Attachment_D_-_Benefit_Payment_Recovery_Standard_Operating_Procedures_(SOP).pdf

Benefit Payment Support - Recovery Processing Standard Operating Procedures

Attachment D

1 TABLE OF CONTENTS

Summary

1 Intake

1.1 Review Recovery Memo

1.2 Process Case In ARES

1.3 Prepare Intake Package

2 Debtor Known

3 Debtor Unknown

3.1 Courtesy Letter (CL)

3.2 Refund Request

3.3 Overpayment Through Check

3.4 Bank Subpoena

3.4.1 Prepare and Send Subpoena

3.4.2 Review Subpoena Response

4 CRS Prep Documentation Packet

4.1 Recovery Due to Benefit Determination Letters (Overpayment > $1,000)

4.2 Recovery Due to Death

4.3 Other Recovery Situations (AP, QDROs)

5 Recommendations To Federal Management Analyst

6 Federal Management Analyst Decision

6.1 Checklist For FMA Decision

7 Processing Centralized Receivables Service (CRS) & FedDebt Payment

SUMMARY

1. Process Flow

Recovery of Overpayments – BPB Processes

BP

B

Payment

Check

Death:

debtor known Refer to Treasury

END

Perform research.

Initial Review

Write-Off.

Case Type Send CRS Treasury

Referral Letter

BDL

Death:

debtor unknown

Yes

ACH Send subpoenaPay Type?

Allow 35/ 60 Days

Debtor Identified

Subpoena

SCC or OIG or fraud investigation

Send Courtesy Letter

Send Refund Request

Funds Available?

Yes

No

Funds Recovered?

No

Yes

No

Recovery Memo

Start

Send Courtesy Letter

Recovery of Overpayments – BPB Processes (Under $200)

BP

B

Complete Intake

Start

Send Courtesy Letter

Refund Request

Required?

Submit Refund Request

Allow 60 Days

Funds Recovered?

Yes

Process/Record Funds End

Process Write-OffNo

Recovery of Overpayments – BPB Processes (Check Recovery Due to Death)

B P

B

Intake

Start

Check Endorsement

Legible?

End

Check dated less than 3 yrs

Yes

Send to PA for Investigation

PA recovers funds? No Overpayment

>$3,500

Yes Refer to OIG

No

No

Overpayment >$1,000 Yes Refer to OGC

Obtain Death Certificate

Yes

Forward to SSC to Identifying Bank that cashed check

Bank Identified? Send 516O

Bank Responds and

Debtor Identified?

Send Courtesy Letter

Yes

Yes

Yes

No

Payment Made?

Yes

No

Refer to CRS

No

Write-Off

No

1 INTAKE

The intake process begins when a recovery memo is received via an email from the Field Offices (FOs). A recovery memo is generated when the FO’s initial action to recover the overpayment amount has failed. The FOs generally attempt to recover funds via an ear through: ACH reclamation for electronic direct deposits; or a “Return to Trust” eCARF, which prompts the PBGC paying agent to stop payment on outstanding checks and return the funds to trust. A recovery memo submitted by the FO generally contains the following information (sample data provided):

Exhibit 1

Sample Recovery Memo Information

1. Participant’s Name: John Doe

2. Participant’s SSN: 123-45-6789

3. Plan Number: 123456789

4. Amount of Debt: $1,500

5. Payment Type (ACH or paper check): ACH

6. ACH Reclamation Initiation Date: 1/3/2018

7. ACH Reclamation Outcome: COMPLETED – NO FUNDS RECLAIMED – CANNOT

LOCATE ACCOUNT

8. Death Recovery Information:

a. Date of Death: 12/1/2017

b. Month OverPaid: 1

c. Monthly Amount: $1,500

We are referring this to Recovery Team for Further Processing. 1/1/2018 Overpayment has not been credit to the PBGC.

