Issuing a 1099

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					     Legal Aid of NorthWest Texas


 Equal Justice Volunteer Program


FINANCIAL MANAGEMENT
     PROCEDURES




                                        Updated: August 8, 2006
                       Approved by LANWT Accounting Department
            T A B L E           O F      C O N T E N T S



                FINANCIAL MANAGEMENT PROCEDURES


I.    Financial Management Accountability System ……………………..          1

      A.   Payment Procedures …………………………………………….                     1

           1.    Reduced Fee Payments …………………………………                  1

           2.    Processing Attorney Billing Statements …..…………...   1-3

      B.   Processing Litigation & Out-of-Pocket Expenses ………………     3

      C.   Reduced Fee Pay Schedule ……………………………………...                4


II.   Purchasing Procedures ……………………………………………..…                     5

      A.   Purchasing Policy ……………………………………………….                     5

           1.    Routine Purchasing …………..…………………………                 5-6
           2.    Receiving Purchases ……………………………………                  6-7

      B.   Purchasing Non-routine Items …………………………………..              7

           1.    Emergency Use of Imprest Account ……………………           7
           2.    Training & Travel Request ……………………………..             7-8
           3.    Emergency Supplies ……………………………………                   8
           4.    Seminars, Video Showings, Events, & Outreach ………    8




           FINANCIAL MANAGEMENT PROCEDURES
I.      FINANCIAL MANAGEMENT ACCOUNTABILITY SYSTEM

        Legal Aid of NorthWest Texas has established a financial accountability system for processing
payments to attorneys who handle reduced fee cases, request payment of out-of-pocket expenses, and general
purchasing for the Equal Justice Volunteer Program.

       An encumbrance system is established for attorney payments based upon LANWT’s Reduced Fee
Payment Schedule (See Section C). Reduced Fee cases are paid at a rate of $40 per hour. Attorneys are
required to submit billing statements on their letterhead and are paid according to the approved allocated
case hours. Additional case hours may be granted on a case-by-case basis as approved by the branch office
Managing Attorney and the Director of Pro Bono & Bar Relations.

         Billing statements must be reviewed and approved by the branch office Coordinator, Managing
Attorney, Director of Pro Bono & Bar Relations (or designee), and the Accounting Department. This system
alleviates the potential for errors and over billing. Out-of-Pocket expense billings are similarly processed.
The Director of Pro Bono & Bar Relations may approve litigation expenses not to exceed $500 only if prior
approval has been granted. The Director of Finance & Budget may approve expenditures up to $1000. The
Chief Executive Officer or in his absence, the Director of Advocacy & Grants Administration must approve
expenses that exceed the authorized limits.

        In compliance with the LSC Regulations Part 1614.3 (e), Legal Aid of NorthWest Texas has a
separate accounting system in place for expenditure of PAI funds.


                                 A.      PAYMENT PROCEDURES

1.      REDUCED FEE PAYMENT PROCEDURE:

        Private attorneys should be encouraged to submit monthly billing statements. The EJVP
Coordinator is required to request mid-year and end-of-year billings from attorneys for unpaid case work.
This will allow accurate budgeting and planning.

        A completed Form W-9 Request for Taxpayer IDENTIFICATION NUMBER AND
CERTIFICATION must be obtained from each attorney retained on a reduced fee basis. The name that
appears on the Form W-9 must also be on IRS records. The Coordinator must mail the original Form W-9 to
Accounting and retain a file copy. No payments will be processed without this form filed in the
Accounting Department.

       All payments to private attorneys will be made by the Central Administration Accounting
Department. The Accounting Department must control these payments to:

               Process billings through the encumbrance system and
               Track IRS reporting and issuing 1099’s.

