Employer Student Loans Sub Group Minutes by ps94506


									   Employer Student Loans Sub Group
Tuesday 22 February 2011 (10:30-13:00)
Room 3A, (South) 22 Kingsway, London

Angela Williams (ICAEW)
Ian Brearley (CIPP)
Kelly Sizer (LITRG)
Linda Pullan (Payroll Alliance)
Pete Jukes (BCS)
Matthew Brown (CIOT)
Kevin O’Connor (SLC)
Jackie McGale (SLC)
Christine Rowse (HMRC)
Liz Cunningham (HMRC)
Alex Lawrence (HMRC)
Helen Glover (HMRC)
Mark Skelly (HMRC)
Meriel Briscoe (HMRC)
Graham Ramsden (HMRC)
Kathryn Symms (BIS)
Andrew King (BIS)

Jackie Petherbridge (FSB)
Rosa Tormo (CBI)
David Malcolm (NUS)
Karen Duncan (BIS)
Nicky Kennedy (HMRC)
Paul Crooks (HMRC)
Janet Clayton (HMRC)
Pam Barber (HMRC)

1. Introduction and opening remarks
Liz Cunningham

Liz Cunningham welcomed everyone to the meeting and made apologies for those
unable to attend. Liz Cunningham welcomed Andy King from BIS who is the lead on
Further Education (FE) loans and Meriel Briscoe from the HMRC Software
Developers Support team.
Introductions were made round the table.

                                   Page 1 of 17
2. Real Time Information (RTI) condoc and
Liz Cunningham
Liz Cunningham advised that around 40 seminars on RTI had been held around the
UK. A number of seminars had also been arranged by the Chartered Institute of
Payroll Professionals (CIPP) and she had attended one of these. Liz Cunningham
asked if any of the employer reps had attended these seminars or had any feedback
from a student loans perspective. Angela Williams advised that she had attended one
of the seminars. Pete Jukes advised that the BCS have a number of serious
concerns about RTI and will be presenting a formal response. CIOT were finalising
their response and LITRG were also sending one.

Liz Cunningham highlighted a number of key points from an HMRC perspective:

             Employers will still have to provide pay advice to employees on
              each pay day.

             Employers will still have to provide employees with a P60 at the
              end of the year.

             HMRC’s intention is that RTI should involve only data already
              collected and recorded by employers for the purposes of PAYE
              or to satisfy other existing legislative requirements.

             Assumption is that payment information covers all employees
              including students and those earning below the lower earnings
              limit for NI.

             Multiple PAYE schemes can be included in single RTI

             In the year that the employer migrates on to RTI, the first
              submission will include ‘year to date’ information in respect of all
              payment related items.

             Information already submitted as payment data through BACS
              will be additional to these items.

IT is to be in place for 6 April 2012.Legislation will also need to be in place for then
and we have been in touch with BIS on this.

Once RTI is in place there will be a phased introduction with volunteer employers at
first, then large employers and all remaining employers will gradually be moved on to
the RTI system by autumn 2013. The main driver is that from the autumn of 2013
HMRC will provide income to DWP to support the payment of Universal Tax Credits.

The Consultation is an important stage in developing the process as it identifies any

                                         Page 2 of 17
Angela Williams asked about student loan information and Liz Cunningham
confirmed that we would be waiting until the RTI process bedded in before
considering how we might change the process to pass on student loan information
more regularly. There would be no change to the student loan process for 2013.

Asked if HMRC saw any potential problems for the proposed RTI process, Liz
Cunningham explained that HMRC currently needs to estimate the payments to be
sent to BIS quarterly. RTI will provide more information about actual student loan
repayments deducted by employers on each pay day. This should mean that HMRC
will be able move onto a process to use actual rather than estimated figures.
However, as there will be no end of year forms any longer, there will need to be a
process to ensure the annual totals and associated information is still available to
HMRC to pass to SLC and BIS.

