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Commission on Audit (Philippines), Performance Audit Report PAO-2023-03, "Small Business Wage Subsidy (SBWS) Program" (Internet Archive copy of Aug. 8, 2024)

Summary

Performance Audit Report PAO-2023-03 of the Commission on Audit of the Philippines, dated September 2023, on the Small Business Wage Subsidy (SBWS) Program. The report states that the Department of Finance initiated the program on April 16, 2020 through the Bureau of Internal Revenue and the Social Security System, funded under Republic Act No. 11469 with a total allocation of ₱51 billion. It finds that wage subsidies amounting to ₱45.1 billion, or 89 percent of the budget, were released, and that 3.1 million of the 3.4 million target employees received subsidies from April 29, 2020, to June 25, 2020. Its headline finding is that a substantial number of target beneficiaries under the non-essential category were not served due to implementation issues.

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“Commission on Audit (Philippines), Performance Audit Report PAO-2023-03, ‘Small Business Wage Subsidy (SBWS) Program’ (Internet Archive copy of Aug. 8, 2024).” Original at www.coa.gov.ph. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/commission-on-audit-philippines-performance-audit-report-pao-2023-03-s-e6a4fb8d0a/, SHA-256 2f73b3ecbaa44da11a11ad17a3ada129bfa012f4b9f8c2f4f4c1484faa1e5b94.

Full text

Performance Audit Report
PAO-2023-03




SMALL BUSINESS WAGE
SUBSIDY (SBWS) PROGRAM

The SBWS Program Accorded
Immediate Relief to 3.1 million
Employees during Lockdowns but a
Substantial   Number    of   Target
Beneficiaries under Non-essential
Category were not Served due to
Implementation Issues that Impacted
on the Attainment of Program’s
Objective
Audit                                                                    September 2023


Highlights                                                              Small Business Wage-Subsidy Program

                                                                        The SBWS Program Accorded Immediate Relief to 3.1 million
Why COA Did This Study                                                  Employees during Lockdowns but a Substantial Number of Target
                                                                        Beneficiaries under Non-essential Category were not Served due to
The global economy was significantly impacted by the outbreak of        Implementation Issues that Impacted on the Attainment of
the COVID-19 pandemic in early 2020. In response, the Philippine        Program’s Objective
government declared a nationwide state of calamity and enforced
the Enhanced Community Quarantine (ECQ). Similarly, the                 What COA Found
Department of Finance (DOF) recognized that the community
quarantines affected 5.8 million employees from the formal economy      The SBWS Program aims to provide immediate relief to employees in the
sector.                                                                 formal economy sector affected by the imposition of the enhanced
                                                                        community quarantine to address the COVID-19 public health
                                                                        emergency. The use of digital platform facilitated the processing of
On April 16, 2020, the DOF initiated the Small Business Wage            applications and timely release of wage subsidies amounting to ₱45.1
Subsidy (SBWS) Program through the Bureau of Internal Revenue           billion or 89 percent of the allocated budget of ₱51 billion. Out of the 3.4
(BIR) and the Social Security System (SSS). This program aimed to       million target number of employees, a total of 3.1 million or 91 percent
support formal economy sector businesses and their employees            received wage subsidies from April 29, 2020, to June 25, 2020.
affected by the COVID-19 pandemic. The SBWS Program, funded             Nevertheless, critical challenges in the program implementation affected
by Republic Act No. 11469, commonly called the “Bayanihan to Heal       the efficiency and effectiveness of the program.
as One Act,” received a total allocation of ₱51 billion, intended to
provide wage subsidies to approximately 3.4 million impacted              Budget Utilization of the Program
employees.

This audit seeks to evaluate the economy, efficiency, and
effectiveness of the Program by examining the following: (1) the
extent to which program implementers met the goals and objectives
of the SBWS Programs for the formal economy sector; (2) the
challenges, if any, impacting the efficient and timely implementation
of the programs; and (3) the extent to which the implementing
agencies ensured proper administration of the financial assistance/
wage subsidy program.

COA reviewed relevant laws, regulations, rules, and memoranda to
ascertain the program's purpose, objectives, and goals. COA
interviewed officials from the DOF, BIR, and SSS Program
managers. To validate reports on program awareness, eligibility, and
subsidy distribution, COA also interviewed employers of
establishments that applied for the program and surveyed SBWS
Program beneficiaries from specified business establishments.             Source: SSS SBWS Program Liquidation Report as of April 30, 2022
Finally, COA conducted interviews and online application process
walkthroughs for the program.                                           The program’s target to reach out and help affected employees in the
                                                                        small businesses, whose businesses did not full operate during
What COA Recommends                                                     lockdowns, fell short by 41 percent or about 717,442 employees. On the
                                                                        other hand, the program had fully served the target number of employees
Although the SSS implemented swiftly the SBWS Program for               in the quasi-essential businesses with skeletal force and even exceeded
impacted formal economy sector employees during the pandemic, a         by 25 percent or 412,077 employees. Moreover, the program did not
similar situation may occur in the future, and similar measures will    cover the employees belonging to the essential categories affected by the
be undertaken. Therefore, COA recommends that SSS in                    imposition of community quarantine. The SSS confirmed that one of the
coordination with DOF and BIR: (1) conduct risk assessment to           factors affecting the attainment of the target was information
identify potential problems and develop appropriate strategies and      dissemination.
mitigating measures to address them; (2) revisit and improve the
identification process of target beneficiaries to ensure that all       The online application system facilitated the program implementation.
affected employees receive equal opportunity to apply to the            However, there were gaps and limitations noted in the data entry and
program; (3) enhance the system used in SBWS Program to                 verification and payout processes causing delay in the payment of wage
consider incorporating among other, features on preventive              subsidy. At the onset, no official or employee checks the initial data inputs
validation controls on data entry of applications, processing,          of encoders such as the employees’ name, TIN, bank account and mobile
approval and payout of wage subsidies; use of national ID system        number. Subsequently, SSS instituted procedures for validation and
and the SSS UMID ATM cards for efficient verification and payouts;      correction, but time constraints in the program implementation pre-
data sharing of compatible databases from different programs and        empted the full validation and correction of data. The incomplete and
mechanism readily accessible to beneficiaries on the verification of    invalid information of employees resulted in the payment of ₱1.92 billion
status of applications and payouts (4) formulate and implement          to 132,506 beneficiaries with duplicate/invalid TIN, and unclaimed
robust information campaign for effective dissemination of program      payouts for 77,167 and 17,205 beneficiaries in remittance centers and
materials and announcements; and (5) enhance the process on             bank accounts, respectively. The absence of reliable databases of
voluntary return of wage subsidies from ineligible beneficiaries.       program beneficiaries for verification and matching purposes caused
                                                                        incorrect tagging in the processing of applications. Also, delayed release
On the other hand, to ensure that program funds have been               and unsuccessful payouts defeats the objective of providing immediate
                                                                        relief to the intended employee beneficiaries.
appropriately utilized and only eligible beneficiaries received the
wage subsidies, COA recommends that SSS in coordination with
                                                                        Further, the implementation challenges and short timeframe to implement
DOF and BIR should identify the ineligible beneficiaries through        the program; the ₱6.7 billion unsuccessful/rejected payouts and the return
post-implementation verification of TINs and take necessary steps       of ₱5.7 billion to the Bureau of the Treasury impacted on the effectiveness
for the immediate recovery of the wage subsidies provided to            and efficiency of the SBWS Program.
ineligible beneficiaries.
                                                                                  Small Business Wage Subsidy Program
Contents




           Contents
           Background ................................................................................................... 3
            What is SBWS Program? .............................................................................. 3
            Budget Formulation ....................................................................................... 4
           Challenges faced in achieving 91 percent of the 3.4 million targeted
           beneficiaries .................................................................................................. 7
            Automated payouts aided the distribution of ₱45 billion in subsidies to 3.1
            million beneficiaries ....................................................................................... 8
            Under the non-essential small businesses, 41 percent of the targeted
            employees' beneficiaries were not served ................................................... 12
            Inaccurate information resulted in the distribution of ₱1.92 billion in wage
            subsidies to beneficiaries with duplicate/invalid TIN. ................................... 15
            Complicated payout processes delayed the release of ₱109 million wage
            subsidies ..................................................................................................... 17
           Immediate program implementation resulted in inaccurate and
           unsuccessful wage subsidy distribution and a lack of corrective
           processes .................................................................................................... 22
            Challenges in cross-matching of SBWS Program applicants and CAMP
            beneficiaries caused incorrect tagging ........................................................ 22
            Online application system did not have effective control to prevent input of
            partial and invalid data entry ....................................................................... 26
            Return of wage subsidies were not properly accounted for and reported .... 31
            Procedures for involuntary return of wage subsidy were not performed ...... 33
           After implementation, program implementers reported ₱6.7 billion of
           unsuccessful payout and returned ₱5.7 billion to BTr ............................. 37
            ₱5.7 billion funds for the program were returned to BTr .............................. 37
            ₱6.7 Billion wage subsidy payouts not successfully received by intended
            beneficiaries ................................................................................................ 39
           Conclusions ................................................................................................. 44
           Recommendations ...................................................................................... 46
           Agency Comments ...................................................................................... 48
           Appendix I: Objectives, Scope and Methodology ..................................... 49
           Appendix II: Application System Developed for the Program .................. 51
           Appendix III: SBWS Program Key Implementers ...................................... 52
           Appendix IV: SBWS Program Process Flow.............................................. 53
           Appendix V: Result of Survey on Employer of Program Beneficiaries ... 54
           Appendix VI: COA Contact and Staff Acknowledgments ......................... 55




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                                                                                   Small Business Wage Subsidy Program
Contents




           List of Tables
           Table 1: Fiscal cost of SBWS Program for two months (Amount in Billion
           Pesos) ............................................................................................................ 4
           Table 2: Amelioration Programs Comparison ............................................. 5
           Table 3: Wage Subsidy Amount per Region ................................................ 6
           Table 4: PSIC Codes of Eligible Employers ............................................... 10
           Table 5: Target vs. Actual Number of Beneficiaries.................................. 12
           Table 6: Affected Employers and Employees per Category ..................... 13
           Table 7: SBWS Program Communication Materials.................................. 14
           Table 8: Disqualified Employees as at June 25, 2020 ............................... 16
           Table 9: Duplicate TIN/Invalid TIN as at November 15, 2021 .................... 17
           Table 10: Wage Subsidy Payouts After the Deadline................................ 19
           Table 11: Eligible Employees Allowed to Receive Payout Beyond June
           25, 2020 ........................................................................................................ 19
           Table 12: Beneficiary Classification/Status of Payout .............................. 30
           Table 13: Breakdown of Voluntary Returns to BTr ................................... 32
           Table 14: Amount Rejected/Unsuccessful as at April 30, 2022 ................ 38
           Table 15: Estimated Number of employees that can benefit from the
           returned amount ......................................................................................... 39
           Table 16: Unsuccessful Payout based on SBWS Program Database ...... 40




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                                                                                 Small Business Wage Subsidy Program
Contents




           List of Figures

           Figure 1: Payout Distribution of Subsidy ................................................... 9
           Figure 2: Businesses Allowed to Operate During First ECQ (March 15 to
           April 14, 2020) .............................................................................................. 11
           Figure 3: CAMP 1 vis-à-vis SBWS Program Timeframe ............................ 24
           Figure 4: Beneficiaries with contact number issues as at June 20, 2022 28
           Figure 5: Unclaimed Wage Subsidies Due to Invalid Contact Information
           and Incorrect Bank Accounts .................................................................... 28
           Figure 6: Manner of notification on Application Status to Beneficiaries . 29
           Figure 7: Who is required to return the subsidy ....................................... 31
           Figure 8: Rejected or Unsuccessful Credits of wage subsidies to
           beneficiaries’ accounts ............................................................................... 35
           Figure 9: Program Budget Utilization......................................................... 38
           Figure 10: SBWS Progarm Queries ............................................................ 42




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                                                Small Business Wage Subsidy Program
Acronyms




             4Ps        Pantawid Pamilyang Pilipino Program
             ATM        Automatic Teller Machine
             BARMM      Bangsamoro Autonomous Region in Muslim Mindanao
             BIR        Bureau of Internal Revenue
             BPO        Business Processing Outsourcing
             BTr        Bureau of Treasury
             BSP        Bangko Sentral ng Pilipinas
             CAMP       COVID-19- Adjustment Measures Program
             CHED       Commission on Higher Education
             COA        Commission on Audit
             COBIT      Control Objectives for Information Technologies
             COVID-19   Coronavirus Disease 2019
             CY         Calendar Year
             DBM        Department of Budget and Management
             DepEd      Department of Education
             DOF        Department of Finance
             DOLE       Department of Labor and Employment
             DOT        Department of Tourism
             DSA        Data Sharing Agreement
             DSWD       Department of Social Welfare and Development
             ECQ        Enhanced Community Quarantine
             E.O.       Executive Order
             ESP        Emergency Subsidy Program
             FAQS       Frequently Asked Questions
             IATF       Inter-Agency Task Force
             ICSPPS     Internal Control Standards for the Philippine Public
                        Sector
             ISSAI      International Standards of Supreme Audit Institutions
             IT         Information Technology
             ITMG       Information Technology Management Group
             JMC        Joint Memorandum Circular
             LBP        Land Bank of the Philippines
             LGU        Local Government Unit
             MECQ       Modified Enhanced Community Quarantine
             NCR        National Capital Region
             PAO        Performance Audit Office
             PD         Presidential Decree
             PSA        Philippine Statistics Authority
             PSIC       Philippine Standard Industrial Classification
             RA         Republic Act
             SAP        Social Amelioration Program
             SBWS       Small Business Wage Subsidy
             SFTP       Secure File Transfer Protocol
             SMS        Short Messaging Service
             SPTF       SBWS Program Task Force
             SSS        Social Security System
             TESDA      Technical Education and Skills Development Authority

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                                           Small Business Wage Subsidy Program
Acronyms




             TIN    Tax Identification Number
             UMID   Unified Multi-Purpose ID
             URL    Uniform Resource Locator




           Page v                                                 PAO-2023-03
                                                                Small Business Wage Subsidy Program


REPUBLIC OF THE PHILIPPINES


Commonwealth Avenue, Quezon City




September 25, 2023


Mr. ROLANDO L. MACASAET
President and Chief Executive Officer
Social Security System (SSS)
East Avenue, Diliman, Quezon City

Dear President and CEO Macasaet:

The Commission on Audit (COA) conducts performance audits to assist
government agencies in better performing their mandates and achieving
program goals and objectives more economically, efficiently, and effectively, in
line with its vision of becoming an enabling partner of the government in ensuring
a better life for every Filipino. In this regard, the Commission has identified the
Small Business Wage Subsidy (SBWS) Program as one of the priorities to be
audited.

