- This sounds easy, what could go wrong?
- What security is there around who invoices me and what I get charged for?
- How do the debit cards work?
- What is direct debit?
- How are accounts funded?
- Are there any contracts or costs?
- Do I get paid interest?
- What if I do not have cash to pay into my account on time or not at all?
Using the account
- I don't have a computer, how do I see my monthly statements?
- Can I pay all expenses through Capital Guardians?
- How do I challenge a cost on a suppliers invoice?
- How do I control the spending in Capital Guardians?
- When will my monthly accounts be ready to look at?
- How is GST treated?
- Is there a complaint procedure if I am unhappy with the service?
- Can we leave Capital Guardians if we are unhappy with it?
- What happens when an account is no longer required?
- What happens to the money when the service is cancelled?
It is easy, not much can go wrong with either a licensed care organisation exercising strong disciplines around their management of care at home as required under the NDIS or Aged Care Act, and Capital Guardians managing trust money securely, with Westpac as required under the Corporations Act, or your management of monies into the account and approval of monies to suppliers our of the account.
Discipline is by all required parties in process and procedure (what we know as the Quality Management System). One area that is always watched carefully is the timeliness of suppliers invoicing accounts.
If suppliers (ie care providers, cleaners, nurses, etc) do not invoice promptly, then accounts can appear overstated, with account balances higher than they should be. This would be most obvious when reviewing the budget variance report, where it might be noticed that planned expenditures are missing, where there is the knowledge that those services were performed.
Capital Guardians recognises an invoice against the account as soon as it has been submitted online by a supplier, and submitting invoices is "easy", Capital Guardians can talk to any accounting system and even have invoices entered in under a minute, with one thumb on a smartphone by smaller suppliers with agreed fixed prices.
There is significant protection around invoices on to accounts, as follows:
Supplier Trust. Whereby care recipients (consumers) do have a say in their suppliers, the home care provider has a legal obligation to ensure the suppliers: comply with the expected standards; offer value for money; are of good character (including recent police checks for anybody visiting a home); and have the capability to provide the full service deemed necessary by the Home Care Provider. Subsequently, the Home Care Provider will have the first and final say in suppliers.
As such, any suppliers whose integrity may be questioned, will just not last (that is if they get an opportunity to service an account in the first place). There is a lot at stake for someone doing the wrong thing.
"Transparency". Capital Guardians is about transparency, as soon as an invoice has been submitted, then it is visible to all parties, including the care recipient and their representatives. The Capital Guardians system allows any variance to the budget to be investigated, online immediately by "drilling down" into the expense, right down to the detailed "pdf" (an electronic version of the invoice, that can be printed), online.
Proof of service or good delivery. As a requirement, all suppliers must be able to keep a record that proves that the good or service was delivered. As contracted and agreed with the supplier, if there is ever a dispute over an invoice, then they need to provide this evidence or risk the payment not being made or reversed. As a requirement of the Capital Guardians supplier payment agreement, the Capital Guardians audits also randomly sample suppliers compliance with keeping such evidence.
Finally, Home Care Provider "review" and authorisation of invoices. As part of the monthly process, home care providers approved all submitted invoices for payment. Their approval will only come after they review the budgeted amounts, their care plan and general knowledge of the services provided.
There is more information available on Security at www.capitalguardians.com
Debit cards are used for those times when small spendings are required with vendors who are not generally recurring or retail. The cards are generally accepted anywhere Mastercard or Visa are accepted. The cards have a maximum balance of $1,000 and limits on use to $500 per month. The cards do require a balance deposited on them (like a float). After the card is used the transaction is recorded in Capital Guardians, and when approved, the money is put back on the card, weekly, taking the balance back to the float value. The cards are ideal for:
- Lifestyle and diversionary therapy staff in residential settings, spending on residents
- As an additional cash source to Capital Guardians account holders, that are still overseen and managed (can be used at ATM’s)
- To add additional flexibility for Homecare and NDIS recipients in purchasing products and services off not recurring suppliers.
Cards can be cancelled if lost, and in most cases, monies retained
A direct debit is an authority a customer signs with an organisation, approved under banking rules, to take money directly from a nominated account under a set of specified conditions.
Accounts are funded through either government programs, public trustee or personal contributions. Typically personal contributions are by way of a direct debit.
