Backflow Testing Billing: Annual Tests, Reminders and Autopay

On this page 7 sections

1. Track Due Dates by Device, Not by Customer
2. The Card-on-File Rules Behind Backflow Testing Billing
3. When to Charge: At Booking, at Completion or After Filing
4. Worked Example: Three Assemblies, One Failed Test
5. Invoicing Commercial Sites and Property Portfolios
6. Failed Tests: Bill the Test, Quote the Repair Separately
7. Start With the Devices Due in the Next 90 Days

Key takeaways

• If you store a card for next year's test, Visa and Mastercard require consent that is separate from your general terms. The agreement has to cover the last four digits, how charges work, how changes are announced, how to cancel and when it ends.
• An annual test charged "on the test date at our current rate" may not count as a recurring charge. Ask your processor which indicator your gateway sends, and word the agreement to match.
• Never charge a repair to a card stored for annual testing. Keep the test invoice and the repair invoice separate, and get written approval for the repair.

Backflow testing billing works best when you treat every test assembly as its own recurring account. Record the due date the water purveyor sets for each device. At the first test, get card-on-file consent that meets Visa and Mastercard's stored-credential rules. After that, charge the stored card when each year's test is done, and put any repair on a separate invoice that the customer approves separately.

You don't have to chase this work. The district's cross-connection control program sends the customer a notice, so the customer isn't deciding whether to test, only who does it. Each water purveyor sets its own testing interval, report format and filing fee under state rules, and annual testing is the usual schedule. Check current requirements with every district you file with. This article is general information, not legal or tax advice.

Track Due Dates by Device, Not by Customer

A commercial property with three assemblies has three due dates. They drift apart once one device is replaced or retested off-cycle. A single spring push also stops working once you file in more than one district, because each district sets its own deadlines, notice timing and filing method. So build the record at the device level.

Backflow testing software, a field service platform or a well-kept spreadsheet can all hold these fields. Whichever you use, never type a full card number into notes or job records. Save cards only through your payment gateway, which replaces the number with a token. Your own systems then never hold card data, and fewer of them fall under PCI DSS.

Count Reminders Back From the District Due Date

This schedule is an example. Adjust it to each district's notice period and how far ahead your crew is booked.

1. 60 days out: Text or email the price and a booking link.
2. 45 days out: Give stored-card customers advance notice of the charge. Send everyone else an invoice or a link to save a card.
3. 30 days out: Call anyone who hasn't booked, and get commercial PO numbers now.
4. 14 days out: Send a final reminder that cites the district deadline and the consequence the district's own notice describes.
5. After the test: Send the receipt and filed report, and log next year's due date.

If you sell service plans, the same device records and reminders can feed monthly member billing for plumbing maintenance agreements.

The Card-on-File Rules Behind Backflow Testing Billing

When you save a card at this year's test to charge next year, the card networks call it a stored credential. Visa tightened its consent rules for stored credentials under its Stored Credential Transaction Framework, effective October 14, 2017, and Mastercard has similar requirements. These are network rules, enforced through your processor, and your merchant agreement can add requirements on top of them.

Under Visa's rules, the cardholder must give express, informed consent to an agreement before the first transaction. That agreement has to be shown separately from your general terms and conditions. You keep it for as long as it is in effect and produce it if Visa or the card issuer asks. The Merchant Advisory Group and Chargeback Gurus both summarize what the agreement must include:

• a truncated card number, such as the last four digits
• how and under what conditions you will use the card
• how you will tell the customer about changes
• how the customer cancels, and when the agreement expires

Stop charging the card once the customer cancels, the end date passes or the customer asks to pay another way. If the first authorization or account verification is declined, Visa's rules say you cannot store the card at all. Visa's full details are in its guide Improving Authorization Management for Transactions with Stored Credentials, which you can get through your processor.

Recurring vs. Unscheduled: Match the Label to Your Agreement

This distinction is easy to miss. Visa sorts merchant-initiated charges, the ones you start without the customer present, into types that include recurring, installment and unscheduled credential-on-file. Your gateway tags every charge with one of them. An annual test fee feels recurring. But if the charge date moves with the day your tech gets on site, and the amount is "our current rate," the charge doesn't follow a fixed recurring pattern. TFSF Ventures' analysis of Visa's rules notes that an agreement allowing only recurring charges does not cover unscheduled ones. Ask your processor which label your gateway sends for annual test charges, and word your authorization to match.

Example authorization language (have your attorney review it): "I authorize [Company] to store my card ending in [last four] and charge it for the annual backflow test of the device(s) listed above, at [Company]'s published rate in effect on the test date, on the date each test is completed. Test dates will vary from year to year. [Company] will notify me by email or text at least [X] days before each test, and in the same way of any change to these terms. This authorization lasts until [date] or until I cancel in writing, whichever comes first. Repairs, parts and retests require my separate approval."

Collect a signature or checkbox that is separate from your general terms. Timestamp it and attach it to the device record. If a customer later says they never agreed, that record is your evidence. Our guide to chargebacks for services rendered explains what else issuers look for.

Capture the Card on Site, Charge It Later as Card-Not-Present

Store the card at the first test, while the customer is standing there. They tap or insert it on a device like the Clover Flex Pocket or another of our handheld terminals for field crews, and the tech captures consent on screen. Our roundup of credit card readers for plumbers who get paid at the truck compares the hardware.

