Direct Payments Prepaid Card Scheme. Quick Guide and FAQs

Transcription

1 Direct Payments Prepaid Card Scheme Adults Services Quick Guide and FAQs A Quick Guide to the Direct Payments Prepaid Card Scheme, for all Adults Services staff involved in setting up Direct Payments from onwards. The full Direct Payment Practice Guidance will be updated shortly and available on the Professional Zone of Connect to Support. Version: 1.0 Effective from: 11 th July 2018 Next review date: March 2021

2 Direct Payments Prepaid Card Scheme: Quick Guide 2 1. What is the Direct Payments Prepaid Card Scheme? From 11 th July 2018 the Direct Payment Prepaid Card scheme is launching as WSCC s core way of delivering Direct Payments. All new Direct Payment customers will be included in the Prepaid Card scheme from the 11 th July 2018 onwards. There is no change at present for customers receiving a Direct Payment set up before 11 th July There is also no change to Carers Direct Payments and One off Direct Payments. Please read the customer and staff FAQs lists attached to this sheet for more information about: What Prepaid Cards are and how they are used WSCC s partner organisation Allpay The benefits for our customers and WSCC Key changes to be aware of The Customer/ Representative does not have to set up a separate bank account for their Direct Payment. The customer cannot go overdrawn as there are no overdraft facilities. The pre-paid card is not linked to the customer s own bank account so there is reduced risk of fraud. Customer/ Representative no longer send in bank statements to the DP Finance team. The customer pays their assessed contribution into the prepaid card account from their personal bank account. The customer can manage their prepaid card account online or via the dedicated customer telephone support service Prepaid Card accounts are monitored online. The Prepaid Card scheme allows up to three Supplementary Card Holders WSCC staff need to carry out additional checks before setting up a Prepaid Card for the customer or other card-holder. The full Direct Payment Practice Guidance will be updated shortly and available on the Professional Zone of Connect to Support. Copyright West Sussex County Council / Version 1.0 / Page 2

3 Direct Payments Prepaid Card Scheme: Quick Guide 3 2. Initial advice and guidance for customers/ representatives The WSCC leaflets Your Direct Payments Prepaid Card and Your life your choice and the Customer Prepaid Card FAQs sheet should be given to customers/ representatives at an early point. There are two Prepaid Card options depending on the customer s mental capacity to manage a DP: Direct Payment Prepaid Card: (person has mental capacity to manage their own DP) Direct Payment: Suitable Person Prepaid Card (person lacks mental capacity to manage their own DP and the DP account is held by a Suitable Person ) The customer s Mental Capacity Assessment about managing a Direct Payment needs to include the customer s ability to understand/ retain/ weigh and use relevant information about using a Prepaid Card account. 3. Supplementary Card-Holders The customer/ Suitable Person may want to appoint up to three supplementary card-holder(s). These are people chosen by the customer/ Suitable Person to help them manage their Prepaid Card account. A supplementary card-holder provides practical assistance to the customer/ Suitable Person to help them manage their prepaid card account. However the primary card-holder (customer/ Suitable Person) retains the overarching responsibility for the prepaid card account and any transactions the supplementary card-holder makes on their behalf. Historically, a customer with capacity to accept a DP could appoint a Nominee to fully manage their DP for them. The Nominee role is no longer available in the Prepaid card scheme. A customer with mental capacity to accept a DP must be the primary card-holder. Supplementary card-holders can make transactions and access account information via the customer online portal/ telephone service. Supplementary card-holders cannot access all the account information via the portal and will just be able to see information about transactions they have carried out on their card. Supplementary card-holders must agree to and sign the WSCC Direct Payments agreement. A supplementary card-holder cannot be anyone Copyright West Sussex County Council / Version 1.0 / Page 3