A direct debit is an authority a customer signs with an organisation, approved under banking rules, to take money directly from a nominated account under a set of specified conditions.
Direct debits are taken, at a chosen amount, either fortnightly, monthly or when the account balance goes below a specified minimum 'trigger' amount. For example, if $100 is the selected minimum balance when the balance becomes less than $100, a direct debit is recorded.
For all residential accounts, a minimum balance is required, to ensure that suppliers can invoice successfully if the value being billed is not in the account, suppliers cannot invoice.
As a rule, Capital Guardians will ensure that the Direct Debit amount is double the minimum balance selected by the customer.
The right minimum balance and direct debit amount depend on the number and type of suppliers that are selected. Further, where avoidable, Capital Guardians does not want to direct debit an account more than once per month, so the value of a month's expenses would be approximately correct as a minimum 'trigger' amount.
Notwithstanding an initial estimate, the right minimum and direct debit amount will become apparent after a few months of transactions and changes can be made at this time.
There are no contracts. If our service is no longer required, please let Capital Guardians know, in writing (i.e email) and include the bank account details for the return of monies. We return all monies within 48 business hours.
There is an account fee of $3 fee for private customers, this pays for itself
- the comfort of having access to funds with a transparent strong audit process:
- savings from suppliers not having to print and mail separate invoices are ultimately passed on (many businesses are charging for paper invoices);
- the fee is lower than the average credit card fee, and there are no credit card surcharges (that are increasingly being charged by businesses); and
- the benefits over cash are significant, in that the money, in the account, will not disappear and money spent can be traced back to signed authorities.
- Consolidating suppliers into this system allows an aged care operator to obtain "discounts" from suppliers that will pass on savings well exceeding the cost of $36 per year.
- for clients who spend very little, and need an account due to their carers policy, they can select a fee-free account, whereby a surcharge of 4% will be added only on transactions when the account is used.
Capital Guardians sole purpose is to keep administration costs down and make things simple, subsequently:
- Software development was briefed to build a system that was capable of millions of transactions per year and at least 500,000 customers. The application has been built in php (common programming code), with an infinitely scalable SQL server database and sits on the world's largest hosting provider, Amazon, in their Australian hosting facility.
- The business model is designed to keep the price down (ie $3 per month for private customers) to the very minimum and subsequently operates largely automatically with little manual intervention. Capital guardians have fully automated where possible for adding new users; paying suppliers and record deposits.
- The work-intensive part of capital guardians is mobilising the service into new communities. This comprises solely of training, answering queries and change management. There are no project or consulting costs, typical of information technology projects.
Capital Guardians, through its AFS License (with ASIC), will pay interest on values above $3,000 for individual's personal monies (monies not part of a government program). All monies above this amount will be held in an interest-bearing account with Westpac on behalf of the individual.
The money is immediately available on request and is invested at the prevailing short term interest rates offered by Westpac, less a 1% management charge.
The interest is accumulated on behalf of the individual, and a tax file number will be required to ensure tax is not paid.
If the individual does not want the interest, then they can nominate for it to be donated to the facility or other charities nominated, thereby eliminating the requirement for a tax file number.
For personal accounts, if a customer cannot pay as required or is having repeating direct debit rejections, they will most likely not be able to be represented by Capital Guardians and the account will be cancelled.
The suppliers Capital Guardians represent and pay are generally small businesses who rely on payments for services for their income and livelihood. Capital Guardians is a payment service that ensures these suppliers get paid, low monies or slow top-ups, or funds not present with direct debits cannot work, as suppliers would not get paid.
Professional powers of attorney are available in all States of Australia, by nomination or by court order, where related powers of attorney are not able to manage spending monies on behalf of residents out of their assets or pension. It is advised, at the first point, a discussion is had with the facility manager as to the steps and actions required here.
Using the Account
You can receive statements and balances, as follows:
- any smartphone or tablet
- library (ask us what your login is, every account has a login if you have an email address this will be your username)
- from your care manager/facility, they can print one
- request a monthly statement mailed to your address at $7
Suppliers (also known as vendors or "supports") need to become part of the Capital Guardians network. If a supplier chooses not to use Capital Guardians for invoicing, they will need to deal with the customer directly regarding payments for goods and services.