Pete Jukes asked about estimating and the link to DWP. Liz Cunningham clarified
that the estimating was in relation to the payments to BIS of the student loan
repayments deducted by employers. HMRC would be aware of the monthly
deductions in real time once RTI is introduced.

Matthew Brown highlighted that if the monthly totals have to be kept until the year
end this shifts the responsibility from the employer to HMRC.

Pete Jukes raised one of BCS’ concerns which is that if any figures submitted in real
time are wrong how they will be corrected. Linda Pullan added that this was a benefit
of the current year end forms as the process allows the employer to do a final ‘check
and balances’. The concern now is about what to do about in year adjustments or
corrections or if adjustments need to be made after the tax year for overpayments or

Liz Cunningham advised that for student loans the HMRC plan is to develop a
'shadow' process to be able to obtain end of year totals. Following this they can look
at having more frequent transfers to SLC and improving the flow of information.

A further concern for software developers was about specifications. RTI assumes
that all of the information that is to be supplied is held on a single system. However in
some cases the payroll system can be separate from employer payment system and
the HR system. (HR systems often being separate to avoid issues around DPA and
confidentiality in having personal information held with payroll data.)

Linda Pullan asked if there would be any problem with accessing the system for
student loans. Helen Glover advised that she was not aware of any and outlined
some areas of work for student loans:

            Identifying the current student loan requirements to ensure there
             is no less than what we have currently.

            Maintaining the current system until RTI beds in.

            Looking at how the end of year information will be provided.

            Looking at how to develop the processing the future.

                                        Page 3 of 17
There was also discussion about the frequency of payments in that there would be
52 payments for weekly paid and 12 for monthly paid. Kelly Sizer highlighted that it
would discourage employers from paying weekly.

There was further discussion regarding concerns about adjustments with wrong
information being sent in. This time in the context of the wrong information potentially
passing to the SLC and their being credits or negative adjustments subsequently
being required to the borrower accounts. Kelly Sizer suggested that if a customer
phoned up the SLC for their balance would they then be able to ask HMRC for the
updated position. Kevin O’Connor explained that there are on-line facilities for
students to get an up to date balance. Angela Williams asked what was involved and
Kevin O’Connor explained that it was based on input from the student’s own
information (Payslips and P60).

Angela Williams asked if there were any plans for HMRC to extract the information
from RTI to send to the SLC rather than from NPS. Liz Cunningham explained that
RTI provides a repository for the information which then flows to our other systems.

Linda Pullan highlighted that there would be a newscast covering RTI on
payrollalliance.com, which Maggie Anderson and Jeremy Stephens took part in.
Linda Pullan will provide the link to share with the group.
Action(1) – To provide link to the RTI newscast.

Liz Cunningham asked the group to have a look at Appendix B of the Consultation
Document to ensure nothing had been missed. Linda Pullan highlighted a missing
piece of information concerned the date of leaving an employment. One reason for
leaving was that the employee had died but this was not asked for. She had queried
this and been advised that HMRC would pick this up from their registry. Linda Pullan
said she would also be feeding this back to the RTI consultation team.

Liz Cunningham then highlighted some of the ‘Next Steps’ from the
consultation document.

The consultation will close on 28 February 2011.

Following analysis of the responses, a final specification for payroll software
developers will be published by the end of March 2011. The Government will
publish its formal response to the consultation, including full details of how RTI
will be implemented, in spring 2011.

Angela Williams raised the concern that there would be little time to review the
responses. Liz Cunningham advised that the RTI team had been reviewing the
responses as they came in. However it was acknowledged that there was likely to be
a lot of feedback all coming in at the end.

Pete Jukes raised the concern about time for feedback if the specification for
software developers was not correct and that it would be good to see a copy of the
draft specification before the end of March. Linda Pullan advised that she had asked
about this and was advised that the specification cannot be issued until the
consultation was finished. However the reps were keen to see the specification as
soon as possible. Liz Cunningham agreed to pursue this with the RTI team.

                                        Page 4 of 17
Action (2) – To ask the RTI team for sight of the specification for payroll software
developers as soon as possible.

