• SASG minutes December 2013

    Meeting details

    Venue:

    Rooms 719 & 720, Level 12, ATO Latitude East, 52 Goulburn Street, Sydney NSW 2000

     

     

    Date:  

    Wednesday 4 December 2013

     

     

    Start:  

    10.00 am

    Finish:  

    2:00 pm

    Chair:  

    Sally Druhan

     

     

    Contact and Secretariat:  

    Phil McDonald

    Contact phone:  

    13 28 69

    Attendees

    Alan Harvey

    AAS

    Amanda Gunn

    Mercer

    Andrea Cooper

    Financial Synergy

    Anne Dixon

    Precision Administrative Services

    Christopher Smith

    Perpetual Investments

    Eion Burke

    Superpartners

    Garry Powell

    Super SA

    George Strilakos

    UniSuper

    Graeme Colley

    SPAA

    Heide Stewart

    James Barnwell

    Jayne O'Ryan

    Jeff Broderick

    Julia Christiansen

    Jun Tang

    Karen Downes

    Karen-Anne Herald

    Kelly Kerr

    Mark Edwards

    IOOF

    Russell Investments

    QSuper

    Bravura Solutions

    Precision Administrative Services

    Onepath

    Superpartners

    NAB / MLC

    BT

    CBA (Comminsure)

    Martin Mikulicin

    Bravura Solutions

    May Low

    CBA (Colonial First State)

    Robert Hodge

    ASFA

    Ryan O’Moore

    Zurich

    Simone Sluchniak

    GESB

    Sumeran Khoshaba

    CBA (Comminsure)

    Tina Cifelli

    AMP

    Beverley Easton

    ATO – CAS, Superannuation

    Elizabeth de Koning

    ATO – Superannuation

    Hamish MacKenzie

    ATO – CAS, Superannuation

    Linda Cheesman

    Michael Gleeson

    ATO – CAS, Superannuation

    ATO – Superannuation

    Phillip McDonald

    ATO – CAS, Superannuation

    Sally Druhan

    Shane Moore

    ATO – CAS, Superannuation

    ATO – Superannuation, Data Standards

    Apologies

    Ian Stirling

    Maria Anislag

    Comsuper

    Zurich

    Neil McMillian

    Pillar

    Rebecca Scott

    Perpetual Investments

    Roman Wegner

    CBA (Colonial First State)

    Sue Pearce

    Suresh Soppa

    FuturePlus Financial Services

    CBA (Comminsure)

    John Shepherd

    ATO – Superannuation

    Mary Arrowsmith

    ATO – CAS, Superannuation

    Next Meeting

    Wednesday 12 March 2014

     

    Please note: SASG agendas, minutes and related papers are not binding on the ATO or any of the other bodies referred to in these papers. While every effort is made to accurately record views expressed, the wording necessarily represents a summary of statements of general position only, and care should be taken in interpreting those statements. These papers reflect the position at the date of release (unless otherwise noted) and readers should note that the position on any issue may subsequently change.

    Agenda Items

    1 Opening

    Sally Druhan (Assistant Commissioner, Superannuation and Accounting, Client Account Services) opened the meeting welcoming all in attendance.

    Declaration of Conflicts of Interest  

    The Chair advised members of the requirement to declare any conflict of interest or conflict of role. No declarations of conflict were advised.

    18 September 2013 SFWG Minutes endorsed

    Amended final draft minutes of the meeting held Wednesday 18 September 2013, sent by SASG Secretariat email Tuesday 26 November 2013 were accepted without change. Amendments took into account member feedback of Final draft circulated previously.

    2 Review of action items from September 2013 meeting

    Action item

    18092013/01 – Review scheduling of meetings for 2014 to maximise membership interaction and ensure appropriate industry segments are identified to facilitate specific issue teleconferences with the appropriate audiences.

    Status  

    In Progress – 2014 proposed meeting dates (taking into account member’ preferences for the timing of meetings after the end of period and prior to the next reporting date) are to be confirmed, subject to assessment of any conflicts with ATO or industry events.

    Wednesdays – 12 March, 28 May, 20 August and 26 November 2014

    SASG Secretariat to send email confirmation of meeting dates early in January 2014.

    Action item  

    18092013/02 – ATO to assess and provide responses to issues raised by Heide Stewart regarding issues with the Fund Validation Service data

    Status  

    Closed – ATO email sent 27 September 2013 provided a response to issues raised.