4 Direct Payments Prepaid Card Scheme: Quick Guide 4 identified as a Cause of Risk in a Safeguarding Adults at Risk enquiry in relation to the customer. Requests for paid PAs to be supplementary card holders will warrant further discussion. The PA or family member that is acting in a paid capacity is unable to pay themselves by transferring money into their personal account (this is blocked by Allpay) but if there are concerns about a proposed supplementary card-holder these should be discussed with a manager before proceeding. 4. Supporting Vulnerable Customers Process Allpay has a free Supporting Vulnerable Customers' process for any customers who may need increased help and understanding to use online and phone services. This process involves sharing information between WSCC and Allpay about areas of difficulty a customer may have, to support these customers to use prepaid card services safely and effectively. An example could be making Allpay aware of a customer s communication needs so that call handling staff can be sensitive to these when the customer calls the customer service line. Allpay will link proactively with WSCC via the Direct Payments team if there is any evidence of potential safeguarding issues for a customer or Allpay become aware the customer is experiencing any difficulties using their prepaid card account. 5. Lost, stolen or damaged cards If any card is lost, damaged or stolen, the card-holder needs to notify Allpay immediately via the Customer Services phone line , there is an automated Lost & Stolen process via this number outside of office hours. As soon as it is registered lost or stolen the card is blocked to prevent anyone using it but the prepaid card account remains open as normal and all supplementary cards can continue to be used. Transactions made before the card is reported lost will be charged to the account. New cards are issued within 5 working days of the request being sent from the Direct Payments Team and if a customer needs to make payments before their new card is received, the following options can be used: Payment can be made via the online portal or customer services helpline Copyright West Sussex County Council / Version 1.0 / Page 4

5 Direct Payments Prepaid Card Scheme: Quick Guide 5 A supplementary card-holder uses their card to make the transaction on the customer s behalf (includes Prepaid Card Support service, if used (Independent Lives) If there are any urgent issues that cannot be resolved the customer should contact the social work team for advice 6. Services provided by Direct Payments Support Service: currently Independent Lives: Some customers may feel they need further advice and guidance about Direct Payments. Independent Lives have an information and advice service to support customers to understand the DP process in full - please see the Direct Payments Practice guidance about how to make a referral to this service. There is no change in the requirement for customers/ representatives to have advice and support if a DP will be used to employ Personal Assistants. A referral should be made to the Independent Lives Personal Assistant Engagement Support Service (PAES), as outlined in the DP practice guidance. The Prepaid Card Support service remains an optional service for customers who have capacity to manage a DP but would like assistance with managing their account and choose to purchase this support outside of their Direct Payment. If the customer chooses to use the Independent Lives Prepaid Card Support service, or the services of an independent broker, this needs to be recorded clearly on the Direct Payments agreement. The Prepaid Card Support service will run as a separate scheme on the prepaid card portal so that the service provider can manage customer s funds in the same way as they do now with the managed bank accounts. 7. Monitoring DP accounts and returning unused funds to WSCC Customers/ representatives need to be advised to keep receipts/ invoices for goods and services purchased with their Direct Payment and employee time sheets. These only need to be sent to WSCC if requested. The process for returning unused funds to WSCC has changed. If an account balance exceeds 8 weeks of the Direct Payment and this was not agreed in the Support Plan, WSCC can recoup these funds via electronic transfer from the Prepaid Card account. The social worker will be contacted beforehand to advise if there is a reason for the surplus. If the accrual has not been agreed the customer will be given written notice in advance of this and the surplus will be reclaimed. Copyright West Sussex County Council / Version 1.0 / Page 5

6 Direct Payments Prepaid Card Scheme: Quick Guide 6 If a customer s assessed contribution has not been paid into their prepaid card account for over 8 weeks, the Direct Payment finance team will request the allocated social worker/ duty worker contact the customer/ representative to explore this issue. If after ten working days there has been no response from the social work team/ customer: a decision will then be taken about whether other options to a Direct Payment need to be considered for the customer. This process is described in detail in the Direct Payment Agreement. 8. Alternatives to the Prepaid Cards scheme: There may be occasions where a customer wants to have a Direct Payment but feels a Prepaid Card scheme is not right for them. WSCC s approach is to educate, help and resolve any concerns to enable all customers to get the best out of the Prepaid Card scheme. The attached Customer FAQs list addresses some of the common queries that may arise and it will be helpful to look through this with the customer/ representative when discussing the new DP. The Care Act (2014) states Local Authorities offering Prepaid Cards schemes must also offer traditional Direct Payment schemes. If the customer/ representative has serious reservations about a Prepaid Card account that cannot be resolved with advice and guidance, please discuss these with your manager as there will be situations where a traditional DP is the only viable option for a customer. 9. Support Planning The Direct Payments team will be using the online portal to access real time information about how DP funds are being spent. Social care staff will be contacted for urgent clarification unless the agreed use of a Direct Payment is made explicitly clear in the Support Plan. To avoid unnecessary workload all Support Plans need to clearly identify how the Direct Payment is going to be spent. The following issues are important to consider when support planning for a prepaid card account: Cash withdrawals Copyright West Sussex County Council / Version 1.0 / Page 6

