Professionally Approved By: Peter Waller-Flynn Human Resources Manager 11 th April 2018

Transcription

1 POLICY FOR THE RESOLUTION OF OVERPAYMENT AND UNDERPAYMENT OF SALARY OR ANY OTHER PAYMENTS MADE VIA PAYROLL Type: Policy Register No: Status: Public Developed in response to: Counter Fraud requirements CQC Fundamental Standards: 17 Consulted With: Post/Committee/Group: Date: Staff Side 21 st March 2018 Human Resources Team 21 st March 2018 Managers of the JCNC 27 th March 2018 Belinda Butt Finance March 2018 Professionally Approved By: Peter Waller-Flynn Human Resources Manager 11 th April 2018 Version Number 2.0 Issuing Directorate Human Resources Ratified by: DRAG Chairman s Action Ratified on: 12 th April 2018 Trust Executive Board Date April 2018 Implementation Date 12 th April 2018 Next Review Date March 2021 Author/Contact for Information Sue Blunsten, Workforce Systems Manager Policy to be followed by (target staff) All MEHT Staff Distribution Method Intranet, Website & Communications Related Trust Policies (to be read in conjunction with) Standing Financial Instructions Counter Fraud & Corruption Policy Delegation of Losses and Special Payments Procedure Document Review History: Review No: Reviewed by: Review Date: 1.0 Sue Coleman 3 rd July Liz Stewart 3 rd December Christina Cowley 28 th April Workforce and HR Managers October Sue Blunsten 21 st January 2017/March Sue Blunsten 12 th April 2018

2 CONTENTS 1.0 Purpose 2.0 Aims 3.0 Scope 4.0 Responsibilities 5.0 Identification of Payment Errors 6.0 Manual Payments 7.0 Recovery of Overpayments 8.0 Failure to Disclose a Salary Overpayment or any other Payment for Employees 9.0 Overpayment of Salary or any other Payments from Employees 10.0 Overpayment of Salary or any other Payments for Employees who have left the Trust 11.0 Willful Misrepresentation by the Employee 12.0 Underpayment of Salary or any other Payments 13.0 Losses arising from Overpayment 14.0 Audit and Review Plan 15.0 Monitoring compliance with, and the effectiveness of, procedural documents 16.0 Equality and Human Rights Impact Statement 17.0 Communication 18.0 Counter Fraud 19.0 References and Associated Documentation 20.0 Appendices Appendix 1: Manual Payments Decision Pathway Appendix 2: Overpayment Recovery Guidance Appendix 3: Overpayment Recovery Agreement Form Appendix 4: Equality Impact Assessment Form

3 1.0 Purpose 1.1 The purpose of this document is to outline the procedure for the recovery of overpayments and rectification of underpayments made to staff. 1.2 To ensure that the public purse is protected. 1.3 To clearly outline the duties and responsibilities of different parties in identifying and managing pay issues. 2.0 Aims 2.1 The aim of this policy is to ensure that the action taken when dealing with such matters is in a consistent, fair and transparent manner throughout the Trust. 3.0 Scope 3.1 This Policy applies to all employees on a permanent, fixed term or bank contract with the Trust. 3.2 Due regard has been given to relevant practice and employment law issues, in particular, the Employment Rights Act (1996). 4.0 Responsibilities 4.1 Director of Finance The Director of Finance is required to authorise any losses arising to overpayments in accordance with the Trust s Standing Financial Instructions and Standing Orders. 4.2 Human Resources Department The Human Resources Department to ensure that the information is input into the Electronic Staff Record System (hereafter, to be written as ESR) in an accurate and timely manner The Human Resources Department to monitor both Trust and Serco ASP Payroll performance regarding accuracy and to escalate, as appropriate The Human Resources Department to escalate any overpayments or underpayments to the relevant parties, Serco ASP Payroll and the Departmental Manager/Budget Holder, as appropriate The Human Resources Department are to ensure that any discrepancies in staff payments via Payroll are dealt with in a fair and equitable manner and in accordance with current employment legislation and good practice.