2.      PROCESSING REDUCED FEE BILLING STATEMENTS:

         LANWT’s staff will utilize the following procedures to accurately process billings received from
private attorneys on reduced fee cases:
                                                    1
EJVP COORDINATOR: The Coordinator is responsible for reviewing and processing billing statements
pursuant to the following procedures:
a) Determine if a portion of or the entire billing has been submitted by reviewing the last billing
   submitted for payment. Indicate which portion that was submitted on a previous billing
   statement prior to submitting to the Director of Pro Bono & Bar Relations (or designee) for
   approval.

b) Reviews the Case Activity Log to confirm that billed hours do not exceed the approved
   encumbered hours. Payments are recorded each time a billing is received and indicated on the
   Case Activity Log under Section: “Reduced Fee Payment Schedule.”

c) Checks to make sure that the initial number of approved encumbered hours are not approaching
   the hourly limit. If the attorney has a balance of less than two (2) case hours, contact the
   attorney to find out the number of hours needed to complete the case. Complete an Authorized
   Hours for Funds to be Encumbered Form. Indicate under “Reason for Increase” why
   additional hours are requested. The attorney should be reminded of LANWT’s policy of
   requesting prior approval to increase reduced fee hours.

     The Authorized Hours Form must be approved by the branch office Managing Attorney and
     Coordinator prior to submitting to the Director of Pro Bono & Bar Relations for approval. Mail
     the original form to the Director of Pro Bono & Bar Relations and file a copy in the client’s file.

d) If an attorney continually exceeds the allotted hours without “advanced” approval, the
   Coordinator should contact the attorney to remind him/her of LANWT’s requirement for prior
   approval before additional hours can be granted. Continued problems must be discussed with
   the Managing Attorney and the Director of Pro Bono & Bar Relations. The Director of Pro
   Bono & Bar Relations MAY place a “cap” on reduced fee hours.

e) Be sure to check the attorney’s mailing address. If there is a change of address, note the new
   address on the billing statement. This ensures proper mailing of checks and 1099 IRS forms.

f) Check math computations to ensure that the hourly rate of $40 is correct. Unless prior approval
   is obtained from the Director of Pro Bono & Bar Relations, LANWT will not pay court
   costs or other related litigation expenses.

g) After reviewing the billing statement, use the Payment Processing Stamp to record the Case,
   Attorney, and Tax ID numbers (or Social Security number). Indicate whether interim or final
   billing, sign and date the billing statement. Submit the original billing to the Director of Pro
   Bono & Bar Relations (or designee) and place a copy of the billing in the client’s file.

         DO NOT make written notations on the billing. However, use a small area on the billing to
         indicate relevant information. Accounting needs space to code and process payment.

h) Record on the Case Activity Log the date the billing was received, number of hours billed,
   amount of payment, balance of remaining hours, and the date billing was mailed to the Director
   of Pro Bono & Bar Relations (or designee).

i)   All billing statements must be processed to the Director of Pro Bono & Bar Relations (or
     designee) no later than two (2) days after it is received by the Coordinator. This timeframe will
     ensure timely payments to the attorney.


                                                 2
DIRECTOR OF PRO BONO & BAR RELATIONS: The Director or (designee) is responsible for
approving all Reduced Fee billing statements submitted for payment. Upon receipt of billings the Director
(or designee) will:

       a) Review billings to ensure that the required information is indicated on the statement.

       b) Check for reasonable charges and calculation errors.

       c) Approve billing for payment.

       d) Forward billing to the Accounting Department for payment within one (1) day after receipt from
          the branch office Coordinator.

       e) Billings with major problems will be sent back to the Coordinator for correction.

ACCOUNTING DEPARTMENT: The Accounting Department is responsible for approving all Reduced
Fee billing statements submitted for payment. Upon receipt of billing statements from the Director of Pro
Bono & Bar Relations or designee, Accounting will:

       a) Check billing for mathematical accuracy, verify that a Form W-9 is on file, and indicate the
          account number on the billing.

       b) Ensure that sufficient funds have been encumbered for the case.

       c) Log payment on the encumbrance system.

       d) After the check has been signed with the required signatures, Accounting will mail the check to
          the private attorney.



           B.      PROCESSING LITIGATION AND OUT-OF-POCKET EXPENSES

1.     The Director of Pro Bono & Bar Relations must approve all litigation expenses in advance. The
       Managing Attorney may approve emergency litigation expenses up to $100.

