This week’s “Ftag of the Week” on the CMSCG Blog is F567 Protection / Management of Personal Funds. The core of this Ftag is that the resident has the right to manage his or her financial affairs. Included in this regulation is the facility’s responsibility for informing the resident of what charges may be imposed against their personal funds.
A facility cannot require a resident to deposit their personal funds with the facility. If, however, the resident chooses to deposit their personal funds with the facility, upon written authorization of the resident, the facility has a fiduciary responsibility to “hold, safeguard, manage and account for” the deposited personal funds. All personal funds in excess of $100 must be deposited in an interest-bearing account(s) that is not co-mingled with the facility’s operating account. All interest earned on the resident’s funds must be credited to his or her account. If the facility pools the residents’ funds into a single account, they must have a system for separate accounting for each resident’s share.
The regulation also addresses those residents whose care is funded by Medicaid. All personal funds in excess of $50 must be deposited in an interest-bearing account(s) that is not co-mingled with the facility’s operating account. All interested earned on the resident’s funds must be credited to his or her account. If the facility pools the residents’ funds into a single account, they must have a system for separate accounting for each resident’s share. The facility is also responsible for maintaining personal funds that do not exceed $50 in a non-interest bearing account, interest-bearing account or petty cash fund for these residents.
Reporting & Requests
Facilities must report quarterly on the status of resident funds to all residents who maintain a personal fund account with the facility. Don’t forget those quarterly statements. Facilities must also ensure that cash requested by a resident ($100 or for Medicaid residents $50) is provided within a reasonable period. The IG notes that requests for less than $100 ($50 for Medicaid residents) should be honored within the same day of the request. The IG also notes that requests for $100 ($50 for Medicaid residents) or more should be honored within three banking days. You are responsible for maintaining amounts of petty cash on hand to meet resident requests for funds. Most facilities have a reasonable idea of the amount of cash to have on hand on a routine basis. A system needs to be in place so that residents can have access to their funds on an ongoing basis as well as arrange for access to larger cash amounts in their account.
Residents should also be able to request that the facility temporarily hold their funds in a safe place without the facility being authorized to manage those funds. There should be a system in place to document the date, time, amount of funds received from and who the funds were released to.
A resident cannot be charged a fee by the facility for management of their personal funds. All fund transactions should include the resident receiving a receipt for the transaction and the facility maintaining a copy for its records.
On survey, residents will be questioned regarding such things as if they get a quarterly statement that indicates any interest earned, if they have a problem accessing their funds (especially outside of routine business hours) or if limited are placed on the amount of money that can be withdrawn from their accounts. Lastly, there is a cross-reference to compliance with F583 – Personal Privacy / Confidentiality of Records. Do some interviews of your own and see what your residents know and understand about the management of their personal funds.