4 4.2.5 The Human Resources Department to provide advice on processes The Human Resources Department to manage and approve manual payments In the event of a dispute or financial hardship, the Human Resources Department, specifically the Trust HR Managers, are responsible for negotiating and agreeing adjustments to an employee s proposed repayment plan. 4.3 Trust Payroll Provider: Serco ASP Payroll To ensure that information is input into ESR in an accurate and timely manner When an overpayment is identified, to take immediate action to prevent further loss and initiate recovery To escalate any overpayment or underpayment to the Human Resources Department, Finance and the Trust employee in a timely manner To monitor both Trust and Serco performance regarding accuracy and escalate, as appropriate to the Finance and Human Resource Department Leads. To enable this, Serco ASP Payroll monitor performance via the Key Performance Indicators (KPIs) and the Overpayment Register; both of which are distributed to the key contacts at the Trust on a monthly basis In adherence with the Agreement for the provision of Shared Services, Serco ASP Payroll will be responsible for the following: To perform the calculation of an over or under payment To write to the employee with an explanation of discrepancy. For example, providing an overpayment breakdown and schedule for recovery or repayment. A copy of which, must be sent to Finance and Human Resources To raise a debtor invoice or amend subsequent payment details for next pay run To implement the recovery of the payment from employee through payroll To produce a monthly summary of overpayments recovered and underpayments made; including the reason for them; analysed by reason for error 4.4 Where an overpayment has occurred and the overpayment equates to greater than 20% of the employee s salary; the Human Resources Department will be notified for due consideration before any debtor processes are undertaken. 4.5 On notification, an investigator from the Human Resources Department will investigate and establish the root cause of the resulting over or under payment and take any appropriate action.

5 4.6 Serco ASP Payroll will implement this Policy in the processing and management of overpayments/underpayments; this complies with their own internal payroll procedure on overpayments (Overpayments, Document Reference PP14). 4.7 Serco ASP Payroll is responsible for arranging for any underpayment of wages to be paid using the criteria set out in Section 12 of this Policy; including liaising with the Human Resources Department to establish an agreement regarding payment. 4.8 Serco Credit Control The Credit Control function is responsible for recording all salary overpayments in the Trust s ledger and monitoring collection of these amounts. 4.9 Managers All Managers with responsibility for budgets have a responsibility to review all salaries and wages charged to their cost centre and alert the Human Resources Department, Serco ASP Payroll and Finance of any anomalies and suspected over or under payments Any amendments to staff working time or conditions should be dealt with in a timely manner by the employee s Manager, by completing and submitting the relevant forms in line with Trust processes and Payroll deadlines. This also includes recording staff duties on HealthRoster or via Monthly Returns in accordance with these values. Until a change in working pattern has been fully approved and confirmed by the Manager, an employee must continue to work their current work pattern Local Counter Fraud Specialist The Trust s Local Counter Fraud Specialist will investigate all overpayments that may be considered fraudulent. All NHS Trusts are duty bound by the Public Accounts Committee to recover overpayments in full; where significant overpayments occur then the Local Counter Fraud Specialist will be asked to investigate the case as suspected fraud or theft The Theft Act (1978) indicates that although an individual may not set out to obtain the additional salary intentionally, by dishonestly keeping it and treating it as their own, for example, by spending it, then they will be guilty of theft. Counter Fraud Investigations will include contacting the individual Employees All employees have a responsibility to remain aware of their position and obligations under their contractual terms of employment. It is at all times the responsibility of the individual to ensure that they are aware of their contractual obligations and to advise the Trust of any changes that may affect

6 their pay, for example, change of hours, unpaid absences, end of contract, and so on All employees are expected to:- ensure they understand their salary entitlement check each payslip issued to them raise any anomalies with their Manager and either Serco ASP Payroll or the Human Resources Department For any changes that will impact on their pay and conditions and require processing through the payroll it is advisable for employees to check with their Manager that the appropriate paperwork has been completed, in a timely manner Regardless of the cause of an overpayment, whether it be system or human error, the employee has a duty to declare to their Line Manager and either Serco ASP Payroll or the Human Resources Department and repay the amount in full. Failure to do so is deemed as suspect Leavers Employees leaving the Trust are required to check their final payslip and to ensure that they do not continue to receive undue pay from the Trust If there are any pay issues or discrepancies arising from paragraph , then the employee is required to declare this to their Manager and either Serco ASP Payroll or the Human Resources Department. 5.0 Identification of Payment Errors There are a number of ways in which an employee can be incorrectly paid, including, but not restricted to: An overpayment of salary An underpayment of salary Payment of incorrect travel or non-travel expenses Duplication of a payment Deduction made in error 5.1 Overpayments An overpayment is where an employee, or an ex-employee, is paid an amount in excess of their contractual entitlement.