1.1 REVIEW RECOVERY MEMO

Upon receipt of the recovery memo:

1. Copy Memo and save to the I Drive

2. Print Memo

3. Review the Memo for Accuracy, using the following checklist:

a. Review PLUS Ledger Verify that the payment amount is correct. Highlight the overpayment in ledger.

If the overpayment was not returned or credited to the ledger, Print and highlight the findings.

b. Review Image Viewer

Look for any recent correspondence to the participant, estate, or anyone related to the case.

Look for return payments or attempts to recover payments including: ACH rejections, reclamation actions, check purges or RRT.

Look to see if death certificate is available.

Print and highlight your findings.

Look for check image and research check details (signature, account number, bank information etc.):

If the check has been endorsed, highlighted findings on the check and enter information in ARES.

If the check endorsement is not legible or account information is unidentifiable, enter appropriate information indicating as such in

ARES.

c. CRM Look for service requests pertaining to the debtor.

Look for any requests for debtor information or information regarding the estate.

Print and Highlight your findings.

d. CLEAR If death certificate is found in image viewer, research the informant.

Print a CLEAR report for the informant on the death certificate.

4. If after reviewing it is determined that additional information is required from the FBA, return the recovery memo to the FBA and set ARES as follows:

Status: Pre-Recovery Reason: With-FBA Additional Research Requested

5. If the memo contains adequate information that can be verified, proceed with next steps.

1.2 PROCESS CASE IN ARES

After review, the case information is entered into ARES. If ARES has a pre-existing SSN for the participant, verify that the plan numbers are different.

1. Login to ARES

2. Click Create a New Recovery.

3. Search for the participant using either the SSN, CUST_ID, CASE_CUST_ID, or Name fields.

4. Double click the correct customer for the list box.

5. Answer Yes/No to any additional prompts, as appropriate.

6. Enter Appropriate Required Information, which may be as follows:

Date of Death (DOD) Recovery Type Payment Type FBA/PVA Information

Overpayments Tab: Retrieve overpayment information by clicking “Fill Payments” under the Overpayments Tab. This shows the Spectrum ledgers.

Select the appropriate overpayments and click “Import Checked Payments,” which will create payment rows in ARES.

User Comments Tab:

o Copy information provided in numbers 5 – 8 (Figure 1 above) from recovery and paste into the comment field.

7. Enter all findings from case research into ARES comments.

8. For check payments, where research indicated that the check was deposited, and the endorsement is illegible, or account number is unidentifiable, enter comment in ARES stating, “requesting SSC to identify the negotiating financial institution.”

9. Enter other recommendations, as appropriate and applicable to the case.

10. Set ARES to:

o Status Code: Pre-Recovery o Reason Code: Needs Initial Review

1.3 PREPARE INTAKE PACKAGE

Once the intake is complete and recommendations are prepared and reviewed by the contract supervisor a printed copy of the intake packet is sent to the FMA. The intake packet should include the following:

PLUS Ledger Document/Correspondence from Image Viewer Documents/Correspondence from CRM CLEAR Report (if death certificate contains an informant, provide a CLEAR report for the informant.

A copy of intake packet is also provided to Document and Records Management Center (DRMC) for imaging into the participant’s file. Set ARES as follows:

Status: Pre-Recovery Reason: With Recovery Coordinator

2 DEBTOR KNOWN

If the debtor is known and the overpayment is a result of a Benefit Determination Letter (BD), the intake packet, including the BDL and PACS information, as well as information related to participant’s appeal, if applicable, is sent to the Federal Management Analyst (FMA) to refer the debt to CRS

1. The FMA will direct the recovery team to refer the case to CRS for collection. The FMA will:

a. Assign a Debtor ID to the debtor. The debtor ID is the same as the Tracking Number.

b. Update ARES:

o Set Status to “Open” o Set Reason to “Refer to CRS”

2. After receiving the FMA direction, the recovery team:

a. Sends a CL/Treasury Memo informing the debtor that the debt is being referred to

