POLICY

Entering an Overpayment in the Recoveries System
The Recoveries System is a web-based system used to calculate Seniors, Community and Social Services' overpayments, debts and to record debt collection activity.

 
The worker enters the information in the OP/Debt Groups Summary screen to calculate a new overpayment in the Recoveries System. All new overpayments and debts entered in the IS/AISH/AAHB Debt Type will default to temporary status when first created.

Temporary status means the overpayment entered is not yet a permanent debt due to the government and no collection activity can commence. There is no time limit on the temporary save function, however notification will appear on the creator’s homepage 40 days after the overpayment has been created to remind the worker that additional action may be required.

Program staff must review the Overpayment Process policy to determine when an overpayment is entered into the Recoveries System and when it converts from a temporary debt to a permanent debt for collection to begin.

Assignment of Overpayment
Normally an overpayment is assigned to the Head of Household. The Recoveries System attaches the overpayment to the Personal Identification Number (PID).

The system allows the worker to assign the overpayment to either the Head of Household, the partner, or split the overpayment between the two (i.e., If the partner had undeclared income, it may be appropriate to assign the overpayment to the partner).

Occasionally an overpayment is assigned to a non-client. In these circumstances Treasury Board and Finance (TFB) enters the overpayment as a Non-IS debt Group.

Splitting an Overpayment
If both the Head of Household and the partner have undeclared income, it may be appropriate to split the overpayment. If the overpayment is split, the total overpayment of the Head of Household and the partner must not exceed:

• The total benefits issued, or 
• The amount of the overpayment which would be assigned to one individual.

Rounding Income
As the Recoveries System does not automatically round cents to the nearest dollar amount, workers must round all income amounts when entering the revised budget. Income entered into the Recoveries System with a cents value less than 50 cents is rounded down to the nearest dollar. Income entered into the Recoveries System with a cents value greater than 50 cents is rounded up to the next dollar amount.

Example
If the client reports income of $417.50 the amount entered and shown on the budget would be $418.

Adjusting a Debt
A temporary debt may be edited (increased or decreased) before the status converts to a permanent debt to ensure accuracy of a debt that will be recovered. Adjustments may be made when:

• an error was made in the previous calculation,
• new information is received,
• the delegated authority’s decision impacts the amount that will be recovered, or
• the Appeal Panel has varied or reversed a decision.

 

A permanent debt cannot be increased without; creating a new temporary debt (overpayment), notifying the client of the new calculation, and providing the right to appeal the new assessment.

Note
A second overpayment for overlapping Periods of Assistance (POA) cannot be created until the first debt is permanent.

Deleting an Existing Debt
An existing temporary debt may be deleted from the Recoveries System when:

• a potential overpayment is no longer being assessed,
• the delegated authority to assess an overpayment has determined that no repayment of an assessed overpayment is required, or
• the appeal panel reverses the department’s decision to assess an overpayment,

Note

The only reason a permanent debt may be considered for deletion would be a response to a write off and suspension of debts policy.

Overpayment Notice
The worker must print the Overpayment Notice (EMP5510) from the Recoveries System whenever a temporary debt is created or adjusted. It details how the overpayment was calculated and includes comments explaining the reason for the overpayment. This notice must be saved to the client’s file as a PDF.

Internal Comments
All comments related to overpayment calculations must be entered in Internal Comments in the Recoveries System, including why an adjustment is made if any.

The following headings and information are defaulted by the Recoveries System:

• Date Entered defaults to the current date
• Author defaults to the person entering the overpayment/debt

 

The worker enters comments under the following headings:

• Subject: a one line summary of the text
• Text: a clear and concise explanation of activities or contact (i.e., Overpayment amount, reason for the overpayment, applicable period of assistance, why an adjustment was made etc.)

Notice Comments
Comments included in the Overpayment Notice are used to outline the reason for the overpayment. Comments are meant to be a source of information for the client, they must be entered in the first person. For example, the worker should enter “you have been overpaid” instead of “the client was overpaid” in Notice Comments. All information entered should be consistent with the content in the notification letter that is issued to the client.

Example
It is not appropriate to simply state “you received excess income”. The client must be told what the excess income was, who earned it and how the program treats that income. If the client is not given an earnings exemption because they deliberately failed to report employment income, that information must be communicated to them.

The following headings and information is defaulted by the Recoveries system:

• Date Entered defaults to the current date
• Author defaults to the person entering the comment
• Period(s) of Overpayment defaults to the month(s) the overpayment occurred

 

The worker enters comments under the following headings:

• Subject: a one line reason for the overpayment
• Text: a clear and concise explanation as to why and when the overpayment occurred, how it was calculated and why an adjustment was made etc.

 

Medical Benefits
If medical benefits were excluded in the initial determination and the worker wishes to continue to exclude them, the worker clicks on Exclude Med Benefits and “reloads” pay history or manually deletes the appropriate medical need line(s) from the Edit OP/Debt Details screen if the pay history was “reloaded”.

If medical benefits were included in the initial determination, all need/income lines (including medical benefits) will be brought in when the worker “reloads” pay history.

