Further Education and Skills News is designed to give our clients and contacts in the sector short, topical updates along with details of our seminar programme on a bi monthly basis.

1. Further Education
& Skills News
July 2012
Real Time Information – handy tips on implementation
With the first pilot being sponsored by HM Revenue and What to do now?
Customs now up and running, Real Time Information (RTI) If you have not started to think about how RTI will affect you, our
will represent the most fundamental change to the way message is start doing so now. RTI will be drawing on data which
payroll information is processed and reported for over 65 is typically stored in both the payroll and HR systems and it is
years. RTI is going to happen, so all employers need to start essential that you understand how your organisation will cope with
preparing for it as HMRC’s aim is that all will have “joined” by those changes.
October 2013.
KEY POINTS
What does this mean to you as an employer?
We would recommend that you make sure you understand how Ensure that all of your RTI data is reviewed and cleansed so
your IT systems will cope with this change and how the systems that RTI submissions are made correctly and on-time with no
will collect and collate the 100+ individual pieces of information additional amended submissions being required.
that will be required for each employee for a submission under RTI.
Robust internal systems and processes are essential for a
If one conclusion can be drawn from the initial pilot, it is that the
successful RTI submission and in avoiding RTI penalties (and
majority of employers hold incomplete and inaccurate data about
potentially PAYE penalties).
their workforce. This data will need to be cleansed and held within
one central function so that it can satisfy the conditions required HR teams should be reviewing the data they currently hold on
in order to be deemed a successful RTI submission. For example, employees as HMRC can request over 100 pieces of data to be
RTI will require the transmission of an employee’s full and given submitted by an employer for each employee every time they
name. Robert Patel can no longer be recorded as R Patel, Bob Patel receive a payment.
or even Patel B. It is therefore important for employers to check
Employers should actively consider the most appropriate
that they have the correct name of each employee. Other essential
strategy for communicating these new RTI data requirements to
information that will be sent in an RTI submission includes the
each employee.
employee’s NI number and other personal data such as their date of
birth and this again must be provided in an RTI approved format. Continued compliance with RTI will require a structured
Indeed, once reporting under RTI, a passport number will be harmonisation of an employer’s HR, Finance, I.T. and payroll
required for new employees. policies and procedures.
Pensions automatic enrolment is You will then have to take different actions for each category of
employee, providing different levels of information and options to
fast approaching each of them. For example, entitled workers need to be told about
your qualifying pension scheme and offered the chance to join,
Most organisations which employ more than 500 staff will even though no employer contributions need be paid. Non-eligible
have staging dates during 2013, with the majority of the jobholders must also be offered the chance to join your scheme and
remainder following early in 2014. You will need to comply if they choose to do so employer contributions must be paid. Finally
with the automatic enrolment provisions from your staging date eligible jobholders must be enrolled into a scheme, with employer
and prepare for this well in advance. contributions, without having to take any action themselves.
The administrative aspects of compliance with the regulations It is likely that employers in the Education Sector will be able
will be complex and time consuming. Employees will have to be to use their existing defined benefit schemes as qualifying schemes
categorised by age and earnings into entitled workers, non-eligible and even to delay automatic enrolment to some extent. This will
jobholders and eligible jobholders. This assessment must then be not be simple though, with strict conditions applying on eligibility,
completed again at every payroll period, whether this is monthly provision of information and options to employees.
or weekly.

2. How secure is your UKBA Highly Trusted Sponsor status
In 2009 the UK Border Agency (UKBA) introduced the to prompt greater scrutiny of education establishments who take
points-based route by which students from outside the overseas students and hold the Highly Trusted Sponsor status.