7 Direct Payments Prepaid Card Scheme: Quick Guide 7 The facility for withdrawing cash from ATMs is not switched on for the Adults Direct Payment Prepaid Card scheme. If small amounts of cash are needed for some element of the support plan, this needs to be discussed with your manager and recorded in the support plan. Arrangements such as the customer using their own money and reimbursing themselves from their DP account may be possible subject to discussion and manager agreement. Restricted purchases There is a list of goods and services outside of the area of social care services which cannot be purchased with a Prepaid Card please see the list attached below. Accruals over 8 weeks When an account balance exceeds 8 weeks of the Direct Payment the DP finance team will ask the social work team to investigate this. This 8 week limit aims to identify unplanned accruals in accounts. If a Support Plan involves planned accruals over 8 weeks of the Direct Payment this needs to be stated in the Support Plan. Low balances When an account balance falls below 2 weeks of the total weekly budget, the DP finance team ask the social work team to investigate this. The two week limit aims to avoid unplanned overspend from the DP. State clearly in the Support Plan if there will be times the account balance falls below two weeks of the total budget. For example, if a customer is only using their DP Payment for monthly care agency bills or PA wages this may occur frequently. 10. Know Your Customer (KYC) checks A Know Your Customer Check needs to be carried out for any card-holder. This is a mandatory anti-money laundering requirement stipulated by Allpay. When the Direct Payment Agreement is signed, the Support Broker or Social Care Worker needs to record they have seen: (1) A piece of photo ID (or a letter from the Department for Work and Pensions) for the card-holder plus (2) Proof of the card-holder s current address plus (3) The card-holder s National Insurance Number Copyright West Sussex County Council / Version 1.0 / Page 7

8 Direct Payments Prepaid Card Scheme: Quick Guide 8 For existing customers who have had a face to face WBA visit, the documents checked by the WBA assessor might already fulfil the requirements for a Know Your Customer check. You can check which documents were looked at on the customer s FSA 3 Financial Assessment. If the criteria for a KYC check are met, you can record the documents seen by WBA on the KYC template without needing to see them yourself. Please bear in mind that any Suitable Person or supplementary card-holder will still require a KYC check. The Know Your Customer checks should be recorded in the Know Your Customer Template (AS465) available in the Assessment and Support Planning Episode. If the customer is going to be the card-holder the Know Your Customer check is for the customer. If a Suitable Person is going to be the card-holder, the Know Your Customer check is for the Suitable Person. For any supplementary card - holder the Know Your Customer check is for each person who will hold a card. 11. Know Your Customer Template (AS465) The KYC Template (AS465) needs to be used for each primary and supplementary card-holder. The KYC template should be uploaded into the customer Mosaic record with all the relevant sections completed. The Direct Payments Team cannot order the card without the key sections completed. Card required There is an option for the customer/supplementary cardholder to not have a physical card but still use the online or telephone banking facilities. You will need to let the DP Team know if a card is or is not required. Proof of ID/Proof of Address Please complete the relevant sections confirming that these checks have been completed. If there is no KYC record on the AS465, then the ordering of the prepaid card cannot progress until these are done. Authentication/Security Question All card-holders will need to select an Authentication Question. The question and answer will be sent to Allpay when the card is ordered so that they can verify the card-holder s identity. Copyright West Sussex County Council / Version 1.0 / Page 8

9 Direct Payments Prepaid Card Scheme: Quick Guide 9 Card delivery address If the card-holder wishes the card to be delivered to a different address, for example, they live in flats and are concerned that the card could be intercepted by others then the alternate delivery address should be recorded on the form. Customers in insecure accommodation may wish to choose the no card option or to have the card delivered to a West Sussex County Council office to collect. These customers will need to bring ID before the card is released. 12. Monitoring and Review Any customer experiencing problems with the prepaid card scheme should be encouraged to discuss these with their social work team as soon as possible. If it is not possible to resolve these issues through advice and guidance, an initial review may need to be brought forward to look at any changes needed in the customer s Support Plan. This may need to consider alternative forms of service provision for the customer. Initial and annual reviews of the Direct Payment also need to cover any issues arising from the use of prepaid cards. Please liaise with the Direct Payment finance team prior to carrying out your review to make sure that any issues relating to use of the Prepaid Card Account can be explored at review. 13. Other helpful materials Customer and Staff Frequently Asked Questions sheet WSCC leaflets Your Direct Payments Prepaid Card and your life your choice List of prevented purchases Allpay handbook Copyright West Sussex County Council / Version 1.0 / Page 9