With the COVID-19 pandemic in the Philippines in 2020, the government
imposed a community quarantine to contain the spread of the virus, forcing some
businesses to close temporarily or permanently. Consequently, the Philippine
Statistics Authority (PSA) announced a record-high unemployment rate of 17.70
percent in April 2020, accounting for 7.30 million1 Filipinos, up from 5.30 percent
in January 20202.

Following Republic Act No. 11469 and in partnership with the Department of
Finance (DOF) and the Bureau of Internal Revenue (BIR), the SSS implemented
the SBWS Program in response to the negative impact of the pandemic on
formal sector employees. The program provides a wage subsidy of ₱5,000 to
₱8,000 per month for two months to complement the social amelioration
programs under the Bayanihan to Heal as One Act by providing targeted support
to formal sector employees and employers.3

The audit focused on three aspects of the Program: (1) the extent has the
program implementers met the goals and objectives of the SBWS Program for
_______________________________________________________________
1
    Philippine Statistic Authority (PSA), Employment Situation in April 2020, available at
https://psa.gov.ph/content/employment-situation-april-2020 (last accessed: July 28, 2022)
2
  PSA, Employment Situation in January 2020 available at https://psa.gov.ph/content/employment-situation-
january-2020
0#:~:text=SUMMARY%20STATISTICS&text=b)%20Employment%20rate%20in%20January,42.5%20million
%20total%20employed%20persons (last accessed: July 28, 2022)
3 Bayanihan to Heal As One Act, Republic Act No. 11469, par. 2 p.1




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                                                  Small Business Wage Subsidy Program



the formal economy sector; (2) the challenges, if any, impacting the efficient and
timely implementation of the programs; and (3) the extent has the implementing
agencies ensure proper administration of the financial assistance/ wage subsidy
program.

This audit was carried out from June 2021 to July 2022. We reviewed significant
program policies, joint memoranda circulars, resolutions, accomplishment
reports, and the program’s database during this period. We also conducted
surveys and interviews with selected employer and employee beneficiaries, as
well as interviews and online process walkthroughs with key officials and
stakeholders of the program to assess the extent of coordination and the roles
of partner agencies.

The audit was conducted according to the International Standards of Supreme
Audit Institutions (ISSAI) 3000 - Standard for Performance Auditing. We believe
that the processes we executed during the audit provided sufficient and
appropriate evidence that served as a reasonable basis for our audit findings
and conclusion based on audit objectives.




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                                                                          Small Business Wage Subsidy Program




Background     1.      In response to the sudden increase in COVID-19 cases nationwide,
               former President Duterte imposed the Extended Community Quarantine (ECQ)
               across the entire island of Luzon for specific high-risk locations from March 17
               to April 13, 2020, with an extension to May 31, 2020.4 Following the
               implementation of ECQ, the number of unemployed Filipinos in the labor force
               increased from 5.3 percent or 2.4 million in January 2020 to 17.7 percent or 7.3
               million in April 2020.5

               2.     Republic Act (R.A.) No. 11469, also known as the “Bayanihan to Heal as
               One Act of 2020” (Bayanihan Act 1), was signed into law on March 24, 2020.
               With the passage of the law, the Department of Social Welfare and Development
               (DSWD) ensured the provision of safety nets and the implementation of Social
               Amelioration Programs (SAPs) and services that subsidized the provision of
               necessities and served as a tool for the recovery and rehabilitation of the most
               affected families and individuals.6 Beneficiaries of DSWD’s SAP are low-income
               households, individuals in the subsistence economy, and employees in the
               informal economy.7 For one of the essential SAPs, the Emergency Subsidy
               Program (ESP), beneficiaries receive a subsidy ranging from ₱5,000 to ₱8,000
               based on the proportion of minimum wage rates in each region.8

               3.    On April 14, 2020, the President of the Philippines approved the SBWS
               Program to complement the SAP and provide wage subsidies to formal sector
               employees. SSS, DOF, and BIR issued Joint Memorandum Circular No. 001-
               2020 on April 28, 2020, to outline implementation guidelines for the SBWS
               Program.

What is SBWS   4.     The SBWS Program is a joint undertaking of the SSS, DOF, and BIR to
Program?       provide financial assistance of ₱5,000 to ₱8,000 for up to two months to
               employees in the formal economy sector who were unable to work due to the
               temporary closure of businesses affected by the ECQ and other forms thereof
               imposed in Luzon and other parts of the country in response to the COVID 19
               public health emergency.9




               _______________________________________________________________
               4 IATF Resolution No. 37 Series of 2020. (2020, May 15).
               5   PSA. (2020, June 5). Employment Situation in April 2020. Retrieved from
               https://psa.gov.ph/content/employment-situation-april-2020. (last accessed June 15, 2022)
               6 DSWD. (2020, March 30). MC-2020-04 Special Guidelines on the Provision of Social

               Amelioration Measures by the Department of Social Welfare and Development to the Most
               Affected Residents of the Areas under Community Quarantine and Continuation of the
               Implementation of the Social Pension for Indigent Senior Citizens and the Supplementary Feeding
               Programs. Pp. 1-2.
               7 Ibid. p. 8.
               8 Ibid. p. 5.
               9 DOF-SSS-BIR Joint Memorandum Circular No. 001-2020, April 28, 2020, §1, pp. 1-3




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Budget Formulation   5.      As indicated in Table 1, on April 20, 2020, the Office of the President
                     approved the funding for the SBWS Program for ₱51 billion, including
                     administrative expenditures of ₱200 million. The ₱51 billion budget was based on
                     the determined 3.4 million beneficiaries. The Bureau of Treasury (BTr) should
                     have deposited the fund into the SSS depository account at the Land Bank of the
                     Philippines (LBP),10 however, the BTr and SSS subsequently opted to change the
                     SSS depository account to the Development Bank of the Philippines (DBP).11

                     Table 1: Fiscal cost of SBWS Program for two months (Amount in Billion
                     Pesos)
                                            Category A        Category B
                                                                                 Category C
                                              (Non-             (Quasi-                               Total
                                                                                 (Essentials)
                                            essentials)       essentials)
                      Examples                                              Markets, Food
                                            Mall, Other      BPO, other
                                                                            manufacturing,
                                              retail        manufacturing
                                                                             and delivery
                      IATF Order                             Can operate
                                             Forced to                        Can fully
                                                            with a skeletal
                                              Closed                           operate
                                                              workforce
                      Fiscal cost for
                      employees in
                                                19.9              18.4           Not Included         38.3
                      the alpha list
                      (primary)
                      Fiscal cost for
                      employees not
                      in the alpha list          6.5                6            Not Included         12.5
                      (secondary)
                      Total fiscal cost
                                                26.4              24.4           Not Included         50.8
                      for two months
                      Total
                      administrative              -                 -                   -              0.2
                      cost

                      Total SBWS
                                                                                                      51.0
                      Program Cost

                     Source: Memorandum to the President DOF SBWS Program Proposal submitted to the
                     President

                      6.     Through the SSS, the DOF rolled out the SBWS Program on April 16,
                      2020, following the DSWD’s SAP and DOLE’s COVID-19 Adjustment Measures
                      Program (CAMP). A comparison of these programs is shown in Table 2.

                     _______________________________________________________________
                     10 Memorandum of Agreement Bureau of Treasury and Social Security System. (2020, April 20)
                     11 Amendment to MOA BTr and SSS. (2020, April 28).




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Table 2: Amelioration Programs Comparison
  PARTICULARS             SAP-ESP                   CAMP 1                     SBWS                     CAMP 2
 Agency/ies            DSWD, LGU                 DOLE                      DOF, BIR, SSS           DOLE-DOT-DepEd-
                                                                                                   CHED-TESDA

 Target                Low-income         Employees in the                 Small business          Same Targeting from
 Beneficiaries         households         Formal Economy                   employees               CAMP-1 with the
                       belonging to   the Sector affected by               affected by the         inclusion     of the
                       informal sector    Flexible      Work               ECQ                     Education        and
                                          Arrangements or                                          Tourism Sectors as
                                          temporary                                                beneficiaries
                                          closures during the
                                          pandemic
 Target Numbers        18   million  low- 657,201 affected                 3.4 million small 851,000-Regular
                       income households  formal employees                 business          600,000- Tourism
                                                                           employees         59,000 -Education
 Budget                    ₱200 billion              ₱3.286 billion           ₱51 billion         ₱7.5 billion
 Amount of               ₱5,000 - ₱8,000                ₱5,000             ₱5,000 - ₱8,000          ₱5,000
 Subsidy
 Number of                       2                          1                        2                          1
 Tranches

Source: COA Analysis

                             7.     Small Business Employers. The SBWS Program intends to assist the
                             employees of small businesses impacted by the ECQ, which the DOF classified
                             into three categories: Category A (Non-essentials), Category B (Quasi-
                             essentials), and Category C (Essentials).12 Only Category A and Category B
                             small businesses may apply for wage subsidies for employees who could not
                             work and were not paid. Category C businesses are considered unaffected by
                             the ECQ because they can remain open during the quarantine period. In contrast
                             to Category A and B businesses, the IATF Guidelines and government orders
                             do not restrict the commercial activities of Category C businesses.

                             8.    Wage Subsidies. The SBWS Program followed the provisions of the
                             Bayanihan Act 1 in providing financial assistance in two tranches ranging from
                             ₱5,000 to ₱8,000. The Program considered the time businesses were closed
                             due to community quarantines. At the time of planning, establishments were
                             expected to remain shuttered until May 2020. The subsidy shall be calculated
                             based on the regional minimum wage rate. (see Table 3)


                             _______________________________________________________________
                             12 Category A (non-essentials) are small businesses that are forced to close down. Category B

                             (quasi-essentials) are those allowed to operate a skeleton force. Category C (essentials) are
                             those allowed to operate during ECQ


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Table 3: Wage Subsidy Amount per Region

                  Monthly wage                             Monthly wage
   Region       subsidy per worker         Region        subsidy per worker
                     (pesos)                                  (pesos)
    NCR               8,000                 VII                6,000
    CAR               5,500                 VIII               5,000
      I               5,500                 IX                 5,000
      II              5,500                  X                 6,000
     III              8,000                 XI                 6,000
    IV-A              8,000                 XII                5,000
    IV-B              5,000               CARAGA               5,000
      V               5,000               BARMM                5,000
     VI               6,000

Source: DOF-SSS-BIR Joint Memorandum Circular 2020-01

9.      The subsidy amount provided in each tranche was based on the SAP per
region, with adjustments made for Regions III and IV-A due to the prevalent
daytime migration of residents in these areas to NCR for employment. However,
the ₱5,000 received by an employee beneficiary under CAMP 1 will be deducted
from the pay subsidy in the second tranche. Hence, employees from regions IV-
B, V, VIII, IX, XII, CARAGA, and BARMM with a minimum wage subsidy rate of
₱5,000 who have previously received financial support from CAMP 1 will not be
eligible for tranche 2 of the SBWS Program.

10.     Following the Bayanihan Act 1 prohibiting undue claims for financial
assistance, only beneficiaries of the DOLE CAMP were considered for the
SBWS Program, as CAMP 1 and the SBWS Program covered the same formal
sector participants. However, some programs such as SAP-ESP, had a distinct
set of requirements that targeted low-income households in the informal sector.

11.     DOF uses data from various government agencies and surveys, from the
PSA. DOF estimated that there were 5.9 million employees in the formal
economy sector, of which 1.77 million were classified as non-essentials or
Category A, 3.28 million employees belonged to Category B or quasi-essential
businesses, which can operate with a reduced workforce, and Category C were
essentials businesses that could operate at full capacity during the pandemic.
During the planning phase, the DOF estimated that 100 percent of employees in
the non-essential category would be affected by the business closure due to the
pandemic, while 50 percent of employees in the quasi-essential category,
totaling 1.64 million, would be affected. Employees in the essential category are
excluded, as they can continue to work during the pandemic. There were a total
of 3.4 million affected employees in the formal sector.




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Challenges faced
in achieving 91
percent of the 3.4
million targeted
beneficiaries


                     12.    The SBWS Program was launched in response to a state national
                     emergency declaration due to the severe interruption of economic
                     operations caused by the COVID-19 pandemic. Using online application
                     processes, the program distributed ₱45.1 billion out of ₱51 billion to serve
                     3.1 million or 91 percent of its 3.4 million targeted beneficiaries in the
                     formal economy sector. Despite this, implementers encountered some
                     challenges, including the (a) non-coverage of industries under the
                     essential category affected by the implementation of ECQ; (b) failure to
                     reach 41 percent of the targeted non-essential small businesses; (c)
                     release of ₱1.92 billion to ineligible employees due to inaccurate
                     information; and (d) delayed release of ₱109 million wage subsidy.

                     13.      The SBWS Program utilized the BIR and SSS databases to target
                     affected small businesses and their employees better. The program incentivized
                     small businesses that comply with tax regulations and mandated contributions
                     by utilizing the SSS and BIR systems.13 Accordingly, through online application
                     processes, the program was able to distribute ₱45.1 billion to 3.1 million
                     employee beneficiaries.

                     14.     In selecting the prioritized target beneficiaries, the BIR pre-qualified the
                     small business employers based on the eligibility requirements outlined in the
                     program’s guidelines.14 Using the BIR Database, the BIR generated a list of pre-
                     qualified employers and sent it to the SSS for further pre-validation. With the
                     SSS automated system, the SSS validated the eligibility of the BIR-provided pre-
                     qualified employers.15 After validating the pre-qualified employers, the SSS pre-
                     validated the eligibility of the employees under the eligible employers.16




                     _______________________________________________________________
                     13 DOF Program Proposal - Memorandum for the President (2020, April 13). p. 5.
                     14 JMC 001-2020 requires, as far as BIR is concern, that the employers must be from industry

                     classified as Non-essential or Quasi-essential in view of the ECQ and other forms thereof, imposed
                     in Luzon and other parts of the country. The employers must be registered in the BIR and have
                     complied with tax obligation in the past three years, up to January 2020.
                     15 JMC 001-2020 requires the eligible employers to be registered in the SSS and must have paid

                     SSS contributions in the past three years, up to January 2020.
                     16 JMC 001-2020 requires that the employee must have no pending or settled SSS Unemployment

                     benefit and must have no unsettled or in-process SSS final claims (Funeral, Retirement, Death,
                     and Total Disability).