CRS.

b. Prepares the package for CRS and updates ARES:

o Set Status to “Open” o Set Reason to “Needs prep for CRS”

c. The recovery team prepares the package and forwards to CRS for collection and updates ARES:

o Set Status to “Pending” o Set Reason to “With CRS – BPB Referral” o Letter Dates & Events Tab: “CRS Treasury Referral” with date of letter as the “Event Date”

2. If the debtor is an estate, trust or other legal entity:

a. Prepare a CCS 568 letter to the executor, administrator or the appropriate party and updated ARES o Set Status to: “Open” o Set Reason to: “Send Letter – Estate Demand”

b. Once the letter is sent, updated ARES o Set Status to: “Pending” o Set Reason to: “With debtor – Estate Letter Sent” o Set Follow up for 35 days.

c. If payment is received, verify the repayment, close the case and update ARES o Set Status to: “Closed” o Set Reason to: “Paid in Full”

d. If no response to the demand letter is received within 35 days or a partial payment is received, follow the subpoena process.

e. If no response to the demand letter is received and the amount of debt is $1,000 or more, refer the case to OGC o Set Status to: “Pending” o Set Reason to: “With OGC – Estate”

3. For overpayment due to death and if the payment was made through a check and the check has been endorsed,

a. For checks with clear endorsement, send a courtesy letter to the person who cashed the check and wait 35 days.

o Set Status to: "Pending” o Set Reason to: “With debtor letter sent”

b. If no response is received within 35 days, follow the same process as described above for BDL overpayment and refer the debt to CRS.

o Sends a CL/Treasury Memo informing the debtor that the debt is being referred to CRS.

o Prepares the package for CRS and updates ARES:

Set Status to “Open” Set Reason to “Needs prep for CRS”

c. The recovery team prepares the package and forwards to CRS for collection and updates ARES:

Set Status to “Pending” Set Reason to “With CRS – BPB Referral” Letter Dates & Events Tab: “CRS Treasury Referral” with date of letter as the “Event Date”

d. If the courtesy letter results in a payment, take appropriate action to record the payment and recommend closure of the case. While the payment is being processed, update ARES to:

o Set Status to: “Open” o Set Reason to: “Pre-Collections Payment Adjustment

e. Once the payment has been processed, update ARES to:

o Set Status to: “Ready for Closure” o Set Reason to: “Pre-ARES Closure”

3 DEBTOR UNKNOWN

If the debtor is unknown, the recovery team takes the appropriate next steps to attempt to identify the debtor and recover payment:

3.1 COURTESY LETTER (CL)

1. Updates the CL spreadsheet with address of recipients.

2. Complete mail merge

3. Mail Letters

4. Submit Letters to DRMC

5. Update ARES

a. Set Status to “Open”

b. Set Reason to “With debtor – Courtesy Letter Sent”

c. Enter data in Letter/Dates/Events Tab: Update action/letter type to “Courtesy Letter” and event date to the date on the CL

6. Set the time to follow up time to 35 days for debts greater than $200

a. If no response received, proceed to bank Subpoena process in Section 4.2.

7. Set the follow-up time to wait 60 days for debts less than $200 and

a. No response Received

i. Recommend write-off and prepare documentation for write-off.

Update ARES Set Status to “Open” Set Reason to “Needs Write-off”

8. If the response to courtesy letter indicates that an estate is involved:

a. Recommend that an estate demand letter (568) is sent. Prepare the estate demand letter and set ARES as follows:

Set Status to “Open” Set Reason to “Send Letter – Estate Demand”

b. Once the letter is sent, update ARES as follows:

Set Status to “Pending” Set Reason to “With Debtor – Estate Letter Sent

c. In no response is received, proceed to bank Subpoena process in Section 4.2.

d. If the response indicates that there may be a legal issue and the amount of debt is over $1,000:

i. Prepare a referral to the OGC and provide the OGC with relevant documentation.