Pete Jukes asked about the timeline beyond the specification being issued. Liz
Cunningham agreed to look into this.

Action (3) – To ask the RTI team what the timelines are beyond the issue of the
specification for specification for payroll software developers

Next steps : Once the consultation closes the responses will be analysed and
a summary produced. Further consultation will accompany the publication of
draft amendments to the PAYE Regulations in autumn 2011.
Liz Cunningham highlighted that any changes need to the BIS regulations for
student loans would also need to be in place from 6 April 2012.

RTI is a key component in the Department of Work and Pensions’ (DWP)
plans for the introduction of Universal Credits from 2013. DWP will use RTI to
award and adjust Universal Credit to take account of employment and pension

Action Point (1) Linda Pullan
Action Point (2) Liz Cunningham
Action Point (3) Liz Cunningham

3. Update from HMRC on Collection of Student
Loan (CSL) issues
Liz Cunningham highlighted some areas of work HMRC were involved in:

Giving input to RTI for the student loan requirements and getting BIS geared
up for regulatory changes needed to the SL Regulations.

Working with BIS on Browne implementation with the impacts for HMRC

            2 income thresholds from April 2016

            Introduction of variable interest rates, looking at what income
             measure to use and how to source it through the tax system.

            Introduction of Further Education (FE) loans and loans for part
             time Higher Education (HE) students. Although the borrower
             numbers are small the new loans carry terms that will keep
             people in repayment longer. (30 years rather than 25 years).Liz
             Cunningham confirmed that these loans would be collected
             through the existing collection system as the primary legislation
             (Teaching and Higher Education Act) relates to both HE and FE

                                       Page 5 of 17
Providing input to BIS on loan sales, which were announced by the previous
government as part of a potential asset sale over the next two years.

Starting on the project to modernise the student loan system. The original project
was mothballed when MPPC was delayed. BIS are keen for modernisation as
student loans is currently delivered from a stand alone IT system and the plan is to
move it to sit on the NPS platform with a delivery date of April 2014. With the current
moratorium on major investment, the project will need Cabinet Office approval.

HMRC Weekly Update

Liz Cunningham highlighted a few of the items recently published.

Update 49 second article refers to changes to Employer mailings and Orderline. Liz
Cunningham advised that HMRC will no longer issue paper Employer Packs and
paper Budget Packs to the vast majority of employers and all employers will now be
expected to access PAYE guidance and forms online. Going forward the Employer
Orderline will only hold limited stocks of paper products. This new approach also
applies to student loans.

Update 49 first article refers to Regional Employer National Insurance Contributions
(NICs) Holiday. Liz Cunningham asked if when the employer takes a holiday they still
record the NIC as student loans are based on NIC. The employers confirmed that
they will be.

Update 47 third article refers to Late filing penalties. Liz Cunningham advised that
HMRC has begun to issue second interim penalties to those employers whose
returns remain outstanding. The first interim penalties were issued in September and
clients may be contacted by HMRC requesting payment of the first interim penalties if
the debt has not already been settled.

Alex Lawrence
Alex Lawrence provided updates on a number of topics:

P14 processing
HMRC send P14s to the SLC to update the borrower’s accounts. As we don’t know
the exact number of P14s we work in arrange with between 1.8m and 1.9m expected
to be sent to the SLC for 2009-2010.

By February 2011 - 1,831,100 P14s were sent to the SLC being 96.3 per cent of the
expected total of 1.9m. This number exceeds the expected lower range and looks as
if we are processing the last few P14s.

At the previous meeting Angela Williams asked how this year’s P14 processing
compares with this time last year. (AP 1/301110). Alex Lawrence provided the
following details:

       2011      1,829,245      98.8%
       2010      1,522,767      95.2%
       2009      1,259,556      89.97

                                        Page 6 of 17
This illustrates that HMRC are processing more P14s and more quickly. The
borrower population grows every year by about 260k to 280k.