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                       15.     To apply for the program, employers must check their pre-qualification
                       status on the SBWS Program Query Homepage on the BIR’s website.17 Next,
                       pre-qualified employers acquire a passcode that will be used on the SSS website
                       to apply for the program and apply their eligible employees via the My.SSS
                       portal.18 The employer must next submit the completed application e-form using
                       a secure portal emailed directly to the employer by the SSS or upload the
                       completed Microsoft Excel application form to sbws.gov.ph.

                       16.     As at June 29, 2020, the SSS has received 173,564 employer
                       applications and approved 3.1 million employees, representing 91 percent of the
                       program’s target.19 Notwithstanding constraints on movement and face-to-face
                       interactions, the program was able to accommodate program applicants through
                       the use of the BIR and SSS databases and the digitization of the application
                       process. In addition, the digitization of the online process helped the program
                       reached 91 percent of its targeted beneficiaries. It reduced the health concerns
                       associated with its manual application as the conventional method of providing
                       financial assistance.

Automated payouts      17.     As the Bayanihan Law requires, the program employed available
aided the              technology to distribute wage subsidies directly to the preferred payout option
distribution of ₱45    of qualified beneficiaries, thereby eliminating interaction with other persons and
                       reducing the risk of contracting or transmitting COVID-19. In addition, employing
billion in subsidies
                       these technologies may help prevent potential irregularities in distributing
to 3.1 million         financial assistance, as the intended beneficiaries will receive assistance
beneficiaries          directly from program implementers.

                       18.    The SBWS Program Task Force (SPTF) sought assistance from the DBP
                       to expedite the distribution of wage subsidies to eligible beneficiaries. As a result,
                       its payment facilities enabled the distribution of wage subsidies through
                       PESONet-accredited banks, remittance centers, and e-wallets.20

                       19.    After processing the applications of small business employers, the SSS
                       must generate and transmit payment files to the DBP to process the wage
                       subsidy payments for approved beneficiaries. The wage subsidies will be
                       claimed following the employers’ chosen mode of payment21 during the
                       application.

                       20.   As at April 30, 2022, the SBWS Program liquidation report indicates that
                       ₱45.1 billion of the program’s budget was distributed to beneficiaries. As
                       _______________________________________________________________
                       17 The SBWS Program Homepage requires the employer’s TIN to be entered in its search box. A

                       green prompt will pop-up if the employer is qualified showing the business registered name and
                       an alphanumeric passcode. A red prompt will pop-up for unqualified or if wrong TIN is entered.
                       18 SSS, Member Login, available at: https://member.sss.gov.ph/, (last accessed June 15, 2022)
                       19 SBWS Program Task Force Report No. 71 (2020, June 29). p. 2.
                       20 Supplemental Agreement, SSS and DBP (2020, April 28).
                       21 Modes of payment (in partnership with DBP): 1. Withdrawal via employee’s SSS UMID; 2.

                       Withdrawal from employee’s bank account for PESONet participating banks; 3. Employee’s Union
                       Bank Quick Card (partnership with SSS); 4. Employee’s e-wallet (PayMaya); and 5. Cash pick-up
                       arrangement through M-Lhullier.


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                    illustrated in Figure 1, 63 percent, or ₱28.22 billion, were released to the
                    registered bank accounts of the beneficiaries. The remaining 34 percent and
                    three percent were distributed through remittance centers and e-wallets,
                    respectively.

                    Figure 1: Payout Distribution of Subsidy




                    Source: COA Analysis

                    21.     Survey results indicated that 55 percent, or 304 out of 550 beneficiary
                    responses, indicated that the wage subsidy was used to purchase food during
                    the ECQ. 28 percent, or 158 responses, answered that it was used to pay utility
                    bills, while 13 percent, or 70 responses, stated that it was used to pay rent.

SBWS Program        22.      The SBWS Program targeted small businesses affected by ECQ
did not cover       restrictions; however, the categorization of small businesses excluded affected
employees from      small businesses’ employees under Category C: Essentials.
industries under
                    23.    During the ECQ, only businesses that provided the necessities were
essentials          permitted to operate. These businesses were compelled to implement a stringent
category affected   skeletal workforce to support operations, in addition to the strict minimum health
by ECQ              protocols.22 As enterprises not exempted from ECQ restrictions were made to
                    cease operations temporarily, their employees were left without a source of
                    income.

                    24.    The SBWS Program guidelines grouped the qualified employees of these
                    small businesses affected by the ECQ into Category A – Non-essential; and
                    Category B – Quasi-essential. In addition, the program specified using the


                    _______________________________________________________________
                    22 IATF Resolution No.14, series of 2020, pp. 3-5




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Philippine Standard Industrial Classification (PSIC) of 1994 to classify small
businesses correctly.23

25.     Employers were pre-qualified for the program by the BIR using their
registered PSIC code. This eliminates the need to determine physically whether
or not a small business is subject to the ECQ’s restrictions. (see Table 4)

Table 4: PSIC Codes of Eligible Employers

                                              Philippine Standard Industrial
           Sector common name
                                               Classification (PSIC) code
 Category A: Non-essentials
 Non-food raw materials/Non-               5, 10, 11, 20, 21, 22, 24 to 29, 34,
 essential manufacturing                   35, 36, 39
 Tobacco                                   16
 Construction                              45
 Airlines                                  62
 Non-essential services                    91, 93, 95
 Hotels and restaurants                    55
 Rental and leasing of personal            71
 goods
 Entertainment                             92

 Category B: Quasi-essentials
 Textiles, wearables, and leather for      17, 18, 19
 export
 Electronics manufacturing                 30, 31, 32
 Retail trade                              50 to 52
 Public transportation/trucking and        60, 61, 63, 64
 cargo handling (food and non-food)
 Business process outsourcing              68, 70, 72, 73, 74
 Banks                                     65, 66
 Personal service and domestic             96
 activities (salons, laundry, funerals,
 domestic help, others)


Source: DOF-SSS-BIR JMC 001-2020

26.     With this category, the program does not cover establishments previously
classified as Essentials but functioning with a skeletal workforce or had
temporarily ceased operations due to adopting ECQ. Employees not included in
the skeletal operation of Category C businesses, such as food
manufacturing, are likewise ineligible for financial assistance under this program.
_______________________________________________________________
23 Supra note 9, § II (3-4), pp. 2-3




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In the Education Sector, administrative personnel were also denied the
opportunity to apply for the program because neither Category A nor B included
them. IATF-issued permits to operate with a skeletal workforce are detailed in
Figure 2.

Figure 2: Businesses Allowed to Operate During First ECQ (March 15 to
April 14, 2020)

 Can Operate at Full Capacity
 None

 Can Operate with Skeletal Force
 • Manufacturing and Processing            •   Power            Energy,          IT,
     Plants of Basic Food Products,            Telecommunications Supplies and
     Essential Products, Medicine, and         Facilities, Water Disposal Services
     Medical Supplies                      •   Export and Business Process
 • Agricultural activities                     Outsourcing
 • Retail establishments                   •   Airline and Aircraft maintenance
 • Logistics Service Providers                 employees, including pilot and crew,
 • Hospitals and Medical clinics               and ship captain and crew
 • Food Preparations and Water             •   Media establishments
     Refilling Stations only for take      •   Hotels
     away and delivery                     •   Energy Companies and their third-
 • Delivery services                           party contractors
 • Banks and capital markets               •   Telecommunications

 Cannot Operate
 • All other businesses

Source: IATF Resolution Nos. 13, 14, and 15, dated March 17, 20, and 25, 2020,
respectively

27.     During the program’s planning phase, the DOF projected that 436,300
businesses listed in Table 6 would be forced to close, while 1,042,688 were
operating with a skeletal workforce. In addition, the DOF assessed that 74,051
businesses fall under Category C: Essentials and can continue to operate during
the ECQ. They shall not be included in the program as target beneficiaries except
when the ECQ will impair their capacity to conduct business. The IATF only
permitted businesses to operate if they utilized alternative work arrangements,
including establishments under Category C: Essentials. Besides, it was explicitly
provided in the program guidelines that eligible employers are small business
employers belonging to non-essential and quasi-essential only. Thus,
businesses under Category C: Essentials, even if subject to ECQ restrictions,
were still not eligible for the program; hence, afflicted employees under this
category cannot apply.

28.     The SSS and DOF confirmed that for a business to be qualified for the
program, aside from being classified as a small business pre-qualified by the BIR
using their database, it must be affected by the imposition of ECQ. In addition, if
the small business had the option to remain open during the period of quarantine,


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                      as in the case of those in Category C, their ability to do commerce is not impinged
                      on by the IATF guidelines/government order, unlike in the case of Categories A
                      and B. However, as presented in Figure 2 above, based on the cited IATF
                      Resolutions, no businesses, regardless of their category, were allowed to
                      operate in full capacity from March 15 to April 14, 2020.

                      29.    The DOF further explained that if the establishment was not included in
                      the pre-qualified list, and still, the employer believes they are eligible for the
                      program; it is noteworthy that the SPTF provided a platform to cater to similar
                      concerns by sending their queries to SBWS_BIRquery@bir.gov.ph.

Under the non-        30.      Overall, 91 percent of the program’s targeted small business employees
essential small       were achieved. Nonetheless, a comparison of total accomplishment to target per
                      category revealed that the program distributed more financial assistance than
businesses, 41
                      intended in the quasi-essential category. In contrast, the most affected
percent of the        establishments in the non-essential category that cannot operate, whether in part
targeted employees'   or in full, during the ECQ were not served.
beneficiaries were
not served            31.     The SPTF oversees communication and dissemination strategies using
                      the official websites of the three agencies (BIR, DOF, and SSS), a Google site
                      dedicated to the SBWS Program, and social media accounts. These agencies
                      were responsible for answering questions regarding their respective roles and
                      obligations outlined in the program guidelines. In addition, they respond to
                      inquiries through their social media and email accounts.24

                      32.    The SPTF held several meetings about the program’s implementation.
                      Since the primary channel of information dissemination was the social media
                      account of the partner agencies, this social media account was used to issue
                      announcements and respond to various questions by providing canned
                      responses or Frequently Asked Questions (FAQs)25 regarding the program. The
                      disadvantage of these communication tools is that those who do not have social
                      media accounts cannot directly access this information.

                      33.   A review of the program’s 91 percent accomplishment disclosed that
                      Category B exceeded its target by 25 percent but reached only 59 percent in
                      Category A, failing to serve 717,442 Non-Essential Small Business employees,
                      as shown in Table 5 below.

                      Table 5: Target vs. Actual Number of Beneficiaries

                            Category               Target        Actual      Difference % Accomplished
                       Category A
                                                 1,768,413     1,050,971      (717,442)              59%
                       (Non-essential)

                      _______________________________________________________________
                      24 Supra note 9, § IX (A-D), pp. 7-9
                      25 FAQ for SBWS Program, available at https://sites.google.com/dof.gov.ph/small-business-

                      wage-subsidy/frequently-asked-questions (last accessed June 22, 2023)


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      Category          Target        Actual    Difference % Accomplished
 Category B
 (Quasi-essential)     1,638,637    2,050,714    412,077             125%
 Total                 3,407,050    3,101,685   (305,365)            91%

Source: COA Analysis

34.    Affected Employees. Of the 3.4 million target beneficiaries identified by
the DOF, 2.6 million were compliant with tax requirements based on the
Alphabetical List of Employees/Payees (alphalist) in the BIR database. The
remaining 838,472 employees were not in the BIR’s database due to the
employer’s non-submission of alphalists or non-compliance with withholding tax
requirements but were also compelled to close or operate with a skeletal staff.
The target beneficiaries were further categorized to non-essential and quasi-
essential. (see Table 6)

Table 6: Affected Employers and Employees per Category

                        Category A      Category B
                                                      Category C
                          (Non-           (Quasi-                        Total
                                                      (Essentials)
                        essentials)     essentials)
 Number of Small
 Businesses (non-         436,300        1,042,688       74,051        1,596,654
 LTS Taxpayers)

 Formal Sector
 Employees               1,768,413       3,277,273      597,240        5,858,142

 Affected
                                                           Not
 Employees               1,768,413       1,638,637                     3,407,050
                                                        Included

Source: DOF SBWS Program Proposal submitted to the President

35.     The tri-agency’s communication platforms for communicating the
program to stakeholders were on their websites and Facebook pages. Facebook
notifications, Frequently Asked Questions (FAQs), Step-by-Step guidance via
PowerPoint presentations or PDF files, and emails to pre-qualified employers
were used to communicate with the beneficiaries. In addition to Facebook live
sessions and media interviews, the key implementers of the program provided
prospective applicants with guidance. The numerous communication activities
launched by the SPTF are detailed in Table 7.




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Table 7: SBWS Program Communication Materials

     Communication materials             Count         Remarks
 Advisories                                 41
 FAQS                                       6
 Step-by-Step Guide                         7
 Testimonial Cards                          16
 Facebook Live Sessions                     3
 Website Landing Pages                      9
                                            45          Drafts
 Emails to Employers
                                            16         Finalized

Source: SSS

36.      It is noteworthy to emphasize the communication efforts of the SPTF to
inform the targeted beneficiaries about the wage subsidy program. The
communication strategies work as long as the small business or its
representative is active on social media or frequently visits the tri-agencies
official website. In addition, the BIR is tasked to notify pre-qualified business
employers to avail of the program through the latter’s official website. As an
alternative, BIR may also inform taxpayers through email when such email
addresses of taxpayers are available from their records.

37.     We confirmed how establishments were informed by interviewing small
business beneficiaries’ HR/representatives. Interview results revealed that six
percent or two out of 33 with approved SBWS Program applications reported
receiving program information by email from SSS/BIR/DOF, and the majority of
HR Practitioners learned about the program from the web platform (Facebook
announcement, Twitter, online news, and tri-media).

