GOV.UK is getting a makeover, but what about HMRC guidance?

As a vital platform serving millions of people each week, it’s about time that tasks such as learning to drive, registering a birth or starting a business were as simple as possible (1).

Launched just 6 years ago, GOV.UK really is only a starting point for governmental online services and its imperative it continues to evolve in a smart way – meeting both the needs of its users and reducing contact time and considerable case work for the government (1).

Currently GOV.UK is not set up with the end user in mind. For example, a business wanting to hire their first employee needs information and services from 5 different areas of government before they can hire them (1). So, it’s sensible that the new site will organise content around user needs rather than government departments (1). Users will have total visibility of the full process required to complete a task, whether it’s learning to drive or employing a new staff member (1).

For increasingly complex tasks, creating a new process for collaboration across government departments, is as essential as designing the new way of navigating (1). Over the past 6 months, 15 different departments have been working together to establish 25 step by step journeys to make the complex simple (1).

These include:

Step by step journey Departments involved
Visit the UK on a standard visitor visa UK Visas and Immigration
What to do when someone dies Department for Work and Pensions
HM Courts & Tribunal service
HM Revenue and Customs
Land Registry
Employ someone HM Revenue and Customs
Home Office
Disclosure and Barring Service
Department for Work and Pensions
The Pensions Regulator

 

It’s good to see the government refocusing GOV.UK towards the user experience, but it’s also vital that varied customer groups are understood and given the opportunity to review content. Whilst there is a team in HMRC called the Customer Journey team who one assumes are feeding into the GOV.UK work, there hasn’t been much visibility of the work they’re doing, and they haven’t been regularly feeding into HMRC’s main employer consultation group the Employment and Payroll Group.

In October the Office of Tax Simplification (OTS) published a report they had undertaken looking at HMRC guidance for employers. I met with the OTS and fed into that review which was the first time the OTS had dedicated a whole report to guidance and the improvements that advances in technology can offer. The report considers HMRC’s work on ‘New Model Guidance’ and makes a plea that I would heartily endorse: ‘A fundamental shift will be to involve future users of the new guidance as part of the guidance writing process, to provide the vital perspective of those who are seeking guidance’ (2). Their 12 recommendations, below (2), call for an important role for users in the design and maintenance of guidance:

  1. A New Model for guidance should be adopted, building upon the current innovative programme that uses new ways of delivery, moving the emphasis to the taxpayer’s needs, away from the needs of HMRC officers. (Chapter 1)
  2. HMRC should have a senior Strategic Head of Guidance, with remodelling guidance as a key departmental priority in HMRC’s operating plan. (Chapter 1)
  3. HMRC should form an ‘advice and guidance panel’ to advise and support HMRC in this endeavour. The panel could consist of senior HMRC officers, respected tax specialists and academics. (Chapter 1)
  4. HMRC should set a strategy of clearly identifying three levels of guidance so that users can immediately see the level of complexity of the material they are about to read. (Chapter 2)
  5. More work should be done on using technology to direct people to enter the guidance at a point appropriate to their needs and level of understanding of tax. (Chapter 2)
  6. HMRC and the GDS should produce a clearer statement of their respective responsibilities. GDS-managed guidance should have more links to HMRC’s more comprehensive guidance. (Chapter 2)
  7. The GDS team should reassess its approach to publishing HMRC technical manuals. (Chapter 2)
  8. Sections in manuals should be annotated swiftly to record that changes will be needed to reflect amended law, or the results of a tax case. (Chapter 3)
  9. HMRC should introduce more feedback links into the technical manuals. These should be accompanied by dating each page (or paragraph number) and ensuring that HMRC contacts for each manual are kept up to date. Technology should be used to improve links between specific parts of manuals and HMRC’s other guidance material. (Chapter 3)
  10. HMRC should discuss and agree protocols with industry and representative bodies where these bodies are supportive of contributing to guidance, building on existing good practice. (Chapter 3)
  11. HMRC should undertake a consultation on the circumstances in which a taxpayer can rely on published guidance and the extent to which a taxpayer will be subject to interest, penalties and the tax in dispute where guidance is found to be incorrect. (Chapter 4)
  12. HMRC should be clearer when its guidance is knowingly giving a statement of HMRC’s opinion rather than something it considers to be generally accepted. (Chapter 4)

Let’s hope that HMRC adopt these recommendations and employers and agents can be involved in designing the new model so they also get an improved user experience given their vital role in administering the tax system.

Sources

(1) Extracts taken from the Government Digital Service blog

(2) OTS guidance for taxpayers: a vision for the future   https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/746076/OTS_Guidance_for_taxpayers_041018.pdf