Ian Brearley asked what is the ratio between start and stop notices being issued. Ian
Brearley advised that this query was raised by a client as they seemed to be getting
as many stops as start notices. Alex Lawrence advised that he wasn’t sure if we kept
this information but would look into it.
Action (4) – To find out the ratio between the issue of start to stop notices.

Liz Cunningham advised that the ICR scheme had been running for over ten years
now and we expect a lot of borrowers would now be at the end of repaying back their
loans. It is expected that the ratio between stop and starts will even out.

Angela Williams asked about he unprocessed P14s. Alex Lawrence advised that this
had been a problem in 2004-2005 but the gap had been reducing each year. Angela
Williams asked if there was figure for those sitting unprocessed. Alex Lawrence
advised that he didn't have an exact figure but there is only about one per cent still to
be processed. Kevin O’Connor advised that they would be aware of a problem if they
received large numbers of calls, but this had not been the case. Alex Lawrence
explained that they did have an agreed process with the SLC to deal with any queries
from borrowers where their P14s had not been processed. Jackie McGale advised
that the numbers were very low, she estimated 10s rather than 100s of customers
had been affected with less than 100 in the last year.

Employer CD-ROM
Update on the timing of the change to the reference to CD-ROM being shown on the
SL1 and SL2 forms. (AP2/301110)

The revised forms are now going through the final approval and proof reading stages.
The anticipated release date is 6 April 2011. For information the main change is to
signpost employers to the HMRC basic tools download area which will replace the
CD-ROM for 2011 onwards. This link is now live and is found at Using HMRC's Basic
PAYE Tools


The CSL1 (leaflet for SA and SA/PAYE borrowers) and the CSL2 (leaflet to answer
common employer and employee questions) now has additional information
explaining non cumulative situation. There is no publish date for the leaflets but the
timescale is 3 to 4 weeks. (AP1/150610)

The anticipated implementation date for updating and linking CSL and SA guidance
will be 6 April to tie in with other annual updates to core content. It will include links to
the CSL leaflets, and CSL core content as previously mentioned. (AP 5/090210).

Action Point (4) Alex Lawrence

4. Update from BIS on
             Loans for part time students

                                          Page 7 of 17
            Loans for FE students

            Annual threshold change

Kathryn Symms
Kathryn Symms highlighted some forthcoming changes to the existing scheme:

            The £15,000 repayment threshold will increase in line with
             inflation in April 2012, 2013, 2014 and 2015 and will use the
             March RPI rate. This means that in April 2012 the thresholds will
             increase by the rate of RPI for March 2011. The increased
             threshold figure will be calculated to the nearest £5, and this will
             be laid down in the regulations.

            The March RPI rate will also be used to set the interest rate on
             existing loans

Pete Jukes asked if this was being published in the Notes for Software Developers
as they will need to know the method for calculating the changes. Pete Jukes
advised that the Notes are the focal point for payroll developers and should include
all updates. Meriel Briscoe said that she would take this forward.
Action(5) - To ensure the updates on the threshold change are included in the Notes
for Software Developers

Kelly Sizer asked whether increasing the £15k threshold by inflation would be
reflected in the repayment thresholds for borrowers working overseas. BIS confirmed
that it would.

It was acknowledged that all the CSL guidance will need changed as well to reflect
the new threshold from April 2012.

Kathryn Symms continued by highlighting some changes to the new scheme – all
subject to Parliamentary approval:

            New threshold to be introduced from 2016 of £21k.

            Interest rate – from September 2012 new students will be
             charged interest at RPI plus 3% until their Statutory Repayment
             Due Date (SRDD). Education Bill is going through parliament
             and will be debated on 31 March with Royal Assent expected in
             autumn 2011 in good time for 2012.

            Variable interest rate that is to be applied during repayment from
             2016 as follows:

             £21k or less = interest at RPI
             £21k to £41K = graduated rate of interest up to
             £41k or more = RPI plus 3%

Pete Jukes checked and BIS confirmed that the interest amount will be added to the
student’s loan balance and there won’t be any employer involvement.

