allowance (PNA) provided under O.D.S.P. is an allowance intended to enrich the quality of life of the person supported. The money provided for the personal use of the Supported Person is intended to purchase goods and services not considered to be the responsibility of the agency

Examples of Purchases – PNA

Hobbies, crafts, cosmetics, perfume, special shampoo, clothing, gifts, recreational/leisure activities, admission to community events, dinner out, cigarettes, alcoholic beverages, coffee shop purchases, snack food, personal purchases, special chair, bicycle etc.

Primary Support Worker’s Responsibilities – PNA

The Primary Support Worker assigned to a Supported Person who receives a PNA will not only be required to follow the above procedures but will also be responsible to ensure that PNA money is spent in the interest of the Supported Person and not for expenses covered by the agency. The monthly review and sign off of financial records for each Supported Person by the Primary Support Worker indicates the review took place and is in compliance with this policy.

Manager’s Responsibilities – PNA

The Manager responsible for the Supported Person who receives a PNA will review expenditures to ensure that PNA money is spent in the interest of the Supported Person and not for expenses covered by the agency. The monthly review and sign off of financial records for each Supported Person by the Manager indicates the review took place and is in compliance with this policy.

Income Tax Preparation

The Primary Support Worker will be responsible for retaining all tax related documents throughout the year. The Manager may delegate responsibility for the income tax preparation to either the Primary Support Worker or a Third Party offering Tax Service.

Record Keeping

5 Full financial records must be kept on all co-signed accounts, identifying each transaction requiring removal of funds from the account, and receipts to match. These accounts may be held with identified advocates or family members, where this has been deemed appropriate. Having a co-signer does not mean that the person being supported has relinquished control over their money or their account, but has identified they need additional support with respect to their financial situation. Having a co-signer on the account may give the Primary Support Worker an opportunity to discuss and/or counsel the person being supported regarding their needs in relation to their wants. It will also provide opportunity for the Supported Person to think through the purchase. If after receiving all possible information, the individual determines they still wish to spend the money a signature will not be denied unless it will leave them with no funds for food or shelter or if funds are not available. All expenses and corresponding receipts for Supported Person accounts are entered into a ledger. Receipts will be kept at the supported person’s residence for one year. Receipts for items that have warranties longer than one year will be kept until the warranty expires. All withdrawals, whether cheque or voucher transactions, requires a signature or mark of the supported person and the Financial Department. The use of Debit cards has been discontinued.

Petty Cash

Each Supported Person will have a Petty Cash fund not to exceed one hundred Dollars $100. When a Supported Person requires full support to spend their money and staff oversee their finances, staff are expected:

 To count the money prior to removing any funds. If it does not match the balance in the ledger, report it to the Primary Support Worker directly, or in the communication book. The Primary Support Worker will complete an investigation and discuss the findings with the Manager as soon as possible.  Enter the actual amount in the ledger and highlight the line.  Record the amount taken from the Petty cash.  Obtain receipts whenever possible, if receipt is not retained the use of a receipt voucher is required.(Appendix f)

Replenishing “Petty Cash” requires the use of a withdrawal voucher and requires two signatures, Supported Person and the Finance Department.

Larger purchases over $50.00 or larger cash requests over $100.00, requires a purchase order and cheque for management approval, at which time the Finance Department would sign the cheque.

All supported persons have the right to keep spending money on their person should they wish to do so. Staff are expected to do appropriate money management counseling. The supported person will initial the ledger to remove petty cash from their account. Receipts are not required. Purchases or activities over $25.00 will require approval from Manager (Purchase Order/Action Plan). Loans/Purchases

6 Staff will not encourage borrowing/lending between persons supported. If necessary, persons supported may borrow from the agency’s petty cash to participate in an activity. If at any time staff or a person receiving support wish to sell or purchase anything from one another written approval must be obtained from the Manager prior to the transaction.

Monthly Review of Financial Records The Financial Department will print off and distribute to the appropriate house, the Bank Statements on the first working day after the end of the month.

The Primary Support Worker is responsible for completing monthly reviews of bank account ledgers (statements, transactions and purchases) for persons supported who are identified as receiving support with their finances in their personal Support Plan. The Review/Reconciliation will consist of the Bank Reconciliation Sheet (Appendix g), the bank statement, a copy of the cheque book ledger and the Petty Cash ledger and all receipts. The Supported Person and Primary Support Worker will sign the record to indicate this has been done. Any discrepancies are reported in writing to the Manager immediately.