Next year's charge runs against the stored token with no card present. It goes through a virtual terminal or a payment gateway. Before you rely on either one for annual charges, ask whether it supports scheduled or stored-card billing and whether it lets you set the transaction label. Card-not-present sales carry higher interchange than tapped or inserted ones, and our explainer on why online and keyed transactions cost more to process shows why. If an office manager reads you a card over the phone instead, follow the steps for taking card payments by phone safely.

In the 12 months between tests, cards expire and get reissued. Ask your processor whether an account updater service is available. Send the 45-day notice early enough to collect a new card before test day.

When to Charge: At Booking, at Completion or After Filing

Charging at completion and filing the same day is the best fit for most testers. The charge lines up with the service the customer authorized, and filing becomes part of what they paid for. Prepaying looks safer until a locked meter box turns into a refund and a second trip. Our article on plumber service call fees when customers decline work covers how to tell customers about a trip charge up front.

Some districts charge a filing fee for each report, often through an online portal. If you pass it on, list it as its own line with the district's name, which makes the fee easy for the customer to verify. Sales tax on test fees depends on your state, so check how states tax plumbing labor, repairs and parts and ask your tax advisor. Charging a fee for paying by card is a separate question, and both card network rules and state law apply. Read whether plumbers can charge a credit card fee on invoices, then compare surcharging where permitted with dual pricing.

Worked Example: Three Assemblies, One Failed Test

Every number here is invented for illustration and is not a market rate. Assume a strip-center landlord has three assemblies in one district and signed the authorization above at last year's test. The district charges $10 per filed report. Your published rates are $95 for a 2-inch RP, $125 for a 4-inch DCVA and $75 for a 1-inch PVB. On test day the RP and PVB pass, and the DCVA on the fire line fails.

The landlord pays $715 in total, but the annual-test authorization covers only $325 of it. Charge the full $715 to the stored card and $390 has no consent behind it. In a dispute, that is the part you are likely to lose, because you have no consent to show for it. If you split the charges and get the repair approved in writing, you have documented consent behind both invoices. Districts differ on whether they charge for both the failed report and the passing one, so check the fee schedule.

Invoicing Commercial Sites and Property Portfolios

A restaurant has an assembly on the domestic line and others on soda or ice equipment. Schools and apartment complexes add irrigation and fire lines, and a property manager may have dozens of sites across several districts. Accounts payable checks your invoice against its own equipment list. So give each device its own line with type, size, serial number, location, result and filing district. Group the lines by property, put the client's PO or work order number on every invoice, and attach the filed reports the property manager needs before approving payment.

Settle who pays before the test. A tenant may book the test while the landlord or management company pays the bill. Get the billing party in writing.

Corporate clients often pay by commercial card, by ACH or on net terms. Put a pay-by-link button on every emailed invoice so accounts payable can pay by card the day the invoice arrives. A portfolio client can sign one card-on-file agreement that lists every covered property. Our guide to invoicing for contractors who want to get paid by card faster explains the setup. If you send dozens of device-level invoices at once, a QuickBooks payment integration saves you from typing everything twice.

Failed Tests: Bill the Test, Quote the Repair Separately

A failed test turns a routine charge into a repair the customer didn't expect, and that is where disputes start. The steps from the example above keep it clean:

1. Charge for the test. You did the work, so the fee applies pass or fail. Say so in the authorization and the booking confirmation.
2. Report the failure the way the district requires. Some districts want failed results filed along with a repair deadline.
3. Send a written repair quote that lists parts, labor and the retest fee, or says the retest is included.
4. Get separate approval, then retest and close out with the passing report and a final receipt.

Publish your retest policy before the first test. You might offer a discounted retest when you do the repair, charge a full fee when another contractor fixes the device, or include the retest in the repair price. Any of these works if you apply it every time. If a customer disputes the repair itself, your signed quote, test reports and photos are what you submit in response. See plumbing chargebacks when homeowners say the repair didn't work.

Start With the Devices Due in the Next 90 Days

Pull every assembly due in the next three months. For each one, check whether a card token is on file and whether the consent behind it meets the rules above. If the consent falls short, send a consent link with the first reminder. Then ask your processor which transaction label your gateway uses for annual charges.

MannyPay provides payment processing, card terminals, virtual terminals and online gateways for plumbing and home services businesses. To review your stored-card billing setup and pricing, request a free quote from MannyPay. A MannyPay specialist responds within one business day.

Sources

1. Visa Stored Credential: New Compliance Mandate Effective October 14, 2017 (University of British Columbia ePayment)
2. AI06496 Stored Credential Transaction Framework Clarifications and Mandates (AIBMS)
3. Visa Stored Credential Transaction Framework (Moneris)
4. A Guide to Visa and Mastercard's New Mandate for Stored Payment Credentials (Merchant Advisory Group)
5. The Visa & Mastercard Mandate for Subscription Transactions (Chargeback Gurus)
6. Visa's New Stored Credentials Program: What Online Merchants Must Know (ClearSale)
7. Visa Credential on File Updates (Compliance101)
8. Visa's Stored Credentials Program (Verifi)
9. Credit Card on File: Rules, Consent and CIT vs MIT (PaymentUSA)
10. Card Network Rulebooks and Agent-Initiated Transactions: Visa and Mastercard Compliance (TFSF Ventures)

IC

About the author

Isabella Cruz

Isabella Cruz is Business Growth & Commerce Editor for Beyond the Swipe, writing for small businesses, restaurants, retailers, entertainment venues and e-commerce sellers.

This article is for general educational purposes and is not legal, tax or financial advice. Card network rules and state laws change; confirm current requirements for your business.