Coronavirus Job Retention Scheme (CJRS) – Changes around the corner

Within the Lambert Chapman Payroll Department to date, we have seen around 220 Employers use the Coronavirus Job Retention Scheme (CJRS) to furlough their employees.  This has resulted in around 850 employees being furloughed since March and claims have been submitted amounting to just over£2.4m.

On Friday 29 May, the Chancellor made further announcements relating to the scheme that Employers need to be aware of.  Having worked closely with our payroll department over the last 7 weeks, I feel the changes announced are not going to make the payroll processing and claim process any easier and there will be challenges ahead in terms of extracting the data effectively.

I have created a timeline below relating to what do we know now and when the changes coming in.  I have also included what I refer to as “Devil is in the Detail” abbreviated to DITD for things that have not been made totally clear at this stage, but the cynic in me feels may become an issue.

10 June

• The final date in which an employer can furlough an employee for the first time. This allows the minimum 21 day furlough period to be taken by 30 June.
• For example, if Joe Bloggs was furloughed for the first time from Monday 8 June for a period of 3 weeks the employer would be able to make a successful claim. If however, he was furloughed from Thursday 11 June even if the period exceeds 3 weeks, the employer would not qualify to make a claim for this employee.

30 June

• Current scheme closes to new entrants.
• Scheme remains open only to those employees who have been furloughed for a full three-week period prior to 30 June. (DITD – it is not clear at this stage if the employee still needs to be furloughed on 30 June to qualify under the new scheme or if they can be put back onto furlough after this period if they already had a 3 week period earlier in the scheme)
• The claim period covering the date to 30 June must include all periods of furlough leave up to 30 June regardless of when they were paid.
• For example, if your pay run date and pay period covers to the last Friday of the month (26 June 2020) you will need the wages information for the following week in order to complete the final 30 June claim. 29 and 30 June fall under the 31 July pay run and therefore these days must be included on 30 June claim and not the 31 July claim.  (DITD – this may mean that June claims have to be delayed or employers may need to consider paying up to 30 June in the nearest pay period in order to make their claims process simpler)

1 July

• Employers that have not previously furloughed any staff will not be permitted to join the CJRS program
• Furlough claim periods must cover the period of furlough leave and no overlaps can occur. (Particularly difficult for those employers that may have weekly and monthly paid staff or staff paid on salary and those paid in arrears on hourly pay).
• Flexible furlough scheme comes into effect. (DITD – it is not clear at this stage if this only applies to those employees still furloughed on 30 June, the phrase in the government guidance “can bring back to work” implies the eligible employees are not currently working but furloughed)
• The flexible scheme will allow employees to be brought back part time whilst the remaining hours not working can continue to be claimed under the furlough scheme. (DITD – this is a contracted change to the employee and this must be agreed and confirmed in writing with the employee concerned)
• HMRC will be issuing guidance on the actual calculation of the flexible furlough scheme on 12 June. The current guidance appears to indicate that normal pay will have to be paid for the hours worked and the furlough claim will relate to the unworked hours.    (DITD – I am assuming that for those that do not have regular contracted hours the hours used will be based on the same weekly/monthly average used for the calculation of the furlough pay)

31 July

• The last date in which a claim covering the period to 30 June can be made.

1 August

• The CJRS will remain at 80% up to a cap of £2,500, Employers will have to pay the employers NIC and employers pension.

1 September

• The CJRS will be reduced to 70% up to a cap of £2187.50, Employers will have to pay the additional 10% plus employers NIC and employers pension

 1 October

• The CJRS will be reduced to 60% up to a cap of £1875.00, Employers will have to pay the additional 20% plus employers NIC and employers pension

31 October

• CJRS scheme finishes – assume one month in which to get in final claims