                                       Page 8 of 17
            No change to the 9% - repayments will continue to be deducted
             at 9% of income above the threshold.

Kathryn Symms explained it is possible that individuals may come under two
schemes (two thresholds), but that this would not affect employers as they would
continue to deduct repayments at the nine per cent above the £15k threshold.

While it was acknowledged that it was a more complex system the aim was to keep it
simple for employers.

Mathew Brown raised the concern that with the extra element there was more scope
for mistakes and HMRC need to have a robust process to minimise this. Liz
Cunningham explained that it is expected that in the future start notices will be
changed to include the threshold level. It was also noted that the system would be
more dependent on start notices than P45s or P46s.

Angela Williams raised an addition a concern in that the Scottish or Welsh devolved
administrations may have something different.

Mathew Brown re-enforced the point that CIOT would like any added complexity to
be invisible to employers.

Pete Jukes highlighted an example of where one County Court wanted their own
change to an attachment of earnings process that meant software developers
nationwide are having to alter their software

Kathryn Symms advised that part-time students will now be eligible for loans and it
has been agreed that they will become liable to repay their loans from the April after
three years of study, even if they are continuing to study. There will be no impact for
employers but as they may be due to start repaying while still studying it will mean
additional guidance

Action Point (5) Meriel Briscoe

5. Proposed work on Further Education (FE)
Andrew King
Andrew King advised that:

            FE loans will operate on the same eligibility and repayment basis
             as HE student loans.

            The reasons for introducing this new way of funding education
             are the need to reduce the BIS resource budget and that the
             focus for providing grants will be on those under 24 and in a level
             two or below course.

            The new loans for over 24s, and in level 3 courses will be
             introduced from September 2013.

                                       Page 9 of 17
            Loans are made direct to the institutions and are fee loans only,
             no maintenance loans.

            This policy only applies to England and is being delivered directly
             by BIS.

            BIS budget for the first year is £129m for 80k students and
             £389m in the second year for 200k students.

            Recognised the need to adhere to the simplicity of national

            There have been communications with employers and a
             reference group has been established, which includes employer
             reps. Those involved are from the Federation of Small
             Businesses, CBI and employers having large numbers of
             apprentices, for example BT. A more detailed paper will be
             discussed by this group and Andrew King agreed to share this
             with this group.

Action (6) – To share the detailed discussion paper with the group

Action Point (6) Andrew King

6. Update from SLC on Collection of Student
Loan (CSL) issues
Kevin O’Connor /Jackie McGale
Kevin O’Connor advised that they are involved in the same areas of work as already
mentioned like:

            Brown review:

             Variable interest rates
             Threshold changes
             Increased loan terms from 25 to 30 years

            Loan sale

                                      Page 10 of 17
7. Query from CIPP member – 'Why don’t we
treat Student Loan deductions like other third
party payments and send them off separately
each month?'
Ian Brearley
Ian Brearley advised that he had been asked the question by one of his members.
The rep had been comparing this to court orders which are paid over monthly.

Helen Glover provided the response which was that the SLC only deal with student
loan information and not money. The agreement is that the employer on behalf of
HMRC collects the money and HMRC then pass this money to BIS.

RTI is likely to provide a benefit as the money would now be paid monthly, but it
wouldn’t be before 2014 that the money could be passed across more regularly and
the SLC notified of the amounts.

Liz Cunningham advised that statutorily the student loan amount is part of the
combined monthly payment to HMRC along with tax and NIC. The collection of
student loan amounts is linked to the tax system and to take it out to be paid
separately would make the employer a collector for another Department (BIS).

Alex Lawrence summarised by saying that it is the transfer of information not money
that goes to the SLC. The monthly payment, as well being included along with tax
and NIC, does not define the individual.

8. Payroll Pooling
Graham Ramsden
Graham Ramsden advised that this was an early alert to a discussion document that
is due to be released soon.

