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Gov.uk

May 28, 2013

What do we think about the new! improved! all-singing, all-dancing! government website, gov.uk?

I only ask because, of course, all the government’s tax consultations have been moved onto the new site, and because of the suggestion – which also became a recommendation by the House of Lords Secondary Legislation Scrutiny Committee – that there should be a single government website listing ALL consultations in the order of the date of closure.

Because – as I have previously mentioned – if you go here, to the consultation page, you have to filter first to get “consultations” from the welter of other “publications”, and then you have to filter again by department (not subject) to get HMRC and HMT consultations, and even then there’s no way of filtering out tax consultations from other Treasury consultations.

However this gives you a list of (today, at least) 19 HMRC consultations and 89 HMT consultations – but of the HMRC 19 there are only four open consultations, as against 10 “closed consultations” and four “consultation outcomes”, and HMT has 5 open consultations, 45 “consultation outcomes” and 39 “closed consultations”.  Wouldn’t it be great if you could just filter by “open consultations” and THEN by Department and get to the nine you were actually interested in?

I had assumed the functionality wasn’t there on the website and that, in response to the House of Lords Committee’s recommendations, they’d be working on it when and if resources allowed.

And then I came across this page, on Getting Involved, where there is a running tally of open consultations telling me there are, currently, 55 open consultations across the government, or at least across government departments and agencies that have moved their web presence over to the Gov.uk site.

So the functionality to identify open consultations IS there somewhere, but isn’t being used in a way that would actually be useful to the users of the site?  You’d almost think it was deliberate…

Posted in Consultation | Tagged , , | 9 Comments »

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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”?

Posted in Consultation, HMRC | Leave a Comment »

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Um… hello?

May 10, 2013

efficient secondary legislation and engagement with the public through the medium of consultation is, in my view, the very bedrock of an effective and inclusive parliamentary democracy.  (The Earl of Lytton, Hansard  11 March 2013 Column GC34)

 

Maybe I’ve just lost my google-fu, my ability to find stuff on the internet? I don’t know.  I’ve been busy with the day job (I’m a PhD student by day and a writer of science fiction and fantasy by night) so maybe I’ve taken my eye off the ball.  But it occurred to me lately that, as well as finishing off my responses to the consultation on closure of the HMRC enquiry centres (the consultation closes on 24th May and I’ve already blogged about it here, here and here.  Oh, and here.  Not to mention here.) I should also check out what other tax consultations are around and plan what work I’m going to do on this blog over the next few weeks and months.

Um… hello?

So there doesn’t seem to be a tax tracker on the HMT pages any more.  The Treasury has moved all its consultations over to the new GOV.UK website, and the links on the Treasury site now take you to the consultations search page on GOV.UK, here.

Which might be helpful, except that, at the time of writing, there are 991 documents under the “consultations” heading on that page, they include open consultations, closed consultations, and consultation responses (and there’s no way to filter by “open consultations”).  Oh, and they’re in date order – of the date they were published and not by the date which would actually be useful, ie the date that the consultation closes.  (Has anyone told the Secondary Legislation Scrutiny Committee? (see para 54 here))

Filtering this with “tax and revenue” as the topic brings up five documents, the enquiry centre closure consultation and four closed consultations.

Well OK then.  Filtering it again by department, brings up 87 documents under HMT, only three of which are open consultations. (Two on finance industry topics, the “special administration regime for payment and settlement systems”, and one on “opening up UK payments” which I may go back to, because from a cursory glance it looks to be about abolishing cheques) and – finally – a relevant one, yet another tweak to the REITs regime, the rules on Real Estate Investment Trusts.

Filtering it by department again but this time scrolling down to find HMRC brings up fifteen results.  Only one of those is an open consultation, and it’s our old friend “Supporting Customers Who Need Extra Help: A New Approach”, which is newspeak for “Closing the Enquiry Centres”

But look back at this time last year.  In April and May 2012 I was responding to a dozen open consultations resulting from Budget announcements and pointing out that there were no fewer than 21 formal consultations which were listed on the tracker as being due to open in May.

