Issues you may face and helpful hints on the process of applying for the CJRS.
We are now coming to the end of the first week of applying for the CJRS grant. The application process started as promised at 8am on Monday 20 April, and the numbers accessing and applying have risen with hundreds of thousands of employers, applying for millions of employees, for billions of funding. This has been so welcome by these businesses, although they have to wait until next week before the funding will appear in their bank accounts.
Given the size of this for HMRC, it appears to have gone better than anyone could have expected. There have been challenges and not everything has gone smoothly from calculating the right numbers to entering the information in the portal.
HMRC now has a Covid-19 helpline to support the portal – 0800 024 1222 and HMRC has been helpful via their online chats.
What have been the problem areas and the Gremlins in the system:
- Employees who don’t have a National Insurance Number – this has been the case for younger employees who haven’t received a National Insurance Number, but there are others. We have heard anecdotally that HMRC has said:
- When making a claim to the Job Retention Scheme, employers are asked to provide a National Insurance number (NINO) for each employee that they have furloughed. We are aware that in some limited circumstances an employer may not have a NINO for all employees.
Employee has a NINO but employer doesn’t know it
Where an employee has a NINO, but the employer does not know it they should make all reasonable efforts to establish it, including by making use of the RTI NINO Verification Request submission if appropriate.
Employee does not have a NINO
Where an employer has fewer than 100 furloughed employees but has one or more without a NINO they should contact the COVID-19 Helpline on 0800 024 1222 who can process their claim over the phone. Where an employer has 100 or more furloughed employees, they must instead provide a payroll or employee reference number for any employee without NINO in their file upload.
- Directors Annual Payment – HMRC’s guidance says the Director must be on an RTI return by midnight on 19.3.20 and have earnings for 2019/20. So if the annual scheme was reported after 19.3.20 they have no earnings and the claim will reject and the director also doesn’t count in your employee numbers if it’s a mixed employee/director claim, so that can cause your claim to reject too.
- Seasonal workers – this is where seasonal workers were employed previously and remained on the payroll, but were not on the employer’s last RTI submission and have now returned. One of the checks that HMRC’s portal makes is to agree the number of employees and if you have more employees this month on your claim than on the last RTI submission, the claim may be rejected.
- TUPE – problems have arisen where employees were part of a TUPE and transferred from one PAYE scheme to a new PAYE scheme, which HMRC guidance allowed but in some instances the portal said ‘no’.
- More complex claims – it has become clear that not every claim is straight forward. Factor in weekly and monthly paid, fixed and variable salaries, salary sacrifice and top up, the calculation can become a lengthy one.
- Rejected claims – no answer yet on what to do if the claim rejected for no good reason, surely you don’t have to wait 3 weeks for the next claim window? I would telephone the helpline.
- Weekly and monthly payrolls – these in the same claim period have caused some queries over the pay periods that should be claimed for. HMRC has confirmed that no claim periods should overlap, which means it might be necessary to apportion some of the days in the pay period.
There are others and probably more that we haven’t come across yet. HMRC is planning on making changes to the portal and hopefully they will notify what these are and when they will be completed. If you have found a CJRS Gremlin then let me know.