    Action item  

    18092013/03 – ATO to assess issues raised regarding access to the SILU website and provide advice.

    Status  

    Closed – SASG Secretariat email sent 24 October 2013 outlining to members that the SILU@ato.gov.au links within SILUSubscribe emails concerning 'Controlled' information will require a 'user ID' to allow the user to access this information. Other general nature SILUSubscribe emails with “SILU@ato.gov.au” links do not require a “user ID” to access.

    Action item  

    18092013/04 – members invite to email SuperStreamStandards@ato.gov.au. Outlining experience with SuperTICK by 4 November 2013:

    • What were your experiences with using SuperTICK?
    • What sort of positive impact has it been on your operations?
     

    Status  

    Closed –SASG Secretariat escalated feedback provided.

    Action item  

    18092013/05 – ATO to consider and respond to the validity of funds treating a member TFN as a correct TFN (without validating the member through SuperTICK) where:

    • member’s MCS is successfully lodged and no TFN Notification is received for that member.
     

    Status  

    Closed – SASG Secretariat email issued 7 November 2013:

    • highlights ATO system changes required to accommodate the Sec299TD process into the TFN Notification process
    • acknowledging the issue as one for consideration in future system change programs of work.
     

    Action item  

    18092013/06 – Email SASGSecretariat@ato.gov.au with details of the member outcomes achieved through an interaction with SuperTICK

    Status  

    Closed – Heide Stewart provided examples to SASG Secretariat 23 September 2013.

    ATO email (Shane Moore, Project Manager, Data Standards and eCommerce) sent 16 October 2013:

    • acknowledged the concerns expressed regarding the outcomes of examples cited
    • outlined the ATO matching methodology, and changes have been implemented to increase the match rate confidence, including communication with users about the extent of information required to be input to assist in producing a more accurate outcome.
     

    Action item  

    18092013/07 – Email SASGSecretariat@ato.gov.au with details of the ATO email interactions regarding the same TFN being confirmed for two different members.

    Status  

    Closed – Anne Dixon provided details of previous interactions to SASG Secretariat 19 September 2013. ATO email (Shane Moore, Project Manager, Data Standards and eCommerce) sent 25 September 2013 provided copy of ATO email sent 29 August to Sunsuper addressing the issue raised.

    Action item  

    18092013/08 – Investigate and advise members on the range of validation error messages.

    Status  

    Closed – SASG Secretariat email sent 18 October 2013 provided silu@ato.gov.au link to Bulk Data Exchange (Bde) Error And Warning Codes And MessagesExternal Link database.

    Action item  

    18092013/09 – Arrange for the search functionality within ato.gov.au to be improved, which will allow external users to find File Transfer information.

    Provide information to assist Funds with File transfer interactions.

    Status  

    Closed – SASG Secretariat email sent 23 October 2013 provided update on:

    • search functionality improvements to allow uses the find file transfer information
    • tips to successful lodgments.
     

    Action item  

    18092013/10 – Review the circumstances of examples highlighted by Sue Pearce where monies have been split by the ATO upon receipt.

    Status  

    Closed – SASG Secretariat email sent 30 October 2013 advised payments made to ATO using Head of Revenue (HOR) code 21 will apply the payment to an existing debt. Funds need to ensure that EFT payments (or by cheque) are supported by the correct HOR to be applied to the intended product.

    Action item  

    18092013/11 – USM processing in ICP impacts to be listed on the agenda for the next meeting to provide an update on the administrative arrangements (including sample letters and notices) associated with monthly aggregated payments of member USM entitlements.

    Status  

    Closed – Further discussion on this issue has been listed for 4 December 2013 meeting agenda.

    Action item  

    18092013/12 – Provide a response to the requirement for the ATO to define a period for the purposes of recovering overpaid SG amounts.

    Status  

    Closed – Discussion of this issue planned under Agenda 7 – Changes to ATO Systems.

    Action item  

    18092013/13 – Provide members with an outline of user issues identified that are being considered by the ATO review of SoA.

    Status  

    Closed – Linda Cheesman advised members the ATO has established a focus group to review the user issues.

