Delivery of employment support schemes in response to the COVID-19 pandemic

While payments under the schemes have ended, the need to bear down on error and fraud has not. HMRC should: a) as part of strengthening its methodology for remaining compliance work, analyse its performance in tackling the main risks of non-compliance and identify what further data it can use to identify and tackle risky claims, including for those where employees may have been working while being claimed for furlough

Ref Page 12, Paragraph 20, point a · Implemented Q4 2023-24

In determining how the government should respond in a future crisis: i) HMRC should identify the data it would need to increase accessibility of future schemes and reduce deadweight costs and error and fraud. It should consider plans to improve the responsiveness and resilience of the tax system to future economic shocks

Ref Page 13, Paragraph 22, point i · Implemented Q4 2024-25

k) HM Treasury should ensure it develops robust plans for responding to economic shocks linked to health, environmental or other crises. Plans should be stress-tested to identify improvements and continually refined

Ref Page 13, Paragraph 22, bullet k · Implemented Q2 2025-26

b) work with the Cabinet Office and government?s counter-fraud functions to improve protocols and thus increase the consistency of data collected on grant claimants, and the pace at which data can be shared between HMRC and other public bodies, in order to identify risky claims now and in the future

Ref Page 12, Paragraph 20, point b

c) restate its expectations for compliance work in the light of performance to date and publicise the number of criminal investigations, and amounts at risk, to act as a deterrent. It should consider how its tax compliance work needs to be adapted to include erroneous grant payments and encourage non-compliant taxpayers to return overpayments in advance of this compliance work

Ref Page 12, Paragraph 20, point c · Implemented Q4 2023/24

In evaluating the value for money of the schemes and learning lessons for the future, HM Treasury should: g) as part of its evaluation of the schemes, define and assess the extent of deadweight, looking at the full range of indicators including the amount of grants paid to employers and the self-employed whose incomes increased, including commissioning research where appropriate to cover gaps in data from existing systems;

Ref Page 13, Paragraph 21, point g · Implemented Q2 2023-24

d) as part of improving its methodology for estimating error and fraud, develop scheme-specific estimates for non-detection of error and fraud and, where appropriate, involve independent experts, such as academics and fraud prevention professionals, for example in assessing the range and scale of frauds by organised crime. The use of external experts can help to mitigate the risk of group-think;

Ref Page 12, Paragraph 20, point d · Implemented 07/2023

e) ensure that it routinely gathers data on the results of all its different compliance interventions and use this when it deploys compliance staff by scheme and risk, targeting resources to recover fraud where it remains cost-effective to do so.

Ref Page 12, Paragraph 20, point e · Implemented 09/2023

f) HM Treasury should where it is cost-effective to tackle error and fraud, ensure sufficient resources are available to HMRC and other departments so that fraud is pursued efficiently across the government?s grant and loan schemes.

Ref Page 13, Paragraph 20, point f · Implemented Q1 2023-24

h) [HM Treasury should] when designing similar grant schemes in the future, devise measurable financial impact tests for consideration by ministers. Where data are not available to validate eligibility we would normally expect a self-assessment of expected income to be preferable to having no test as it could significantly reduce payments to those not in need, and provide clear criteria against which claimant behaviour could be assessed for possible instances of fraud

Ref Page 13, Paragraph 21, point h · Implemented Q4 2024-25

j) HMRC should draw on the lessons it has learned from its compliance response on CJRS and SEISS to consider how it would quickly identify, assess and respond to the main causes of non-compliance in future support schemes, and penalise fraud;

Ref Page 13, Paragraph 21, point j · Implemented Q2 2024-25