Set Status to “Open” Set Reason to “Send Estate to OGC”

ii. Once referred to OGC, change ARES:

Set Status to “Pending” Set Reason to “Pending – With OGC – Estate”

iii. Set follow up to 30 days and follow up with OGC.

9. If at anytime before referral to OGC or the bank subpoena, the debtor promises to pay within two weeks, set follow up in ARES for two weeks and change ARES to:

Status to “Pending Reason to “With Debtor – Payment Promised – Allow 2

Weeks”

3.2 REFUND REQUEST

If the overpayment occurred through an ACH transaction and the response for Paying Agent shows that partial funds were collected or the account is frozen, submit a refund request to the bank that received the payment.

3.3 OVERPAYMENT THROUGH CHECK

For overpayment due to death and if the payment was made through and the check has been endorsed:

1. For checks with clear endorsement, send a courtesy letter to the person who cashed the check and wait 35 days.

o Set Status to: "Pending” o Set Reason to: “With debtor letter sent”

b. If no response is received within 35 days, follow the same process as described above for BDL overpayment and refer the debt to CRS.

o Sends a CL/Treasury Memo informing the debtor that the debt is being referred to CRS.

o Prepares the package for CRS and updates ARES:

Set Status to “Open” Set Reason to “Needs prep for CRS”

c. The recovery team prepares the package and forwards to CRS for collection and updates ARES:

Set Status to “Pending” Set Reason to “With CRS – BPB Referral” Letter Dates & Events Tab: “CRS Treasury Referral” with date of letter as the “Event Date”

d. If the courtesy letter results in a payment, take appropriate action to record the payment and recommend closure of the case. While the payment is being processed, update ARES to:

o Set Status to: “Open” o Set Reason to: “Pre-Collections Payment Adjustment

e. Once the payment has been processed, update ARES to:

o Set Status to: “Ready for Closure” o Set Reason to: “Pre-ARES Closure”

2. For checks without clear endorsement:

a. forward the case to Paying Agent COR for submittal to the PA to identify the bank that cashed the check and update ARES:

o Set Status to: “Open” o Set Reason to: “Refer to SSC – identify bank that cashed check”

b. Once the check is sent to the paying agent, updated ARES:

o Set Status to: “Pending” o Set Reason to: “With SCC – to identify the bank that cashed check”

c. If the bank is identified, follow the subpoena process.

d. If the bank responds to the subpoena and a debtor is identified, send a Courtesy Letter to the debtor following the process outlined in the Courtesy Letter section.

e. If the courtesy letter results in a payment, take appropriate action to record the payment and recommend closure of the case. While the payment is being processed, update ARES to:

o Set Status to: “Open” o Set Reason to: “Pre-Collections Payment Adjustment

f. If the bank does not respond or debtor is not identified, obtain a death certificate for the deceased payee.

g. If it is confirmed that the paid check was not received by the intended recipient and the payee is deceased, and the check was dated no more than three year ago:

i. Forward the case to the paying agent for investigation and Update ARES to::

o Set Status to: “Open” o Set Reason to: “Refer to SSC – Fraud Investigation.

h. If the paying agent recovers the funds, verify the funds are received and close the case.

i. If the paying agent does not recover funds and the overpayment amount is more than $3,000, recommend to the FMA that the case be sent to OIG for investigation and updated ARES:

o Set Status to: “Open” o Set Reason to: “Refer to OIG- Fraud”

j. The FMA will review and forward the case to OIG, and updated ARES:

o Set Status to: “Pending” o Set Reason to: “With OIG – Fraud”

k. If the overpayment amount is more than $1,000 and less than $3,500, recommend to the FMA that the case be sent to OGC.

3.4 BANK SUBPOENA

If no response is received from the CL, or if the response from the CL fails to identify the debtor, a subpoena is prepared to obtain information from the bank. Before processing a subpoena, review:

ARES for comments and/or updates.