So where are the 2013 consultations?  Were there no tax changes announced in the 2013 Budget?  (They weren’t all consulted on in a fortnight via twitter while I wasn’t looking, were they???)

The HMRC Budget 2013 page says all consultations will be on the GOV.UK site.

So, um… hello?  Where are they?

 

Posted in Consultation, HMRC, HMT | Tagged , , , , | 1 Comment »

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Return of the tax muggles

April 26, 2013

It’s like there’s this vast complicated otherworld existing alongside our own.  In the otherworld – let’s call it Taxworld, for the sake of argument – in Taxworld there are people who understand the mysteries of tax, who speak its language and share its assumptions.  Then there are the muggles, the rest of us, who live in the mundane world and don’t ever see the bizarre world of tax living alongside and parallel to our own, except when it thrusts itself into our attention in, say, a mysterious piece of code on a payslip or a scary brown envelope on the mat.

Me?  I suppose I’m a Squib: I know the Taxworld is there, and I know some of its funny little ways, but I’m on the side of the muggles, mostly.

So here comes the head muggle, “Tax Prat of the Year” Margaret Hodge and her merry band, issuing their PAC report into  Tax avoidance: the role of large accountancy firms

Their conclusions?

  1. The UK tax system is too complex and a more radical approach to simplification is needed
  2. There is no clarity over where firms draw the line between acceptable tax planning and aggressive tax avoidance
  3. It is inappropriate for individuals from firms to advise on tax law and then devise ways to avoid the tax
  4. Tax laws are out of date and need revising.
  5. Greater transparancy over companies’ tax affairs would increase the pressure on multinationals to pay a fair share of tax in the countries where they operate.
  6. HMRC is not able to defend the public interest effectively when its resources are more limited than those enjoyed by the big four firms.

The headlines, of course, are all about conclusion 3: is it appropriate for accountancy firms to loan out their staff to the Treasury and HMRC and then have them go back and work on the same legislation from the other side of the picture?

This is a red rag to a bull, so far as the accountancy and tax professions are concerned.  They think of themselves as professionals, and that they are more like the barrister who can give objective advice to a party to a court case whether the person is innocent or guilty.  They certainly do not recognise themselves in the “poacher turned gamekeeper” that PAC perceives.

To me the meat of the argument is in conclusion 6, but then I’m a retired tax inspector so I would say that, wouldn’t I?  But HMRC has lost 10,000 staff and many of its qualified and experienced staff are in their fifties and are leaving at an alarming rate – and there is very little “backfill” of people who have been through training and being seasoned by experience to fill those gaps.

Accountancy Live also reports that “hard working tax accountants” pay has risen by 10% in a year to an average of £79,670.  Which must be nice, because their HMRC equivalents have been frozen since 2011 at between £46,983 and £74,209.

So if HMRC is under-resourced, understaffed and underpaid, how are they to proceed except by borrowing staff from people who know about the subject under discussion?  Would it be more reasonable to take staff seconded from, say, a steel manufacturer or a supermarket?

To me, this is one giant red herring.  The responsibility for the existence of tax legislation and for the quality of that legislation lies with the people who make it, with Parliament.  Since the coalition came to power it has had a clear set of priorities for the tax system, set out at article 29 on page 30 of The Coalition: our programme for government:

The Government believes that the tax system needs to be reformed to make it more competitive, simpler, greener and fairer. We need to take action to ensure that the tax framework better reflects the values of this Government.

Part of that framework was set out in Tax policy making: a new approach which led to the invention of the TIIN – the Tax Information and Impact Note.  So each Budget they publish their proposals, consult on them, and then bring the legislation to Parliament along with a TIIN which tells you what the legislation does and why, how much it will raise and how much it will cost, and who will be affected.

Does Parliament ever look at them?

Do MPs ever challenge the legislation, and if they do, are any changes ever made?