Payroll pooling has been around for a couple of years and was asked for by
employers. In 2009 there was an initial discussion document followed by workshops.
There was feedback but it wasn’t taken any further at that time. Since then work on
RTI has started and payroll pooling is being looked at again.

The idea of payroll pooling is to have one PAYE reference for connected employers.
An example of this would be a NHS trust, which would be treated as a single
employer rather than have a PAYE reference for each of the individual hospitals.
This would also make it easier when staff move between the hospitals.

Ian Brearley asked if it would apply to multi-corporations who are legal entities in the
UK. Graham Ramsden advised that the ‘close connection’ had not yet been defined.

                                       Page 11 of 17
Meriel Briscoe asked about the benefits to HMRC as it was an employer-driven
request. Graham Ramsden advised that if it was one reference there would be no
need for the movement process when staff move between the ‘connected’ employers
and there would also be only one end of year return.

Pete Juke asked about benefits in kind and Graham Ramsden advised that is has
still to be explored.

Graham Ramsden raised the point that some of the advantages of payroll pooling
may be delivered by RTI and this may mean that employers are no longer interested
in payroll pooling

Ian Brearley asked if the discussion document would specify what is classed as
‘close connection’. Graham Ramsden explained that they first needed to find out if
employers were still interested in payroll pooling before the low level detail is defined.

Angela Williams highlighted an impact on student loans where an employee currently
has two jobs below the threshold with different ‘connected’ employers but under
payroll pooling there would only be the one payroll. While the employer has the
choice in deciding whether to adopt payroll pooling this could have an impact on
individual employees.

The issues of NIC aggregation and split tax codes were also raised.

Graham Ramsden advised that the initial high level document would be out next
month and there will be a minimum of an eight week discussion period.

9. Update on Validating Household Income
(VHI) Project
Liz Cunningham
Due to the extended discussion on RTI this agenda item is carried forward to the next

10. Communications Evaluation
Liz Cunningham
Liz Cunningham thanked everyone who took part.

As there was an extended discussion on RTI this agenda item is carried forward to
the next meeting.

11. Review of Action Points
Angela Williams asked how the processing compares with this time last year. Alex
Lawrence agreed to look into this and provide details.

Action – To provide details of how P14 processing compares this year with last.

                                        Page 12 of 17
22 February 2011 - Alex Lawrence provided the following details:

                    2011      1,829,245         98.8%

                    2010      1,522,767         95.2%

                    2009      1,259,556         89.97

This illustrates that HMRC are processing more P14s and more quickly. The
borrower population grows every year by about 260k to 280k each year.
Action Point :Closed

Employer CD ROM – HMRC Weekly Update 37 advised employers to download the
November update of the CD-ROM.

It is the Department’s intention to withdraw the CD-ROM and it will not be issued in
large numbers. The calculators and information and guidance currently included on
the CD-ROM will now be available on the web. This includes the student loan
calculator and guidance.

Alex Lawrence highlighted that reference is made on the SL1 and SL2 to the CD-
ROM. This will be changed for 2011-2012 for both paper and on-line SL1s and SL2s.

The employer reps advised that this would need to be highlighted to employers and
they will need to know when the wording will change as copies of the forms will be
included in their publications and they would not wish to show the old forms. Alex
Lawrence agreed to advise on the timing of the change to the reference to CD-ROM
being show on the SL1 and SL2 forms.

Action – To advise on the timing of the change to the reference to CD-ROM being
shown on the SL1 and SL2 forms.

15 February 2011 - The revised forms are now going through the final approval and
proof reading stages. The anticipated release date is 6 April 2011. For information
the main change is to signpost employers to the HMRC basic tools download area
which will replace the CD-ROM for 2011 onwards. This link went live today and is
found at Using HMRC's Basic PAYE Tools
Action Point : Closed

Karen Duncan advised that she already had a list of issues to be resolved and there
were key milestones for BIS and HMRC. The reps asked about sharing this
information with their members and it was agreed to provide a note for reps to
feedback to their members.