Review IPS to ensure a payment has not been returned.

Ensure a duplicate request is not being sent.

Document findings of review in ARES.

3.4.1 Prepare and Send Subpoena

Once a review is complete and it is determined that the subpoena process should continue, a subpoena package is prepared. This includes Prepared Administrative Subpoena (CCS 516 Letter), printed from IPS; and system generated enclosures to include:

Certification for Demand of Documentary Material Schedule A.

Statement in Support of Motion or Order.

Certification of Service.

A 516 letter informing the debtor or estate that a subpoena has been sent to the bank must also be included in the package.

Resources for preparation of subpoena package are as follows:

Data Required Resource Payee/Estate Address IPS (505 Letter) Addressee Name IPS (505 Letter) Address of Bank TGBR, Bank Resource DB Name of Bank ARES Export Bank Account Number ARES Export Tracking Number ARS Export Subpoena Date Enter Manually Monthly Payment Amount ARES (Overpayment Tab) Date of Last payment ARES (Overpayment Tab) Overpayment Amount ARES Export

1. Prepare Subpoena Documentation and set ARES to:

Set Status to “Open” Set Reason to “Send Letter – 516 Subpoena” Update follow-up period to 30 days.

2. If estate is involved, send 516CCL letter to notify the estate that PBGC issued a subpoena to the financial institution and update ARES.

Set Status to “Pending” Set Reason to “With Estate – 516CCL Sent”

3. If no estate is involved, inform the individual debtor that a subpoena has been issued by sending 516CCL Compliance letter.

Set Status to “Open” Set Reason to “Send Letter – 516 CCL Compliance Letter”

4. Once prepared, submit subpoena to the BPB Division Manager for review and signature.

Subpoenas should be completed and submitted into CCS for approval 2 days prior to the mailing date.

5. Update ARES the same day that subpoenas are mailed:

Set Status to “Pending” Set Reason to “With RDFI – 516 Sent”

Update Letters, Dates, Events, and Comment Tabs with appropriate information to indicate subpoena was sent.

3.4.2 Review Subpoena Response

If the financial institution complies and returns the subpoena information timely:

1. Review the documents provided in the response for the following and set ARES to:

i. Status to “Open”

ii. Reason to “Needs Review of Subpoena Documentation”

a. Debtor Identification o Review subpoena cover page/bank affidavit to assist in identifying the debtor.

o Review signature card, which identifies the account ownership.

b. Overpayment Identification o Review bank statement to identify and highlight the overpayment on the statement.

o If overpayment is not listed in the provided statements, a follow up to subpoena will be needed to specify the period of bank statements required to identify the overpayment received.

c. Transactions that Implicate Debtor o Review debit transactions that would indicate that debtor may have withdrawn funds: Transfer slips, cashier’s check, withdrawal slips, other checks.

2. Update ARES using the information received:

i. Update Debtor’s tab and enter as much information as possible.

ii. Update Letters and close out the follow-up by entering the date response was postmarked.

iii. Update Comments tab by describing the basis for identifying the debtor.

3. Recommend Next Steps as appropriate. These may include the following:

a. If response from the bank is received in 35 days, and Funds are available:

i. Draft Refund Request Letter and update ARES:

Set Status to: Open Set Reason to “Send Letter- Refund Request”

ii. Once the letter is sent, update ARES:

Set follow up for 35 days Set Status to “Pending” Set Reason to “With bank/other – Refund Letter Sent”

b. If response from the bank indicates that the funds are not available, but the identity of the debtor is established, prepare case for Referral to CRS and:

i. Update ARES Set Status to: “Open” Set Reason to: “Needs Prep for CRS”

ii. Once the FMA reviews the case and authorizes referral to CRS, ARES is updated to:

Set Status to: “Open” Set Reason to: “Refer to CRS”

c. If additional Information is Required: Prepare CCS 516O letter to the bank and set ARES as follows:

Set Status to “Open” Set Reason to “Send Letter – 516O for Other Docs”

Request any of the following as appropriate in the 516O:

Withdrawal Documents: Documents to identify the person who facilitated the withdrawal transactions on the account.

