Is HMRC’s RTI project really a success?

By Tony Collins

On  Eddie Mair’s “PM” programme on R4, I suggested that HMRC’s real-time information project was not the failure many had expected it to be.

“Even some hawk-eyed critics of government IT projects like journalist Tony Collins think that HMRC may have something of a success on its hands,” said BBC reporter Chris Vallance who produced the RTI item.

I was quoted as saying that many had expected RTI to become another government IT disaster. “But given that there are millions of PAYE employees who are on the system at the moment, if there were any major difficulties we’d expect to have seen them by now.”

Now an HMRC expert has questioned whether my comments were justified. He says parts of RTI are in chaos. He doesn’t want to be named. He writes:

“The RTI system was intended to report on a weekly or monthly basis the same information as had previously been reported by employers on an annual basis. Although details of pay and tax would be forwarded to HMRC far more frequently the same core logic applied. Details of the statutory deductions by the employer would have to be reconciled with payments made, and details of the income and tax paid recorded against the employee’s PAYE record.

“What appears to have happened is that HMRC has designed a system that takes details of employees’ earned or pension income, and statutory PAYE deductions, and then makes various illogical assumptions.

“For instance it would appear that where an employee receives no earnings in a particular pay period, the RTI system assumes that no information is “transmitted” for this employee, indicating that the employee has “left the employment”.

“Similarly where an employer undertakes a re-order of the pay identities (codes on the payroll system called Works Numbers that identify employees), the fact that payroll information is transmitted to HMRC with a Works Number different to that used previously triggers an assumption that the employee has two employments, with the same employer.

“This has the consequence of allowing the NPS (New PAYE Computer System – costing in excess of £400 million) to assume that the employee’s estimated income for the tax year has doubled. The NPS then looks to see if the employee has any part-time or other employment, and in many cases it changes the PAYE code number of these part-time employments from Basic Rate, which deducts tax at 20%, to Code D0, which deducts tax at 40%. All because of an incorrect and invalid assumption.

“Similarly, this failure to understand how PAYE and payroll interact has lead to the situation where an employee who leaves an employment that has attracted a PAYE coding deduction for Car Benefit in Kind and starts another Employment, has the PAYE Coding Deduction removed. The fact that the new employment may well involve a company car is completely ignored, with the result that the employee is more than likely to have a large underpayment of income tax at the year end, despite being on PAYE.

“This failure to understand the basic operation and logic of PAYE would appear to be due to that fact that HMRC has been influenced by those who have an understanding of data flows and cash transfers. The rush to modernise PAYE and move away from “a 1940’s system” has completely omitted the fact that basic operations for employments, tax and NI deductions and the accountability of these remains exactly the same, even if the calculations are undertaken electronically rather than with a quill pen and large ledger book.

“The old PAYE system had as part of its reporting system two components: the forms P14 detailing each individual’s pay, tax etc. and a summary of all employees information, the form P35. The P14 passed information to the NPS system and the P35 information was passed to the accounts computer systems. This allowed HMRC to determine the income of the employee and calculate if sufficient income tax etc had been paid. It also allowed HMRC to match the figure of tax / NIC due and payable on the P35 with the amount actually received from the employer. RTI has failed to comply with this basic logic and chaos is ensuing, to the extent that the National Audit Office recently commented

 ‘The financial and accounting systems supporting RTI are not yet fully accredited. Financial accreditation is a formal requirement of HMRC’s Change Programme and provides assurance that any new systems are acceptable for accounting and financial control purposes. The RTI systems went live on the basis that action would be taken to resolve identified financial design issues by 31 October 2013.

‘These issues do not affect an employer’s ability to submit data to HMRC but do weaken HMRC’s ability to produce and report financial information on PAYE. HMRC is currently undertaking work to understand the impact of these issues and how best to address them.’

“Why the RTI system was not designed in the same logical manner is of great concern.

“The system failures that are occurring are not due to computer components or programs not being fit for purpose. Indeed the processing of the PAYE data streamed to HMRC as a result of the RTI system could reasonably be compared to any other large commercial organisation, albeit that the NAO has concerns over the fall-back planning HMRC has in place should there be any hardware failures and commented

‘The resilience needed to maintain the RTI service if there is a major technical failure is not in place. Online and time-sensitive system implementations are usually developed with formal technical resilience and disaster recovery capability.

‘HMRC chose not to pay for full resilience because of the cost implications and because PAYE could be operated in an emergency without RTI. However, although RTI has the potential to be used by other government departments, the lack of full resilience may inhibit its use in areas of activity where a temporary disruption to service cannot be tolerated.

‘Data submissions can be held temporarily in a queue but this would not provide continuity of service in the event of a catastrophic failure. The RTI service failing at a critical processing time could increase the volume of customer communications and lead to more effort for employers.’

“The RTI system is a very clear example of basic failures to properly prepare a Business Analysis Requirement for a system which in essence does no more that increase the number of times payroll information is passed to HMRC. Claims for the reinvention of PAYE for the 21^st Century are as invalid as the claim that the ability to write has been done away with due to email and electronic communication. There has been a flawed reliance on the thoughts and views of those who have little or no experience in PAYE or payroll.”

On the PM programme, Ruth Owen, Director General of PersonalTax at HMRC, accepted that all was not perfect. She said

“We have had over 1.4 million PAYE schemes come into Real-Time Information [each PAYE scheme may have many employees on it] and that exceeds our expectations at this point in the year. But there’s still more to do. We have got to get everybody on and there are still people who need our help to get on.”

She added: “We have had a small number of difficult issues… We have had issues where people have got the wrong tax codes.”

Owen said the links between RTI and Universal Credit were “going well” but conceded that there have been only a tiny number of UC claimants so far.

“We have had around 100 claimants who we have helped DWP identify income stream data for. So it’s going to plan at the moment.”

Chris Vallance concluded the item by saying that some of the largest employers have yet to be added to RTI. “It’s only when it works at scale that we will really know how good real-time information really is,” he said.

Update: Chartered accountant Baker Tilly says on its website  that thousands of people have been issued wrong tax codes as a result of RTI-related problems. 

Audio of PM programme item on RTI – 4 July 2013 (approx 5 mins)