10 Direct Payments Prepaid Card Scheme: Quick Guide 10 Direct Payments: Prepaid Card Staff FAQs 1. What if a customer doesn t want to have a Prepaid card? The Prepaid Card DP scheme is WSCC s default option for Direct Payments, but as is clear in the Care Act, the option of a traditional DP also needs to be available. WSCC s approach is to provide support, advice and guidance to help customers get the most out of the Prepaid Card scheme including advice about services from our Direct Payments Support Service at present: Independent Lives. Customers need to be offered a traditional DP at this point if they feel this is a preferable option for them. 2. Who carries out Know Your Customer checks? Full Practice Guidance around Know Your Customer Checks is being developed, but in the interim this will be carried out when the customer signs the Direct Payment agreement. The staff member carrying out the DP agreement (social care worker or Support Broker) needs to make sure the Know Your Customer check is carried out and recorded for everyone who is going to have a card. This means checking and recording: - Card-holder s photo ID or a DWP letter - Proof of card-holder s address - National Insurance Number for each card-holder 3. What support is there for vulnerable customers? Allpay have a Supporting Vulnerable Customers process to help people who may find using a Prepaid card difficult. This involves WSCC sharing information with Allpay when the card is set up about any issues call handling staff may need to bear in mind (problems with verbal communication/ hearing problems/ cognitive problems). Allpay will contact WSCC if their staff are concerned a customer is struggling with managing their account. WSCC may need to consider reviewing the Support Plan and considering whether there is a better option for the customer if the problem is not resolvable with advice and guidance. 4. Can two card-holders jointly manage the account? No, the scheme is set up to have a primary card-holder who has the overarching responsibility for the account, and up to three supplementary card-holders. 5. Is there a phone App for the Prepaid Card? There is no App but the website is mobile optimised so customers can log in via their mobile phone to check balances and make payments as they would through their computer/tablet. Copyright West Sussex County Council / Version 1.0 / Page 10

11 Direct Payments Prepaid Card Scheme: Quick Guide Is the Prepaid Card Contactless? No. This is likely to be introduced from April 2019 but at the moment the card is set up for Chip and Pin. 7. Is it a premium rate line or high cost to call Allpay in respect of queries or telephone banking: No, the cost from a landline or mobile is 0.03 pence per minute and the average length of call is 2/3 minutes to set up payments so the cost to the customer is around 10 pence per call. Some mobile phone companies allow free calls to 0330 numbers so the cost of a call my come within the existing phone plan. Allpay also offer a call back service if there is a problem for the customer to stay on the line or the call cannot be resolved quickly. 8. Is the IL Banking and Admin service still available? Yes: Independent Lives will offer a Prepaid Card Support Service. The service will operate in the same way as the Managed Bank Account service; the only difference is that Independent Lives will be able to manage accounts directly from the online portal on behalf of the customer. If the customer chooses this service this will still be a paid service outside their Direct Payment. 9. Can there be more than 3 supplementary card-holders? No there are a maximum of three supplementary cards per customer in the Prepaid Card scheme. 10. Can a PA be a card-holder? Yes, subject to discussion with your manager. You as a social care worker will need to ensure the customer and any supplementary card holder are aware of their responsibilities in terms of ensuring the Direct Payment is used lawfully and effectively and only to achieve the outcomes identified in the Support Plan. In the event of the prepaid Card being misused by a Supplementary card-holder WSCC is not responsible for any losses incurred. 11. What do I do if a card-holder may be misusing the account? If there are any concerns about how the DP funds are being used, you may need to consider raising a Safeguarding Adults at Risk concern, and letting the Direct Payments team know immediately so they can look at the account. 12. How does the card get ordered? All new customers can go onto the Prepaid Card scheme from the 11 th July It needs to be made clear to the Support Brokerage team when the Prepaid Card scheme is going to be used, so that the correct Direct Payment Agreement can be completed and the information passed to the Direct Payments team. Copyright West Sussex County Council / Version 1.0 / Page 11