Suppliers generally choose not to deal with Capital Guardians for two main reasons:
- they want to be paid cash; or
- their processes and accounting systems are designed for postal account mailing and payments, and the independent billing of some customers through Capital Guardians is not efficient.
Generally, suppliers who want to be paid cash are discouraged by care organisations due to the risks and control limitations with cash. Capital Guardians provide such suppliers a transition opportunity away from cash without investing in accounting systems and complex processes. Capital Guardians will let you know if there are suppliers who choose to deal directly with you.
Capital Guardians does not check the validity of services or products on suppliers’ invoices, this is the responsibility of the account holder or representative.
The account holder and/or representative are the only ones who know what services have been requested to suppliers and their frequency. Capital Guardians is not privy to this information, thus cannot validate invoices on behalf or residents and/or representatives.
If an account holder has a query in relation to a suppliers charge, then they should liaise directly with the supplier in relation to the charge. If it is agreed that a credit is required, then the supplier will credit the account on the next invoice or statement.
Contractually, all suppliers must keep a “proof of delivery of good or service” record and present it on request. If there is disagreement regarding a charge and the proof of delivery cannot be presented, then Capital Guardians will reverse the charge. This process is very similar to how credit card company "chargebacks" work.
Capital Guardians has a significant number of controls for customers to control expenditure, including:
- Selecting the suppliers who have access to invoice the resident (including taking suppliers off).
- Total limits per supplier. A customer can limit the total billings any supplier can make in a work by selecting the total supplier limit. Note, facilities are also suppliers and limits can be made here on the amount of cash given out at facilities.
- Daily limits per supplier. This restricts the total billing value (on a day).
- Using the budget and booking tool available organisations or self-managed account holders and/or their representatives. The booking tool allows users to allocate a budget to a number of suppliers and ensuring requests for goods and services are kept within budget, and the supplier has written confirmation of what can be invoiced.
Please note, the system controls above are really a backup. The most appropriate control comprises individual discussions with suppliers and/or carers (ie care organisation) on appropriate spending, affordability, and limits. It is very important for suppliers to understand restrictions independently of the Capital Guardians system not allowing an invoice to be created. Just because an invoice cannot be created, does not mean a debt is not owing.
These controls appear in your login, alternatively, you can contact Capital Guardians for advice.
Accounts are in 'real time', as soon as a supplier invoices, the accounts are ready to look at.
The monthly accounts will be complete and ready to look at when all the suppliers have their invoices in. As a starting point, by policy, suppliers need to have their invoices in within 7 calendar days of a calendar month end for services performed in that prior calendar month.
Where this timeline isn't met, it will become a performance development item for the supplier overseen by the home care provider as it is part of their service delivery contract, and timely invoicing allows for quick identification of issues and helps everyone, even the supplier to be on top of their game.
All suppliers, big and small are provided with very simple efficient tools within capital guardians to get invoices in, with or without accounting system support.
For privately funded accounts, such as residential or village accounts, GST is treated similarly to any normal private expenditure, that is, applicable GST is included in the transaction value.
For government-funded NDIS payments under the National Disability Insurance Scheme Act and government-funded home care within the Home Care Packages Program under the Aged Care Act, expenditures are GST free to individuals and approved providers respectively.
- The supply of home care services by the service provider will be GST-free under section 38-30(3) of the A New Tax System (Goods and Services Tax) Act 1999 (GST Act).
- A supply of home care is GST‑free if home care subsidy is payable under Part 3‑2 of the Aged Care Act 1997 to the supplier for the care.
- Eligible services Item 2.1 of Part 2 of Schedule 1, Quality of Care Principles 2014. Part 3.2: Quality of Care Principles 2014, Schedule 3 "Care and services for home care services".
Approved providers of home care clients (Government funded)
- All the invoices of an Approved Provider are GST free except exit fees. Approved providers are required to remit GST on all exit fee income to the ATO.
- Invoices from third-party organisations to clients of Approved Providers (Sub-contracted services) GST is payable unless the services are GST free, see Non-government funded home care services below.
- Approved Providers will claim GST expenditure, as recorded in Capital Guardians on their BAS statement, and refund an established GST Account in Capital Guardians, thereby avoiding any GST on client home care statements.