European Economic Area (EEA) can enter the UK to study, Since January 2011, Parliament has approved sets of changes
known as Tier 4 of the points-based system. Students must to immigration rules that affect students and their sponsors
therefore score a sufficient number of points to gain entry to covered by the tier 4 rules. They include:
study in the UK. As part of this assessment, Tier 4 students • an increase in the number of courses where students
must also show that they have a place at an education provider require an Academic Technology Approval Scheme (ATAS)
that holds a sponsor licence; education providers cannot get certificate before commencing their studies
a sponsor licence from the UKBA unless they are inspected / • the introduction of a five year time limit on studies for the
audited by the appropriate statutory body. majority of tier 4 students
Sponsors are required to report to the UKBA to confirm • tightening work placement restrictions for tier 4 students
whether students are complying with the conditions of their • changes to English language requirements for students on
stay and must maintain appropriate and sufficient records to undergraduate degrees
evidence that their controls are operating effectively. Sponsors • clarification on the use of a Certificate of Acceptance of
can be audited at any time and if found to be non-compliant Studies (CAS)
with the UKBA’s regulations, risk having their license • changes to the document retention requirements set out in
suspended or revoked and being removed from the register of Appendix D of UKBA guidance.
sponsors. This means that the organisation would no longer be
able to bring any migrant worker to the UK or recruit overseas In our opinion the increasing risks attached to the tier 4 route
students. prompt a number of questions for colleges as they review the
In March 2012, the National Audit Office (NAO) reported sustainability of future income from overseas students:
that the tier 4 system had predictable flaws and that the UKBA • How up to date is your institution with the latest UKBA
has taken little action to prevent and detect students overstaying rules and guidance?
or working in breach of their visa conditions. • When did the UKBA last inspect your tier 4 sponsor
The concerns about the tier 4 system have a number of arrangements, and what was the outcome?
serious implications for the education sector. The UKBA has • Are you getting assurance that you continue to meet the
revoked over 100 sponsor licences since the tier 4 route was UKBA’s current requirements?
introduced, and one large recruiter of overseas students had • Is that assurance sufficiently robust and transparent?
its Highly Trusted Sponsor status suspended earlier this year, • Is compliance with UKBA requirements covered in the scope
preventing it from recruiting non-EEA students. In the light of of work by your internal auditors?
the NAO’s report, the UKBA’s new compliance regime is likely
Grant Thornton is ranked as a top three adviser to the charity, education and housing sectors and we pride
ourselves on providing specialist knowledge to them. We would like to invite you to attend a series of
seminars focusing on some of the current issues affecting organisations within these sectors. Each of these
sessions will address a different issue and you are welcome to attend as many sessions as you wish.
Seminar programme for 2012
An update on IFRS London
As the migration of UK GAAP to IFRS continues to develop, this session Wednesday 10 October 2012
will provide an update on the latest position for the not for profit sector, 8.30am Registration and coffee
highlighting key developments, areas of concern and practical issues which 9.00am Seminar commences
need addressing. Specialists from our not for profit and IFRS conversion 5.30pm Finish
teams will lead the session with plenty of opportunity for debate.
Tax/VAT/Employee issues update London
Our tax seminar will provide an update on developments in direct taxes, Wednesday 5 December 2012
VAT and an update on employee issues as they affect the sector, as well as 3.30pm Registration and coffee
providing timely reminders on topical issues. 4.00pm Seminar commences
5.30pm Drinks and canapés
© 2012 Grant Thornton UK LLP. All rights reserved.
‘Grant Thornton’ means Grant Thornton UK LLP, a limited
liability partnership. London
Grant Thornton is a member firm of Grant Thornton International Grant Thornton House
Ltd (Grant Thornton International). References to ‘Grant Thornton’
Melton Street
are to the brand under which the Grant Thornton member
firms operate and refer to one or more member firms, as the Euston Square
context requires. Grant Thornton International and the member London NW1 2EP
firms are not a worldwide partnership. Services are delivered
independently by member firms, which are not responsible for the T 020 7383 5100
services or activities of one another. Grant Thornton International
F 020 7383 4715 Jenny Brown
does not provide services to clients. Head of Further Education & Skills
grant-thornton.co.uk E ava.kimpton-pasfield@uk.gt.com T 020 7728 2316
V21906