    • short term objective – to review, update and improve information regarding SoA explanatory information on ato.gov.au website
    • longer term change scope (no timeframes advised) – provision for larger funds to access SoA electronically, to enable data to be exported and manipulated and address system limitations to the number of transactions that can be displayed.
     

    Action item  

    18092013/14 – SG processing in ICP impacts to be listed on the agenda for the next meeting to provide an update on the administrative arrangements (including sample letters and notices) associated with monthly aggregated payments and recovery of member SG entitlements.

    Status  

    Closed – Further discussion on this issue has been listed for the 4 December 2013 meeting agenda.

    Action item

    18092013/15 – Review the TFN Notification electronic reporting specification to address member concerns that the proposed means to identify the file contains either Sec 299TA or Sec 299TC Notifications or “Please resolve” letter candidates.

    Status

     

    Action item

     

    Status

    Closed – SASG Secretariat email sent 18 November 2013 confirms to members that the ECI File transmission message name will contain an alpha reference to separate the different TFN notification file types.

    18092013/16 – Provide email confirmation to advise funds receiving Sec 20C notifications issued to the incorrect entity (ie the fund’s trustee) that notice has been revoked.

    Closed – SuperCRT email sent to Superpartners confirming revocation of Sec 20C notices incorrectly issued to Fund trustee / Administrator.

    Action item

    18092013/17 – Arrange for a review of the USM protocol and examples raised to identify the shortfalls in guidance as discussed.

    Status

    Closed SASG members advised issue will be addressed at 4 December 2013 meeting.

    Action Item

    18092013/18 – Ascertain the requirements for funds to separately identify member LISC payments for member statement reporting.

    Status

    Closed – SASG Secretariat email sent 28 November 2013 advised members of the ASIC class order providing temporary relief (until 31 December 2014) from any requirement to separately report LISC payments on member statements. Members were encouraged to familiarise themselves with the requirements.

    Action item

    18092013/19 – Ascertain a delivery timeframe of the ATO position with the correct treatment and reporting of ASIC interest paid on unclaimed superannuation amounts refunds.

    Status

    Closed – SASG Secretariat email sent 7 November 2013 advised ASIC interest is:

    • exempt income
    • not regarded as a superannuation contribution for the member.
     

    Action item

    18092013/20 – Provide members with a report on the Unclaimed Superannuation Money collection statistics.

    Status

    Closed – SASG Secretariat email sent 12 November 2013 provided members with USM collection statistics as published in the ATO Annual Report.

    Action item

    18092013/21 – An update on Division 293 to be scheduled for the next meeting.

    Status

    Closed – In the absence of Regulations being passed, this item closed.

    Action item

    18092013/22 – ATO to provide clarity around the EPF implementation date, Super TICK and POI concerns.

    Status

    Closed – SASG Secretariat email sent 25 October provided clarity to members regarding POI and use of SuperTICK concerns.

    Action item

    18092013/23 – Consult with your colleagues to ensure that electronic DASP applicants are not being directed to DIAC to obtain proof of departure information.

    Status

    Closed – SASG Secretariat email sent 24 October 2013 to remind members to consult with counterparts and provide feedback at the 4 December 2013 meeting. Issue closed 4 December 2013 following no further comment from members on consultation outcomes.

    3 Superannuation Industry Advisory Group (SIAG) update.

    Sally Druhan (Assistant Commissioner, Client Account Services) provided members with an update on Superannuation Industry Advisory Group (SIAG), one of eight peak consultation stewardship committees implemented earlier this year as a result of the ATO review of consultation arrangements.

    The SIAG is the stewardship committee for superannuation, established to:

    • discuss high level significant matters where the outcomes are considered to be in the national interest
    • provide opportunities to discuss the strategic direction of the superannuation system – specifically opportunities for improvements to the administration of the superannuation systems
    • provide input and bring ideas to the table to support a whole of Government approach.

    Membership has been limited to 15 members and includes representatives from:

    • various associations:
      • accounting and related professions, Trustees and superannuation industry, employer and business, and Industry experts.
       
    • government agencies:
      • Treasury, Australian Prudential Review Agency (APRA) and Australian Investment and Investment Commission (ASIC)
      • Superannuation Complaints Tribunal and Depart of Human Resources.
       

    The SIAG are proposing to meet twice a year but this may change depending on the discussion at the first meeting (Tuesday 3 December 2014), with the next meeting scheduled for the Tuesday 3 June 2014.

