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WE CAN'T REMEMBER, in the Taxation office, whether the form was called a 2CI or a 5CI, but since all three of us have spent some time working for the 'other side' in local tax districts, we do remember having to report on a regular basis the number of items of post we had to which we had not yet replied. No doubt our readers will remind us of the reference, though I understand that the system has since been changed to one based on traffic lights. In our (no doubt soft-focus) memories, it was highly unusual to have items waiting over 28 days. What, then, are we to make of the following extract from a letter sent to a Taxation reader from a 'complaints handler' at Centre 1 in East Kilbride?
'When a Contact Centre member of staff receives enquiries about delays in receiving a reply to correspondence which we have recorded as being received, I understand the staff have been instructed to give the caller a realistic expectation of when they may receive a reply. At the moment I understand that to be between ten to twelve weeks.'
Well, the first response must be to resist the temptation to shoot the messenger. It is far better to be given an honest and realistic response rather than an over-optimistic one which is not going to be achieved. The letter goes on to acknowledge that this level of service is not good enough and says that senior managers are addressing the problem. But the second response is to ask why this problem still persists, and if so what can be done about it.
Surprising statistics?
We asked the HMRC press office for details of the delays at Centre 1, and received a detailed reply.
'The Department's published target for correspondence is to deal with 80% completely within 15 days (we often have to obtain information to fully deal with the correspondence). Centre 1 is meeting that target and general correspondence is currently all being dealt with within 18 days.'
Now that is good to hear, but why is it that Centre 1 is still often referred to by practitioners as if it is a black hole into which correspondence is sucked, never to reappear? Is that just a historic hangover, or is the explanation more complex? Note the reference to 'general correspondence' in the HMRC reply above, because this is where the problem seems to lie.
Unappealing
Our reader's case concerned a late submission of a tax return. The return showed an amount of tax due which was less than the penalty, but attached to the return was a letter appealing against the imposition of any penalty due to certain personal circumstances of the taxpayer. The good news was that the return was processed promptly; within two weeks. The bad news is that the appeal was not.
Three weeks after submitting the return, the adviser sent a reminder about the appeal. Six weeks after that a reply to the reminder was received, which confirmed that the appeal had been received, but regretted that it had not yet been actioned. It was this that thoroughly exasperated our reader — why waste time replying to the reminder rather than dealing with the original appeal?
A complaint was sent in a week later, which received a response within a few days, from which I have already quoted the comment about a 10 — 12 week delay. It also explained that the appeal was separated from the return, and from the general correspondence, and put aside. There is, apparently, a 'rolling programme' allowing a number of appeals to be examined each day. The programme had obviously not 'rolled' far enough by the time the reply was being sent to our reader some eleven weeks after the appeal had been submitted, as the complaints' handler had to trace it; the appeal was accepted and the penalty cancelled.
But what of HMRC's assertion that all general correspondence was dealt with in 18 days? Well, it depends what you mean by 'general'. The press office said:
'Centre 1 receives over 20,000 items of correspondence each week and some of that will be more complex. You will appreciate that appeals against penalties, for example, can be complex and have to be considered carefully by experienced officers. Centre 1 is experiencing some delays in this area as it has lost some of its most experienced staff who would normally do this work. Local managers have plans in place to get that work back on track and the backlog will reduce significantly in the next month or so.'
By the time this article is published it will be a month later, so we would be interested in hearing from readers whether they still have technical correspondence with Centre 1 that is unanswered more than two or three weeks after it was submitted. Certainly the reader whose letter led to this article being written does not think that it has improved, she says it is a problem which has been going on for at least two years, and she never gets a response to correspondence within two months.
… and statistics
Which all goes to show how limited a picture statistics can paint. Looking at the correspondence in this case, there is only one piece of 'general' correspondence which has not been handled promptly — the six weeks that it took to reply to the reminder letter. The return was processed promptly, the complaint letter was answered promptly, and the appeal was not general correspondence. But the appeal is the crux of the case, and replying to the reminder without dealing with the appeal added insult to injury.
So while I have no reason to doubt the accuracy of the statistics, they do not show the real story. I am sure that in many other routine cases, maybe even in most cases overall, Centre 1 meets expectations and provides a decent service. It is always going to be the things which go wrong that stick in the mind, not the things that go right. But by their nature, the letters that agents send in are more likely to be of a technical nature, and certainly the more important letters are most likely to be the more technical ones. Regardless of what answers you get from a purely arithmetical analysis, the real-life experience of our reader is one of frustration and aggravation as she waits two or three months for a reply to a letter, and then sends off a response knowing that she will have to wait another two or three months before getting a reply to that.
Call centre blues
Another key to the aggravation felt by agents is the reference to the 'Call Centre staff' giving the estimate of ten to twelve weeks to callers. Our reader's temper is not improved by her inability to ring in and speak to someone who can deal with technical queries. Call Centre staff can answer basic questions such as the amount of tax due, but anything more complex needs to be dealt with by a technically trained officer. The standard procedure is apparently for one of these to ring back within the next three days. In other words, the system is run entirely on HMRC's terms, not on the terms that react to the needs of agents.
Additionally, it is not possible to deal with queries by email. So practitioners are forced back into using snail mail, at precisely the same time as HMRC are (quite rightly) insisting that the future is online. 'Oh, for the days when you quoted the last three digits of an NI number and spoke to someone who dealt with the enquiry there and then' says our reader. That, of course, requires a system which ensures you will generally speak to the same person in HMRC who has ongoing responsibility for ensuring that particular taxpayer's affairs are dealt with.
Most tax departments in accountancy and tax adviser firms are organised in much the same way. For every client, there is a known point of contact for dealing with their tax affairs. Technology has dramatically changed the way that the profession operates over the past two decades, but the basic organisation has remained the same, at least in part because clients want to know who they should call if they have a problem.
By contrast, the Inland Revenue and now HMRC appear to have been immersed in a Trotskyite's dream of permanent revolution. Initially this was at a macro level, as various grand schemes for organising and reorganising services were started but never completed before being overtaken by the next. Indeed, the very name of Centre 1 indicates that there were meant to be a number of other very large PAYE processing centres which never materialised. But the more recent change is that there is no longer one person who has responsibility for a taxpayer's affairs, and it is harder and harder to talk to anyone who has any serious technical tax training.
Our reader was at pains to point out that she was not attacking Centre 1 staff, who she felt were 'good people forced into adopting the call centre regime and a system that is totally unfriendly'. I agree. I am sure that the managers at Centre 1 are doing their best to sort out the backlog of post, though I am less confident than the HMRC press office that they will be able to do so. But the problem is structural, not purely logistical. Call centres don't work for agents, and the profession needs to be able to deal directly with people who know the tax system, know their taxpayers, and have responsibility for getting their affairs right. Correct me if I'm wrong, but I have a feeling that tax officers would welcome that too.
