Churches across the country are considering appropriate ways to implement social distancing and other sanitary practices to help protect worshippers and staff. These considerations must include addressing the sanitary aspects of the offering collection process while maintaining appropriate internal control.
Traditionally, many churches have relied on the passing of plates, baskets, bags, or similar containers during worship services for the collection of offerings. An alternative approach many churches have adopted is the use of collection receptacles (e.g., drop boxes) placed in or near the sanctuary. Use of collection receptacles eliminates the hand-to-hand contact that naturally occurs during the passing of containers from one congregant to another. When using collection receptacles, it is important to apply certain internal control procedures to safeguard both the contributions and the reputations of those involved in retrieving them from the receptacles.
Dual control
Dual control should be maintained over the contents of the collection receptacles such that no one person acting alone has access to unprocessed funds. (In this context, dual control means having at least two unrelated individuals working together in the handling of live, unprocessed funds, up to the point that a deposit is prepared and a log or record of the funds is created.) A lack of dual control significantly increases the risk of undetected misappropriation.
Locks on receptacles
A collection receptacle should be secured (locked) in a manner that requires dual control (described above) in retrieving the contents of the receptacle. (When we say “requires” here, we mean physically requires…not that dual control is simply required as a matter of policy.) Dual control can be physically required if each collection receptacle is locked with a single lock and the key to the receptacles is stored in a manner that requires two unrelated individuals working together to access it (for example, the key is stored in a safe or vault that physically requires dual control to open it). Alternatively, the receptacles can have dual locks configured so that no one person can open both locks. The receptacle could have two key locks or a key lock together with a combination lock. No one person should have the ability to open both locks. Regardless of the manner of securing the receptacle, the key point is that the design of the receptacle should always physically require at least two unrelated individuals working together to access its contents.
Location and security of collection receptacles
Collection receptacles should be placed in high traffic areas that are in plain view – both to make them accessible and to enable observation by others. A church may also wish to consider the use of security cameras to monitor activity around collection receptacles. Churches should also consider the physical security of the collection receptacles. Collection receptacles should be firmly secured to the floor or wall so that they cannot be easily removed from their location.
Retrieving funds
At the appropriate time, at least two unrelated individuals should work together to retrieve the contents of each collection receptacle. These individuals can then deliver the funds to the counting location where the deposit is prepared. Some churches have security guards or off-duty law enforcement officers accompany or monitor the transportation and processing of offerings collected.
Segregation of duties
In addition to implementing appropriate dual control, individuals responsible for the physical collection and processing of funds should be separate from and unrelated to those who have accounting responsibilities for the funds.
A final word
As the COVID-19 pandemic has affected worship attendance and related activities, our firm has noted that the churches that have weathered the pandemic better financially are generally those that already had robust programs for live-streaming their worship services and electronic giving. Churches that had successfully encouraged their congregants to give electronically were among the least adversely affected in their giving levels – an observation that is particularly true when the congregants establish automatically recurring giving plans. We encourage churches who find themselves collecting a significant amount of funds through a physical collection process to consider implementing other means of collecting donations…including online giving, text-to-give, and giving via secure software applications. While a discussion about the appropriate internal controls in electronic giving is beyond the scope of this article, we can generally say that internal controls over electronic giving tend to be stronger than those surrounding in-person giving of cash and checks.