W4's and Employee Self-Service

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Terry P
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    For those that have implemented ESS and the Tax Withholding form (W-4). How are you handling making sure you have a printed copy of the document is turned in or kept on file. I believe the requirements are a minimum of 4 years.

    There is no notification, like address or direct deposit changes. You could turn on auditing for the fields and report those. But that is not the same as having a copy of the W-4.
    Lacey
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      We are still working this out for implementation, but what we are looking at is a smart note being set up that a change has occured and then saving the smart note for documentation. Before that we were running a query of the field and tracking the user ID that made the change.
      Margie Gyurisin
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        I found this on the IRS site. We are planning on using the PR280 for our electronic history record.

        Electronic submission of Forms W-4, W-4P, W-4S, W-4V, and W-5. You may set up a system to electronically receive any or all of the following forms (and their Spanish versions, if available) from an employee or payee.

        Form W-4, Employee's Withholding Allowance Certificate.

        Form W-4P, Withholding Certificate for Pension or Annuity Payments.

        Form W-4S, Request for Federal Income Tax Withholding From Sick Pay.

        Form W-4V, Voluntary Withholding Request.

        Form W-5, Earned Income Credit Advance Payment Certificate.

        If you establish an electronic system to receive any of these forms, you do not need to process that form in a paper version.For each form that you establish an electronic submission system for, you must meet each of the following five requirements.

        The electronic system must ensure that the information received by the payer is the information sent by the payee. The system must document all occasions of user access that result in a submission. In addition, the design and operation of the electronic system, including access procedures, must make it reasonably certain that the person accessing the system and submitting the form is the person identified on the form.

        The electronic system must provide exactly the same information as the paper form.

        The electronic submission must be signed with an electronic signature by the payee whose name is on the form. The electronic signature must be the final entry in the submission.

        Upon request, you must furnish a hard copy of any completed electronic form to the IRS and a statement that, to the best of the payer's knowledge, the electronic form was submitted by the named payee. The hard copy of the electronic form must provide exactly the same information as, but need not be a facsimile of, the paper form. For Forms W-4 and W-5, the signature must be under penalty of perjury, and must contain the same language that appears on the paper version of the form. The electronic system must inform the employee that he or she must make a declaration contained in the perjury statement and that the declaration is made by signing the Form W-4 or W-5.

        You must also meet all recordkeeping requirements that apply to the paper forms.

        For more information, see:

        Form W-4—Regulations sections 31.3402(f)(5)-1(c).

        Terry P
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          Margie - how do you handle the "electronic signature" requirement though?
          Margie Gyurisin
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            We were considering the id stamp from self service to be the electronic signature.

            Our payroll dept is now double checking with our auditor to make sure we are in compliance. We have just begun to roll out ESS to all our employees.
            Terry P
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              Let me know how that goes. I'm not so sure that a time stamp on a data record suffices, but I'll be interested to hear what your auditors say.
              Margie Gyurisin
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                It is not just a time stamp. It is also the ess user id on the HRHISTORY file. Also, the tax deduction has the web user id on the EMDEDMASTR. Granted that record is the last time the EMDEDMASTR is changed but the PR280 pulls from HRHISTORY. I would like to see Lawson put the web user id everywhere it currently writes the ess user id instead.
                Jodi Kruesel
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                  For those of you that have already implemented Tax Witholding in ESS or are planning to, do you have employees in multiple states? Are you using an outside vendor to pull state forms into ESS? And if so, do you have edits in place for rules such as, the state exemptions can't exceed Federal (this is a MN rule)?

                  We are in the beginning stages of ESS tax withholding rollout and are working through these concerns.
                  Mary Porter
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                    Margie - where did you end up with this? Did your auditors say that being able to print the user update fields from EMDEDMASTR sufficed as electronic proof of the submission?