Specific Bank Statements: Bank statements for a specified period.

Account Transfer with or without Account Numbers: Documents to identify the person who facilitated transfer of funds from the participant’s account to another account.

Hard Copy Documents: If documents provided electronically are unreadable.

Response to Refund Request: Copies of bank statement, withdrawal slips, and closeout debits facilitated on the account.

Debit Card & ATM Transactions: Documents including account signature cards, which identify the person having authority to withdrawal assets from the account using a debit card or to make debit card purchases or ATM withdrawals, from the date of death until the account was closed.

Signature Card: Signature cards associated with the account.

Specific Transactions: Documents that identify the person who facilitated specific transactions on the account.

Death Certificate: Death certificate to initiate federal fraud investigation.

ii. Once the 516O is sent, Set ARES as follows:

Set Status to “Pending” Set Reason to “With Other – 516O Sent” Set timer in ARES to 35 days

d. If no response is received from the bank within 35 days, follow up with the bank:

i. Prepare a follow up subpoena and update ARES to:

Set Status to “Open” Set Reason to “Send Letter – 516F Subpoena.

ii. Once sent, update ARES to:

Follow up for 35 days

Status to “Pending” Reason to “With RDFI – 516F Sent”

e. If the bank fails to respond to the subpoena and the overpayment amount is more than

$1,000:

i. Refer the case to OGC for appropriate action:

Set ARES Status to: “Pending “ Set ARES Reason to: “With OGC – Subpoena Situation”

f. If the information obtained from the subpoena does not identify the debtor or no funds are available:

i. For debts less than $10,000 recommend write-off and closure, and image the recovery benefit overpayment closeout report.

Set ARES Status to “Ready for Closure” Set ARES Reason to “Write-Off BPB (Deceased Debtor < $10,000”

ii. For debts greater than $10,000 refer the case to OGC and set the follow up to 30 days. Proceed according to OGC’s direction.

Set ARES status to “Pending” Set ARES Reason to “With OGC – xxxx”

g. If information provided by the bank is conclusive prepare case for CRS processing.

i. Update ARES

Set Reason to: “Needs Prep for CRS”

ii. Once the FMA reviews the case and authorizes referral to CRS, ARES is updated to:

Set Reason to: “Refer to CRS

4 CRS PREP DOCUMENTATION PACKET

The following checklist is used in preparation of CRS Packet.

4.1 RECOVERY DUE TO BENEFIT DETERMINATION LETTERS (OVERPAYMENT >

$1,000) Print Ares Cover page (Resource: Ares, Clear Report) o Input participant information from Clear report ARES Details field o Input date of the BDL into Ares Letter/Dates/Events field

Print Participants Clear report (Resource: Clear) Print Proof documents (Resource: Image viewer, CRM) Print BDL o Highlight BDL Date, Overpayment Amount ACH Situations: Print plus Ledger o Highlight Participant name, Overpayments, (Spectrum Code, “PBGC 1 or Pbgc 4”)

Check Situations: Print Check Print PACS Print CRM docs o Print & Highlight recovery related information only.

Print Appeals documents (if applicable) o Highlight OP amount o Highlight Appeals adjusted amount if the debt is increased or reduced by the

Appeals board Print Original Referral Memo Forward Packet to FMA o FMA approves and issues a tracking number Image CRS Packet o Submit to DRMC for imaging after FMA approval

4.2 RECOVERY DUE TO DEATH

Print Ares Cover page (Resource: Ares, Clear Report) o Input debtor information from Clear report Print Clear report (Resource: Clear) Proof documents (Resource: Image viewer, CRM) o ACH Situations Bank docs showing proof of PBGC overpayment(s)

Highlight PBGC Deposit on bank docs Bank docs showing proof of the debtor’s involvement.

