MEMBERSHIP INSIGHT
On your behalf
Policy team update
Diana Bruce MCIPPdip, CIPP senior policy liaison officer , provides an update on developments TPR/DWP re-enrolment workshop questions that cover a broad range of situations. Samantha Mann attended this
As a reminder the employer prompts are ‘nudge’ techniques that are being used by HMRC this year to prompt an employer to action with a first ‘gentle reminder’ followed by a second in the event that no student loan deduction is made, followed by a telephone call in the event that the two written prompts have no effect. It is at the phone call stage that the employer will have the opportunity to explain why they haven’t actioned the SL1 notice – and at this stage we can only guess at the reasons. Threshold validation will be carried out by HMRC before issuing the employer prompts thus reducing the risk of them being issued in error; however, as has been highlighted many times in recent months, an attachment of earnings could impact on the amount of pay available for making a student loan deduction and the phone call gives an opportunity for the employer to explain if that is the case. Until the phone call there is no process as such for the employer to bring a halt to the employer prompts. Fixes to prevent pensioner payrolls from being issued with unnecessary employer prompts are to be initiated by HMRC. Work is ongoing with the development of post graduate loans (PGL) policy. At the time of writing the loans application programme had just recently, and successfully, gone live – applications were being received within 24 hours – and discussion was ongoing as to the benefits or otherwise of a switch v stop process for dealing with PGL and student loans plans 1 and 2 when PGL come in to repayment in April 2019. Stakeholders favoured a separate process that takes account of differing thresholds and % deductions for student and post graduate loans including separate start and stop notices. From a software development perspective this was seen as the most straightforward to implement, which would provide greater
A workshop was held in early summer, hosted by The Pensions Regulator (TPR), to discuss the challenges of re-enrolment for advisors and professionals. Many issues were discussed and clarified; one being that during the communication stage and prior to re-enrolment, the employer will need to notify TPR again of the contact person to write to – even if this was done at staging. This was queried from an administrative burden perspective on the day, but to no avail; however, there will be an increased drive to highlight that employers should make contact with TPR to ensure that contact details are updated particularly where an adviser or agent is used. TPR has also decided, based on feedback from large employers, that they will move to a two-letter journey at minus six months and minus three months rather than the four letters as originally used. TPR will be developing a key set of articles aimed at human resources (HR) and ideally to be delivered through trade press to strengthen the message about clarifying who will complete the declaration of compliance. Will it be the agent or client? This needs to be clearly established at the outset. The impact of errors, particularly where the employer may have changed payroll providers and/or pension providers, was discussed. It was confirmed that the consequences of non-compliance are the same as at staging. It was suggested that if may be helpful if the issue of errors and correcting mistakes is addressed more widely in guidance and in frequently asked
workshop on behalf of the CIPP along with members of the Professional Bodies Forum. If you have any experiences that you feel other members would benefit from hearing about, please contact Samantha by email at policy@cipp.org.uk. If you would like any issues raised at the TPR/Department for Work and Pensions (DWP) Software Developers Forum or the Professional Bodies Forum who meet regularly throughout the year, the same contact details can be used. Student loans The Collection of Student Loans Consultation Forum met at the end of June, unusually at Bush House in London, and saw the coming together, both in the room and across the phone lines, of the Collection of Student Loans Forum, HM Revenue & Customs (HMRC) and the Department for Business, Innovation and Skills. This was the first meeting since plan 2 student loans came into repayment and the go-live of employer prompts (generic notifications), which for the first time sees the student loan team maximising the opportunities presented by real time information data to ensure employer compliance in making not only the correct deductions for repayments but also making them on time. At the time of meeting it was too early to establish what the most common reasons were for employers not making timely deductions.
...there is no process as such for the employer to bring a halt to the employer prompts
| Professional in Payroll, Pensions and Reward | September 2016 | Issue 23 6
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