Chris Doxey: "The US market is finally paying more attention to e-invoicing"

Could you describe in a few words, for our readers, who is Chris Doxey and what is your main area of activity?

I have held senior finance and controller positions at Digital Equipment Corporation, Compaq, and Hewlett-Packard which allowed me to develop and implement standards of internal control and leading practices for all aspects of financial operations. I was recruited to assist WorldCom (MCI) with the implementation of internal controls, policies, and corporate governance. I then fine-tuned my consulting experience at APEX Analytix and BSI Healthcare.

In 2012, I joined my husband David at Doxey, Inc. Now as president, I use my extensive background to provide best practices solutions to my clients in the areas of governance, risk, and compliance (GRC) focusing on the Procure to Pay (P2P) and Record to Report (R2R) processes.

I work with several global clients which include one of the world’s largest ERP solution providers, and a global accounts payable recovery firm. I am currently implementing a self-audit tool and reporting tool for the accounts payable process.

I also consult with NACHA and I’m a writer and speaker for the IOFM’s AP/P2P and AR/O2C networks. I’m a sought after speaker at global conferences. I present several webinars each year. As a published author, I write numerous blogs and whitepapers in the GRC space.

Taking a look at the US market, how do you see the e-invoicing adoption panning out in the next few years?

The US market is finally paying more attention to e-invoicing as they see the benefits in process improvements, cost reductions and efficiency gains in the accounts payable process. The US is starting to measure the result of the implementation of e-invoicing in metrics and scorecards since CFOs and controllers are now paying attention. Also, CPOs and procurement professionals are requesting that all suppliers provide invoices electronically when the relationship is established.

The challenges are: a) navigating through the maze of solution providers and finding the right solution for a specific company since “one size doesn’t fit all”; b) properly defining e-invoicing and not trying to implement many automation solutions at once; c) having a solid understanding of one’s accounts payable process, invoicing, and vendor master process; d) understanding the risks and challenges of the accounts payable process.

What are lessons to be learned from Latin America’s approach to e-invoicing?

Latin America is constantly changing their invoicing and tax policies and the concept of e-invoicing is completely different from other parts of the world.

• While there are some similarities between each country, the main issue is the lack of a common definition and standard for the e-invoicing process. This means that the full automation of the purchase order, invoice, and goods receipt does not occur in some cases – creating matching and reconciliation issues.

• It is difficult to implement a Latin American Shared Service Centre concept because of all these process differences – PDF, XML, EDI etc. And because the government is involved in the process, it is very time consuming to get an invoice corrected.

• There is a tremendous impact during the Record to Report (R2R) Process. If there is an issue in the XML, incorrect information is pushed through to the ERP system. This means that the financial teams need to always review the data during the before the closing process to avoid significant fines.

What are the main aspects that must be kept under control in order to prevent fraud in the procure-to-pay (P2P) process?

Here is a listing of universal “fraud flags” for the P2P process. Additionally, most companies pay close attention to the three critical corporate controls which are: 1) Delegation of Authority, 2) Segregation of Duties, and 3) Systems Access.

• Employees posing as suppliers

• Suppliers with high spending located at residential addresses

• Multiple suppliers located at the same address

• Scam or Fictitious Suppliers

• Consecutive invoice numbering

• The First payment small relative to average payment (Spikes in Invoice Payments)

• Pricing Anomalies

• All invoices are even dollar amounts

• No purchase orders or purchasing policy

• No policies for the use of P-Cards or other corporate credit cards

• Lack of management attention to internal controls and accounts payable procedures

On September 23rd, same-day ACH went into effect. Who are the actors involved and what are the main use cases?

Same Day ACH will provide several benefits to corporations and consumers in the world of business-to-business and business-to-consumers/consumer-to-business/person-to-person payments. There will be reduced costs for immediate payments for senders and receivers compared to wire payments along with quicker funds availability – and more importantly, there will be the faster receipt of payment remittance - if the remittance is transmitted with the ACH payment.

Business-to-Business Payments

• Hourly and emergency payroll (bonuses, garnishment payments, travel and entertainment payments, off-cycle payroll corrections)

• Faster business-to-business payments (payments to strategic suppliers, customer goods can be held until payment is received)

• Accelerated merchant card settlement (on digital and mobile sites)

• Business-to-Consumer/Consumer-to-Business/Person-to-Person Payments

• Expedited business-to-consumer payments (insurance pay-outs)

• Consumer-to-business online bill payments (due-date payments)

• Person-to-person payments (split bills, emergencies)

Timing of Same Day ACH

The proposed changes will not all go into play at once. Some have wondered why not make all the changes at once. NACHA had surveyed its members and based on the feedback from that survey, decided to implement in this manner. Spreading implementation across three phases will ease the industry’s implementation effort, and allow the industry to acclimate to a faster processing environment with Same Day ACH credits prior to processing Same Day ACH debits. Additionally, this phased-in approach allows corporations to make all the changes to the payment files sent to their banks, fully test, and realize the benefits of the Same Day ACH process.

Could same-day ACH bring about new fraud threats and how can businesses prepare in advance?

The standard ACH controls are provided below and would need to be considered with any changes to the ACH process.

• ACH Debit Block: Prohibits all ACH debit withdrawals from the account.

• ACH Debit Filters: Only ACH debit transactions that match criteria you set based on payee and dollar amount are permitted.

• ACH Positive Pay: Allows the account holder to review ACH debit requests before they are paid.

In answer to part two of this question, I’m providing a list of considerations which is an overview of the items a company needs to consider when implementing Same Day ACH. In this checklist, I take a corporate view as a starting point and consider the impact on all financial processes.

About Chris Doxey

Chris held senior finance and controller positions at Digital Equipment Corporation, Compaq, and Hewlett-Packard. In 2012, Chris joined her husband David at Doxey Inc. She holds a bachelors degree in English, a bachelors in accounting, a masters in business administration, and has a graduate certificate in project management. Chris is a member of the Institute of Internal Auditors (IIA), the Institute for Internal Controls (The IIC), and the Institute of Management Accountants (IMA). She is a board member of the IMA’s Ethics Committee and Research Foundation. She is also a member of the advisory board for The IIC. She is a writer and speaker for the IOFM’s AP/P2P and AR/O2C networks.