OPS-SOP-018 — Trust Funding Flow & Escrow Management
1. Purpose & Scope
This SOP defines the monthly funding cycle for the Unity Care Member Plan Master Trust — from employer premium collection through Allied escrow funding and claims payment. It covers the Nuwell Medical Network LLC employer group and all future participating employer groups under the trust.
Entities covered: Unity Care Solutions, LLC (Program Manager) | Unity Care Member Plan Master Trust | Allied Benefit Systems (TPA / Escrow Holder) | Participating Employers
Critical: Allied holds the escrow account — not the trust. Trust bank account holds monthly contributions before transfer to Allied. Never commingle employer contributions.
2. Roles & Responsibilities
| Role | Responsibility in This SOP |
|---|
| Operations Director | Collects employer premium submissions; prepares per-employer funding detail; initiates trust transfer; monitors escrow balance |
| Primary Approver | Signs off on monthly transfer to Allied; escalation point for shortfalls exceeding 5 business days |
| Finance | Reconciles trust bank ledger; posts GL entries per employer; flags discrepancies |
| Trustee (Steve Schindler) | Holds and administers trust and sub-trust assets; signs authorized disbursements per trust agreement |
| Program Manager (Unity Care Solutions, LLC) | Coordinates funding submissions across employer groups; interfaces with Allied on escrow balance |
| Allied Benefit Systems | Holds claims escrow; executes Thursday ACH claims pull; notifies of shortfall within [TBD] hours |
3. Funding Flow Overview
The monthly cycle follows this path:
Participating Employer(s) — submit monthly contribution by [TBD] day of month
↓
Unity Care Member Plan Master Trust Bank Account — Operations collects and holds contributions per employer
↓ (transfer by first week of month with per-employer detail)
Operations Director submits to trust with per-employer breakdown → Primary Approver signs off
↓
Allied Benefit Systems — Escrow Account — funded by trust transfer
↓ (every Thursday)
Allied executes Thursday ACH claims pull from escrow to pay provider claims
↓
ProAct (PBM) — invoices trust directly 2x/month (separate from Allied escrow)
4. Monthly Funding Cycle — Step by Step
Step 1
Employer Premium Collection
Owner: Operations Director
- Each participating employer submits monthly contribution by [TBD — confirm with each employer at onboarding]
- Contributions are logged per employer in the master payment tracker with: employer name, plan(s), headcount, contribution amount, date received
- Sub-trust accounts track assets separately per employer plan — do not commingle
- If a contribution is not received by day [TBD]: Operations contacts employer HR same day and escalates to Primary Approver if unresolved within 2 business days
Step 2
Prepare Per-Employer Funding Detail
Owner: Operations Director + Finance
- Compile per-employer detail sheet showing: employer name, contribution received, plan tier breakdown, lives (employees vs. dependents)
- Cross-reference against prior month's Allied enrollment summary — flag any headcount discrepancies before transfer
- Finance confirms sub-trust ledger balance matches contributions collected
Step 3
Submit to Trust — Primary Approver Sign-Off
Owner: Operations Director → Primary Approver
- Operations submits per-employer funding detail to trust by first week of month (target: day 5)
- Primary Approver (Dr. Greg) reviews and approves transfer
- If Primary Approver unavailable: Backup Approver (Nora Naman) may authorize payment transfers only — not SOP changes
- Signed approval documented in payment tracker
Note: Trust bank account is separate from operating accounts. Transfer must include per-employer detail — Allied requires this for sub-trust allocation.
Step 4
Fund Allied Escrow Account
Owner: Trustee (Steve Schindler) + Operations Director
- Trust transfers approved amount to Allied escrow account
- Allied receives and confirms receipt within [TBD — confirm with Allied] business days
- Finance posts GL entries: debit per-employer sub-trust account; credit Allied escrow
- Retain Allied confirmation as evidence for monthly payment packet
Step 5
Weekly Thursday Claims Pull
Owner: Allied Benefit Systems (monitor: Operations Director)
- Allied executes ACH claims pull from escrow every Thursday
- Operations receives claims register from Allied by [TBD — confirm time with Kim James]
- Operations reviews for anomalies per OPS-SOP-001 (Weekly Medical Claims Funding)
- If escrow balance is insufficient for the Thursday pull: see Section 5 (Shortfall Protocol)
Step 6
ProAct (PBM) Invoice — Separate Cycle
Owner: Operations Director + Finance
- ProAct invoices the trust directly — not through Allied escrow
- ProAct invoices 2x per month (dates TBD — confirm with Dolores Hynes on March 26 call)
- Process per OPS-SOP-002 (PBM Invoice Processing)
- Payment authorized by Operations Director; Primary Approver required if invoice exceeds [TBD — Finance to set threshold]
Step 7
Monthly Reconciliation & GL Close
Owner: Finance
- Reconcile trust bank account vs. Allied escrow balance vs. per-employer sub-trust ledger
- Confirm all Thursday pulls are reflected in GL within [TBD] business days
- Any variance over [TBD — Finance to define] requires written explanation
- Completed reconciliation filed in PHI-secure records location [TBD]
5. Escrow Shortfall Protocol
Critical: If Allied escrow is insufficient to cover a Thursday claims pull, claims may be delayed. Correct within 5 business days per trust operations call (March 2026).
Shortfall Response
Steps when escrow balance is below projected Thursday pull
Owner: Operations Director + Primary Approver
- Day 1: Allied notifies Operations of shortfall. Operations confirms amount and identifies which employer(s) contribution is pending.
- Day 1–2: Operations contacts delinquent employer HR directly. Escalates to Primary Approver if employer does not respond within 24 hours.
- Day 3: If shortfall not cured, Primary Approver authorizes trust to advance from reserve to cover Thursday pull. Reserve advance is documented and employer is invoiced separately.
- Day 5 hard deadline: Shortfall must be fully cured. If not: escalate to ERISA Legal Counsel (Eric Gregory). Repeated shortfalls from a single employer trigger the group review process per OPS-SOP-012.
6. Controls & Evidence Requirements
| Control | Evidence Required | Retained By | Retention Period |
|---|
| Monthly employer contribution received | Bank receipt / wire confirmation per employer | Finance | 7 years (ERISA) |
| Per-employer funding detail submitted to trust | Signed per-employer summary + Primary Approver approval | Operations | 7 years |
| Allied escrow funded | Allied confirmation / escrow ledger | Finance | 7 years |
| Thursday claims pull | Allied claims register + escrow debit confirmation | Operations (per SOP-001) | 7 years |
| ProAct invoice paid | Invoice + payment confirmation (per SOP-002) | Finance | 7 years |
| Monthly GL reconciliation | Signed reconciliation worksheet | Finance | 7 years |
7. Open TBDs
- [TBD] Employer premium submission due date each month — set at onboarding per employer
- [TBD] Allied notification SLA when escrow is low — confirm with Kim James
- [TBD] Allied escrow confirmation turnaround time after trust transfer
- [TBD] GL reconciliation SLA (business days) — Finance to confirm
- [TBD] GL variance threshold requiring written explanation — Finance to define
- [TBD] PHI-secure records storage location
- [TBD] ProAct invoice authorization threshold above which Primary Approver is required
- [TBD] Reserve target (weeks of claims) and funding trigger — Finance + SRS to define
OPS-SOP-018 v1.0 | Unity Care Solutions, LLC — Internal / Confidential
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