12 Direct Payments Prepaid Card Scheme: Quick Guide 12 What is the DP team s role? The DP team will check that the KYC checks have been undertaken and are recorded before ordering the prepaid Card on behalf of the customer. The DP team will provide Allpay with the customer/ Suitable Person and any supplementary card holder s details. What is the role of Allpay? Allpay will send out the card to customer/ Suitable Person and any Supplementary Card Holder(s), with information about how to activate the card. For example, the Direct Payments Team order the card(s) before 2 pm on the 11 th of that calendar month, Allpay will process the request and it will be sent out the next day on the 12th and the customer(s) will have the card by the 16th or 17th. 13. Is the Direct Payment automatically loaded on the Prepaid Card once it is activated? In the majority of cases there will be a delay between the card being activated and the Direct Payment being paid onto it. This is no different to the current process as the length of time between the card being ordered and payment depends on how quickly the budget holder authorises the purchase, the setting up of the charge and the next Direct Payment run. The delay to the customer receiving their Direct Payment can be frustrating and the intention is to review these processes to improve the customer experience. However, in the interim please advise the customer that it may take up to four six weeks from the point at which they receive the Prepaid Card until they receive a letter from the Direct Payments Team advising them of their first and subsequent Direct Payments schedule. 14. Can all existing Direct Payment customers move to a Prepaid Card? The Direct Payment Prepaid Card option is available to all existing customers. However, where there are issues of regular and ongoing non-compliance in respect of non-payment of the customer contribution or of sending in bank statements, there will need to be further scrutiny/review before a decision can be made about these customers transferring onto the Prepaid Card. The intention of these checks is not to put up unnecessary barriers but to ensure there is a clear audit trail in moving from one system to another. 15. What about risk of fraud? Customers that are concerned about identity theft or their card being mis-used should be reassured by the following: The prepaid card is not linked to the customer s personal bank account so the only funds on the card are the Direct Payment. Allpay will monitor and alert WSCC of any irregular or unusual transactions made to the Prepaid Card. Copyright West Sussex County Council / Version 1.0 / Page 12

13 Direct Payments Prepaid Card Scheme: Quick Guide 13 Allpay operates an Address Verification Service so if someone tries to order good online and uses a different billing address to the one on Allpay s record then the card will be blocked. If the customer is making regular monthly payments into a payee(s) bank account then these payments can be set up with Allpay over the telephone and there will be no need to hold a physical card. Allpay will suspend the card until they can speak to West Sussex if they suspect there has been fraudulent activity. Allpay is able to contact the merchant and potentially charge back to the customer s Direct Payment Prepaid Card if a fraudulent payment has been made. The allpay prepaid card is issued by allpay Ltd pursuant to license by Mastercard International Incorporated. allpay Ltd is a company regulated by the Financial Conduct Authority (FRN ) for the issuance of electronic money. Head office and registered address: Fortis et Fides, Whitestone Business Park, Whitestone, Hereford, Herefordshire, HR1 3SE (Company No ). Mastercard is a registered trademark of Mastercard International Incorporated. Copyright West Sussex County Council / Version 1.0 / Page 13

14 Direct Payments Prepaid Card Scheme: Quick Guide 14 Appendix 1 AS465 Know Your Customer Checks The Prepaid Card is a Financial Product and as such Allpay has a duty to ensure that card programmes are compliant with regulations and policies and procedures are in place to combat financial crime. All clients (e.g. Councils) must carry out KYC Due Diligence on card-users as prescribed by Allpay. This will entail identification and verification of the card user along with their address. Type of Request New Primary Card Holder New Supplementary Card Holder Primary Card Holder Customer Mosaic No: Name and Title: National Insurance Number: Address: Telephone/Mobile No: Address: Is the Customer Card to be issued: Yes: No: Proof of Identity Select one option below to indicate type of document seen Current not expired Full Passport or Travel Document Passport Number: Current not expired Full Driving Licence with Photo ID showing current address Driving Licence Number: Copyright West Sussex County Council / Version 1.0 / Page 14