38.    Considering that the program is a first come, first serve application, a
review of the program’s guidelines on achieving the target per category indicated
that the program lacked a mechanism to ensure that the target number of
beneficiaries in each small business category would be achieved. As a result,
the implemented guidelines and procedures did not account for accomplishing
the objectives on a per-category basis.

39.     Although the program nearly achieved its target for the number of
affected beneficiaries, looking at the program’s target by category, 41 percent,
or 717,442 target employees from non-essential businesses that cannot operate
at all during the lockdown, which required financial assistance the most to
withstand the negative impact of the pandemic, were underserved in comparison
with the businesses that can partially operate.



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                         40.    SSS confirmed that one of the factors affecting the achievement of the
                         target was information dissemination. The BIR should have informed the
                         targeted beneficiaries through email instead of posting the information on the
                         BIR website, but could not fully utilize the communication method.

                         41.      DOF commented that all eligible non-essential and quasi-essential
                         businesses were given ample time to avail of the wage subsidy program, and
                         aside from the efforts listed in Table 7, the Officials of DOF, BIR, and SSS also
                         made television appearances to promote the program. However, despite these
                         efforts, the applications received were mainly from quasi-essential businesses.
                         DOF further explained that small businesses targeted by the program (whether
                         nonessential or quasi-essential) must still apply to the program and will not
                         receive the payouts automatically. This is to ensure that the eligibility criteria are
                         met.

Inaccurate               42. Given the program’s limited application period and key implementers’
information resulted     limited capacity to respond to inquiries, information dissemination strategies are
in the distribution of   essential for the program’s efficient implementation. So, the implementer of the
₱1.92 billion in         program must ensure the accuracy of the information disseminated to the
                         intended user so that they may make informed decisions. The program
wage subsidies to
                         disqualified 19,963 employees due to disinformation provided by the SSS about
beneficiaries with       the input of 000-000-0000 or random digits TIN. In contrast, SSS granted wage
duplicate/invalid        subsidies totaling ₱1.92 billion to 132,506 beneficiaries with duplicate/invalid
TIN.                     TIN.

                         43.      Program guidelines stipulated that the SSS must provide the BIR with a
                         list of small business employers who utilized the program, along with the names
                         of employee beneficiaries and their Taxpayer Identification Numbers (TIN), to
                         monitor the number of employers availing versus those pre-qualified.26

                         44.     Disqualified Employees. To incorporate the program guidelines on TIN
                         into the online application system, employers must supply the employee’s name
                         and TIN. However, a discussion with HR representatives indicated that early in
                         the program’s implementation, the SSS instructed them through email to submit
                         TIN 000-000-0000 or a random TIN to complete the application process. We
                         have validated this information based on comments made by HR representatives
                         on various social media platforms and based on the minutes of the meeting citing
                         the advice made by SSS. Accordingly, the SSS issued advisories that confused
                         employers and employee beneficiaries regarding TIN information. In addition,
                         SSS instructed the entry of TIN 000-000-0000 or a random TIN in some webinar
                         sessions for the program briefing.

                         45.    Following SSS’s instruction and advice, the company’s employer/human
                         resources department entered 000-000-000 or a random TIN for those
                         employees who either forgot their TIN or were still applying for one. SSS
                         _______________________________________________________________
                         26 Supra note 9, § IX (C.7), p. 7




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explained that the instruction to use a TIN of 000-000-0000 or a random TIN was
because the program did not utilize the TIN as a basis for including the employee
as a program beneficiary. However, SSS later realized the advice was incorrect
and published an advisory on May 5, 2020, three days before the application
deadline, stating that using 000-000-000 or random digits as the TIN of
employees will result in exclusion from the SBWS Program. In addition, the
advisory noted that the method for the return of the wage subsidy would be
announced for employers that input 000-000-000 or random digits for the TIN of
their employees.

46.   As indicated in Table 8, an analysis of disaggregated data on disqualified
employees disclosed that 19,963 employees were disqualified due to an invalid
TIN.

Table 8: Disqualified Employees as at June 25, 2020

                                            # of Employees
  Reason For Disqualification
                                              Disqualified
 Invalid TIN                                     19,963
 Invalid Bank Details                             7,795
 With Maternity Claim                              136
 With Final Claim                                  21
 With Unemployment Claim                           67
 Total Disqualified                              27,982

Source: COA Analysis

47.    Qualified Employees with Invalid TIN. In the meantime, there have
been instances where applications were approved even though employers
entered duplicate or invalid TINs. As part of the control procedures of the online
application system, the applicant could not modify the information provided in
the system after applying. Following the program’s guidelines and the advice
published on TIN, duplicate and invalid TINs may also result in the employee’s
exclusion from the program and eventual refund of wage subsidies.

48.     In light of the potential for invalid TINs and other inaccurate information
to be accepted by the application system, the SPTF launched a correction
module. However, despite the SPTF’s implementing a correction module, an
analysis of application system data revealed that 132,506 beneficiaries had
duplicate and/or invalid TINs. The invalid TINs identified were limited to 000-000-
000-000, duplicate alphanumeric characters, and outdated or obsolete. As
shown in Table 9, the total wage subsidy granted to beneficiaries with duplicate
and/or invalid TINs amounted to ₱1.92 billion.




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                      Table 9: Duplicate TIN/Invalid TIN as at November 15, 2021

                                      Particulars            With Duplicate TIN/Invalid TIN
                       No. Of Beneficiaries                                           132,506
                       Wage Subsidy Granted                                    ₱1,933,449,000
                         Tranche 1                                                988,023,500
                         Tranche 2                                                945,425,500
                       Amount Recovered                                             8,368,381
                       Wage subsidy granted to
                       Beneficiaries with                                      ₱1,925,080,619
                       duplicate/invalid TIN

                      Source: COA Analysis

                      49.     Thus, the instructions regarding the input of 000-000-000 TINs and
                      random digits led to the exclusion of 19,963 employees from the program and
                      the granting of wage subsidies to 132,506 employees with duplicate and invalid
                      TINs. Had the policy governing the input of TIN been executed in accordance
                      with the program guidelines, the number of 19,963 disqualified employees due
                      to invalid TIN should have been reduced. In addition, with the issuance of an
                      advisory on disqualification from the program due to the use of duplicate and
                      invalid TINs, which the program implementer advised at the outset of program
                      implementation, 132,506 beneficiaries with duplicate and invalid TINs should
                      have been subjected by the BIR for TIN verification and subsequent wage
                      subsidy return procedures by the SSS should they found to be ineligible
                      beneficiaries.

Complicated payout    50. The program could not distribute all wage subsidies within the allotted time
processes delayed     frame. The delayed release of financial assistance to 10,544 beneficiaries of
the release of ₱109   Tranche 1 and 3,759 beneficiaries of Tranche 2 who were severely impacted by
million wage          the adverse economic effects of the pandemic defeats the objective of providing
subsidies             immediate relief to beneficiaries.

                      51.    Consistent with the declared policy in Section 3 of RA No. 101469 to
                      urgently respond to the socioeconomic impact of COVID-19 that has greatly
                      affected the Philippines that has caused and continues to cause the loss of lives
                      and significant disruption of the economy, the State recognizes the urgent need
                      to undertake programs for recovery and rehabilitation.27

                      52.     Following the enactment of Bayanihan Act 1 on March 20, 2020, then
                      President of the Philippines approved the SBWS Program on April 14, 2020. By
                      issuing DOF, SSS, and BIR Joint Memorandum Circular No. 001-2020, dated
                      April 28, 2020, as the guidelines of the program, the SBWS Program application
                      _______________________________________________________________
                      27 Supra note 9, par. 1, p.1




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period began on April 16 and ended on April 30, 2020. In contrast, the payout
period was set from April 29 to May 15, 2020, for Tranche 1 and May 16 to 31,
2020, for Tranche 2. 28

53.     However, the application period has been extended from April 30 to May
8, 2020, due to application issues encountered by employers regarding the
details of necessary personal information of the employees, such as TIN (see
discussion in inaccurate information resulted to distribution of ₱1.92 billion in
wage subsidies to ineligible beneficiaries, page 15). In addition, the payout
periods have been extended to May 31, 2020 and June 15, 2020, for Tranche 1
and Tranche 2, respectively. The extension was made to give companies extra
time to address deficient information on their applications.29

54.       In evaluating applications, SSS detected invalid account numbers while
processing the payouts of the beneficiaries. Therefore, the SSS had to notify the
employers of the corrections. In addition, the SSS needed to receive the return
files30 from the DBP to identify the concerned employers and individual employee
files. However, despite the requests from the SPTF and intervention of the
Bangko Sentral ng Pilipinas (BSP), the payout banks have not complied with the
agreed deadlines to submit the return files to the DBP. This resulted in the delay
in identifying and notifying the affected employers and in the distribution of wage
subsidies. Thus, the payout periods were extended to June 19, 2020, for both
tranches and up to June 25, 2020, for payouts resulting from SBWS-CAMP
grievances and SBWS Program appeals.31 As at June 24, 2020, 21,466 CAMP
appeals from employee beneficiaries were recorded, and 13 percent or 2,705,
were granted or resolved.32

55.     According to SBWS Program data, Tranche 1 wage subsidy payouts
totaled 3,101,685 and amounted to ₱23.34 billion, while Tranche 2 wage subsidy
payouts totaled 3,084,583, amounting to ₱22.37 billion. Nonetheless, despite the
reported payout being extended until June 25, 2020, a review of the reported
accomplishment of the program indicated that 10,544 beneficiaries for Tranche
1 and 3,759 beneficiaries for Tranche 2 received wage subsidy beyond the
deadline, totaling ₱109.98 million. (see Table 10)




_______________________________________________________________
28 Supra note 9, § VI (7). (2020, April 28). p. 5
29 SPTF Resolution No. 1 (2020, May 15).
30 Return file refers to the report provided by DBP to SSS containing details as that of Payment

File with information on successful and unsuccessful transactions with specified reasons.
31 SPTF Resolution No. 3 (2020, May 28).
32 SPTF Updates Meeting (2020, June 25.) p. 259.




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Table 10: Wage Subsidy Payouts After the Deadline

                                       Tranche 1                           Tranche 2

    Particulars              Number of       Amount of Wage      Number of         Amount of Wage
                            Beneficiaries     Subsidies (₱)     Beneficiaries       Subsidies (₱)

 Payouts ON or
 BEFORE June
                                 3,091,141    23,252,147,000         3,080,824       22,345,923,000
 25, 2020,
 Deadline
 Payouts AFTER
 June 25, 2020,                     10,544         83,199,000             3,759          26,782,000
 Deadline
 TOTAL                           3,101,685    23,335,346,000         3,084,583       22,372,705,000

Source: COA Analysis

                  56.    The SSS Management confirmed that there were instances wherein
                  wage subsidy was released beyond June 25, 2020. However, these transactions
                  were fully supported by SPTF Resolution No. 8, dated August 14, 2020, which
                  recommends to the Secretary of DOF the further payout of the SBWS Program.
                  In a positive response, the DOF issued an opinion on the legality of the SBWS
                  Program payout after June 25, 2020.

                  57.    In the issued legal opinion of the DOF, the vested right of the employees
                  was emphasized, wherein the SBWS Program was granted because of the loss
                  of income of employees due to strict quarantine measures imposed from March
                  to May (2020). That, despite the lapse of RA No. 11469 or The Bayanihan to
                  Heal as One Act, the reason for the grant of the SBWS Program and its effect
                  on the employees has occurred.

                  58.   SPTF Resolution No. 8 was issued to address the concerns of eligible
                  employees who have complied with and satisfied all the program’s guidelines
                  and qualifications but failed to receive their wage subsidy due to causes beyond
                  the employer's control of the payee-employee. In particular, the extended payout
                  beyond June 25, 2020, was only applicable to the eligible employees
                  enumerated in Table 11:

                  Table 11: Eligible Employees Allowed to Received Payout Beyond June 25,
                  2020

                                 Category                                Details
                   1. Employees who did not Tranche 1 was not credited due to using old
                      receive  their  SBWS or cash/prepaid card account numbers.
                                            With the overlap in the schedule of Tranche


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                                                 Small Business Wage Subsidy Program



            Category                                  Details
     Program Tranche 1 but 2 payouts and the late submission by banks
     received their Tranche 2 of return files for Tranche 1, the discovery
                              of non-payment was made after reconciling
                              all the return files beyond the payout
                              periods.

 2. Employees who received a. Employees with incorrect account
    their   SBWS      Program details, which banks accommodated for
    Tranche 1 but did not     Tranche 1 payout but no longer
    receive their Tranche 2   accommodated in Tranche 2, were not
                              informed to correct their account details.

                                    b. Employees with incorrect account
                                       details who were able to amend their
                                       credentials but whose Tranche 2 was
                                       not released.

 3. Employees who did not a. Employees whose disbursement status,
    receive   both  SBWS     as reported to SSS by the banks, were
    Program Tranche 1 and    changed from “Credited” to “Not
    Tranche 2                Credited.”

                                    b. Employees with incorrect account
                                       details who were not notified could not
                                       correct the same.

 4. Employees who received a a. Employees whose DOLE CAMP
    subsidy from the DOLE’s        appeals were not processed until the
    CAMP but did not receive       determination of payout for Tranche 1
    SBWS Program Tranche 2         have been settled based on the
    representing the net of any    submission by the banks of the return
    amount received under the      files.
    DOLE’s CAMP
                                b. Employees whose DOLE CAMP
                                   appeals were not processed before the
                                   payout deadline.


Source: SSS, SPTF Resolution No. 8, dated August 14, 2020

59.    It is noteworthy to mention that the cited reasons for the delay of the
payout beyond the control of the beneficiaries and the SPTF considered the
impact of the program on the beneficiaries even beyond the payout deadline.
However, we maintain that these identified beneficiaries were among the formal
sector employees severely impacted by the significant economic disruption
caused by the COVID-19 pandemic. Delaying wage subsidy distribution beyond
June 25, 2020, defies the purpose of the SBWS Program, which is to provide


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beneficiaries with immediate relief. This is corroborated by the explanation of the
DOF that the program was not extended or reopened as it was conceptualized
to provide immediate relief to small business employers and their employees.
(see a detailed discussion on ₱5.7 billion funds under the program that were
returned to BTr, page 37)




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Immediate
program
implementation
resulted in
inaccurate and
unsuccessful wage
subsidy
distribution and a
lack of corrective
processes
                       60.    Due to a lack of time to prepare the program and an immediate
                       requirement of implementation, program planning, application processes,
                       and remedial procedures were challenging during the implementation of
                       the SBWS Program. As a result, (a) the program implementers incorrectly
                       tagged beneficiaries; (b) no effective control was established to prevent
                       the acceptance of incorrect and invalid information to the online
                       application system; (c) acceptance of invalid and/or incorrect information
                       about beneficiaries that caused the unsuccessful payout of ₱557 million
                       wage subsidies from money remittance centers; (d) voluntarily returned by
                       an employer was not fully reflected in the report provided; and (e) SPTF
                       issued resolution transferring its fiscal accountability to COA by relying
                       on the former’s post-audit procedures in identifying ineligible
                       beneficiaries.

