Halloween cannot come quickly enough for me in 2020. It will mark the end of the Coronavirus Job Retention Scheme (CJRS) – as far as we know. However, 31 October 2020 will only be the start of HMRC’s compliance activity. In fact, this will probably be after 30 November 2020 which is the final date for CJRS claims.
To be compliant, employers need reliable and consistent guidance. That just has not been the case with the CJRS guidance that seems to change on a daily basis. On 22 June 2020 there was another change:
Claim for wages through the Coronavirus Job Retention Scheme
This guidance was first published on 20 April 2020. It is the fundamental piece of guidance that gives instructions to employers on how to make a CJRS claim for an employee that has been furloughed. It has been updated 11 times since that date, the latest on 22 June 2020 as follows:
- Updated to advise employers that if the claim is for an employee with a temporary National Insurance Number, HMRC should be contacted
(Of course, a temporary National Insurance Number should not be used in the payroll. Or, if it is, it should not be sent to HMRC on the Full Payment Submission (FPS))
The National Insurance Number is a fundamental field for completion when making the claim. This is for matching purposes when the claim gets to HMRC. However, there are occasions when an employer will not have the Number for one reason or another.
So, in that regard, the revised guidance says:
- Search for the Number in the first instance. This can be done by the National Insurance Number Verification Request (NVR) in software or via Basic Pay As You Earn (PAYE) Tools (BPT)
- If the number cannot be found or does not exists, contact HMRC
I understand this change to guidance. If this is what it takes for an employer to be able to make a successful CJRS claim, then it is essential information to have.
Keep a copy of this latest guidance, the 11th version in just over 2 months. That must be some sort of record!