Following the recent contracting-out forums held by HMRC in Edinburgh, Leeds, London and Newcastle to discuss macro issues relating to the end of contracting-out, we've rounded up the key issues and changes that you need to be aware of.
The end of CA forms?
Sent to HMRC…
For events that happen after 5 April 2016, administrators will no longer submit CA forms to HMRC informing them of the event – it will be up to administrators to ‘track’ the GMP liability in conjunction with other interested parties, such as a scheme receiving a transfer payment.
Sent by HMRC…
From January 2016, HMRC will no longer issue a CA1625 when a member leaves contracted-out service or a CA1629 when a member is approaching State Pension Age – administrators should ensure they have enough information to identify GMPs on leaving and due to come into payment.
Notice of widow(er)s GMP will continue to be issued until December 2018 and after that, administrators will be responsible for identifying any eligible spouse. Historically, these widow(er) notices have been helpful in identifying benefits payable from a scheme where a member has died after leaving service and before their pension is paid. Given the focus on record keeping and data improvement, we don’t foresee delays in paying future benefits when they fall due.
...the demise of CA forms and HMRC tracking should help you make up your mind. Trustees are to have the future responsibility for tracking GMP liabilities and will not have HMRC records to fall back on in case of any disputes with members or other schemes. This may have an impact on the future costs of administering the scheme and paying benefits.
GMP micro service
The snappily titled Accrued GMP Liability Service and Contracted-Out Contributions and Earnings Information Service – AGLS and COCIS to their friends – are being phased out and will be unavailable from 2019. HMRC are currently developing an online self-service facility for administrators to use in place of these services, currently known as 'CheckMyGMP.com'. HMRC are looking for volunteers to be part of the testing process – as part of the user research (what outputs/functionality does the industry want to see?) or being part of a system pilot.
This is the process of HMRC providing data for members who are still contracted-out. HMRC have issued a survey asking what information administrators would like them to provide and how. Feedback during the forums was that earnings data (usually provided by COCIS) will not be provided as standard and that the output of the closure scans is likely to be staggered throughout 2016 in order to avoid a 'big bang' of queries from administrators. Further information should be provided as part of the Countdown bulletin due to be issued in February 2016.
As announced in Countdown bulletin 12 – December 2015, HMRC are holding additional forums early in 2016 which will focus on issues relating to Scheme Reconciliation Service.
CEPs can be paid until April 2019
HMRC are still uncertain what information will be provided to members
Get involved in the testing for the GMP micro-service