Challenges in cross-   61. The DOF cross-matched CAMP and SBWS Program beneficiaries to
matching of SBWS       prevent double-dipping or unauthorized receipt of multiple subsidies. However,
Program applicants     beneficiaries were mistakenly tagged due to a lack of a unique identifier for the
and CAMP               beneficiaries' information, the different format of the names used across the two
                       programs, and the timing of the financial assistance. As a result, overpayments
beneficiaries
                       of ₱51.88 million were made to 10,375 CAMP and SBWS Program participants,
caused incorrect       while ₱4.43 million were wrongly deducted from the 886 SBWS Program
tagging                beneficiaries.

                       62.      The CAMP is a cash-assistance program administered by the DOLE that
                       provides financial support to affected employees in private businesses that have
                       adopted flexible working arrangements or temporary shutdowns during the
                       COVID-19 pandemic.33 While the SBWS Program is the successor to CAMP, the
                       latter’s beneficiaries can also benefit from the SBWS program so long as the
                       ₱5,000 received from CAMP is deducted from their second tranche.

                       63.   Upon review of the SBWS Program guidelines, it was determined that
                       the DOF is responsible for matching CAMP beneficiaries with qualified SBWS
                       _______________________________________________________________
                       33 DOLE Department Order No. 209, Series of 2020




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Program beneficiaries. Therefore, under the Data Sharing Agreement (DSA)
signed by the DOF, DOLE, and SSS on May 4, 2020, the DOLE shall share its
list of beneficiaries with the SSS and DOF via an in-house developed SSS Web
Service with a dedicated URL and secure file transfer protocol (SFTP). The DOF
will utilize the data to cross-match beneficiaries of the CAMP and SBWS
Program. The DOF provided the cross-matched data to SSS over SSS’s SFTP
as a reference for processing the applications.

64.     The DOF performs the pre-processing of CAMP beneficiaries and the
cross-matching with SBWS Program beneficiaries through the data scientist.
The data scientist employed numerous data analytics tools for a proper data
cleaning technique for deduplication and name matching, considering the
different information formats required by the two systems. The DOF noted that
cross-matching proved challenging because the data sets from the respective
systems lacked a unique identity and had different naming conventions. For
example, the SBWS Program database uses the format First Name, Middle
Name, Last Name, whereas the DOLE-CAMP database uses the format Last
Name, First Name, Middle Name. In addition, DOLE-database CAMP is
susceptible to human error, such as the employer’s improper entry of applicant
names (with Jr., same name, incorrect spelling, etc.).

65.    Due to the highlighted difficulties in cross-matching beneficiaries
between the two programs, 886 SBWS Program beneficiaries were incorrectly
tagged as CAMP beneficiaries. As a result, their second tranche wage subsidies
were improperly reduced by ₱5,000, totaling ₱4.43 million.

66.     The cross-matching result of the CAMP data and the SBWS Program
indicates that 29 percent or 196,000 out of the 680,000 CAMP beneficiaries also
benefited from the SBWS Program.34




_______________________________________________________________
34 SBWS Program report no. 71 p. 2




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Figure 3: CAMP 1 vis-à-vis SBWS Program Timeframe




Source: Program Guidelines of DOLE-CAMP and SBWS Program

67.     The timing of the release of financial assistance to CAMP 1 beneficiaries
posed an additional difficulty in the cross-matching process. As shown in Figure
3, the payout period for CAMP 1 was from March 24 to September 2020, but the
payout period for SBWS Program was from April 29 to June 25, 2020. Due to
the longer payout term of CAMP 1 compared to SBWS Program, employer
applicants for SBWS Program were not permitted to list their employees
applying under CAMP 1 beneficiaries until they received financial support from
CAMP 1. Neither employers nor employees knew when they would receive
financial support from CAMP 1. Applicants to the SBWS Program indicated in
good faith that they were not CAMP beneficiaries during the application process.
This resulted in obtaining the entire subsidy amount under both programs. Even
with the CAMP cross-matching procedures performed by the DOF to determine
whether qualified SBWS Program beneficiaries were also CAMP beneficiaries
before the distribution of SBWS Program subsidies, there was no assurance that
multiple requests for financial assistance would be identified.

68.     The cross-matching concern of the SBWS Program and CAMP
beneficiaries compelled the SPTF to develop a grievance mechanism. As a
result, SPTF Resolution No. 4 was passed, allowing beneficiaries who were
improperly tagged and entitled to the SBWS Program to file an appeal.35 The
SPTF will decide the request based on the appellant’s information. The SPTF
will communicate its final decision to the appellant. If the appeal is upheld, the
SPTF shall recommend the decision to the SSS administration for immediate
processing of the difference between the SBWS Program and CAMP amounts
received by the appellant.
_______________________________________________________________
35 SPTF Resolution No. 4, p. 3




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69.    A partial analysis and comparison of the two databases (CAMP and
SBWS Program) found that the DOF’s cross-matching process missed
approximately 10,375 employees who were both CAMP and SBWS Program
beneficiaries. Hence, they received the full wage subsidy. In contrast, we
noted that around 886 employees were incorrectly identified as CAMP
beneficiaries, and the amount of ₱5,000 was deducted from their second tranche
of wage subsidies. This resulted in an overpayment of ₱51.88 million to CAMP
and SBWS Program beneficiaries and an underpayment of ₱4.43 million to
SBWS Program beneficiaries who were incorrectly tagged.

70.     Throughout the application process walkthrough, we noted that the
Program’s Online Application System permits invalid/incorrect TINs for
employees (see a detailed discussion on inaccurate information caused the
release of ₱1.92 billion wage subsidies to ineligible employees, page 15). Due
to the lack of a shared database between key stakeholders, the three program
application systems used for the SBWS Program were unable to validate the TIN
provided by the employer. However, a separate analysis identified invalid and
duplicate contact information for 936,976 employee beneficiaries without contact
information and 54,454 employers with invalid contact information.

71.     The program implementation constraints prohibited the implementer from
establishing sound design internal control at the onset of program
implementation. To expedite implementation and address the immediate
demand for relief in the formal economy sector, an online application system was
established for employer applicants to give information, resulting in invalid and
incomplete data entry in the system. To minimize the data entry problem, SSS
Management offered and relied on a commitment signed by employers upon
program application submission that the information provided is true and correct.

72.     DOF commented that in addition to the factors identified that pertain to
cross-matching, the following also contributed such as: (a) the DOLE CAMP
Application was manually done, (b) the SBWS Program Team received the
DOLE database in a per region file, (c) the middle name of the recipients are
included in the first name column. Other files did have middle names in a
separate column, but only middle initials, (d) birthdays were not included, and
(e) only employers, barangay, city, and municipality were given. DOF further
explained that as the DOLE CAMP data is “incomplete” and/or incorrectly
formatted,” conducting a perfect cross-matching was difficult.




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Online application     73. In terms of data entry, an examination of the application system's internal
system did not have    control revealed no effective control to prevent invalid and incomplete data from
effective control to   being entered into the program's online application system.
prevent input of
                       74. The Control Objectives for Information and Associated Technologies
partial and invalid
                       (COBIT) 5 framework created by the Information Systems Audit and Control
data entry             Association provides information technology best practices that conform to
                       international standards. Under the COBIT 5 Enabling Processes, control
                       activities under the Deliver, Service, and Support domain state that input
                       transactions should promptly validate that they are accurate, complete, and valid;
                       validate input data; and edit or, if necessary, send back for correction as close
                       as possible to the point of origination.

                       75.     The SPTF ensured that the SBWS Program be fully digitized to distribute
                       the wage subsidy within the allotted timeframe to promptly mitigate the adverse
                       economic effects of the COVID-19 pandemic on the formal economy sector.
                       Hence, an IT system was established to support the program’s implementation.
                       With this developed IT system, SSS created three online application methods.

                       76.    The login mechanism and procedure for encoding the applicant’s
                       information vary in between the three different application methods. These three
                       methods depend on the information the employer applicant provides and the
                       information already stored in the SSS database.

                       77.     A review of the application system’s disaggregated data indicated invalid
                       or insufficient data. SSS Management explained that the information could not
                       be altered or changed once an employer submits an application.36 In this
                       instance, the information that employers encoded in the application system are
                       considered final and cannot be modified without SSS permission. This was also
                       confirmed in the email issued in response to SBWS Program inquiries, which
                       said that if an employer encoded wrong employee information such as account
                       number, mobile number, TIN, etc., the information would be considered final.
                       This resulted in the database application containing inaccurate or incomplete
                       data.

                       78.     Since the DOF, SSS, and BIR do not have a common database, there
                       was this concern regarding data submission. Therefore, there is a high possibility
                       that the information details for employers and employees from the BIR pre-
                       qualification will not match the information in the SSS database, even though the
                       beneficiaries belong to the same formal economy sector.

                       79.    SSS Management commented that no procedures or systems were
                       created to validate employee beneficiaries’ TIN, bank account, and mobile
                       number.



                       _______________________________________________________________
                       36 SBWS-Step by Step Guide (Method 1), p. 12




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The acceptance of      80.     The distribution of wage subsidies through money remittance centers
blank, duplicate, or   depends on employees’ contact information. As such, a review and analysis of
invalid contact        disaggregated data from the online application database as at April 30, 2022,
numbers by online      show that there are 936,976 employee beneficiaries without contact information,
                       invalid or duplicate contact details, 17,205 incorrect bank accounts, and 54,454
application systems,   employers with invalid contact information. The deficiency resulted in unclaimed
as well as             payouts of 59,167 beneficiaries in money remittance centers and 17,205
inaccurate bank        beneficiaries in banks, which amounted to ₱557 million in wage subsidies.
accounts, are
                       81.      According to the program guidelines, the SSS is responsible for informing
among the issues       the employers and employees of small businesses about the status of their
contributing to        payouts.37 After the DBP has processed the payment files corresponding to the
failure payouts in     payment methods, it must notify the SSS that they have been uploaded. The
remittance centers.    SSS will then prepare the text blasts table of employees with mobile numbers to
                       send notifications regarding the status of the SBWS Program payout and send
                       it to the Text Blast Service Provider. Text messages (SMS) were used to notify
                       qualified employee beneficiaries of the DBP’s release of their wage subsidy. The
                       SMS notice contains information regarding the status of the wage subsidy,
                       including whether it has been credited to the beneficiary’s bank or e-wallet
                       account or is available for pick-up at an authorized remittance center. The
                       message also provides the Transaction Reference Number and instructions on
                       how to claim the wage subsidy for beneficiaries who decide to pick up the
                       subsidy at an accredited remittance center.38
                       82.     A review of the disaggregated SBWS Program data revealed the
                       following: (a) beneficiaries without contact information/number; (b) beneficiaries
                       with reported mobile phone numbers containing invalid letters and special
                       characters. There were also invalid phone numbers lacking 11 digits and
                       containing prefixes of nonexistent networks included39; and (c) beneficiaries
                       shared identical contact information with other beneficiaries (see Figure 4).




                       _______________________________________________________________
                       37 Supra note 9, § IX (C.5.) p. 8
                       38 SSS Office Order 2020-049. p. 3.
                       39 Mobile Network Prefix is the first four digits of an 11-digit mobile number, e.g., 0912, 0913, etc.




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                                                      Small Business Wage Subsidy Program




        Figure 4: Beneficiaries with contact number issues as at June 20, 2022




        Source: COA Analysis

        83.    Analysis of the disaggregated data from SSS for the unclaimed wage
        subsidies revealed that 59,167 counts of unclaimed wage subsidies due to
        contact informations issues resulted in an unclaimed amount of ₱430 million.
        Meanwhile, 17,205 counts of wage subsidies with incorrect bank accounts
        resulted in ₱127 million unclaimed wage subsidies, as shown in Figure 5.


        Figure 5: Unclaimed Wage Subsidies Due to Invalid Contact Information
        and Incorrect Bank Accounts




                     23%
                                                         INVALID
                                                         CONTACT
₱557 Million                                             INFORMATIONS


                                                         INCORRECT
                                         77%             BANK
                                                         ACCOUNTS



        Source: COA Analysis

        84.   Given the frequency of missing, invalid, and duplicate phone numbers,
        text message notifications to employee beneficiaries would be challenging.


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Nevertheless, notification of a beneficiary’s application status is essential,
particularly for those elected to receive the wage subsidy through money
remittance centers.

85.     According to interviews with 11 out of 27 HR representatives of
participating small businesses, there were cases where neither emails nor text
messages were delivered to employers to inform them whether wage subsidies
were successfully credited, remitted, or claimed by employee beneficiaries.

86.     The beneficiary survey revealed that 47 percent, or 157 out of 335
respondents, did not get any information from the SSS regarding the status of
their wage subsidy. The respondents noted that some employee applicants (see
Figure 6) depended on their employer, co-employees, and frequent bank
account checks to determine the status of their application.

Figure 6: Manner of notification on Application Status to Beneficiaries




Source: COA Analysis

87.    Conversely, 54,454 employers did not have valid phone numbers, and
52 did not provide email addresses. As a result, these establishments can not
determine the status of the wage subsidy for their employees without contact
information, and many employers, particularly the HR representatives, became
dependent on the reports of their employees or co-employees from other
companies to monitor the wage subsidies.

88.    Upon evaluation by the SSS, the applications were classified into three
categories: qualified for the successful application, lacking credentials for
applications requiring additional information, and disqualified, as detailed in
Table 12 below.




