Food Stamps and Reimbursement

Discuss questions around local unit policies for budgeting, reconciling, etc. This forum should not contain specific financial or membership information.
nutterb
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Food Stamps and Reimbursement

Postby nutterb » Mon Apr 20, 2009 5:02 am

This isn't an urgent issue, thank goodness, but let me provide the context of my question.

We had a member submit four receipts for reimbursement. Reimbursement was not being requested for all of the expenses on the receipts (line item reimbursement).


  • The total of the receipts was approximately $300.
  • The total reimbursement requested was approximately $80.
  • On one receipt, there was $70 of charges, only $4 of which was to be reimbursed
  • On that same receipt, food stamps were used to make $30 of the payment.


Fortunately, the reimbursement is small relative to the charge, so I don't think we'd run into any problems here, but we a feeling that reimbursing a receipt with a food stamp payment could open us up to some legal problems. But we're not entirely sure, and I haven't found anything that addresses the issue. Does anyone here have any knowledge or experience with this type of thing?

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aebrown
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Postby aebrown » Mon Apr 20, 2009 5:32 am

nutterb wrote:
  • On one receipt, there was $70 of charges, only $4 of which was to be reimbursed
  • On that same receipt, food stamps were used to make $30 of the payment.
...feeling that reimbursing a receipt with a food stamp payment could open us up to some legal problems. But we're not entirely sure, and I haven't found anything that addresses the issue. Does anyone here have any knowledge or experience with this type of thing?


I don't have actual experience with this particular issue, but I don't see that there is a problem. If the food stamps had been used for the entire payment, then I could see a potential issue, since the person would be reimbursed with cash for a payment made using food stamps. But in this case there was $40 of the $70 paid in cash, and the request is that $4 of that $40 is to be reimbursed.

It sounds like there is no itemization that would show exactly which items of the $70 were paid by food stamps and which by cash, but it seems reasonable to assume that the items being reimbursed were among those paid by cash. In any case, you're talking about a mere $4, so I wouldn't be too concerned about legal problems. You are making a good faith effort to reimburse a small expense made by cash, even though other items were paid for by food stamps.

However, to avoid any such concern in the future, it would probably be good to advise the person to have the reimbursible items be put on a separate receipt.

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Zero Tolerance-p40
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Food Stamps and Reimbursement

Postby Zero Tolerance-p40 » Mon Apr 20, 2009 8:54 am

I checked with the Church Legal Department on this one. Here is the official word on food stamps:

"It would be better if the member had the reimbursable charges on a separate receipt, but I do not see a problem in reimbursing the member for non-food items on the same receipt where food stamps were used to pay for food."
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nutterb
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Postby nutterb » Mon Apr 20, 2009 9:46 am

Thanks guy, that's helpful.

I wasn't greatly worried about this incident, but wanted to be sure we didn't get ourselves into trouble down the road.

scion-p40
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Postby scion-p40 » Tue Apr 21, 2009 2:58 pm

Here is another side of this issue: If someone requires food stamps to meet basic needs, then it seems to me that paying for church reimbursable expenditures out of pocket is a hardship for that person. An estimate can be made with cash provided in advance. Reconciliation to receipts is expected, of course.

jbh001
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Postby jbh001 » Tue Apr 21, 2009 7:48 pm

Forgive me for being dense, but I don't see what the issue is with food stamps. The person, not the Church, chose to use means under their own control to provide items for a church activity, for which they were then reimbursed. There was no hint of concern that this person might be trying to manipulate the reimbursement system for their personal benefit or trying to perpetrate a fraud.

Yes it makes things a lot cleaner when reimbursable items are all on their own receipt, but that is a separate issue from using food stamps or not.

Whether or not the use of food stamps is okay is a policy issue, not a technical issue.

The danger I see is that just by virtue of this discussion, an unwritten policy regarding food stamps might reach consensus with apparent (but not actual) authority to create such a policy. This is not the forum for policy discussions.

If it is not okay to use food stamps, by extension is it more right or wrong if the person charges the expenses to a credit card and is now carrying interest? Or what if they paid using a debit card or a check which caused their bank account to go negative and they incurred overdraft fees? Do we now say that only items that can be proven they were paid for by cash or money order are acceptable for reimbursement from the Church? Because that is the logical end point of where this policy discussion is headed.

What if their only source of income happens to be Social Security benefits? Should they then be barred from participating financially in the Church?

It is impossible to answer these questions without creating policy (or at least a semblance of it), and this is not where or the way Church policy should be made.

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Postby jbh001 » Tue Apr 21, 2009 7:49 pm

scion wrote:[size=84]Here is another side of this issue: If someone requires food stamps to meet basic needs, then it seems to me that paying for church reimbursable expenditures out of pocket is a hardship for that person. An estimate can be made with cash provided in advance. Reconciliation to receipts is expected, of course.[/SIZE]
While that is definitely possible, it sounds needlessly more complicated.

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aebrown
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Postby aebrown » Tue Apr 21, 2009 9:04 pm

jbh001 wrote: I don't see what the issue is with food stamps.


The question regarding food stamps was a reasonable one. There are strict laws against refunding cash for purchases made by using food stamps (see the Food Stamps Retailer Training Guide on pages 16 or 19). So it seems that it is prudent for the Church to be careful about reimbursing expenses paid with food stamps.

Although the response from the Church's legal department is second hand, it does give a pretty good indication that it is appropriate to take care in this area. And I don't see how credit card payments and Social Security benefits are at all in the same category as food stamps.

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aebrown
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Postby aebrown » Tue Apr 21, 2009 9:15 pm

jbh001 wrote:While that is definitely possible, it sounds needlessly more complicated.


An advance is appropriate in any situation where it would be a hardship for a member to make the reimbursable purchase using their own funds. It's a bit more work for the financial clerk, but that's a small price to pay to make sure there is no undue burden placed on people who are serving in positions where they need to make purchases on behalf of the Church.

Of course, there is no direct connection between the above statement and food stamps. It may be no hardship at all for someone on food stamps to be reimbursed after the purchase; conversely, it may be a hardship for someone not on food stamps to use their own funds. Leaders should be sensitive to the specific needs of the members.


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