7 5.1.2 The likely causes of an overpayment include, but are not restricted to: A termination notification not being completed, received or processed on time Late or lack of notification of sickness absence Staff not returning from maternity leave An error being made A late change notification Incorrect salary banding See Section 7 of this Policy for clarification on the recovery of overpayments. 5.2 Underpayments An underpayment is where an employee, or an ex-employee, is underpaid what they are due under their contractual or statutory entitlement The likely causes of an underpayment include, but are not restricted to: A variation to contract notification being submitted or processed after payroll cut off A late change notification Incorrect salary banding Late submission of expense claims, excess hours, enhancements, overtime Expenses, additional hours, enhancements and overtime are exempt from consideration for a manual payment, as they are not contractual. Therefore an underpayment that falls under these criteria will be paid in the next available payroll run as standard. 5.3 Payment errors can be identified in several ways: A member of the Human Resources team identifies that an error has occurred A member of the Payroll team identifies that an error has occurred The employee, upon receipt of salary, identifies that an error has occurred The budget Manager identifies that an error has occurred 5.4 When an error in payment has been identified, action should be taken as quickly as possible to rectify the error and ESR updated accordingly. 5.5 Any manual payment requests should be made with reference to the qualifying criteria set out in Section 6 and Appendix 1 of this Policy. 6.0 Manual Payments 6.1 Manual payments are by definition a temporary payment for hardship cases until the next available payroll run takes place. Until a payroll run takes place, a manual payment will only release a standard 60% of the total gross amount due (to allow for standard PAYE, National Insurance and Pension to be taken formally), as per Serco ASP Payroll policy. This is to enable a payment to be

8 made outside a formal payroll run and within restricted timescales. It should be noted that the manual payment amount may be reduced further, if the employee is in a high tax bracket or is subject to increased national insurance or pension contributions. The gross payment will then be put through the next available payroll run and adjusted accordingly for deductions. Any further arrears that may be due would therefore paid in the next available payroll run In accordance with Serco procedures, manual payments are only made on a Monday, Wednesday and Friday. However, if one of those days falls on a Bank Holiday, then provisions will be made to compensate Manual payments can be requested by an employee s Line Manager to the Human Resources Department for consideration. Manager s should give careful consideration before making this request; ensuring that the employee meets the criteria set out in Section 5.2 and Appendix 1 and qualifies as a hardship case. Payment requests will be assessed on an individual case basis and Manager s should be aware that payment may be deferred to the next available payroll run, if the request is categorised as non-urgent. Please review the Manual Payment Decision Pathway (Appendix 1) for an overview of the decision process If an employee is in receipt of nil pay or missing a significant amount of their contracted pay; then the employee will receive a same day manual payment at the earliest possible opportunity once the Human Resources Team are notified of the underpayment Manual payments due to underpayments caused by Trust error are limited to a maximum number for Trust error - capped at 1% of the total head count at Mid Essex Hospitals - to exceed the number available will incur an additional service variation charge to the respective departmental budget. This service variation charge is set on Serco Payroll s evaluation of the work involved. The maximum payment cap is approximately 60 payments per month at the current head count, as of June To raise a manual payment caused by Manager or Employee delay or error, there is a standard charge (either 25 or 35; depending on payment type), which is payable by the budget holder for that department. This applies to all payments; regardless of whether they breach section Manual payments cannot be made for amounts under 50 (Net) under any circumstances Advances or loans on contracted pay are not available to employees; unless through a Trust registered scheme, such as the Travel Ticket Loan Scheme.

9 7.0 Recovery of Overpayments 7.1 For the purpose of recovery, overpayments have been categorised into three areas: Salary/Wages Adjustment: An adjustment to pay that recovers monies overpaid in the previous month will be recovered in the current month (please refer to Section 9.1 of this Policy). These will be recovered automatically from salary and will not be treated as an overpayment Overpayment: An adjustment to pay that requires monies to be recovered from an individual and relates to periods prior to the current and previous month. Employees will be advised in writing of the details of the overpayment by Serco ASP Payroll and will be given a 14 day period from the date the letter is sent to respond; otherwise the full amount will be recovered from the employee s next salary payment; with notification from Serco ASP Payroll to the Human Resources Department. Debt: An unrecovered overpayment to an ex-employee. An invoice will be raised and sent to the ex-employee together with appropriate information identifying the basis of the overpayment. 8.0 Non-Disclosure a Salary Overpayment or any other Payment for Employees 8.1 All employees have a responsibility for checking each payslip they receive and to advise their Manager, Serco ASP Payroll or the Human Resources Department if they have been overpaid by any amount. See Section 18 regarding Counter Fraud. 8.2 All employees are advised that they are bound by explicit contractual terms that in the event of any overpayment of salary, expenses or other sums referable to employment with the Trust, any such overpayment will be deducted from staff s salary (refer to Paragraph 7.0). 8.3 In addition, all Managers with budgetary responsibilities have a duty to review all salaries and wages charged to their cost centre and query any unusual items or unexplained variances with the Human Resources Department, Serco ASP Payroll and Finance. 9.0 Overpayment of Salary or any other Payments from Employees 9.1 If the overpayment is classed as a Salary/Wages Adjustment (see Section 7.1), then the recovery will be taken in the next month s pay and it will not be treated as an overpayment. 9.2 After an overpayment of salary or any other payment has occurred, the employee will be provided with written notice of the background to the overpayment, the amount, how immediate payment can be made and the planned reversal. The employee s address used will be the last known home