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                                                   Small Business Wage Subsidy Program



Table 12: Beneficiary Classification/Status of Payout

       Qualified          Lacking Credentials                Disqualified
 Credit subsidy to       No Bank Details/invalid     Part    of    the    Skeletal
 bank account,           PESONET account             workforce or work from
 Paymaya, or M.                                      home, with a salary of more
 Lhuillier                                           than 15 days
                         Records with Shared         On any leave during the
                         Bank Account                pandemic (maternity, sick
                         details/Mobile number       leave, vacation, etc.)
                         Invalid Format of           Resigned during the period
                         mobile numbers for          when ECQ was being
                         Paymaya/ML payment          implemented
                         000 TIN or                  With Maternity Benefits,
                         invalid/incomplete TIN      Unemployment         Benefits
                                                     Claims, or SSS Final Claims

Source: COA Analysis

89.    Without the contact information, employers and employee beneficiaries
could not be apprised of the status of their applications. Without SSS notice,
concerned beneficiaries could not effect corrections or complete their
applications which were classified as “Lacking Credentials”.

90.     No concerns are associated to qualified employees who choose a bank
account as their payout option. In contrast, it is unclear whether employees with
qualified status who choose M Lhuillier as payout options can claim their salary
subsidy without notification of their reference number. Thus, as at April 30, 2020,
SSS reported ₱557 million in rejected/unsuccessful salary subsidies from banks
and M Lhuillier.

91.      SSS explained that invalid or incomplete data were transactions from
Excel files submitted through the SharePoint and Azure online application
methods. These are not real-time online filing; thus, data validation was done
after receipt of Excel files. To correct the erroneous data, employers were
notified and allowed to change their contact information using the post-
payout correction module. Upon receipt of the notice, the employer shall enroll a
valid bank account or mobile number of their employee recipient. If the
beneficiary selected MLhullier as the payout option, information for the mobile
number is needed. However, SSS had no database where to determine the
validity of the mobile number enrolled.

92.      Apparently, even if the concerned employers were notified of the
erroneous data and utilized the post-payout correction module to enroll a new
mobile number in the case of a money remittance center payout, SSS could not
verify the validity of the new mobile number provided by the employer.




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Return of wage          93.    Part of the program implementer’s initiative to recover wage subsidy
subsidies were not      granted to ineligible beneficiaries was through voluntary return. However, a
properly accounted      review of the voluntary returns revealed that there were unidentified deposits,
                        which amounted to ₱49.20 million.
for and reported
                        94.      Under the SPTF Resolution # 2, 5, and 9 on Voluntary Return of wage
                        subsidy procedures, employers and employees must return the subsidy granted
                        if they violate any of the eligibility requirements found in the program guidelines.
                        Therefore, the return of wage subsidy will either be the responsibility of
                        employers or employees, depending on the violation, as shown in Figure 7.


        Figure 7: Who is required to return the subsidy



                                                • Employers who fail to maintain
                                                  employment status of the
                                                  beneficiaries within SBWS period
                                                • Employers of employees who are
                                                  DOLE-CAMP beneficiaries who
                                                  received full amount of SBWS 2nd              Employer
                                                  tranche
          SBWS                                  • Misinterpretation in their application
                                                  the fact of payment of wages or any
           LBP                                    material fact relevant to the eligibility
          Return                                  requirement of their employees

         Account
                                                 • Employees-beneficiaries who
                                                   resigned when ECQ or MECQ is
                                                   imposed in the LGU or place of
                                                   business where his employer is             Employees
                                                   found
                                                 • Employees who received DSWD-
                                                   SAP-ESP



                        Source: SPTF Resolution #2

                        95.     As specified in the Employer’s Undertaking, the employer has certified
                        that all provided information is accurate and complete. Misinterpreting the
                        application will result in the employee’s disqualification, requiring the employer
                        to refund the subsidy. Employers or employees must voluntarily deposit the
                        amount subject to refund into BTr’s Land Bank of the Philippines (LBP) account,
                        which was established expressly for the SBWS Program wage subsidy return.
                        The employer or employee who submitted the return amount must email SSS
                        the deposit slip with a list of employees’ information and the reason for the return.
                        After receipt, SSS will reconcile and encode the amount to the SBWS Program
                        return module.




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96.    A review of wage subsidy return documents revealed that, as of July 5,
2021, the entire amount of voluntary return deposited to the BTr through the
designated LBP account was ₱504.20 million, including an unidentified deposit
of ₱49.20 million. The unidentifiable amount refunded resulted from deposits to
the account that lacked adequate disclosure of transactional information (see
Table 13).

Table 13: Breakdown of Voluntary Returns to BTr

                                            Number of
          Reason for Return                                              Amount
                                            Employees
 Misinterpretation                                     27,453               392,959,205
 Resignation                                               383                 5,806,757
 CAMP Beneficiary                                        9,926                51,475,606
 SAP Beneficiary                                           433                 3,886,500
 4Ps Beneficiary                                            70                   884,400
 Unidentified Deposit                                         -               49,200,000
 Total amount deposited to
                                                       38,265               504,200,000
 BTr

Source: SSS

97.    Thirty-eight thousand two hundred sixty-five (38,265) identified employee
beneficiaries deposited 90 percent or ₱455 million of the entire amount returned;
86 percent or ₱393 million out of ₱455 million was due to misrepresentation. Due
to the closing of DSWD, DOLE-CAMP, and LGUs’ subsidies, management
confirmed that there were voluntary returns for SAP, 4Ps, and other subsidies
issued by DSWD and LGUs that were deposited to the account of SBWS
Program. So, the reason for the ₱49.20 million deposit could not be ascertained,
nor could its nature be related to the SBWS Program funds.

98.     In addition, in one of the field validations, a comparison of the deposit
made by a company against the number of employees reported in the database,
disclosed that the deposit was not matched. We noticed that the return for
deposit slip of ₱1,104,00040 was recorded in the database as ₱1,040,000 with a
difference of ₱64,000, equivalent to four employees.41

99.    Proper monitoring and reporting of the program’s implementation are
essential to agencies’ accountability and transparency on whether the
appropriated funds were spent correctly for their intended purpose. In accounting
_______________________________________________________________
40 2nd SBWS Program walkthrough meeting
41 Establishment located in the NCR, wage subsidy amounted to ₱16,000 per employee for

tranche 1 and tranche 2


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                        for money and property received by public officials, P.D. No. 1445 stated that
                        except as may otherwise be expressly provided by law or competent authority,
                        all money and property officially received by a public officer in any capacity or
                        upon any occasion must be accounted for as government funds and government
                        property. Government property shall be taken up in the agency’s books at
                        acquisition cost or an appraised value.42 However, with the noted observations
                        on the unaccounted ₱64,000 deposit from the voluntary return, it is doubtful that
                        ₱455 million accounted for voluntary return was correctly recorded. And also, at
                        a certain point when post-implementation verification of beneficiaries will be
                        rolled-out, unaccounted voluntary returns will significantly impact its efficiency.

                        100. SSS confirmed the process of voluntary return and enumerated the
                        identified constraints during the reconciliation of deposits that caused the
                        unidentified ₱49.2 million. Accordingly, some employers or employees did not
                        submit deposit slips and details of the payments. Based on the bank statement,
                        there is no means by which SSS will know who is the employer or employee
                        responsible for the transaction. During the reconciliation process, there were
                        instances where no SSS numbers were indicated or the documentation was
                        incomplete. No reply to the request was made until the program's closing, the
                        amount deposited did not reconcile with the listing submitted, and no
                        explanation/reply was received from the employer or employee.

Procedures for          101. Examination of accomplishment reports, program guidelines, and issued
involuntary return of   policies disclosed that the program implementers had not initiated procedures
wage subsidy were       for involuntary return of wage subsidies.
not performed
                        102. The head of any agency is immediately and primarily responsible for the
                        funds and property that pertain to their agency.43 Therefore, the primary objective
                        of the program’s post-implementation mechanisms is to systematically track
                        implementation and outputs and evaluate the program’s effectiveness.

                        103. Further, it is worth highlighting that an SPTF Resolution was issued
                        authorizing the SSS to institute appropriate civil actions upon receipt of the
                        endorsement prepared by the SPTF containing its findings and recommendation
                        that there is a prima facie case or sufficient ground to proceed with the filing of
                        an action against a concerned employer or employee.44

                        104. The resolution for the involuntary return mechanism enumerates
                        instances when wage subsidies shall be refunded to the government following
                        the program guidelines. As such, the employer must return upon failure to
                        maintain the employment status of all employee beneficiaries before the ECQ
                        and other forms thereof and when the employer misrepresented their application.
                        In contrast, the employee, on the other hand, shall return the wage subsidy when


                        _______________________________________________________________
                        42 Presidential Decree No. 1445, § 63, p.19
                        43 Ibid, §102.1, p.27
                        44 SPTF Resolution No. 11, p3




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they resign during the ECQ period and other forms imposed in Luzon and other
parts of the country.45

105. However, a review of SBWS Program guidelines and SPTF resolutions
to determine the extent to which the agency monitors the program revealed that
program       implementers      did    not    appropriately     implement      post-
implementation mechanisms planned to identify ineligible beneficiaries. Further,
analysis of wage subsidy returns showed that wage subsidy refunds were
entirely voluntary. (see detailed discussion in return of wage subsidies were not
properly accounted for and reported, page 31). This demonstrates that SSS has
not yet instituted appropriate action, at least to the noted invalid TIN with a total
of 132,506 counts which resulted in ₱1.92 billion wage subsidy (see detailed
discussion in Inaccurate information caused the release of ₱1.92 billion wage
subsidies to ineligible employees, page 15). TINs identified were limited to 000-
000-000-000, duplicate, alphanumeric characters, and outdated or obsolete.

106. Moreover, a review of the budget allocated for the program’s
implementation showed that no funding was allocated for the program’s post-
implementation activities. About 99.6 percent, or ₱50.8 billion, of the entire
program budget of ₱51 billion was allocated only for the fiscal cost of the wage
subsidy. While the remaining ₱200 million was provided for administrative costs
associated with implementing the program.

107. In addition, the review of the latest SPTF resolution for the involuntary
return of wage subsidy disclosed that program implementers explicitly
transferred their fiscal responsibility by relying on the COA’s post-audit
procedures to identify ineligible beneficiaries without consulting the COA upon
the discovery that the employer or employee is deemed liable to return to the
government the amount of wage subsidy granted, or upon the discovery of fraud
by the DOF, SSS, or BIR. The SPTF will issue a demand letter for the return of
the said subsidy within 15 calendar days from receipt thereof with a warning that
failure to return will result in the filing of the appropriate criminal and/or civil
action.46 Hence, the post-implementation mechanism for the program or the
fiscal obligation of the program implementers has been shifted, with the COA’s
determination of disqualified beneficiaries serving as the basis for the decision
to return subsidies for the program.

108. SPTF established new measures to verify the beneficiaries’ eligibility
during the program’s implementation. The employer confirms through an
“Employer’s Undertaking” that each employee who has applied for the program
has met all eligibility requirements. Employers who mislead information pertinent
to the eligibility of their employees shall be held accountable and refunded the
amount of wage subsidies received.47


_______________________________________________________________
45 Supra Note 44, p.2
46 SPTF Resolution # 12, § V. Procedures for involuntary return, p. 5
47 Supra note 9, Item VI. General Guidelines, no. 4, p. 4.




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109. We observed that the management’s decision to depend on employer
undertakings without confirming other papers sped up the application process
but increased the potential of improper applicant payments.

110. On the other hand, we highlighted that the SSS’s automated application
system verifies whether or not employees are actively paying SSS members,
have no pending or settled SSS unemployment benefits, and have no pending
or in-process SSS final claims. In addition, the SSS’s automated system verifies
the correctness of all qualified employees’ credentials, such as bank accounts
and mobile phone numbers.48 This led SSS to reject the applications of 48,295
employees with invalid TINs, bank details, and unemployment claims with SSS
during the application phase (see Figure 8).


 Figure 8: Rejected or Unsuccessful Credits of Wage Subsidies to
 Beneficiaries’ Accounts




  Source: COA Analysis

111. A post-implementation mechanism is crucial to confirm that the desired
program result was achieved and could help identify ineligible employees who
should have returned the wage subsidy. This may have been determined during
program planning by examining the program’s susceptibility to inappropriate
payments. However, due to the short time available for program design, the DOF
admitted in response to our inquiry that they could not undertake a complete risk
assessment.

_______________________________________________________________
48 SSS Office Order No. 2020-026b, Annex B.1 Validation of Pre-Qualified Employers and

Employees. p. 11


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112. BIR Management commented that through the issuance of SPTF
Resolution No. 11, dated September 2, 2021, it was resolved that SSS is the
authorized agency to initiate the involuntary return of wage subsidy. It was
specified in the said resolution that SSS had already represented the Republic
of the Philippines concerning the beneficiaries of the SBWS Program, coupled
with the fact that SSS is privy to the information on the compliance by the
beneficiary employers and employees with the continuing qualifications outlined
in JMC No. 02-2020. Hence, the SSS is the proper and practical party to institute
a civil action to recover the subsidy.

113. Furthermore, the Legal Opinion issued by the Office of the Solicitor
General (OSG) dated November 11, 2020, states that, since the functions of the
SSS include the acceptance and processing of applications, determination of
eligibility for the wage subsidy, coordination with and disbursement of funds to
qualified employers and employees, the SSS represents the Republic as far as
the beneficiary employers and employees of the SBWS Program are concerned.
The OSG added that the SSS, as the representative of the Republic, is the
proper party to institute the appropriate action against the employer or employee
in case of failure to return the wage subsidy.

114. Lastly, the BIR, in its response/comment dated May 23, 2023, stated that
upon receipt of data submitted by the SSS on June 17, 2021, it has already fully
validated the TIN of both the employers and employees and will transmit the
results of the verification to the SPTF and SSS for appropriate action. As a result
of the post-implementation verification made to the TIN of the employees granted
the wage subsidy, the BIR has counted 384,726 TINs not found in the BIR
database.

115. It could be noted that this is an indication that wage subsidies were
granted to employees whose TINs were incorrectly encoded in the applications
and their correct information need to be validated to determine their eligibility to
the program. Further validation of the beneficiaries’ TIN with the BIR could not
be undertaken by the audit team due to the restrictions specified in the National
Internal Revenue Code on the confidentiality of taxpayers’ information.49




_______________________________________________________________
49 National Internal Revenue Code, Unlawful Divulgence of Trade Secrets, § 270




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After
implementation,
program
implementers
reported ₱6.7
billion of
unsuccessful
payout and
returned ₱5.7
billion to BTr
                     116. Implementing the SBWS Program as an early response to the
                     pandemic's adverse economic impact on the formal economy sector
                     necessitates meticulous planning. Because of the speed with which it was
                     implemented, there was insufficient data entry and acceptance of
                     erroneous and/or incorrect beneficiary information, which resulted in the
                     inability to distribute ₱6.7 billion in wage subsidies and the subsequent
                     return of ₱5.7 billion to the BTr.