Action – To share the document covering the list of issues and key milestones with
the group.(Karen Duncan)
22 February 2011 – Carried forward

                                      Page 13 of 17
The Impact Assessment can be viewed on the BIS website at Impact Assessments .
Any feedback from the reps should be provided by mid December.
Action – To provide any feedback on the Impact Assessment by mid December.
(Employer Reps)
1 February 2011 - Closed

Pete Jukes asked about feedback on the plan to introduce multiple thresholds and
Karen Duncan was confirmed that feedback to BIS was due mid January and should
be through the Employer Student Loan Sub Group.

Action – To provide any feedback on the plan to introduce multiple thresholds
through the Employer Student Loan Sub Group by mid January. (Emplyers reps)
2 February 2011 – No feedback received - Closed

Kelly Sizer raised concerns about the SLC site as some of the content is out of date.
Action – To advise SLC of these concerns. (Christine Rowse)

1 February 2011 – The SLC were advised that some of the content is out of date.
The SLC will review it and refer any required updates to the relevant department for
action. – Closed

Matthew Brown suggested that while current guidance mentioned the need to keep
payslips we should also highlight that the P60 only shows cumulative student loan
deductions for the last employment in any year. What information the employee
needs is appropriate and in what manner it should be provided is part of a wider

Action – To look at current guidance to check what information there is in relation to
keeping payslips and highlighting that the P60 only shows cumulative student loan
deductions for the last employment. Change guidance as appropriate and publicise
the message. (Liz Cunningham)

14 September 2010 – Liz Cunningham explained that we are proposing to put an
extra paragraph in the CSL 1 (Collection of Student Loans for SA Customers) and
some extra words into the CSL 2 (Guide for Employers and employees to help
answer common Student Loan queries) to explain that theP60 only reports income
from the latest employment held at the end of the tax year and the expected
timescales for the updates. It will take eight to ten weeks for the online versions of
the leaflets to be updated, then a further two to three weeks for the paper versions.
We hope to have the new leaflets around November and once the leaflets have been
updated it is proposed to publicise in the February 2011 Agent Update.
23 November 2010 - Carry forward

                                      Page 14 of 17
30 November 2010 - Alex Lawrence advised that as mentioned earlier they had
completed their internal review of all three CSL leaflets following feedback from the
group. The leaflets have now been passed to HMRC’s Communications and
Marketing department, who are responsible for design and web page content. Once
they have signed off the leaflets the website will be updated. The expected date of
publish will be late December or early January 2011. The delay was due to co-
ordinating the update of all three leaflets at the same time.

15 February 2011 - The CSL1 (leaflet for SA and SA/PAYE borrowers) and the
CSL2 (leaflet to answer common employer and employee questions) now has
additional information explaining non cumulative situation. The delay in co-ordinating
all the relevant changes has now been resolved. Alex does not yet have a publish
date for the leaflets but once the versions have changed over on the HMRC site he
will email you the links to pass out to the sub group. The timescale on this is three to
four weeks.
22 February 2011 - Carry forward until publication has been confirmed then close.

Liz Cunningham referred to leaflet CSL1 which covers over-repayments. The advice
is that to deal with over-repayments HMRC have to go through an informal set off
process as we can’t change the income on the return, which is correct. Matthew
Brown pointed out that the advice is to apply in writing to have the amount stood over
by HMRC but this raises an issue in that this lengthens the time involved with the
result being that the customer is overcharged and over repays. Could the request not
be made by phone?
Action – To check if an informal standover has to be made in writing or could it be
made by phone.

28 June 2010 - The informal standover is part of the SA process, so we are bound
by Self Assessment rules. For the Collection of Student Loans, they can be found
here in the SA Manual http://home.inrev.gov.uk/sammanual/SAM11130.htm You will
notice that it says that the request must be made in writing. I would imagine that this
is because it’s part of the appeals process which has to be carried out under fairly
rigid rules so that, if the case goes before the Commissioners, HMRC is seen to have
carried out the correct procedures. For the same reason, it is in HMRC’s interests to
deal with these requests as quickly as possible, so there shouldn’t be a significant
delay in dealing with them. I’d advise the borrower to make it quite clear in the letter
(for example, in the heading) that the letter is a request for a standover.