    The focus of the meeting held yesterday was framed around:

    • The view of the current superannuation system from perspective of:
      • the regulators (ATO, APRA and ASIC); and
      • industry representatives.
       
    • working with the new government, and
    • development of a forward agenda.

    The Tax Office is currently in the process of updating the Consultation page on ato.gov.au website with the new committee information.

    We are working through how this group will interact with the SIAG. Further information on this should be available in early 2014.

    4 Legislation updates

    Sally Druhan provided members with the following updates:

    4.1 Division 293 update

    No updates at this stage regarding regulations, indicative dates or likely date of passage.

    • It was acknowledged there are some members that are anxious to resolve regulations defining:
      • who is “a state higher level office holder” and
      • how to calculate the “notional employer contribution amount” for defined benefits funds.
       

    General discussion highlighted member concerns about expected workflows (assessments issuing to individuals and related telephony workflow to fund call centres, and Release Authorities to funds for payment release, etc) should the regulations be passed early in 2014 (given government’s anticipated revenue expectations) or if they are not passed until April or later.

    Action item

    04122013/01

    Tax Office to provide an outline of anticipated workflows of Division 293 Assessments and Release authorities based on anticipated passage of Regulations

    Responsibility  

    SASG Secretariat

    4.2 Low income Superannuation Contribution (LISC)

    There are no updates regarding the repeal of LISC as the law is not yet enacted. However, a Senate Committee Report dated the 3 December 2013 did support the repeal of LISC.

    The Legislation and supporting material – The Mineral Resource Rent Tax Repeal and other Measures Bill 2013 and Explanatory memorandum were tabled in parliament on 13 November 2013 and passed in the Lower House.

    The legislation will now go before the Senate for consideration from 11 February 2014.

    Action item

    04122013/02

    Provide an update on the repeal of LISC

    Responsibility  

    Michael Gleeson

    5 MCS lodgement update – including Business Portal and File Transfer

    Linda Cheesman provided members with an update on MCS lodgment and issues impacting fund lodgments.

    1. 2013 Lodgments

    The ATO is liaising with funds to:

    • follow-up on those not lodged as planned
    • clarify information provided that appears incomplete or incorrect
    • confirm progress to lodge by agreed deferred date.

    The ATO advised feedback from industry about concerns that some funds may be using the deferral process and SuperMatch to access other funds 2013 lodgments led to CRT Alert 050/2013 being issued. The use of SuperMatch is being monitored and to date, no instances of inappropriate use have been found.

    1. File Transfer functionality issues

    The ATO discussed a number of issues identified and resolved:

    inclusion of the Provider Member Account Number as a key identifier, based on feedback from industry

    employer postcode requirements.

    The ATO implemented a change to both the File Transfer “Test” facility and the "Validation" process to address the issue of successfully lodged files that did not progress to ATO Systems. The implemented change addressed the test for mandatory employer address data (ie if no employer address field then the employer address post code must be zero filled).

    17 funds impacted have been contacted and have re-lodged the files with the data field completed.

    • Notional Employer contributions and Notional taxed contributions.

    These fields are numeric fields that must be “zero” filled if no value is to be reported.

    Feedback from members highlighted concerns with:

    • Slowness with:
      • validation and lodgment of MCS (during the week ended 29 November 2013).
      • downloading Electronic Portability Forms.
       

    Action item

    04122013/03

    Review File Transfer Functionality performance during the week ending 29 November for issues creating slowness with uploading and downloading files including error messages to try again.

    Responsibility  

    Linda Cheesman

    • File Validation processes:
      • appear to present only 1 error at a time, and at the next attempt to validate, another error is presented
        • Some errors reported do not identify where the error is presented (ie file corrupted by error in number of characters per line - too long).
         
       

    Action item

    04122013/04

    Investigate and advise members on issues identified with File Transfer Validation process:

    Does the process present:

    • all identified errors across the file; or
    • only the first (limited range) errors identified

    Where the process identifies an error with the file structure, can the error message produced be amended to identify where the error exists (eg data line xxx)

    Responsibility  

    Linda Cheesman

    Updated list of lodgements

    Successfully lodged files are not being listed in lodged file display in a timely manner.

    Action item

    04122013/05

    Investigate the timeframe of successful files being listed in the File Transfer Functionality “Lodged File” display.