Meanwhile the big glaring elephant in the room is the commitment to a tax system which is “more competitive, simpler, greener and fairer”.  In Taxworld, a “competitive” tax rate is a lower tax rate – a rate which competes for business with other tax jurisdictions.  Yes, it’s official coalition policy that, in the great multinational tax race, the UK should do its best to win the race to the bottom.

Posted in Bit of politics, HMRC, HMT | 5 Comments »

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Closing the enquiry centres: part four

April 16, 2013

There’s a nice flowchart in chapter 5 (on page 10) of the consultation into what will replace the closed enquiry centres.  There are different coloured pathways, each ending in a smiley face and a comment like “resolved online”  or “resolved by HMRC contact centre”

My google-fu isn’t sufficient to reproduce it here but, please, go to the consultation and have a look at it.  See that big box in the middle, the one that nearly all the pathways lead through?  The one that says:

HMRC Contact Centre

Straightforward queries are solved on the spot by expert advisers in HMRC’s contact centres

Customers needing extra support are referred to the new HMRC specialist support team

Where does that leave the rest of us?  You know, those of us who ring the contact centre with queries that aren’t “straightforward”, but we aren’t deemed “needy” enough to qualify for the “extra support” of the new HMRC specialist support team?

The flow chart is silent.  There’s no arrow leading us out of this binary box.  Either our queries need to be “straightforward” enough that the contact centre can answer them, or we need to be “needy” enough to qualify for “extra” support.  There’s no third way, no provision for an ordinary taxpayer with an out of the ordinary problem.  We can bounce around inside the big box and never reach a smiley face at the end of the pathway.

>:-(

Posted in Consultation, Equality, HMRC | 4 Comments »

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Closing the enquiry centres: part three

April 12, 2013

Let’s delve a little further into the weasel words of the consultation into closing HMRC’s enquiry centres – or, rather, the consultation into what will be left when the enquiry centres close.

3.16 When an adviser decides that the customer’s query is best dealt with by a voluntary and community sector organisation, they will provide information to the customer to help them choose the organisation most suited to their needs

So… at the moment I could wander down to my local enquiry office and ask someone a question.  Most of the time I would be pointed to a phone hanging on the wall and told to phone the helpline, but at least if I found the helpline didn’t know the answer, or I couldn’t understand what they meant, then I could make an appointment to speak to someone about it, probably with a few days wait time.  Under the new proposals I wouldn’t have that facility at all.  The choice of a face to face meeting is taken from the taxpayer and given to the Department.  Am I “needy” enough?  Would I be identified by an HMRC advisor as having sufficient “need” to warrant being given anything but the same answer over and over?

All of us who have tried to find something out on a website and got “stuck” will know how frustrating it is to be directed back to the same site, the same words.  When you don’t understand the words, or they don’t quite answer your question or fit your circumstances, and all you want is the reassurance of talking to a human being (“So if I put just ignore the pennies and put the pounds in the box that’s all right, is it?  Or do I have to round it to the nearest pound?”) well, tough.

Am I exaggerating?

And what about the idea that HMRC will simply tell some people to bog off and talk to someone else?  Or, to put it another way, “3.16 When an adviser decides that the customer’s query is best dealt with by a voluntary and community sector organisation, they will provide information to the customer to help them choose the organisation most suited to their needs”

Does this not mean, then, that some cases HMRC will decide the customer is too “needy’ or difficult, or their affairs are too complicated, or it’s simply not “cost effective” to help them, and will instead shuffle them off to a “voluntary and community sector organisation”.

Where are these organisations to come from?  Where are their volunteers, their funding, their training and experience, to take on the work that a government department has decided it hasn’t got the funds to provide for its citizens?

Am I the only person appalled by this?

For shame, HMRC.  We are citizens, not customers; we have rights and responsibilities.  And a government department doesn’t get to decide whether we’re “needy”.  And it definitely doesn’t get to decide whether we’re needy enough.

