Our Fraud Awareness in the Church series continues as we look at Payroll Fraud and Phantom Employees. We asked churches to respond to these statements:
“Someone not involved in the payroll preparation process distributes paychecks or direct deposit stubs.”
“We review direct deposit account information for duplicate accounts.”
Survey Results – Very few churches do any kind of employee verification once the employee has been hired. According to our survey only 25% of the churches engage in any form of paycheck verification (check stubs in the case of direct deposit). A little higher percentage, particularly among NACBA members, perform periodic reviews of direct deposit data (Social Security numbers, addresses, duplicate accounts, names of relatives, etc.)
KEY: To avoid phantom employees and payroll fraud, a church must KNOW who their employees are.
The term “phantom employee” refers to situations like this:
An employee is terminated but a supervisor continues to submit hours so that the “employee” continues to receive a check for months, sometimes years, after the employee left. The supervisor either colludes with the phantom in order to have the check endorsed and cashed or resorts to forgery.
A payroll clerk creates fictitious employees. These often are friends and relatives and once again, the fraudster will collude or forge.
I suspect the compliance is low regarding these questions because most “church” employees are easy to identify due to the relatively small staff size of most churches (25 to 50) and turnover is relatively low. HOWEVER, this is not the case with satellite operations such as a daycare program. Many, if not most, daycare programs are staffed by low paid, low hour, often temporary employees. Almost by definition, the turnover rate of a daycare program will be volatile compared to the parent organization, the church. With so many people coming and going, it is almost impossible to know each and every employee – an ideal place to breed “phantom employees.”
Part 10 of our ongoing Fraud in the Church series. PSK in cooperation with the National Association of Church Business Administration (NACBA) conducted a survey to determine the extent to which churches are attempting to address the problem of church fraud. We asked them to respond to this statement:
Our church has established a “Positive Pay” arrangement with our bank.
Increasingly, due to technological change and advancement, the threat of fraud is no longer limited to dishonest employees. Hackers and other “online bandits” have become quite proficient in draining the bank accounts of the unsuspecting. One defense against this is to establish a Positive Pay arrangement with your bank.
Only 5% of our respondents have this type of bank account protection in place, which is surprising because Positive Pay is a simple three-step process.
- During the check writing process, a list is compiled of bills to be paid.
- The list is sent to the bank.
- The only checks or drafts to be cleared by the bank are those on the list.
I am very curious why so few take advantage of this. Any ideas?
Except in the rarest of cases, personnel costs are the single largest expenditure of a church. Because churches are in the “service industry”, it should come as no surprise that forty-five to fifty percent of the typical church budget will be dedicated to employee related costs.
This highlights a basic principle in the behavior of an embezzler. For obvious reasons, people committing fraud prefer to remain anonymous. In order to enjoy the fruits of their labor they must remain hidden. It is much easier to hide fraud among the bigger numbers – like payroll.
Key: As a result, personnel costs are a favorite target of fraudsters. Usually, fraud in this area is small-time with one employee falsifying their own time card or submitting phony expense reports. However, some payroll frauds can be quite extensive and creative. The more spectacular (and costly) may involve:
- “Phantom” employees
- Fraudulent insurance claims
- Bogus tax refunds.
These scams can easily run into the tens of thousands of dollars.
Churches should not be naïve about payroll fraud. Because churches are as vulnerable to personnel fraud as businesses, they should do two things.
- First, repeating the theme of a previous section, churches must follow the IRS compliance guidelines. This means designating an independent compensation committee to set compensation amounts, based on market comparison information, and documenting all decisions made. At a minimum, this process should be followed for executive level staff but is also a good practice to follow for the entire church staff.
- Second, churches should also follow a “best practices” approach in human resources administration. In addition to contributing to a healthy workforce these best practices also contribute to eliminating the possibility of fraud. A few of these practices are:
- Establishment of formal job descriptions
- Performing background checks
- Performing regular performance evaluations and obtaining written termination letters from departing employees.