10 address held on ESR; it is the employee s responsibility to ensure that this is correct using ESR Employee Self Service. 9.3 Recovery of an overpayment through the payroll will not exceed 20% of an employee s basic pay; unless permission is granted from the employee or the employee is leaving the Trust (see Section 9.9). 9.4 If the employee considers that the repayment plan in their overpayment letter is not viable, either due to exceptional circumstances or that they dispute the claim, then the employee will have the responsibility of contacting the Human Resources Department, specifically their Trust HR Manager, with the request before the payroll deadline for that particular month. If this occurs and is deemed to be a reasonable request, the deductions will be suspended until an investigation has been completed or an alternative repayment plan is agreed. The repayment plan must be a reasonable suggestion from the employee and should not stray too far from the period of time in which the overpayment occurred. 9.5 To request an alternative payment plan due to financial hardship, the employee should contact their Trust HR Manager in writing. This will involve submission of statements to evidence their financial hardship (See Overpayment Recovery Guide (Appendix 2) for details of the procedure). 9.6 The Trust may consider changes to an agreed repayment plan, if an individual s circumstances change substantially by incidents outside their control, for example, maternity leave or long term sickness. These requests are considered on an individual basis (refer to the Overpayment Recovery Guide (Appendix 2)). 9.7 After initial review of the application by the Trust HR Manager, a proposal will be presented to the Head of Human Resources; the Divisional Associate Director of Operations & Director of Finance/Deputy Director of Finance for a final decision to be made as to whether-or-not the repayment amendment request is approved. Their decision is final. 9.8 If an employee unreasonably refuses to make repayments in relation to a salary overpayment, then by law the Trust is permitted to make deductions through the Payroll without the individual s permission. This is in line with the Employee Relations Act (1996) and Employment Right Act (1996). 9.9 If an outstanding overpayment exists at the point of termination of contract, the final balance will be deducted from the employee s final salary payment. If there is a shortfall, in these circumstances Section 10 will be enacted. Should the final salary payment (or the amount of any arrears subsequently due) have not been sufficient to cover any balance outstanding immediate payment is to be demanded prior to departure.

11 10.0 Overpayment of Salary or any other Payments for Employees who have left the Trust 10.1 The Deputy Director of Finance and Human Resources Department will be advised as soon as the overpayment is identified and the amount will be recorded in the Trust s debtor s ledger For ex-employees where an overpayment has been found, they will be provided with written notice of the background to the overpayment, the amount, and immediate payment demanded. The address will be the last known home address held on ESR. Payment will be requested within 14 days To request an alternative payment plan due to financial hardship, the exemployee should contact Serco Credit Control. This will involve the submission of statements to evidence their financial hardship; depending on the circumstances of the request. Please review the Overpayment Recovery Guide (refer to Appendix 2) for an overview of the application and review process If no response is received from the ex-employee within the stipulated 14 days, Serco ASP Payroll will inform the Human Resources Department and the nominated Trust representative for debtor collections. The Trust s normal Debt Recovery Procedure will then be followed for the amount outstanding Ex-employees who unreasonably refuse to repay overpayments may be subject to action, as set out in Section Willful Misrepresentation by the Employee 11.1 If an overpayment of salary is caused because the employee has willfully misrepresented facts or relevant data, all possible steps must be taken to effect immediate recovery. Please see Section 18.0 for clarification regarding action in this event Underpayment of Salary or any other Payments 12.1 Once identified, an underpayment will be rectified on the ESR System in a timely manner. For the purposes of reimbursement, the underpayment will then fall into either of the following categories: Payroll adjustment: where the employee has received 100% of their basic pay, any arrears over this will be received in the next available payroll run If the employee has suffered a significant reduction to their basic pay, then a manual payment may be made (see Section 6 listing the criteria for manual payments)