Posted in Consultation, Equality, HMRC | 3 Comments »

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Closing the enquiry centres: interlude

March 29, 2013

Yesterday I suddenly remembered that on 11 June last year I blogged about the HMRC Enquiry Offices not being included in the programme of work that – finally, after seven years – replaced all the old Inland Revenue signs with new HMRC ones.

And, when I was looking for the entry, I also noticed the entry from 8th June regarding the Bentley case and my prediction that Enquiry Centres would soon have to have notices warning they couldn’t cope with demand.

Just how long have they been planning the closure of the enquiry centres anyway???

Posted in Bit of politics, HMRC | 1 Comment »

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Closing the enquiry centres: part two

March 28, 2013

In today’s weasel hunt, let’s move on to the detail of the proposed replacement for HMRC’s Enquiry Centres.

Section 2 of the document is all about defining our terms – looking at who these people are who need the “extra” help that will replace the Enquiry Centres.  There are six categories of “need” identified, one of which is people needing help because of HMRC “complexity and errors”.  The others are:

  • difficulty of accessing current services
  • personal confidence
  • mental or emotional state
  • lack of ability
  • complexity of the enquiry

and there are further examples and descriptions of what might put a person into one of these “needy” categories such as hearing or eyesight issues.

Now this bothers me.  I reject the initial premise that help should only be provided for those with “extra” needs rather than to all citizens, but even if you accept that premise and take it on its own terms, look at the contrast between this and the current enquiry centre offering, where it is explicit that “most” enquiry centres “can” offer

  • Induction Loops.
  • Lighted Magnifiers – to help you read our forms.
  • Crystal Listening Devices – to help you if you are hard of hearing.
  • Sign Language Interpreters – we can arrange a British Sign Language Interpreter for you if you let us know in advance.
  • Written material in Braille, audio and large print.
  • Help for people for whom English is not their first language – we can arrange interpretation for you. Please ask at your nearest Enquiry Centre.
  • Help for people who need assistance in completing forms or returns – We can help you. Please ask at your nearest Enquiry Centre.
  • Home Visits – if you have limited mobility or have caring responsibilities we may be able to offer you a home visit. Please ring the helpline.

I’m not sure how much I believe this – there’s a big difference between something you “can” offer and something you actually DO offer – but look at the proposed new “improved” offer:

3.6 The adviser will identify customers who might need extra help, based on a number of factors identified by our research. They include customers mentioning their disabilities, being particularly anxious and/or distressed, failing to understand the guidance being given or follow the conversation, repeating questions, inability to express themselves…

So let’s take the example of a person who is elderly and hearing impaired.  At the moment, she can go to an enquiry centre and ask to use the induction loop so she can hear the adviser via her hearing aid, checking for accuracy via lip reading and facial expression, and be treated in the same way as any other customer except for the organisation making the reasonable adaptation necessary to comply with the Equality Act in its dealings with her.

In future?  She’ll have to ring up and rely on an adviser identifying her as needing extra help – is she deaf enough?  old enough?  to be “deserving” of the “extra” help that the Department might “offer“?

Is it just me, or is this so offensive it makes your head want to explode?

 

 

 

 

 

 

(edited 28/3/13 to replace “DDA” with “Equality Act” – the requirement to make reasonable adjustments is now in section 20 of the Equality Act 2010)

Posted in Consultation, DDA, HMRC | 2 Comments »

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Closing the enquiry centres part one

March 20, 2013

All right then, let’s have a look at the consultation on HMRC’s closure of its enquiry centres.  It’s here, on the GOV.UK website and please note it closes on 24 May.

But don’t rush – the decision to close the enquiry centres has already been taken.  The consultation isn’t about whether to close the enquiry centres but about what kind of “service” will replace them.  You think I’m exaggerating? Because the introduction says:

No final decision will be made until we have consulted on and piloted the new service, and fully assessed the findings of the consultation and the pilot.