                     117. The economic consequence of the pandemic in the formal economy
                     sector was unimaginable. Therefore, it was notable that the government
                     formulated a program to specifically intervene in the adverse economic impact
                     on the affected worker in the formal economy sector. With the aid of technology,
                     in just two and a half months, program implementers had served 91 percent of
                     the targeted beneficiaries. In addition to facilitating applicants’ access to the
                     program, it safeguards them from the possibility of COVID-19 infection.
                     However, the program’s implementation in a limited timeframe caused the
                     underutilization of the funds released for the program.

₱5.7 billion funds   118. As at February 15, 2022, SSS had returned to the BTr unutilized SBWS
for the program      Program funds totaling ₱5.7 billion, including interest earnings totaling ₱2.8
were returned to     million (Figure 9). Accordingly, as the Bayanihan Act 1 requires, the government
                     allocated ₱51 billion to the SBWS Program to provide wage subsidies to the 3.4
BTr
                     million affected employees in the formal sector until June 25, 2020.




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Figure 9: Program Budget Utilization




Source: SBWS Program Liquidation Report (2022, April 30)


119. Instead of distributing the unused fund for the SBWS Program, the SPTF
returned the fund to BTr. The DOF explained that the program was not extended
nor reopened, and the ₱5.7 billion in unused funds were returned to the BTr
because the program was intended to provide immediate relief to affected small
business employers and their employees when ECQ and modified ECQ (MECQ)
were imposed from March 17 to May 31, 2020.

120. Examination of the program’s utilization report disclosed rejected or
unsuccessful payouts of ₱6.7 billion, as shown in Table 14.

Table 14: Amount Rejected/Unsuccessful as at April 30, 2022

          Payout Option                      Amount
 PESOnet                                         ₱6,159,019,500
 M Lhuillier                                        440,023,500
 PayMaya                                             92,191,000
 TOTAL                                           ₱6,691,234,000

Source: SSS

121. The ₱5.7 billion returned fund may have been used to give subsidies to
additional employee beneficiaries if other issues impacting the program’s
operation, such as time and physical resources, were considered in the
implementation. In a conservative estimate, assuming that the unutilized fund
will be distributed to non-CAMP beneficiaries who reside in regions with the
highest wage subsidy of ₱8,000 per tranche, the fund could have covered an


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                    additional 354,757 employees from affected small businesses, which would have
                    been sufficient to cover the program’s overall target beneficiaries. (see Table 15)

                    Table 15: Estimated Number of employees that can benefit from the
                    returned amount

                     SBWS Program Fund returned to BTr                                 ₱5,676,124,170.22
                     Divide: Maximum Grant for two tranches                                       16,000
                     Additional employees that could benefit from                               354,757
                     SBWS Program

                    Source: COA Analysis

                    122. As part of the BIR’s responsibilities, the program guidelines offered a
                    system to ensure that all affected employers are considered during pre-
                    qualification. In response to a separate inquiry to the BIR regarding employers
                    who requested to be placed on the list of pre-qualified employers, it was revealed
                    that the BIR received 23,561 requests from these employers. Still, only 805 were
                    approved due to budgetary constraints. The BIR indicated that the SPTF did not
                    want to overcommit to these employees; hence, it was reasonable to decline
                    their applications.

                    123. SSS explained that the rejected/unsuccessful payouts were not
                    reprocessed due to the unavailability of data from DBP before the due date of
                    liquidation.

₱6.7 Billion wage   124. One of the factors contributing to the underutilization of the wage
subsidy payouts     subsidies fund was the rejection or failure of ₱6.7 billion in payouts. Instead of
not successfully    utilizing the fund through the SBWS Program, the SPTF returned ₱5.7 billion to
                    the BTr, which could have provided wage subsidies to an extra 354,757 affected
received by
                    employees.
intended
beneficiaries       125. During pre-payout, SSS will email qualified employees with invalid or
                    duplicate bank accounts and mobile phone numbers. The employer must access
                    the application system on the program website to amend the details of affected
                    employees and resubmit the application along with the Employer’s Undertaking
                    upon receiving notification from the SSS. The SSS shall then reprocess the
                    application as it would with new applicants.50

                    126. During the distribution of wage subsidies, there have been instances of
                    unsuccessful crediting due to invalid bank accounts and mobile phone numbers
                    that were not identified during application processing. Thus, the affected
                    employees will not receive the wage subsidy. In this instance, the SSS will notify
                    the employer through email of the noted issue. The employer must then use the

                    _______________________________________________________________
                    50 Supra note 44, Annex A.3 Detailed Procedures on the Handling of Exception Cases for SBWS

                    Program. p. 3


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My.SSS website to access the Post-Payment Data Correction Module. With
the updated undertaking, the employer must supply the concerned worker’s
corrected bank information or mobile phone number. Finally, SSS will conduct
the corrections, produce the summary disbursement report on the post-payment
correction module, and send the report to the SPTF.51

127. In cases of non-receipt of the Reference Number, the SSS shall review
the complaints and conduct identity verification upon receipt of the appeal from
the involved employers. The affected employer will receive an email to correct
or update the worker’s details if validated. After correcting the information, SSS
will resend the required reference number to claim the wage subsidy.52

128. Regarding the missed opportunity, we analyzed the factors influencing
the unsuccessful payouts worth ₱6.7 billion (see the detailed discussion ₱5.7
billion funds for the program were returned to BTr, page 37). Unfortunately, the
SPTF Board returned the remaining funds rather than extend the program’s
implementation. However, if they had been accommodated into the program by
extending the payout period instead of returning the program fund to the BTr,
more beneficiaries would have benefited from the program.

129. We reviewed approximately four percent of the SBWS Program database
for unsuccessful distributions. As a result, we observed that, despite the
corrective procedures established, there were 78,221 beneficiaries with
unsuccessful wage subsidy payout totaling ₱571 million due to the various
reasons detailed in Table 16.

Table 16: Unsuccessful Payout based on SBWS Program Database
       Reason for                                              The total amount not
                                      No. of Beneficiaries
   Unsuccessful Credit                                               credited
 Incorrect Bank                             17,205                     ₱ 127,835,000
 Account
 Unclaimed ML Payout                        59,167                         429,417,000
 Closed Account                              1,213                            9,478,500
 With Restrictions                            50                                372,000
 Canceled Transaction                         127                               952,500
 by SSS
 Credited To Not                              440                             3,041,500
 Credited
 Account Differs from                         11                                 88,000
 Payee Name
 Dollar Account                                4                                 32,000


_______________________________________________________________
51 Supra note 29, Payouts
52 Supra note 49, Annex A.3. p. 16.




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      Reason for                                          The total amount not
                               No. of Beneficiaries
  Unsuccessful Credit                                           credited
 No Existing Account                     4                               32,000

 TOTAL                                78,221                        ₱571,248,500


Source: COA Analysis

130. A review of the program guidelines and issued resolutions indicated that
most of SSS’s procedures were predicated on the assumption that SSS and
employers would communicate effectively. For example, SSS will notify
employers of any problems identified with the credentials of beneficiaries, and
employers will notify SSS if wage subsidies are being claimed incorrectly.
However, SSS also had difficulty contacting employers and responding to
questions and concerns, which impeded updating bank accounts and mobile
phone numbers. One of the factors that hampered the anticipated correction
procedures during the pre-payout phase was the allotted time for employers to
make corrections. Particularly for beneficiaries who elected to receive the wage
subsidy through a money transfer facility, employers are given three days upon
receipt of instruction from SSS to rectify the information.53

131. A review of the SBWS Program database also showed that
20 worker beneficiaries did not receive the second tranche. According to the
program’s guidelines, it is possible that some beneficiaries will not get the second
tranche. This is the case when the beneficiary resides in a region with a wage
subsidy rate over ₱5,000, and the worker is also a DOLE-CAMP 1 beneficiary.
Nevertheless, the needed field in the SBWS Program database is empty, so
whether these beneficiaries are also CAMP beneficiaries is unknown. One of the
20 beneficiaries was marked with an invalid bank account, and another was
marked as an Unclaimed ML Payout. SSS explained that six of the
20 beneficiaries were discovered to have two separate SSS Reference Numbers
but were the same person. SSS further noted that the beneficiaries were
ineligible for the second tranche to prevent duplication of subsidies. While the
remaining 14 beneficiaries were discovered to have received unemployment
benefits and final claims, they were deemed ineligible. Even though these 14
beneficiaries were disqualified, the SSS did not send a demand letter for the
return of the wage subsidy; instead, they were only excluded from receiving their
second tranche of subsidy.

132. Based on the generated disbursement report from the SBWS Program
reporting website (sbws.sss.gov.ph) accessed from the SSS account of the
employers, we found that more than 300 employees did not receive their second
tranche. The following were cited as reasons for these unclaimed and unpaid
subsidies based on interviews and surveys with employers and employee
beneficiaries:
_______________________________________________________________
53Supra note 32




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    1. Lockdown restriction, thus, cannot claim in Money Remittance Center (M.
       Lhuillier claim).
    2. CAMP-subsidy recipient and choose not to claim.
    3. Employers’ queries were unanswered (for resending of reference
       number).

133. It is not clear whether the reports posted online were updated. Therefore,
a separate audit query was issued to determine the purpose of the online reports
accessible to employers and whether or not the data accessible to program
beneficiaries was integrated into the SBWS Program database. Nevertheless,
there was no response from SSS Management.

Figure 10: SBWS Program Queries




Source: SPTF Updates Meetings


134. Out of 724,081 queries, 63 percent or 453,548 were answered by
program implementers, while 270,533 remained unanswered and to mitigate this
issue, canned responses and frequently asked questions were issued and
published on the program’s primary media outlet (SBWS Program google drive,
Facebook pages) as shown in Figure 10 above.

135. SSS         Management       commented       that   the   recording     of
rejected/unsuccessful payouts was based only on the SOA data due to the
unavailability of complete reports (Inward Files from the DBP). As of April 26,
2023, SSS still awaits the necessary Inward Files from the DBP to complete the
analysis and reconciliation process. However, based on the email provided by
DBP, a review of the email exchanges between SSS and DBP provided, it was
observed that DBP claimed that the inward files requested by SSS were already
sent to SSS SFTP on October 29, 2021.

136. If SSS completes the analysis and reconciliation process using the
inward files from DBP on October 29, 2021, still grant of a wage subsidy to the
beneficiaries for the ₱6.7 billion rejected/unsuccessful would be possible. Given


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the fact that, firstly, the SPTF Resolution No. 8 dated August 14, 2020, which
covers the extension of the payout period after June 25, 2020, was applicable
only for beneficiaries who did not receive Tranche 2 wage subsidy and secondly,
the remaining fund of the program was fully returned to the BTr on February 15,
2022.

137. Moving forward, the risk of reoccurrence of pandemic and other national
health emergencies is generally accepted that may result to adoption or
implementation of similar financial relief programs. Taking into account the
lessons learned from the implementation of SBWS Program that heavily relied
to the inputs from the applicants, additional measures such as utilization of
government’s national database could be a source for a reliable and accurate
information to specifically target beneficiaries. As for payout options, to at least
prevent the unsuccessful claims of subsidy due to incorrect bank accounts and
invalid contact information, program implementers may capitalize the use of SSS
UMID ATM card and also the database resulting from the implementation of
Subscribers Identity Manual (SIM) Registration Law.




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Conclusions    138. The SBWS Program aims to provide wage subsidy for two months to
               employees in the formal economy sector who were unable to work due to the
               temporary closure of businesses affected by the ECQ or other forms of
               quarantine in response to the COVID-19 public health emergency. Considering
               the risk of COVID-19 infection and the program’s overarching purpose of
               providing immediate assistance to impacted employees, the program
               implementer’s decision to employ technology was prudent.

               139. The online application system has facilitated the grant of wage subsidies
               to the target employees from the small business in the formal economy sector.
               Given the time constraints associated in its implementation, the program was
               able to distribute wage subsidies aggregating to ₱45.1 billion within three months
               out of the ₱51 billion budget. The program has served 3.1 million out of the target
               3.4 million employees.

                140. In spite of the program accomplishment, its implementation encountered
                challenges impacting on program’s effectiveness and efficiency. The program
                was not able to achieve its target number of employees from the small
                businesses in the formal economy sector. Out of the 1,768,413 target
                beneficiary from the non-essential business (Category A), only 1,050,971
                benefited from the program leaving 717,442 employees or 41 percent of the
                target employees not served. On the other hand, target of 1,638,637 employees
                under quasi-essential businesses (Category B) exceeded by 412,077
                beneficiaries. It was also notable that employees affected by the pandemic
                classified as Category C: Essentials were not covered by the program. SSS
                confirmed that one of the factors affecting the attainment of the target in the
                non-essential category was information dissemination.

                141. There were gaps and limitations noted in the online application system
                particularly in data entry, verification process and payout process causing delay
                in the processing and payment of wage subsidy. The employees’ name, TIN,
                bank account and mobile number encoded by the employers were considered
                final and there were no procedures to validate them. As a result, the system was
                able to capture incorrect and incomplete information. Later, correction
                procedures were instituted but could not accommodate all corrections due to
                limited time. The absence of reliable databases of program beneficiaries also
                caused incorrect tagging in the processing of applications. These gaps and
                limitations caused the distribution of ₱1.92 billion to 132,506 beneficiaries with
                duplicate or invalid TINs. The incomplete and invalid information also resulted in
                unclaimed payouts for 77,167 and 17,205 beneficiaries in remittance centers and
                bank accounts, respectively. Moreover, delayed and unsuccessful release of
                payouts defeats the objective of providing immediate relief to intended employee
                beneficiaries.

                142. The lack of effective monitoring and reporting mechanisms compromises
                accountability and transparency in properly using government funds. There were
                improper payments that the program implementers should have rectified.