2.     Litigation and out-of-pocket expenses must be reviewed and approved by the Coordinator,
       Managing Attorney, Director of Pro Bono & Bar Relations, and Accounting in the same manner as
       RF billings.

3.     Out-of-pocket expenses on Pro Bono or Reduced Fee cases must be processed with the Payment
       Processing Stamp as described under 2-f. Receipts must be attached to the reimbursement request.

4.     Mail the reimbursement request to the Director of Pro Bono & Bar Relations for approval. The
       Director will submit the request for reimbursement to Accounting for payment.




                                                     3
                            C.       REDUCED FEE HOURLY SCHEDULE

LEGAL PROBLEM                                                        CODE                       HOURS

CONSUMER/FINANCE
      Bankruptcy/Debtor Relief                                       01                         8/7
      Collection                                                     02                         5
      Contracts/Warranties                                           03                         2
      Credit Access                                                  04                         2
      Energy                                                         05                         2
      Loans/Installment Purchases                                    06                         2
      Public Utilities                                               07                         2
      Unfair Sales Practice                                          08                         2
      Other Consumer/Finance                                         09                         2
EDUCATION
      Education                                                      11                         5
EMPLOYMENT
      Wage Claims                                                    22                         5
      Other Employment                                               29                         15
FAMILY
      Adoption                                                       30                         10
      Custody/Visitation                                             31                         10
      Divorce/Separation                                             32                         10
      Guardianship/Conservatorship                                   33                         5
      Parental Right Termination                                     35                         10
      Paternity                                                      36                         10
      Spouse Abuse/Protective Orders                                 37                         12
      Support                                                        38                         12
      Other Family                                                   39                         6
HEALTH
      Medicaid                                                       51                         5
      Medicare                                                       52                         5
      Other Health                                                   59                         5
HOUSING
      Federally Subsidized Housing                                   61                         14
      Homeownership/Real Property                                    62                         10
      Landlord/Tenant                                                63                         5
      Other Public Housing                                           64                         5
      Other Housing                                                  69                         5
INCOME MAINTENANCE
      TANF/Other Welfare                                             71                         3
      Food Stamps/Commodities                                        73                         3
      Social Security                                                74                         10
      SSI/SSD                                                        75                         10
      Unemployment Compensation                                      76                         10
INDIVIDUAL RIGHTS
      Individual Rights                                              89                         10
MICELLANEOUS
      Incorporation/Dissolution                                      91                         3
      Wills/Estates                                                  95                         6
      IRS Tax                                                        97                         6

Case Matters NOT LISTED should be opened with five (5) case hours.
                                                                            RF Pay Schedule.Updated: 4/2006

                                                          4
II.   PURCHASING PROCEDURE

                             A.      PURCHASING POLICY

      ALL purchase requests must be submitted on LANWT PURCHASE REQUISITION and
      approved by the branch office Managing Attorney. The Director of Pro Bono & Bar Relations
      Director is responsible for approving ALL EJVP purchase requests up to $500. If a request is
      over $500, the Chief Executive Officer or in his absence, the Director of Advocacy & Grant
      Administration must approve the purchase. The Purchase Requisition should include:

                     Name of vendor;
                     Page number from the catalog; and
                     Price of the item(s).

      Purchase requests must be submitted to the Pro Bono & Bar Relations Director on the 10th or 25th of
      each month. This will allow the Accounting Department ample time to process the request for a
      Purchase Order (PO) number. If there is an emergency, this requirement can be waived upon
      notification to the Pro Bono & Bar Relations Director.

      NO PURCHASES are not to be made without a PURCHASE ORDER Number
      which is provided by the ACCOUNTING DEPARTMENT.

      To save cost, Centralized Purchasing will be utilized by our program whenever possible. Bulk
      Purchasing allows the program to obtain larger discounts. Coordinators should not spend the time
      shopping for bargains, traveling to pick-up supplies, or writing checks for the purchases. This is a
      function of the Accounting Department.