12 12.2 Serco ASP Payroll will supply confirmation to the Human Resources Department and Finance that interim payments have been reclaimed from the next month s salary Losses arising from Overpayment These will be dealt with in accordance with the Trust s Delegation of Losses and Special Payments Policy Audit and Review Plan 14.1 Records of overpayments will be produced by Serco ASP Payroll and maintained by the Finance department Copies of all letters and correspondence that Serco ASP Payroll send to staff (both current and ex-employees) will be forwarded to the Human Resources Team who will monitor that actions taken are consistent as per this policy Monthly Reviews of Payroll Discrepancies will be held by the Director of Human Resources and the Deputy Director of Finance Monitoring Compliance with, and the Effectiveness of, Procedural Documents Monthly analysis of payroll overpayments to include any necessary actions and investigations undertaken Internal/External Audit review 16.0 Equality and Human Rights Impact Statement 16.1 The Trust is committed to the provision of a service that is fair, accessible and meets the needs of all, respecting the needs and privacy of individuals while also protecting the interests and privacy of others. An Equality Impact Assessment relating to this Policy is attached in Appendix 2, which shows that this Policy impacts on all protected groups equally and without barriers occurring Communication 17.1 Staff will be made aware of this Policy through reference at Corporate Induction and via Staff Communications. This Policy will be stored on the MEHT Intranet for all staff to access under HR Policies Counter Fraud 18.1 Employees alleged to be involved in fraudulent activity may render themselves liable to disciplinary action, including termination of employment Employees must be aware that failure to provide a true declaration when asked by the Trust, or the making of a false declaration, could result in an

13 investigation by the Local Counter Fraud Specialist, which could lead to disciplinary and/or criminal/civil action References and Associated Documentation Theft Act (1968) The Employments Right Act (1996) The Employment Relations Act (1996) Standing Financial Instructions Policy (2016) Counter Fraud & Corruption Policy (2013) Scheme of Responsibility, Authority & Decision Policy (2014) Department of Health: Losses and Special Payment Guidance (2016) Serco ASP Payroll: Overpayment Procedure (2014)

14 Appendix 1: Manual Payment Decision Pathway

15 Appendix 2: Overpayment Recovery Guidance Overview Once an overpayment is identified; the employee will be contacted directly, in writing, by Serco Payroll to advise them of the overpayment and Trust Policy. The Human Resources Department will receive a copy of the overpayment letter from Serco Payroll for reference. Repayment plans will be drawn up in accordance with the following guidelines: If the overpayment is one lump sum payment, then recovery will be expected in a single amount It is preferable for payments be made within the same financial year; as overpayments may otherwise have to be revised for PAYE purposes and new invoice reissued Monthly installments should be made over the same time period that the overpayment occurred Consideration will be taken to prevent employee s hourly rate from falling below the minimum hourly wage Payments will be revised with incremental increases, hours increases or promotions Should repayment not be agreed; a repayment plan will be required using this appendix for reference (and by confirming the final agreement via completion of the Recovery of Overpayment Agreement (Appendix 3). On approval, the form should be submitted to the Workforce Systems Team to implement. Employees: Repayment Guidelines 1. Overpayment confirmed in writing to the employee from Serco Payroll. 2. The overpayment recovery plan stated in the overpayment letter will be implemented in the next available payroll run; unless Points 3 and 4 are enacted. 3. Employee has a 14 day right to reply to the letter, if they consider that, due to exceptional circumstances, they are unable to repay the stipulated amount at that point in time, for instance, financial hardship or dispute the overpayment. 4. Then the employee has the responsibility to contact their HR Manager, in writing with the request, within 14 working days of receipt of the letter from Serco Payroll. Supporting documentation should be included with the letter, for example, bank statements, bills, invoices for existing debts, etc. If the employee fails to provide the supporting evidence, then the Trust reserves the right to reinstate automatic recovery of the overpayment.