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  Management relied on Employers’ Undertaking and self-attestation to check
  employees’ eligibility for the program and recover any potential erroneous
  payments. Additionally, implementers relied on COA’s post-audit to identify
  ineligible beneficiaries. And due to the inadequate post-implementation
  mechanism, recovery of wage subsidy payments to ineligible beneficiaries would
  be difficult.

  143. In addition, the program’s bank account for voluntary returns from ineligible
  SBWS program beneficiaries includes deposits from other programs such as
  SAP, 4Ps, and CAMP rendering unreliable accounting of voluntary returns for
  the program.

  144. Lastly, the implementation challenges and the limited timeframe to
  implement the program coupled with the rejection and failure of ₱6.7 payouts,
  which were not reprocessed, caused the SPTF Board to return the unutilized
  fund of ₱5.7 billion to the Bureau of Treasury. The unutilized fund could have
  covered at least 350,757 employees from the affected small business under the
  formal economy sector.




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Recommendations     145. While the program’s implementation has ceased, the same wage subsidy
                    program for the workers in the formal economy sector may be adopted in future
                    health emergencies and pandemic with the same responsible agencies.
                    Considering the lessons learned from the implementation of the SBWS Program
                    during the COVID-19 pandemic, an enhanced program can be formulated. In line
                    with the principles of efficiency, economy, and effectiveness, we recommend
                    measures that can be considered by the SSS in coordination with DOF and BIR:

                      a) During the planning phase of the program, there is a need to conduct risk
                         assessment to identify risks and problems and thereafter develop
                         appropriate strategies and mitigating measures through a work plan to
                         ensure that implementation is carried out in accordance with the timeline
                         and objectives of the program. To maximize utilization of fund allocation
                         and ensure that all affected employees receive equal opportunities to avail
                         of the wage subsidy program, the identification process and criteria used
                         in the SBWS Program need to be revisited and improved;

                      b) The system used in the SBWS Program be enhanced by considering,
                         among others, additional features relating to preventive validation controls
                         on data entry required for the application, processing and payout of wage
                         subsidies. The specific controls should include efficient capture and
                         validation of TIN and completeness of required information. The use of the
                         national ID system and SIM may facilitate the verification of program
                         beneficiaries while the use of SSS UMID ATM cards may prevent payments
                         to ineligible beneficiaries and/or invalid accounts. In addition, data sharing
                         from compatible program databases may need to be considered for
                         efficient and effective validation of applicants in accordance with program
                         guidelines;

                      c) There should also be a reliable and accessible mechanism for beneficiaries
                         to verify the status of their applications and payouts so that any deficiency
                         can be readily addressed;

                      d) There is also a need to formulate and implement a robust information
                         campaign for effective dissemination of program materials and
                         announcements to avoid misunderstanding and misappreciation of
                         information and instructions to employers and employees. This information
                         campaign along with improved process on return of wage subsidy will
                         ensure efficient, appropriate and correct accounting of return of subsidies
                         inadvertently provided to the beneficiaries; and

                    146. In the meantime, to ensure that program funds have been utilized in
                    accordance with the program guidelines and objectives, the SSS in coordination
                    with BIR and DOF should:

                            a)   Identify the ineligible beneficiaries from those with duplicate/invalid
                                 TINs or whose TINs were not found in the BIR Database; and



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          b)   Take appropriate steps to recover wage subsidies granted to
               ineligible beneficiaries.




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Agency       The Management of SSS, DOF, and BIR submitted their comments on the
             Report. Their comments were considered, as appropriate, in this Report.
Comments
             Contact points for our Performance Audit Office may be found on the last page
             of this Report. In addition, significant contributors to this report are listed in
             Appendix VI.

             In addition, the Report will be available at the COA website, which can be
             found at https://www.coa.gov.ph.




             MICHAEL L. RACELIS
             Director IV
             Performance Audit Office
             Special Services Sector




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Appendix I: Objectives,
Scope and Methodology


                  COA conducted performance audits to help government agencies better perform
                  their mandate and achieve program goals and objectives more economically,
                  efficiently, and effectively. It identified the SBWS Program to be audited
                  considering its materiality and significance being one of the social amelioration
                  programs to mitigate the socio-economic impact of the COVID-19 health crisis.
                  The audit aimed to determine: (1) the goals and objectives of the financial
                  assistance/wage subsidy program implemented by SBWS for the formal
                  economy sector; (2) the challenges encountered impacting the efficient and
                  timely implementation of the program; and (3) the extent the implementing
                  agencies ensure proper administration of the financial assistance/wage subsidy
                  program.

                  To determine the goals and objectives of the financial assistance/wage subsidy
                  program implemented by the tri-agency BIR, DOF, and SSS for the formal
                  economy sector, desk reviews were conducted on relevant laws, policies, rules,
                  and regulations related to the SBWS program. These include documentation of
                  the target number of beneficiaries, budget allocation, budget utilization and
                  distribution, and SBWS program accomplishments regarding the number of
                  beneficiaries who benefitted from the program. In addition, the alignment of
                  SPTF-issued guidelines with the implementation of the SBWS program to
                  relevant laws, policies, rules, and regulations was also reviewed to determine
                  whether the objective of the program as economic relief to mitigate the adverse
                  socio-economic impact of the COVID-19 pandemic was observed and target
                  beneficiaries were prioritized.

                  To determine the challenges encountered impacting the efficient and timely
                  implementation of the program and the extent, the implementing agencies
                  ensure proper administration of the financial assistance program, the team
                  performed walkthrough procedures to review the existing controls/mechanisms
                  in place in processing the applications, which involves the receipt, initial
                  evaluation, final evaluation/review, and release of financial assistance to payout
                  centers/money remittance service providers. The team also conducted
                  interviews and administered questions to BIR, DOF, and SSS Management to
                  determine their planning, coordinating the monitoring, and reporting processes
                  related to the implementation of the SBWS program. The team also conducted
                  meetings and briefings with the tri-agency regarding program implementations,
                  program walkthrough process, and review of program guidelines to determine
                  each agency’s respective roles and responsibilities. In addition, the team
                  analyzed data regarding SBWS program beneficiaries provided by SSS and a
                  pre-qualified list from BIR. Finally, the team analyzed financial assistance
                  evaluation completion data and payout distribution.

                  Further, the team reviewed data-sharing agreements, joint memorandum
                  circulars, joint resolutions, and advisories relevant to implementing the SBWS
                  program. The team also analyzed and compared the data from DOLE-CAMP 1

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 Appendix I: Objectives, Scope and Methodology




beneficiaries to determine duplication and incorrect tagging of program
beneficiaries. Moreover, the team administered survey questions to selected
private establishments/applicants and employees/beneficiaries to assess the
level of their awareness of the program, and the challenges they had
encountered in the course of application, communication with the implementers,
tracking the status of the application, and receiving the financial assistance.

The audit was conducted from June 2021 to June 2022. Given the limitations on
travels posed by the localized community quarantine impositions and health
protocols in 2021, in-person interviews, audit fieldwork, and validations were
restricted. As an alternative, most of the audit activities were done using
electronic means. The supposed deadline of the audit execution in January 2022
was extended for three months or until April 2022 excluding the report writing
process. In view of the relaxed protocols in 2022, the team was allowed to use
the audit period extension to conduct audit fieldwork and validation on four
selected Regions, namely NCR, Regions III, VII, and XI. The selected provinces
were Bulacan, Pampanga, Cebu City, Davao City, and Davao del Norte. The
audit fieldwork and validation are comprised of interviews with HR/employers on
the process of applications to the program and administration of survey
questions to private establishments and their employees, who they had applied
for, and become beneficiaries of SBWS.

We visited beneficiaries from the country’s three island groups: Luzon, Visayas,
and Mindanao. Region III for Luzon, Region VII for Visayas and Region XI for
Mindanao. NCR was also included, considering it is the center of the COVID-19
pandemic and the most affected region economically. In addition, samples
selected from Quezon City processed employers/applicants and
employees/beneficiaries were the subjects of the pilot survey. The team also
conducted CAMP-DOLE beneficiary matching based on the data available for
both programs.

The audit followed the Standard for Performance Auditing embodied in the ISSAI
3000. The standard requires that we plan and perform the audit to obtain
sufficient and appropriate evidence to provide a reasonable basis for our findings
and conclusions based on our audit objectives. We believe the evidence
obtained provides a reasonable basis for our findings and conclusions based on
our audit objectives.




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 Appendix II: Application System
 Developed for the Program


                                    Method 1 My.SSS Portal54
                                    The first method of application is thru My.SSS portal. The technical experts make
                                    this from application systems development from the ITMG team. The first step is
                                    for the employer to log in to the SBWS portal through the SSS website
                                    (www.sss.gov.ph) using the login account of the employer’s SSS account and the
                                    passcode sent by BIR to the pre-qualified employers. The employer is the one
                                    responsible for encoding the details of employees thru the application system of
                                    SSS (My.SSS Portal). They must input the TIN, mobile number, bank account
                                    number, and other details for the application to proceed. If an employee is not
                                    listed in the SSS list, it may be because (1) the Employee is not yet registered in
                                    My.SSS facility, (2) is disqualified, and (3) lacks information in My.SSS account.
                                    The employer can only confirm the name of the employees listed in the SSS
                                    application system to be included as program beneficiaries.

                                    Method 2 E-form Submission via Secure link55
                                    The 2nd application method is E-form submission through a secure site
                                    (SharePoint). Again, eligible employers were sent a secure email link. Through
                                    this method, the employer receives the email link SSS sent to all pre-qualified
                                    employers on the SSS file. Thru this link, the employer will sign in using their
                                    Microsoft account to log in to the system; if they don’t have a Microsoft account,
                                    they should create one before accessing the link. The next step is for the
                                    employer to encode all the details of its employees applying for the program.
                                    Finally, the employer must sign the electronic undertaking before applying. This
                                    application does not require any BIR-issued passcode given for the employer to
                                    access. You only need the link for the employers to access. Also, you can only
                                    use this method once; subsequent submission is not allowed per employer
                                    account. Once the employer applies, SSS shall process the application and will
                                    update via email on its status.

                                    Method 3: Microsoft Excel file upload to SBWS Portal56
                                    In this method, the employer can download the Excel template and then encode
                                    the list of employees’ data offline before finally uploading the file online. It was
                                    also noted that on this method, you could only submit it once, and no amendments
                                    or edits are allowed using this method. Any request for amendments shall be
                                    made through the My.SSS facility. The file template should not exceed 10 Mb file
                                    size per upload.




_______________________________________________________________
54 Small Business Wage Subsidy (SBWS) Program, Procedure for My.SSS Portal
55 Alternative application guidelines and procedures for small business wage subsidy (SBWS Program) method 2
56 Application guidelines and procedures for Small Business Wage Subsidy (SBWS) Program: File upload

through secure site (Microsoft Excel file upload to https://sbws.sss.gov.ph)

                                   Page 51
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                                                                           Small Business Wage Subsidy Program



Appendix III: SBWS Program Key
Implementers




      Department of Finance           Bureau of Internal Revenue             Social Security System

 •Provides Policy and technical      •Generate List of Pre-qualified      •Process program application
  guidance to the program             Small Business Employers and        •Create secure online platform
 •Match the DOLE-CAMP                 notify them thru email or            for the application of SBWS
  beneficiaries with SBWS             posting in BIR website              •Handle subsidy payout and
  Program-beneficiaries              •Provide list of Pre-qualified        notification to
 •Monitor, study the impact and       Business to SSS                      employer/employees
  report the progress of the         •Answer queries and requests         •Submit daily report to the
  program to the President of the     from employers for pre-              SBWS Program task force on
  Philippines                         qualification                        the figures and status of
                                     •Monitor and report the progress      applications of employees to
                                      to the SBWS Program task             the program
                                      force




The SPTF mainly handled the SBWS Program, consisting of various DOF, BIR, and SSS officers. They
address issues relating to policy, the application process, payout distribution, other related queries, and
concerns about the program.




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                                                                                PAO-2023-03
                                                                                Small Business Wage Subsidy Program




Appendix IV: SBWS Program Process Flow




           •BIR create list of pre-qualified small business employer and send them notification thru
            email or publish the list of qualified employers in BIR website
           •BIR send the list of pre-qualified small business employer to SSS
  BIR      •Process SBWS program appeals
           •




           • Qualified small business employers apply online through using any of the 3 methods provided by SSS
             (My.SSS, Sharepoint, Azure)
           • Confirm the names of qualified employees and provide their details online (TIN, bank account, mobile
 Small       number)
Business   • Once completed employers need to sign the undertaking online and submit the application to SSS
Employer



           •Cross matching of DOLE-CAMP beneficiaries to avoid deduplication of subsidy and
            send results to SSS
           •Approve Payout of Validated SBWS Program applications and send endorsement to
 DOF        SSS-SBWS taskforce thru email




           • Process the application of qualified business employer and remits the subsidy to approved employees to
             their respective disbursement account (PESONET banks,Paymaya or M. Lhuillier)
           • Send electronic notification to employees when subsidy is credited to their respectives accounts

SSS          (PESONET Banks, Paymaya, M Lhuilier).




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                                                                                              PAO-2023-03
                                    Small Business Wage Subsidy Program


Appendix V: Result of Survey on
Employer of Program Beneficiaries




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                                                 PAO-2023-03
                                                                     Small Business Wage Subsidy Program


Appendix VI: COA Contact
and Staff Acknowledgments


COA Contact       Michael L. Racelis (Director IV),
                  (02) 8952-5700 local 2022 or mlracelis@coa.gov.ph; pao@coa.gov.ph

                  Dondon P. Marcos (OIC Director III),
                  (02) 8952-5700 local 2033 or dondonmarcos.coa@gmail.com



Staff             Directors Michael L. Racelis and Roberto D. Mabagos, Jr. provided technical
                  assistance from planning the audit to developing the report. OIC Director III
Acknowledgments   Dondon P. Marcos provided support in developing and reviewing the report. In
                  addition, State Auditors Ruby L. Caballes (Team Supervisor), Policarpo L. Silva Jr.
                  (Team Leader), Charmaine L. Chua (Team Member), Mark Anthony G. Cabuco
                  (Team Member), Gerverlyn Mila (Team Member), Lester M. Camaso (Team
                  Member), conducted the audit and made key contributions to this report. And,
                  Mariann U. Ceripulo (Independent Referencer) performed referencing on the audit
                  report.

                  Assistant Commissioner Alexander B. Juliano provided invaluable inputs in
                  finalizing the Report.




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