The Manager must review and sign off each Supported Person bank account ledger each month. Discrepancies that cannot be adequately explained or supported will be investigated and a report will be forwarded to the Executive Director.

If the discrepancy is more than $100 or there are more than three occurrences in one month the Executive Director will be notified and a designated Audit Team will conduct an audit of the Supported Person account and report the findings to the Manager and Executive Director. It is the responsibility of the persons supported Primary Support Worker to rectify any discrepancies after an investigation by the Manager and Executive Director.

Personal bank account information, bank books, ledgers, etc. are to be available at all times to the Supported Person (and/or their significant other with his/her permission). When this is necessary the reason will be documented in the Annual Financial Plan. This will provide consent from the Supported Person and their significant other.

Due to the confidentiality of this information it will be required that this information is kept in a secure location.

Internal Audits

A designated Audit Team will review annually the books of accounts and financial records prepared and maintained for people who receive assistance with the management of their day- to-day finances as identified in their individual support plan. The review will include a report to the Executive Director and the board of directors.

Annual Board Report for People we support Finances

7 Preamble: To fulfill the Quality Assurance Measure requirement as outlined in the regulation below; annually the designated Audit Team will provide a report to the board of directors confirming independent reviews of people supported finances were completed during the fiscal year.

Ontario Regulation 299/10 Ontario made under the Services and Supports to Promote the Social Inclusion of Persons with Developmental Disabilities Act, 2008; Quality Assurance Measures; Part VI Commencement; Part II Quality Assurance Measures with Respect to Service Agencies General states:

“Assistance with the management of finances

6. (1) Each service agency shall have policies and procedures regarding assistance with the management of finances for a person with a developmental disability who receives services and supports from the agency, where the person requests assistance with the management of their day-to-day finances or the assistance is identified in the person’s individual support plan. (2) The service agency shall prepare and maintain separate books of accounts and financial records for each person with a developmental disability who receives assistance from the service agency with the management of their day-to-day finances for each fiscal year. (3) The service agency shall ensure books of accounts and financial records prepared and maintained in accordance with subsection (2) are independently reviewed by a third party annually; the independent review shall include a report to the board of directors.”

Procedure:

 A Designated Audit Team will perform audits as the independent third party reviewer.  The Manager provides a list of persons supported whose personal support plan identifies assistance with day to day finances to the designated Audit Team.  The reviewer contacts both the Supported Person and the Manager to explain the procedure, ask for the Supported Person permission to review their finances and schedule the date to perform the audit.  The reviewer performs the audit as outlined in the scope of audit below.  The reviewer prepares a report which identifies any significant findings and or recommendations.  Follow up as to the implementation of the recommendations is done by the Manager.  Follow up during the next audit is done by the person performing the audit to confirm changes  The designated Audit Team is responsible for coordination and final reporting.

Scope of Audit:

Review current Supporting People with their Personal Finances Policy making recommendations where the policy does not reflect what is occurring. Review use of existing forms and procedures and make recommendations. Randomly review documentation such as bank balances with ledger balances, cash on hand with Petty Cash ledger sheet and required signatures and back up receipts.

Example of YEARLY Report: 8 # of people identified as requesting assistance with their day to day finances. Audits were completed on all of the people within or just prior to the beginning of the fiscal year ending March 31, YEAR.

In general records were in good order with no significant discrepancies. In an effort to continually review and improve systems and provide ongoing training the following recommendations were made:

Approved June 27, 2013 Board of Directors

9 PERSONAL BUDGET (Appendix b)

______

INCOME (including amount and method of payment):

Note: Convert monthly, bi-weekly and quarterly payments to annual amounts

ODSP/OAS ______

Gains Supplement ______

Ontario Trillium Benefit ______

Income Tax Returns ______

Employment Earnings ______

Other Income (trust, subsidies) ______

Total Income: ______

EXPENSES (including amounts and frequency):

Note: Estimate all expenses on annual basis

Residential Fees ______

Transportation ______

Personal Spending ______(e.g., cigarettes, personal allowance, recreational activities)

Personal savings ______(e.g., vacation, larger purchases)

Personal care ______(e.g., hair cuts, person hygiene products)

Other ______

Total regular expenses: ______

Date updated: ______Staff:______

10 SUPPORTED PERSON’S FINANCIAL PROTOCOL

Name: ______Program: ______

Bank(s) 1. Address:

Types of account(s) and Account #: ______

2. ______Address:

Types of account(s) and Account #: ______

Location of:

Bank book/statements:

Financial ledger: ______

Petty Cash: ______

Frequency of withdrawal/transactions (including day of the week and times): ______

Who completes the transactions: ______

How does the Resident get to the bank:

Information on the completion of cheques and withdrawal slips:

Information regarding Resident’s spending money:

Other related information:

11 ANNUAL FINANCIAL PLAN (Appendix a)

Name: ______Date: ______

1. I understand my finances are my personal information I would like to  Take care of all my finances, I don’t need any assistance  I need some help with______

2. I understand on a monthly basis  MVACL receives money from ODSP and I have a trust account  ______receives my money from ODSP  MVACL deposits money in my bank account.  ODSP deposits money in my bank account  I am happy with this and do not want to change at this time  I would like this to change to ______

3. Currently my savings/money is kept at  MVACL trust account  ______family/support network manages my funds  ______bank  I am happy with this and do not want a change at this time  I would like this to change to______

4. Currently my banking is done by  MVACL through my trust account  ______(a family or support network member) does my banking  Staff at MVACL does my banking  I go to the bank with staff  I go to the bank alone  I am happy with this and do not want a change at this time  I would like this to change to ______

5. I do not have a bank account  ______(a family or support network member) signs  I sign with ______(a family or support network member)  ______or______(a MVACL staff) signs  I sign with ______or______(a MVACL staff)  I am happy with this and do not want a change at this time  I would like this to change to______ If staff are assisting with banking attach a copy of the Authorization for Financial Assistance Form  Ensure the bank has a current copy only of this form

6. I understand my finances are my personal information, and I can choose who sees that information  I personally receive all bank/trust statements and keep my bank book  ______(family member) receives my bank/trust statements and keeps my bank book  ______( MVACL staff member) receives my bank/trust statements d keeps my bank book

7. This year I am saving money for the following things:

______$______I would like to save this by ______

12 ______$______I would like to save this by ______

______$______I would like to save this by ______

8.  I feel I have enough money to do the things I want to do  I don’t feel I have enough money. There are things I want that I can’t have  I have asked for help to plan for ways of getting more money or spending my money differently ______will help me with this

9.  I understand that I need to keep my money and belongings safe.  I have a safe place to put my money in my room  I have a safe way to carry my money with me  I also protect my belongings in the following ways ______ I am happy with this and do not want a change at this time  I would like this to change to ______

10.  I understand that to guard against lost or stolen funds my banking and purchasing activities should regularly reviewed  I will review my own information  I will review my information with the assistance of ______(family/support network)  I will review my information with the assistance of ______(staff) and the manager

11.  I understand that I have a right to access my funds and property  I am aware of the Rights & Responsibilities of Supported People Policy and that I can ask for help if I need it

12. Staff have told me about the following risks and how they think this could be better ______

13.  I have a current list of my personal assets  I do not have a list of my personal assets because I do not want one. I understand that staff will help me do a list if I change my mind.

14.  I complete my Income Tax  ______(a family or support network member) currently completes my Income Tax  ______(a staff member) currently completes my Income Tax  ______(Tax Service completes my Income Tax

15. ODSP Trustee Review  I act as my own ODSP trustee  I am aware that ODSP requires me to have a trustee to send information and the trustee acting on my behalf is ______ I am happy with this and do not want to change it at this time.  I would like to change this to ______

Signature: ______Date: ______13 14 Notice of Change of Signing Authority (Appendix e)

Madawaska Valley Association for Community Living 19491 Opeongo Line Box 1178 Barry’s Bay, ON K0J 1B0

Date:

Bank Branch Manager

Dear Sir or Madame:

On behalf of MVACL, we request that you remove [name of previous caregiver(s)] from the personal account (the “Account”) of [name of client]. Effective [date] we request that as of [date] [name of new caregiver(s)] be added to the Account as the new designated employee who will operate the account.

We attach herewith an indemnity dated ______, for and in favour of Bank that is duly executed by ourselves and acknowledged by [name of new caregiver].

We understand that the Account is a non-borrowing account and that no form of borrowing (including overdraft protection and VISA) is permitted on the Account at any time.