16 5. The Trust will consider any requests on individual merit based on this Policy, which will be fair to both parties. 6. On receipt of the letter from the employee, the HR Manager will instigate the temporary suspension of the recovery with Serco Payroll until the request has been investigated. 7. The investigation process may invoke a meeting between the HR Manager and employee to discuss. At the meetings, the employee has the right to be accompanied by a Trade Union Representative or colleague, should they wish to have support. 8. The HR Manager will review the following points on receipt of an application: The cause of the overpayment The time period that the overpayment occurred over The amount involved Whether or not the employee could have been aware of the overpayment Has the employee queried with any HR/Payroll/Manager at any point Other issues, which may be raised by either party (as applicable) 9. The HR Manager will, taking account of the above, issue the proposed revisions (using Appendix 3) to the Head of Human Resources, the Divisional Associate Director of Operations & Director of Finance/Deputy Director of Finance for a final decision to be made. 10. Once a decision has been made, as per Point 9, either enable a mutual repayment plan will be produced or the original repayment plan will be reinstated; depending on the outcome. 11. After review, you will be formally notified by the HR Manager of the decision made. 12. If the employee is on maternity leave or reduced sick pay, they may request, in writing to their respective HR Manager, to review and propose a Recovery of Overpayment Agreement their existing agreement, if applicable. In these cases, Points 4 10 should be followed.

17 Ex-Employees: Repayment Guidelines 13. Overpayment confirmed in writing to the ex-employee from Serco Payroll. 14. The letter will be sent to the ex-employee s home address on record. If the address turns out to be out-of-date and the letter is returned to sender, then Serco Credit Control will employ tracing methods to track down the individual. 15. The overpayment recovery plan will be outlined in the letter. 16. The ex-employee should contact Credit Control directly (using the reference number provided in their letter) to set up a payment method. The methods of payment accepted are either by debit card, credit card, bank transfer, standing order or cheque. 17. The ex-employee has a 14 day right to reply to the letter, if they consider that, due to exceptional circumstances, they are unable to repay the stipulated amount at that point in time, for instance, financial hardship or dispute the overpayment. 18. If Point 17 is applicable, then the ex-employee has the responsibility to contact Serco Credit Control, in writing, with any requests for amendments to the repayment schedule or disputes. 19. Serco Credit Control will then forward the request to the respective HR Manager for investigation and Points 4-10 will be followed. 20. Unless contact is made, after the time frame stipulated in Point 17, Serco Credit Control will enact follow up procedures with the ex-employee. 21. If no response is received following Point 20, then the Trust and Credit Control will consider taking formal legal action against the ex-employee, with Trust approval.

18 Appendix 3: Recovery of Overpayment Agreement Employee Name: Payroll Number: Job Title: Department: Total Amount of Overpayment: Total Amount of Overpayment: Reason for Overpayment: Gross Net I agree to the recovery of the above overpayment on the basis of gross/net* being deducted from my wage/salary* each week/month*. This arrangement commences on and continues for a period of weeks/months* until the overpayment is repaid. If I leave the Trust prior to the balance being paid; I understand that the outstanding balance will be taken out of my final salary, as stipulated in Section 9.8 of this Policy. If there is any amount remaining after this, I understand that I will be invoiced and further action will be taken if payments are not established at that point. Employee Signature: Name (Printed): Date: * Delete, as appropriate In order for the agreement in Appendix 3 to be valid, the following approvals must be obtained: Head or Human Resources, the Divisional Associate Director of Operations & Director of Finance/Deputy Director of Finance.

19 1. Head of Human Resources Signature: Name (Printed): Date: 2. Associate Director of Operations Signature: Name (Printed): Date: 3. Director of Finance or Deputy Director of Finance * * The Director of Finance must sign off for all repayment plans for overpayments of 5,000 or over. Signature: Name (Printed): Date: SUBMITTAL: On completion by all parties, Appendix 2 should be submitted to the Workforce Systems Team for implementation.

20 Appendix 4: Equality Impact Assessment Form Equality Impact Assessment (EIA) Title of document being impact-assessed: Policy for the Resolution of Overpayment and Underpayment of Salary or any other payments made via Payroll. Equality or human rights concern (see guidance notes below) Gender Does this item have any differential impact on the equality groups listed? Brief description of impact. Impact of the Policy is neutral How is this impact being addressed? Race and ethnicity Impact of the Policy is neutral Disability Impact of the Policy is neutral Religion, faith and belief Impact of the Policy is neutral Sexual orientation Age Impact of the Policy is neutral Impact of the Policy is neutral Transgender People Social class Impact of the Policy is neutral Impact of the Policy is neutral Carers Impact of the Policy is neutral Date of assessment: March 2018 Names of Assessor(s): Sue Blunsten