Withdrawals, Signature card, transfer documents, etc.

PLUS Ledger: Highlight Participant name, Overpayments, (Spectrum

Code, “PBGC 1 or PBGC 4”) o Check situations

Print Check Print CRM documents: Highlight pertinent information only

Original Referral Memo Forward Packet to FMA o FMA approves and issues a tracking number Image CRS Packet o Submit to DRMC for imaging after FMA approval

4.3 OTHER RECOVERY SITUATIONS (AP, QDROS)

Print Ares Cover page (Resource: Ares, Clear Report) o Input debtor information from Clear report o Input Generic Letter Date in ARES

Print Clear report (Resource: Clear) Print Proof documents (Resource: Image viewer, CRM) o Generic Letter o QDROS o PIF

Print CRM docs o Highlight pertinent information only

Print Original Referral Memo o Highlight Month of Overpayment

Forward Packet to FMA o FMA approves and issues a tracking number

Image CRS Packet o Submit to DRMC for imaging after FMA approval

5 RECOMMENDATIONS TO FEDERAL MANAGEMENT ANALYST

Cases that require the involvement and approval of the FMA include the following:

1. Referral to Paying Agent for Fraud Investigation.

2. Referral to OGC for ACH fraud situations.

3. Referral to OIG for fraud investigations.

4. Referral to CRS.

5. Recommendation for Write-off.

6 FEDERAL MANAGEMENT ANALYST DECISION

The FMA reviews the case and provides its decision regarding the recommendation provided by the recovery team. The FMA conducts additional research using PBGC tools to verify the:

validity of the debt, identity of the debtor (if known), debt amount, and that the case should be referred or written-off as described in section 5.

6.1 CHECKLIST FOR FMA DECISION

The FMA decides the next steps in the process using the following checklist:

Action Basis for Decision Tools Used Refer to OGC (Subpoena Issue)

• Bank is unresponsive, and overpayment is greater than $1,000

• Verify overpayment amount using PLUS and ARES and ensure it is a valid debt.

• Review case information in ARES to see if the bank was provided enough time for a response.

• Review the subpoena package to ensure that instructions to bank in the subpoena were correct.

• Reviewing other supporting document as appropriate in Image Viewer.

Refer to SSC (Fraud) • Cannot Determine the bank that cashed check Check was dated no more than 3 years ago

• View the image of the check to verify that the endorsement information is illegible and that the check was dated within the last three years.

• Review case history in ARES.

• Review PLUS for any returned payments etc.

Refer to OIG (Fraud Investigations)

• SSC cannot retrieve funds (checks) and the debt amount is over $3,500

• Other Fraud situations

• Review ARES to research case information.

• Verify the debt amount and ensure validity of the debt.

• Review Communication to/from the SSC.

Refer to CRS • Identity of Debtor is known

• BDL or Non-Deceased debtor

• Subpoena response sufficient to identify the debtor

• Review original referral memo

• Review cover pages from ARES and Clear

Reports.

• Review Proof documents (Resource: Image viewer, CRM)

• Ensure that the bank docs show proof of PBGC overpayment(s)

• Ensure bank document show proof of the debtor’s involvement.

• Review Withdrawals, Signature card, transfer documents, etc from the subpoena information provided by the bank.

• Review PLUS Ledgers to verify overpayment and participant information.

• View checks, if check situation

• View CRM documents provided by the referral team and conduct additional research in CRM, as required.

• Print CRM

Write Off • No Response to courtesy letter for amount less than $200

• No Results from subpoena for amounts less than $10,000 after OGC efforts

• Third Party Debtor

• Unrecoverable checks under $1,000

• Review ARES

• Review Image Viewer

7 PROCESSING CENTRALIZED RECEIVABLES SERVICE (CRS) & FEDDEBT

PAYMENT

After CRS referral is processed and payments are received, they must be processed in order to be posted to ARES and the debtor’s ledgers.