If the SA taxpayer also has a PAYE source, then the SLC has introduced a process
for identifying borrowers who are within 23 months of the end of their loan. They will
invite the borrower to change to Direct Debit repayments for these final months. A
Stop will be issued to HMRC earlier than under the normal procedures so there
should be less (or no) chance of over-repaying. This new process (introduced in
December 2009) does not apply to borrowers who only have an SA source.

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14 September 2010 - The information Liz Cunningham has been given is that the
request must be made in writing. Angela Williams said this was quite unsatisfactory
as she was under the impression that there is a month backlog of post at HMRC. Liz
Cunningham explained that this is outwith our area of jurisdiction but she agreed to
explore the scope for customers requesting informal standovers by phone or email
with SA policy colleagues and report back.

23 November 2010 – We have been able to confirm that informal standover requests
can be made over the phone although it will depend on the circumstances of the
case. We are still waiting on a definitive response on email requests.

30 November 2010 Angela Williams queried the ‘circumstances of the case’ aspect
and it was explained that the request could be made by telephone but it would be
accepted on a case by case basis. Angela Williams asked if it there was some way of
improving the process where it was just the student loan amount.

Angela Williams suggested that SA303 form ‘Claim to reduce payment on account’
could be used in some way as another reason may be that ‘I have calculated that I
will overpay my student loan’

Liz Cunningham explained that there were difficulties as the student loan amount is
included in the tax amount but she would explore this suggestion.

1 February 2011 – It was confirmed that requests for informal standovers apply to all
telephone calls not just to contact centres. The use of email is on the enhancement
register but will not happen in the near future as there would be a cost attached and
there is no money for any changes other than policy/legislative ones.

We raised the possibility of using form SA303 – Claim to reduce payment on account
and the response was,“How we calculate payments on account is based on the
previous years liability, but do not include any student loan contributions for that year.
I don’t think therefore that this idea should be progressed, since it would involve a
juggling of liabilities that I think would prove too complex and would incur a cost'.

SA Customer over payment issue: It was thought that the CSL guidance is not very
well linked to SA guidance. Liz Cunningham asked if it was worth taking an extract
from the leaflet and putting it on the website so that it would get to the target
Action - Alex Lawrence will look at the SA guidance and see if it should be ‘sign
posted’ to student loans.

15 June 2010 – We are looking at what can be done to improve/beef up the
guidance and the CSL leaflets begin to address this.

CSL1 - Collection of Student Loans for SA borrowers A quick guide

                                        Page 16 of 17
CSL2 - Collection of Student Loans a guide for employers and employees to help
answer common Student Loan queries. See 1/150610
Action – Still under review. Alex Lawrence will provide a written note to the group
when the point is resolved.
14 September 2010 – Carry forward.

30 November 2010 – A link to over-repayments is being included in all the leaflets.
In addition to a narrative description there will also be a link to the SLC site.

Pete Jukes asked if there were standards around links (URLs - Universal Resource
Locator). Alex Lawrence advised that there were and this was part of the ongoing
convergence work at HMRC. Design approval is needed before a CSL product can
go on the web.

15 February 2011 - Updating and linking CSL and SA guidance. The anticipated
implementation date for this will be 6 April to tie in with other annual updates to core
content. It will include links to the CSL leaflets, and CSL core content as previously
mentioned.(Alex Lawrence)

22 February 2011 – Closed

12. Any other business
Peter Jukes asked if there were still plans to have a teleconference.

Liz Cunningham explained that the intention had been to have this meeting as a
teleconference but as there were expected to be guest presenters on RTI it was
made a face to face. She still thought it was a good idea to have a teleconference for
the winter meeting.

13. Date and venue of next meeting
Future Meetings

Tuesday 24 May 2011 London
Tuesday 20 September 2011 London
Tuesday 6 December 2011 London

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