But look at the summary of consultation questions, on page 16 – there isn’t one question where respondents are asked whether closing the enquiry centres is a reasonable idea unless you think you can sneak it into question 2:

What do you think are the main benefits and disadvantages of the proposed new approach?

So let’s start.

Why we are changing

1.1 Some HMRC customers need extra help to get their taxes and entitlements right. We want to provide this extra help in a way that suits them.

All right.  Look at the weasel word “extra”.  SOME customers need EXTRA help.  What about the rest of us, who just need, you know, help?  Not “extra” help, over and above: just “some” help?

Now, I know my way around a tax return.  But just about every year that I’ve had to complete a tax return I’ve hit some kind of snag, somewhere that I’ve wondered which box does this go into, does that mean the net or gross figure…   Do I need “extra” help, or just “help”?

People have been complaining for years about being called “customers” instead of “taxpayers” and this consultation makes it clear to me why.  Because taxpayers are citizens and citizens have rights; customers are sources of revenue who have customer service, tailored to their value to the organisation.  And a low paying customer like you or me will get a lesser service than a high value customer like a multinational.  We don’t get a customer relationship manager or a customer coordinator: we get the “pay up and piss off” service.

Moving on.

1.2 Most customers with simple queries choose to visit our website for help…

Do they?  Do they really?  The weasel word this time is “choose”.  Do they make a “choice” to visit the HMRC website, or are they driven to it because the enquiry centre is only open between 9.30 and 1.30 on Tuesdays and Thursdays and there’s nowhere to phone up and check that out before you actually get there, and it takes five minutes to answer the phone and that’s after you’ve navigated through two minutes of recorded messages and telephone trees…

Again, let’s move on to 1.3

For many people, visiting an Enquiry Centre is not, and has never been, a convenient option. Because of this, some customers have struggled to get the support they need from us.

Let’s play “spot the weasel”, shall we?  Anyone?

Yes, that’s right, it’s “and has never been”.  Because at least in direct taxes, in the days of the old Inland Revenue, we used to have a network of tax offices in the communities in which they served, with an enquiry counter where people could come in and drop off their tax returns and ask their questions.  And, because of the structure of the organisation, there were other people in the building with specialist expertise who could answer trickier questions and access specialist advice.  The reason enquiry centres aren’t a convenient option now is purely down to the actions of the organisation since the merger.  So it may be true, but it isn’t a law of nature – it’s a political decision.

Moving on…

1.4 Even for customers living close-by, the use of Enquiry Centres has fallen sharply in recent years…

In our Hexham office, which received just 601 visits last year, the average cost of an appointment is £185.

I had to google Hexham (it’s in Northumberland – looks a really nice place for a visit actually) but it didn’t take me long to work out why they only had 601 visits last year: if you look at the helpfully inaccessible spreadsheet here you’ll see that the Hexham enquiry office is open for exactly four hours a week, between 9.30 and 1.30 on Friday mornings.

And there I’m going to stop for today and try to calm down a bit.  Although the Budget’s starting in a few minutes, so maybe it’s time to break out the emergency bottle of Talisker…

Posted in Consultation, HMRC | 2 Comments »

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Corrections and clarifications

March 18, 2013

I am, rather unusually, posting from a coffee shop on my mobile phone so forgive any infelicities of formatting.  But I’ve just seen this, from The Times’ “corrections and clarifications”:

The closure of HM Revenue & Customs inquiry centres will not, as reported…add 2 million extra calls to HMRC phone lines. Of the 2.4 million people who attended enquiry centres in person last year, 2 million were already being directed to make their enquiries by telephone.

So 2 million people – TWO MILLION PEOPLE – walked through HMRC’s doors and were told to piss off and pick up the phone instead? They were given an appalling service so we’re going to make it better by abolishing it? And what about the four hundred thousand people with whom HMRC evidently DID deign to converse? Will they get home visits?  This is nonsense!

Posted in HMRC | Leave a Comment »

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