In order to process payments from CRS or FedDebt:

1. Open ARES, SharePoint eCARF.

2. In Receivables Coordination System, open the following:

i. BPBReceivables_SharePoint.accdb & CurrentCRSPayments or CurrentFedDebtPayments

ii. BPB Recovery Work Books/Pending Recoveries. If it is the first payment, start a new spreadsheet for the case.

iii. BPB comments, and spreadsheet links.

iv. Open each case’s spreadsheet in BPB Recovery Work Books.

v. Retrieve general ledgers from PlusWeb using social security number.

vi. Retrieve payments and Ares status records from BPB Receivables database/CurrentCRSPayments or CurrentFedDebtPayments using tracking number.

vii. Put the retrieved information in a new worksheet of the spreadsheet and retrieve he case in ARES using tracking number.

3. Payment Reconciliation

i. Use DOD or BDL to find the debt that needs to be recovered in general ledger.

ii. Calculate total payments from CRS payment table

iii. Calculate total credit memos in GL. Total payments minus total credit mom (CM) posted in GL will equal to the new payment if the account is previously reconciled (if it does not equal the new payment, analyze the possible reasons, which may include:

SSC did not post the repayment previously processed).

iv. Determine the amount of credit that needs to be applied against the correct overpayment.

Situation 1: CM has been offset with balance in SSC

If SSC offset credit memo with balance, then add back the the offset credit memo to the CM currently shown in the Plus ledger to get the total credit memo posted.

Add back the offset debt to debt currently shown in the Plus ledger to get the original debt amount. Lump Sum cases’ ledger will not have CM offset with balance situation.

Situation 2:

Payment carried over until it can be fully credit one overpayment for tax refund purpose. SSC does not return the tax filed within three years automatically if partial payment is entered to credit the overpayment amount. Therefore, when the partial payment cannot fully credit one overpayment, the payment is carried over in spreadsheet until one full payment can be credited and tax is returned. In this case, only ARES will be updated and eCARF transaction will be retired.

eCarf will be credited with full payment later, when the available CM is enough to fully credit one overpayment. The additional payment will continue to be carried over until the second full payment can be made.

4. Process the Payment

i. Retrieve ARES record using tracking number. Process the payments in ARES Adjustments section.

ii. Enter the CRS transaction number in the reference section (long transaction number indicates lock box adjustment; short transaction number indicates pay.gov adjustment).

iii. For FedDebt payments, enter FedDebt DebtID in the reference section.

iv. Process the payment in eCARF. Note any difference between DMC check amount and actual credit memo requested in BPB comments, such as: funds received in excess of debt amount; tax refund; payments received by treasury but not credited to SSC, etc.

v. Insert spreadsheet link and change to the correspondent tracking number.

vi. Click BPB complete box and save to transmit the eCARF to SSC for processing

(always credit against ledger net amount and apply payments up to each year’s balance).

5. Debt Paid in Full

i. When the debt is paid in full, last payment is only credited up to the net balance.

Funds received in excess of debt amount is entered in eCARF comments and processed as a neutral entry, and overpayment refund can be processed in eCARF, after confirmation that part of the payment indeed is in excess of funds. The taxes paid must be returned to the debtor within three years of filing.

ii. For FedDebt case, open the FedDebtUploadArchive table in BPB Receivables-Share Point database.

iii. Find the case using AgencyCaseID (tracking number), and check whether any payments needs to be returned to debtor. Copy the information in the spreadsheet to determine whether there is an overage that needs to be returned to the debtor. If so, use the ARES Debtor information to process an eCARF overpayment.

iv. Move the spreadsheet from pending cases folder to closed cases folder.

v. Change the ARES status reason code from Pending/Collection to “Pending-with PA

Awaiting for Ledgers.”

7 Processing Centralized Receivables Service (CRS) & FedDebt Payment