15 Direct Payments Prepaid Card Scheme: Quick Guide 15 Benefit Entitlement Letter from DWP at current address Immigration Visa Immigration Visa Number: Proof of Address Select one option below to indicate type of document seen Utility bill issued within the last three months Local authority council tax bill for the current tax year Current UK driving licence (but not if used as proof of name) Bank Statement/Credit Card/Debit Card statement issued within last three months: Customer Security Question when contacting Allpay Authentication Question: Authentication Response: 1.What is your mother s maiden name? 2.What is the name of your best friend from childhood? 3.What was the name of your first pet? 4.What was the colour of your first vehicle? 5.What was the name of your first teacher? Card Delivery if different to address above: Supplementary Card Holder 1 Customer Mosaic No: Name and Title: National Insurance Number: Address: Copyright West Sussex County Council / Version 1.0 / Page 15

16 Direct Payments Prepaid Card Scheme: Quick Guide 16 Telephone/Mobile No: Address: Card to be issued: yes/no Supporting Customer Mosaic ID: Proof of Identity Select one option below to indicate type of document seen Current not expired Full Passport or Travel Document Passport Number: Current not expired Full Driving Licence with Photo ID showing current address Driving Licence Number: Benefit Entitlement Letter from DWP at current address Immigration Visa Immigration Visa Number: Proof of Address Select one option below to indicate type of document seen Utility bill issued within the last three months Local authority council tax bill for the current tax year Current UK driving licence (but not if used as proof of name) Bank Statement/Credit Card/Debit Card statement issued within last three months Customer Security Question when contacting Allpay Authentication Question: Authentication Response: 1.What is your mother s maiden name? 2.What is the name of your best friend from childhood? 3.What was the name of your first pet? 4.What was the colour of your first vehicle? 5.What was the name of your first teacher? Copyright West Sussex County Council / Version 1.0 / Page 16

17 Direct Payments Prepaid Card Scheme: Quick Guide 17 Card Delivery if different to address above: Supplementary Card Holder 2 Customer Mosaic No: Name and Title: National Insurance Number: Address: Telephone/Mobile No: Address: Card to be issued: yes/no Supporting Customer Mosaic ID: Proof of Identity Select one option below to indicate type of document seen Current not expired Full Passport or Travel Document Passport Number: Current not expired Full Driving Licence with Photo ID showing current address Driving Licence Number: Benefit Entitlement Letter from DWP at current address Immigration Visa Immigration Visa Number: Proof of Address Select one option below to indicate type of document seen Utility bill issued within the last three months Copyright West Sussex County Council / Version 1.0 / Page 17

18 Direct Payments Prepaid Card Scheme: Quick Guide 18 Local authority council tax bill for the current tax year Current UK driving licence (but not if used as proof of name) Bank Statement/Credit Card/Debit Card statement issued within last three months Customer Security Question when contacting Allpay Authentication Question: Authentication Response: 1.What is your mother s maiden name? 2.What is the name of your best friend from childhood? 3.What was the name of your first pet? 4.What was the colour of your first vehicle? 5.What was the name of your first teacher? Card Delivery if different to address above: Supplementary Card Holder 3 Customer Mosaic No: Name and Title: National Insurance Number: Address: Telephone/Mobile No: Address: Card to be issued: yes/no Supporting Customer Mosaic ID: Copyright West Sussex County Council / Version 1.0 / Page 18

19 Direct Payments Prepaid Card Scheme: Quick Guide 19 Proof of Identity Select one option below to indicate type of document seen Current not expired Full Passport or Travel Document Passport Number: Current not expired Full Driving Licence with Photo ID showing current address Driving Licence Number: Benefit Entitlement Letter from DWP at current address Immigration Visa Immigration Visa Number: Proof of Address Select one option below to indicate type of document seen Utility bill issued within the last three months Local authority council tax bill for the current tax year Current UK driving licence (but not if used as proof of name) Bank Statement/Credit Card/Debit Card statement issued within last three months Customer Security Question when contacting Allpay Authentication Question: Authentication Response: 1.What is your mother s maiden name? 2.What is the name of your best friend from childhood? 3.What was the name of your first pet? 4.What was the colour of your first vehicle? 5.What was the name of your first teacher? Card Delivery if different to address above: Worker Name: Worker Signature: Date:.. Copyright West Sussex County Council / Version 1.0 / Page 19