      The Coordinator is responsible for submitting the Purchase Order Requisition Form to the Pro
      Bono & Bar Relations Director for approval.

      The Coordinator should be able to project what supplies will be needed until the next order date or
      supplies arrive. If an unforeseen item is needed prior to the scheduled order date, a purchase
      order requisition may be submitted to the Director of Pro Bono & Bar Relations for approval.
      The Director will submit the purchase order requisition to the Accounting Department for
      issuance of a PO number.

1.    PROCEDURE FOR ROUTINE PURCHASING

      a)      EJVP COORDINATOR:

                     Retrieves blank Purchase Requisition from the “Intranet” Forms Bank and prepares
                      the Purchase Requisition.

                     Designate "EJVP” and explanation why item is needed under the "Purpose
                      Column”.

                     Mail Original to the Pro Bono & Bar Relations Director after approval from the
                      Managing Attorney. Do not FAX Purchase Requisition Forms. ORIGINAL
                      Purchase Requisitions must be submitted unless instructed to fax the form by the
                      Director of Pro Bono & Bar Relations.

                                                   5
                       Create a Purchase Requisition File Folder to place a copy of all requests.

                       After receiving a copy of the Purchase Requisition from the Accounting
                        Department, attach it to the file copy retained in the Purchase Requisition file.

        b)      MANAGING ATTORNEY:

                       Reviews ALL Purchase Requisition requests.

                       Determines if the purchase request is within branch office budget.

                       Approves request by signing the Purchase Requisition Form, return the form to the
                        branch Coordinator to be mailed to the Director of Pro Bono & Bar Relations for
                        approval and processing by the Accounting Department.

If a Purchase Requisition is “disapproved” by the Managing Attorney, he or she should sign on the
disapproval line, indicate the reason for the purchase disapproval, and place the disapproval in the Purchase
Requisition File Folder.

        c)      DIRECTOR OF PRO BONO & BAR RELATIONS:

                       Upon receipt of the Purchase Requisition, the Pro Bono & Bar Relations Director
                        must review and approve the purchase request.

                       Purchase Requisitions received must be submitted Accounting no later than three (3)
                        days after receipt from the EJVP Coordinator for issuance of a PO number.

        d)      ACCOUNTING DEPARTMENT:

                       Reviews Purchase Requisition and decides on the Vendor, if a Vendor is not
                        noted on the purchase request.

                       Completes a Purchase Order Form that indicates the PO number. This form will be
                        mailed or faxed to the branch office EJVP Coordinator.

                       Accounting will note any changes and/or disapproved item.

                       Accounting will place the order with an approved vendor. Non-routine orders
                        may take longer.

                       A Purchase Order is valid for ONLY thirty (30) days.

2.      PROCEDURE FOR RECEIVING PURCHASES

        The branch office EJVP Coordinator must do the following upon receiving purchases:

        a)      Check the Purchase Order upon delivery of items from vendor and sign the Freight Bill
                noting any shortages or damages to the purchased items.

        b)      Check purchases actually received against the Purchase Requisition and the Purchase Order
                Form.

                                                      6
       c)      Immediately complete and sign Receiving Report listing items actually
               received. Do not just copy the vendor’s list of items. Actually look at items received and
               write down what is seen.

       d)      Send the Receiving Report, invoice(s), freight bill, and packing slip to the Accounting
               Department. DO NOT SEND XEROXED COPIES OF THESE ITEMS, "ORIGINAL"
               COPIES MUST BE SUBMITTED.

       e)      If there is a discrepancy between the purchases received and the approved Purchase Order,
               immediately notify the Accounting Department.

               Exception: If a discrepancy is noted by vendor on the Invoice or packing slip (i.e., back
               order), do not notify Accounting.

       f)      If the APPROVED Purchase Order has been MISPLACED AND                       CANNOT BE
               LOCATED call the Accounting Department before accepting the purchases.      Accounting will
               instruct whether or not to accept the order.

       g)      If the order is complete, staple the purchase order to the Purchase Requisition and
               the Receiving Report, then place forms in the Purchase Requisition File Folder.