The Account will be operated in accordance with banks standard Client Agreement – Personal Deposit Accounts subject to the borrowing restrictions noted above, and such other modifications as may be agreed to, and accepted by the bank.

Signing authority for the Account is to be established as follows: [ ] Any two to sign [ ] All to sign [ ] Any one to sign

We acknowledge our duty to maintain and operate the Account at all times in a manner that is in the best interests of [name of client].

If you have any questions please contact MVACL’s Financial Manager

Yours truly,

15 Letter of Direction (Appendix d)

Madawaska Valley Association for Community Living 19491 Opeongo Line Box 1178 Barry’s Bay, ON K0J 1B0

Date:

Bank Branch Manager

Dear Sir or Madame:

On behalf of MVACL, we request that you open a personal account (the “Account”) for [name of client], the individual named on the Appointment of NOA document dated ______, attached herewith. We also attach an indemnity dated ______, for and in favour of Bank, that is duly executed by ourselves and acknowledged by [name of caregiver(s)], our designated employee(s) who will be operating the Account on behalf of [name of client with an intellectual disability].

We understand that the Account will be a non-borrowing account and that no form of borrowing (including overdraft protection and VISA) will be permitted on the Account at any time.

Signing authority for the Account is to be established as follows: [ ] Any two to sign [ ] All to sign [ ] Any one to sign

We acknowledge our duty to maintain and operate the Account at all times in a manner that is in the best interests of [name of client].

If you have any questions please contact MVACL’s Financial Manager

Yours truly,

16 INDEMNITY (Appendix c)

WHEREAS MVACL has been appointed on [Date] by [Substitute Decision Maker] as POA to act for [Name of client] (the “Client”) and to receive and administer the monies paid out pursuant to the Family Benefits Act, Ontario Disability Support Programs Act, 1997 and/or Ontario Works Act, 1997, or other funds as the case may be, for the benefit of the Client; AND WHEREAS MVACL deposits monies received pursuant to such Appointment of POA into an account (the “Account”) maintained with [Bank] in the name of the Client, but under the administration of MVACL who is empowered and authorized pursuant to the Appointment of POA to withdraw and disburse monies from the Account for the sole benefit of the Client; NOW THEREFORE for valuable consideration (the receipt and sufficiency whereof is hereby acknowledged) MVACL hereby agrees to pay, indemnify and hold harmless Bank, its directors, officers, employees, agents, successors, assigns and associated entities (collectively, the “Indemnified Persons”) from and against any and all loss, liability, obligations, actions, causes of action, claims, damages, statutory rights or remedies, complaints, demands, costs and expenses incurred by it with respect to, or in any way arising from, the Account and/or the maintenance or operation thereof with Bank and/or the deposit and/or withdrawal or disbursement of monies to and from the Account from time to time or at any time. MVACL has the power, capacity and authority to provide this Indemnity. This Indemnity is and shall be binding upon MVACL and its successors and assigns and shall ensure to the benefit of the successors and assigns of the Indemnified Persons. IN WITNESS WHEREOF, MVACL has executed this Indemnity as of [Date].

I/we [Name of caregiver(s)] have been designated by MVACL to act on its behalf relative to the Appointment of POA for [Name of client]. I have read and understand the terms and conditions set forth in this Indemnity

Per: ______(Signature of Care Giver)

Per: ______(Signature of Supported Person) .

I/We have authority to bind the corporation. ______Executive Director

______Board President

17 Receipt Voucher Date:

Store/Supplier:

Items purchased:

Amount:

Reason receipt was not obtained or retained.

Staff name and signature:

Receipt Voucher Date:

Store/Supplier:

Items purchased:

Amount:

Reason receipt was not obtained or retained.

Staff name and signature:

Receipt Voucher Date:

Store/Supplier:

Items purchased:

Amount:

Reason receipt was not obtained or retained.

Staff name and signature:

18 BANKING RECONCILLIATION SHEET

Individual’s Name: ______

Month:______Bank Statement Closing Total: ______

Outstanding Cheques: ______Total: ______

Closing Total LESS Total Outstanding Cheques: ______(A) Outstanding Deposits: ______Total: ______

Total (A) PLUS Total Outstanding Deposits: ______(B) *Total (B) should be the same figure as the individual’s cheque-book balance. Comments: ______

______

______(Supported Person’s Signature/Mark) Date

______(Primary Support Worker’s Signature Date

______(Manager’s Signature) Date 19