    Responsibility  

    Linda Cheesman

    Key messages to funds included:

    • ATO recommends funds to test lodgments prior to actual lodgment to ensure the latest changes to the system are captured.
    • CRT Alert 048/2013 recommended funds to compress files prior to lodgment:
      • a file greater than 100MB should be compressed and sent alone;
      • files under 100MB can be grouped (maximum of five), compressed and sent.
       
    • Funds were encouraged to escalate details of File Transfer functionality performance issues to SuperCRT@ato.gov.au at the earliest opportunity with relevant details including any screenshots of error messages presented.
    • The Business Portal Help website provides more information on
      How do I use the File TransferExternal Link.
    • The Error ManualExternal Link and messages to assist funds with Validation rejects can be found on the Software Industry Liaison Unit homepage.
    • System performance has been impacted during peak processing of MCS and SuperTICK validations.
    1. Delays with outcome of lodgment reports (OOLR)

    The ATO advised members that OOLR of MCS lodgments (and other ATO reports including lost member statements) may be delayed due to our systems ability to match one or many member forms included in the lodgment.

    Funds were advised to email SuperCRT@ato.gov.au with fund details (eg ABN) and lodgment details (including lodgment date and lodgment confirmation number) if an OOLR has not been received 14 days after the MCS lodgment.

    In actioning these cases, the ATO will confirm lodgment and ensure action is in progress to resolve any unprocessed member forms.

    Action item

    04122013/06

    Review the 3 outstanding OOLRs identified by Anne Dixon

    Responsibility  

    Linda Cheesman

    6 Reuniting Super - Update

    Linda Cheesman provided a brief update in relation to the following activities that form part of ATO Reuniting Super strategies:

    1. Lost Member Register – Provision of updated addresses

    A number of suggested improvements raised at the last meeting have been progressed. Members were advised:

    • the ATO is working towards the delivery of address data in January 2014 and July as recommended by funds at our September meeting
    • the Provider Member Account Number data field is included in the data set of each member
    • ATO data cleanse processes are applied to the address data (sourced from the individuals latest income tax return) to minimise the inclusion of:
      • tax agent addresses and other default type addresses, and
      • obvious suburb / postcode errors (eg Bondi Junction, Sydney NSW 2022) that don’t satisfy the Australia Post DPID criteria.
       
    • the January 2014 data file is expected to have 3 sets of data to incorporate members aged 65 or greater and deceased members.

    The ATO has not yet determined the position in relation to the provision of member email and mobile telephone number data within the POA data.

    1. Lost Member Register – Short message service (SMS) and email campaign

    As communicated previously (September 2013 SASG meeting and CRT Alert 046/2013 issued 23 October 2013), the ATO undertook a campaign during October and November, to contact (by SMS and email) 30,000 individuals reported on the LMR (but without any ATO held Unclaimed Superannuation Money (USM) or Super Guarantee amounts).

    Due to SMS message length constraints and SMS/email privacy and security issues, the message content was quite generic, advising individuals:

    • they may have lost superannuation money, and
    • to access their superannuation information at the ATO Individuals Portal.

    The outcomes of this campaign have been viewed positively in terms of overall cost, the increased awareness of individuals’ superannuation, and the response rate given the profile of the targeted audience. Approx. 10% responded:

    • 550 successfully submitted an electronic portability form through the ATO Individuals Portal to rollover lost accounts worth $4.3M
    • more than 2,500 accessed the ATO systems to view their superannuation and other taxation information including progress of income tax returns.

    Further email/SMS campaigns are being planned in 2014, with greater participation expected with the inclusion of members that have ATO held amounts.

    1. Other strategies for 2014

    The ATO is considering a range of activities for specific segments within the scope of Reuniting Super strategy including:

    • contact with funds holding active accounts for individuals that have ATO held amounts
    • contact with Inactive members to confirm their preference to remain with their fund.

    Fund representatives highlighted the benefits of ATO communication with funds in advance of implementing outbound strategies (correspondence, email, SMS or telephone) to reunite individuals with their superannuation; which may increase individuals’ interaction with their fund.

    • The advanced communication will enable industry to adequately resource and align the focus of fund call centres and processing teams with the anticipated workflows of that strategy.
    • Where possible, the provision of information that gives funds intelligence (eg their membership numbers or location by postcode) about the intended audience would assist funds in their preparation.