Non-government funded home care services
If a provider does not receive funding directly from the government for home care services or the government funding cannot be used for services to certain people, the supply of any of the following home care services to an aged or disabled person is GST-free:
- personal assistance, including individual attention, individual supervision, and physical assistance with
- bathing, showering, personal hygiene, and grooming
- maintaining continence or managing incontinence, and using aids and appliances designed to assist continence management
- eating and eating aids, and using eating utensils and eating aids (including actual feeding if necessary)
- dressing, undressing and using dressing aids
- moving, walking, wheelchair use, and using devices and appliances designed to aid mobility, including the fitting of artificial limbs and other personal mobility aids
- communication, including to address difficulties arising from impaired hearing, sight or speech, or lack of common language (including fitting sensory communication aids), and checking hearing aid batteries and cleaning spectacles.
Examples of Non-government funded home care services that are not GST-free:
- housework and gardening
- preparing meals and grocery shopping for individuals
- aids, appliances and monitoring medication; however, they may be GST-free health supplies under a different section of the GST Act
- rehabilitation and health care services; however, they may be GST-free health supplies under a different section of the GST Act
- help with writing cheques, emails, and letters
- advocacy services
- driving individuals to and from appointments and social activities
- social and community activities, such as providing companionship, craft and reading activities to individuals.
Please note, where an individual voluntarily contributes money to their care for services by a home care provider, many services, outside care will need GST to be paid, such as:
- Monitoring and applying medication
- Provision of social and community activities, such as companionship or security for clients feeling lonely or vulnerable, or initiating and taking part in craft or reading etc;
- Provision of rehabilitation services
- Home help such as domestic chores, gardening or home maintenance, including making beds and general tidying of living quarters;
- Meal preparation
- Provision of travel services and transport assistance; and
- Grocery shopping.
Yes, ideally send us an email or call in the first instance, you may be asked to clarify your issues, provide more information and discuss your expectations. Please provide as much information as you can when you lodge your complaint. This helps us to understand all the issues and determine the most appropriate way to resolve your concern.
Our Complaints Policy is attached, for insight on how we deal with complaints internally.
Yes, just let us know by phone, email or letter. There is no cost and funds will be remitted after giving suppliers five five business days notice regarding outstanding invoices.
When a client departs a facility, home care package or village, Capital Guardians needs to be notified by phone, email, fax or otherwise. As soon as we become aware of a departure, we will:
- send an acknowledgment to the power of attorney with the existing balance and a notification that the funds will be returned by eft after 5 business days, less any invoice deductions dated prior to their departure;
- the monies are returned automatically to the client or approved provider (home care) using the bank account details we have on file (direct debit) or alternative bank account where we do not have account details on file;
- send a notice to all suppliers, giving them five business days to ensure all pre-departure invoices are entered; and
- monies are returned by electronic transfer to the account representative.
From here on, the account is closed, without any fees or charges.
Please note, that we are regulated under ASIC as a provider of financial services and all monies must be returned, regardless of value, and if we cannot return monies after making reasonable efforts, monies are required to be sent to the relevant state revenue office (unclaimed deposits) within 12 months.
What happens to the money when the service is cancelled?
This depends on the purpose and use of the money.
- Privately managed funds will be returned back to the account holder.
- For account holders on a Home Care Package, under the Aged Care Act, any unspent funds are transferred or will be split between the government and the account holder in proportion to how they were contributed.
- Homecare funds are transferred with a move to permanent residential care, death or to move to a new provider on a mutually agreed date.
- The unspent home care monies, being the total amount of home care subsidy (including any supplements) and home care fees paid (for the period of care) to an approved provider for a client, that have not been spent or committed for the client’s care will need to be:
- transferred to the client’s new home care provider; or if the client has left home care (for example if they entered permanent residential aged care or passed away), returned to the Commonwealth and the client (or their estate).
Once a care recipient and provider have mutually agreed on a date to change providers, care services continue until the date, they will become the responsibility of the new provider.
- For NDIS funding recipients, funding is upon receipt of invoice, so there will not be funds available for return.
- Easy access to products and services
- Eliminates administration
- Access to the audit trail of expenditure authorisations
- Environmental – no paper…
- Transparency of all expenses
- Ability to set expenditure limits by the supplier
- Automatic "top" of up trust balances when they are low
- No requirements for trust account management time or software
- Environmental focus with electronic solutions
- No requirements to hold trust cash monies within aged care facilities
- No significant cash holding for residents
- Ease of use by residents, power of attorneys, etc