HMRC updates CJRS guidance again
27 April: Updated guidance from HMRC includes how to report wages using RTI, a new calculator and more explanation about who qualifies. ICAEW’s Tax Faculty outlines the changes and shares a new downloadable template.
On 24 April 2020, several pages of HMRC guidance on how to use the Coronavirus Job Retention Scheme (CJRS) were updated and more have been added to GOV.UK.
For employers and agents who spent much of the last week submitting claims, this may seem too late, but as the claims process will need to be repeated several times in the next few months, some of the clarification will be welcome.
New and updated guidance:
ICAEW is able to share a useful CJRS claims template from HMRC which may assist in record keeping for future claims.
Reporting payments in PAYE RTI
Of all of the new documents perhaps this guidance has the most practical significance; some employers have been confused about what to report and when.
The key rule to keep in mind is that an employee should be paid in accordance with their employment contract, which may of course have been renegotiated in the light of the COVID crisis. This may mean the employer is now only paying wages in line with the grant they expect to receive for each employee.
An employer who has followed the normal Real Time Information (RTI) reporting rules, reporting payments to employees on or before the date they are actually paid, will have already complied correctly. The date the furlough grant is received by the employer will have no impact on RTI reporting. This merely emphasises that the cash coming in and that being paid out to employees are looked at separately.
Some employers will have already run payrolls for furloughed staff earlier in April, making the usual RTI reports, so receiving furlough grant funds now does not need a further RTI report.
However, some businesses which waited to receive their grant before paying wages, may not yet have made RTI reports, but should do so now when they run the payroll as usual.
This document sets up various scenarios, including what to do if you have made an FPS submission in March 2020 incorrectly.
The guidance also gives an important reminder emphasising that RTI reports indicate when the individual receives their wages for Universal Credit (UC) purposes. So it is important to get the report in the correct UC assessment period.
A new section on using an agent to make claims has been added.
A new CJRS calculator has been added to GOV.UK. New paragraphs are added to this guide giving more help with the calculations. It also explains that there is currently no facility to make amendments to a claim to the CJRS grant.
This will be unsettling for many employers, but it seems that amendments will be built into a future update. In the meantime, an element of pragmatism would seem sensible provided detailed notes are retained for the details submitted.
This guidance includes a new section explaining how an employee can contact HMRC. This is a web only service. There is also a detailed explanation of the rules affecting those made redundant after 28 February or after 19 March, who are subsequently reemployed.
For employees on fixed term contracts, note that the employer can renew or extend the contract, relevant for future furlough discussions, but must have done so before the contract ends.
This guidance contains a table and more explanation of the connection between eligibility for the CJRS, employment on 28 February or 19 March, and the cut-off date by which an RTI submission notifying payment must have been made to HMRC.