Closing the enquiry centres: the final response

May 24, 2013

Don’t forget that today is the last day to make your feelings known about the proposal to close HMRC’s face to face enquiry centres.  Here’s what I sent:

This is an individual response and is also published online, with commentary, on my blog http://tiintax.com.  There were four earlier blog posts on this issue which you might also find interesting to read.

1.  You have not included the question of *whether* contact centres should be closed within the scope of your consultation, presumably because the decision has already been taken.  However you say you will evaluate the “pilot” closure before proceeding further.  Given that the research on which your decision is based is only into the “always needs help” population (and does not include those of us who are “willing but need help” occasionally) I strongly suggest you include some customers in the group evaluating the pilot closure.  In particular, you ought to assess the impact on customers in your “willing and able” and “willing but needs help” categories as well as on the “always needs help” group.  You should do this by appointing an external scrutiny panel to work with you on the evaluation.  This should include trades union representatives and civil society groups from the affected area.
2. Here are the answers to your specific questions.  However you should note that your consultation document has some accessibility issues, for instance the inability to convert it to another format (e.g. at the simplest level, to copy and paste from it into an email) and is not in accordance with best practice.
Q1 Have we missed any particular groups in our definition of customers who need extra help?
This is a fundamentally misconceived question.  The enquiry centres support ALL of HMRC’s customers, not only those who need “extra” help.  Your proposals do not seem to allow for any service offering other than telephone and the web for anyone except “customers who need extra help” and so I suppose my answer is that the group you have missed is, everyone else!
Q2.  What do you think are the main benefits and disadvantages of the proposed new approach?
Clearly the main advantage is that you will “save” some £60 million a year in operating costs by closing the enquiry centres.  The main disadvantage is that you are diverting some £60 million a year away from customer service without any clear advantage in return.  The ordinary citizen has, surely, a right to a service from HMRC that enables them to pay their taxes efficiently.  Unless you can radically improve your basic service level offering over the phone and on the net, you are effectively taking £60m “savings” by putting the costs onto service users and civil society organisations.
The consultation also suggests to me that “ordinary” taxpayers are being offered a “take it or leave it” service and that the decision whether a person requires “extra” help will rest with HMRC rather than the service user.  This is deeply offensive – for example, I have a mild hearing impairment.  At present I can decide for myself whether I am able to transact with you over the phone or require further assistance either in person or otherwise.  Under your proposals it seems I will have to explain my impairment to a call centre operative and let THEM decide whether I’m disabled ENOUGH to be offered assistance.  I consider this is not only a “disadvantage” of your proposals but is likely to be in breach of your  statutory obligation to provide reasonable adjustment to citizens with disabilities.
Q3  Could any particular groups of customers find it difficult to contact HMRC using the new service?
Um… all of them?
Q4.  How do you suggest we can overcome any difficulties?
By treating taxpayers and service users as citizens with rights, rather than customers.
Q5  How else could we improve the proposed new service?
Ask the people affected at regular intervals.  Use citizen juries to check your conclusions.  Establish an oversight committee with representatives from civil society groups, trades unions and other affected parties to report back on progress.
Q6  What else could we do to improve:
(a) our new extra support telephone adviser service
(b) direction of certain customers to the voluntary sector and vice versa
(c ) the flexibility of our approach to providing support for those customers who need it?
A – see A5, above
B and C – these seem to me to be fundamentally misconceived questions.  HMRC should not be abandoning customers by telling them to eff off and talk to a charity – you have a duty of care towards all the citizens who transact with you, and “flexibility” is not, in and of itself, a positive to which you should aspire.  What you should be aspiring to is a satisfactory service (or, preferably, a better than satisfactory, i.e. a GOOD service) to ALL citizens of the uk.
Q7  Are there any other factors we need to take into account when trying to identify people who need extra help?
It is not your place to “identify” people who need extra help: people should be able to access help according to their own assessment of their needs, and you should be meeting those needs in accordance with the concept of all citizens having equal rights.
Q8.  Is there anything more we need to do to make sure that customers who currently use our Enquiry Centres, but don’t need extra help to resolve their query, can access our services?
You need to make substantial improvements to both your web and telephone offerings.  You might try a number of approaches, including but not limited to:
  • using citizen juries and other feedback mechanisms to improve your web presence
  • using basic feedback forms to capture feedback from users of the website in order to improve it
  • responding to enquiries submitted via email, twitter and other social media platforms and aggregating any frequently asked questions to create a dynamic feedback loop to improve your website
  • experiment with actually answering your phones (rather than filtering calls via recorded message trees)
  • take note of the research with clearly indicates that people dislike multilayered menus and voice recognition systems and increase the number of actual human beings responding to calls
Q9.  Are there any impacts on particular groups of customers that we have not identified and that need to be addressed?
Yes: people who need one-off help do not appear to be well served by the suggested new service.
Q10 How do you suggest we can overcome these?
See 8, above.
Q11.  Are there any other groups of customers that we have not included in our considerations.  If so, please specify who they are and let us know what we need to take into account in respect of these groups.
See 9 above.
Q12.  What other methods of communicating the consultation response should we be considering?
Seriously?  You’re going to close down the face to face service and you’re asking us how we prefer you to tell us?  How about “in a hundred years time”?

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