These are unprecedented times. This COVID-19 situation is putting significant financial strain on employers and we anticipate that many of our clients will have immediate concerns on their ability to stay current on benefit account funding commitments.
As you may be aware, OCA front-pays merchants for all point of sale debit card activity, participants for direct deposit reimbursement, and for HSA payroll funding. For this reason, employers have specific responsibilities to ensure that ACH transactions are processed correctly on a daily basis, and that OCA is made whole when attempting to recoup these funds from the employer bank account.
To protect the well-being of our clients and of OCA, we have instituted new ACH policies, effective today, March 20, 2020.
OCA has always monitored account contributions and settlement activities closely and we have existing policies in place that determine what happens if/when contributions are missed or fail to process. However, based on the significant additional risk imposed by the current COVID-19 environment, we are implementing added controls.
Upon receiving an ACH failure notification, OCA will be conducting the following procedures:
- For all clients: If an ACH debit to an employer account fails for any of the reasons deemed 'high risk' (ie. insufficient funds, account closed, authorization revoked, payment stopped, etc.) then all benefit accounts associated with the employer will be immediately suspended - including temporarily deactivating debit cards and freezing claim activity until resolved.
- For HSA accounts: OCA will reverse the specific payroll posting of contributions to employee account, thereby reducing the employee accounts by the contribution amount and preventing further spending of these payroll funds. Upon correction of the funding issue that resulted in the ACH failure, the employer will need to reload the payroll file to initiate contributions posting and the HSA-funding ACH.
- If either of the above were to occur, OCA will be taking swift action to help re-mediate this issue and avoid any disruption to their employees benefit accounts.
OCA always strives to proactively work with clients and to understand their questions or needs related to funding and settlement ACH failures. We understand the negative impact of inactivating cards and reversing payroll contributions for consumers, and therefore aim to continue our proactive protection of your financial status.