If the medical benefits were excluded in the initial determination and the worker now wishes to include them, the worker reloads the pay history and does not click Exclude Med Benefits.

If the medical benefits were included in the initial determination and now the worker wishes to exclude them, the worker must manually delete the appropriate medical need line(s) from the Edit OP/Debt Details screen.

Note
If after the adjustment is entered, the result is a credit balance, the amount owing is issued from LISA to the client.

PROCEDURES

Creating a New Overpayment

The worker:

1. Reviews the procedures section in the Overpayment Process policy to ensure that the overpayment should be entered in the Recoveries System, and if so,
2. Creates the overpayment as a temporary debt by clicking on the Op/Debt Group folder and adding a IS/AISH/AAHB debt type (OP Pending status).

Note

If an overpayment is being created for a non-client, TBF enters the overpayment as a Non-IS debt Group.

Adjusting a Temporary Debt
The worker:

1. Edits the temporary debt based on the new or corrected information using the Edit Debt Group feature to edit or OP Pending save.
   
   Note
   
   If partial repayment is required, the temporary debt must be adjusted to reflect what needs to be repaid before it is converted to a permanent debt. Prior to this the entire Overpayment Notice from the Recoveries System must be printed and saved as a record of the full overpayment calculation on the client file.
   
2. Enters new Notice Comment and Internal Comments to reflect the new information.

Converting an Overpayment to a Debt Due
Once the appeal period has elapsed (confirmed, varied or upheld), the appeal has been withdrawn or the appeal has been determined to be abandoned by the Appeal Panel, the worker:

1. Converts the overpayment into a debt by changing the temporary or OP Pending status to permanent status.
2. Prints and issues the applicable copy of the Debt Notice from the Recoveries System (which includes the Statement of Debt) to the client.
3. If the documents are returned, enters Internal Comments in the Recoveries System and records this activity in Compass Comments.

Note
Sometimes a client will make a payment at an Alberta Supports Centre without the worker's knowledge before the overpayment has been converted to a debt or the debt has been entered into the repayment system (i.e., when the amount of a repayment agreement is unknown). Treasury Board and Finance will contact the worker when they receive the client's payment in order for the worker to enter or convert the overpayment to a permanent debt. Treasury Board and Finance will then enter the payment against the debt.

Decreasing a Permanent Debt

When it is determines that a permanent debt should be decreased, the worker:

1. Edits the permanent debt using the Edit Debt Group function and manually updates the status inside the debt to convert it to a permanent save status. (Note: when decreased it does not display as temporary status).
2. Prints two copies of the updated Statement of Debt (EMP2827). Sends one copy to the client along with a letter (created by the worker) explaining how and why the debt was decreased and places the other copy on Section 1 of the client’s file.
3. Enters new Notice Comments and Internal Comments to record the reason for the change.
4. If the documents are returned, enters Internal Comments in the Recoveries System and records this activity in Compass Comments.

Entering a Debt from a Repayment Agreement or a Restitution Order after a Fraud Conviction
If the client has signed a repayment agreement agreeing they have a debt or has been convicted of fraud and has been ordered to pay restitution or compensation, the worker:

1. Sets up the overpayment as temporary debt, but does not print the Overpayment Notice.
2. Converts the overpayment to a permanent debt and enters Internal Comments.
3. Prints a copy of the appropriate Debt Notice then issues to the client.
4. If the documents are returned, enters Internal Comments in the Recoveries System and records this activity in Compass Comments.

Note

If a court ordered repayment does not cover the entire overpayment amount, the overpayment process is followed to recover the balance after the permanent debt for the restitution order is established.

If there is a fraud conviction and the client has been ordered to pay restitution the Income Services Investigations Unit (ISIU) Operational Support worker:

1. Enters the temporary debt showing the amount that needs to be paid under the court order using Fraud Conviction as the reason for the debt, and changes the Court Order/Fraud Conviction flag to YES
2. Immediately converts this temporary debt to permanent. Collection for this debt is not recovered by a deduction from an active client’s benefits, so the R Flag for this debt is set to 3.
3. Follows the Overpayment Process if there is a balance from the full overpayment amount and enters the appropriate reason for the overpayment (i.e. unreported income) in the Recoveries System. The R flag for this debt follows the standard Recovery of Debt policy and the R Flag is set to 1.
4. Records all activity in the Recoveries System Comments and in Compass Comments.

Deleting an Existing Debt
The worker:

1. Enters Internal Comments in the Recoveries System and record the details of why the overpayment is being deleted in Compass Comments to ensure a record of the activity is retained.
2. Prints a copy of the Overpayment Notice from the Recoveries System to be retained as a record of the overpayment calculation on the client’s file.
3. Deletes the temporary debt from the Recoveries System.

LISA and CCD
Once a debt is entered on an active file, the Recoveries System downloads the:

• Debt amount to LISA
• R Flag change on LISA
• Recovery Flag change on CCD

 

Once a debt is entered on a closed file, the Recoveries System downloads the:

• Change to the Recovery Flag on CCD
• Updated information to LISA if the file is reopened.