            B.      PROCEDURE FOR PURCHASING NON-ROUTINE ITEMS

        Occasionally expenses arise which may not lend themselves to the Routine Purchasing Procedures;
however, this should not occur frequently. If a non-routine purchase is needed, follow the procedures
indicated below:

       1.      EMERGENCY USE OF IMPREST ACCOUNT:

                      Court Costs: Emergency Court Costs of up to $100.00 may be paid from the
                       branch office Imprest Account with the Managing Attorney's approval. If the cost
                       EXCEEDS $100.00, approval must be obtained from the Pro Bono & Bar
                       Relations Director. Upon approval, the Pro Bono & Bar Relations Director will
                       process the request to the Accounting Department. Accounting will issue a
                       Purchase Order Number if approved by the Director of Budget and Finance.

                      Supplies: Generally, supplies ARE NOT to be purchased out of the branch
                       Imprest Account. It was established to pay EMERGENCY FILING FEES or other
                       EMERGENCY LITIGATION costs.

       2.      TRAINING AND TRAVEL REQUESTS:

               Training and Travel requests must be submitted on the REQUEST FOR TRAINING AND
               TRAVEL FORM. The Training Request must be approved by the Managing Attorney
               prior to submitting to the Director of Pro Bono & Bar Relations for approval. The Director
               will submit the Training & Travel request to the Chief Executive Officer for final approval.
               Request for training and travel should be submitted at least three (3) weeks prior to the
               training event.



                                                            7
     Routine travel for outreach, attending legal clinics, and visits to an attorney’s office do
     not require prior approval. However, ALL requests for travel reimbursement expenditures
     MUST be submitted on the DAILY EXPENSE FORM. The Daily Expense Form must be
     approved by the Managing Attorney and submitted to the Pro Bono & Bar Relations
     Director for approval.

     Advances are processed by the Accounting Department and mailed to the branch office
     Coordinator. If an Advance is needed for an emergency trip in a short time frame, contact
     the Accounting Department for instructions on how to proceed.

3.   EMERGENCY SUPPLIES:

     Occasionally, an unforeseen item is needed quickly by the branch office. When this occurs,
     a Purchase Order Number MUST be obtained from the Accounting Department. If the
     item cannot be invoiced or charged to our Program, payment may be made from the Imprest
     Account upon approval from the Director of Budget and Finance. Purchase order
     numbers will not be issued after a purchase has been made or order placed.

     The Purchase Order number MUST appear on the check request. If supply items are
     purchased WITHOUT a Purchase Order, reimbursement to the employee from the Imprest
     Account will be QUESTIONABLE.

4.   SEMINARS, VIDEO SHOWINGS. OUTREACH AND PRO BONO EVENTS:

     The Managing Attorney and the Pro Bono & Bar Relations Director must approve
     expenditures that “exceed” $25 to host a seminar, video showing, and/or an Annual Pro
     Bono event. A detailed budget MUST be submitted to the Pro Bono & Bar Relations
     Director for review and approval. The budget must be specific as to costs and vendor(s) that
     will be used for the activity.

     Upon receipt of the budget, the Pro Bono & Bar Relations Director will approve the
     expenditures and submit the budget to the Chief Executive Officer for final approval for
     expenses over $500. The approved budget will then be submitted to the Accounting
     Department for issuance of the Purchase Order numbers.

     A RECEIVING REPORT must be completed for all expenditures over $25. This report
     must be processed as explained under PROCEDURE FOR RECEIVING PURCHASES-3
     c, d, and e.

     An expenditure that is under $25 does not need a PO Request. With approval from the
     Managing Attorney, reimbursement can be made from the “IMPREST” account or
     you may claim reimbursement on the Daily Expense Form submitted monthly. You
     must provide a receipt to claim reimbursement for expenditures.


                                                     EJVP Purchasing Policy/Procedure.
                                                     APPROVED & IMPLEMENTED 7-03
                                                     Updated: March, 2004
                                                     Updated: August 8, 2006



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