    While making reference to one aspect of market research recently undertaken by ASFA on consumers’ attitudes on their superannuation, etc., Robert Hodge:

    • advised feedback indicated strong support on the ATO playing an active role in the amalgamation of super accounts, with comments suggesting individuals’ active use of ATO registers
    • recommended future ATO communications relating to reuniting campaigns, incorporates a message that encourages those that have been unsuccessful in previous searches, revisit the “refreshed” ATO Registers (Individuals Portal) to search for their lost super (given MCS reporting of all super accounts held by funds, and increased holdings of ATO-held amounts)
    • indicated he was negotiating for the research to be shared with the ATO.

    7 Changes to ATO Systems

    7.1 Unclaimed Superannuation Money (USM) to Integrated Core Processing (ICP)

    Beverley Easton discussed progress with the transition of USM to ICP and a number of impacts for funds from early 2014.

    1. Shutdown of ATO processing USM of inbound and outbound activities

    ATO processing of inbound fund USM lodgments and disbursement of amounts to members accounts are currently being held due to the shutdown of USM processing in our legacy system.

    • Receipt dates of USM lodgment and payments delayed will used to minimise any general interest charge calculation for late payments.

    Processing of these files and accounts, along with issuing Outcomes of Lodgment Reports will recommence in the ATO ICP platform, from early in January 2014.

    Funds’ SuperMatch requests for transfer of ATO-Held USM along with any individual’s claims for refund are also not being processed.

    1. Payments not equal to the USM statement balance will not be allocated to members accounts

    Funds were advised to ensure that payments made in relation to a USM lodgment match the total amount payable.

    • ICP looks for these two transactions to match prior to disbursing the amounts to the individual's accounts.
    • Where the amounts do not balance, ICP may apply some of the payment to a previous outstanding balance or to GIC, leaving the balance as a credit on the account. The ATO will advise the Fund to pay the difference to enable payments to be disbursed to members.
    • The ATO confirmed that the undisbursed payment will not be offset against another debt of the fund (eg income tax or surcharge).
    1. Weekly USM Rollover payments to funds

    ATO Reuniting superannuation strategies for actioning ATO held USM has identified approx. 600,000 accounts (greater than $200) worth $47M that can be targeted for rollover to funds during 2014.

    Leveraging off of the enhanced system capability provided by the move of USM processing to ICP, the ATO is planning to rollover matched member accounts (with an active fund nomination) to that specific fund in weekly payment processes (limited to 20,000 accounts each week).

    • the ATO currently has approx.4,000 accounts that can be paid from late January 2014.
    • the number of accounts that can be paid will progressively increase as various strategies to pay ATO-Held USM to individuals’ super fund accounts are ramped up in 2014 (refer to Agenda 6 – Reuniting Super).

    The current fund nomination form has been amended to include the payment of USM to the members’ fund of choice.

    Action item

    04122013/07

    Review and advise members on ATO policy direction to payments of ATO held USM to funds without holding a valid direction from an individual to pay a fund of choice

    Responsibility  

    Beverley Easton

    Funds that cannot accept the member’s rollover have 28 days from issue of the RBS to complete the payment variation advice either in paper form or electronic format and pay the amount to be returned to the ATO.

    Action item

    04122013/08

    ATO to confirm no plan to introduce a limit on the number of USM Rollover Payment Variation Advice from funds not able to accept the rollover.

    Responsibility  

    Beverley Easton

    Note: Direct payments of amounts less than $200 will be paid direct to matched members in similar weekly batches.

    The ATO is considering a number of technical USM Recoveries issues raised in relation to which components (ie taxable, non-taxable) of a member accounts does the fund repay the USM Recovery amount from. Other issues include

    • What should the fund do, if it’s processing a recovery (any recovery type) based on the original remittance and cannot drawdown a particular tax component?
      Would this qualify as a rejection due to insufficient funds?
    • What would the proportioning rule be for untaxed funds?
    • What drawdown order should the preservation components follow?

    Action item

    04122013/09

    Provide advice on a number of technical issues being considered in relation to USM Recoveries.

    Responsibility  

    Beverley Easton

    1. Rollover Benefit Statement (RBS)

    The ATO will be issuing an RBS (in paper form only) to the funds for each member account rolled over in the weekly process payment process. A covering letter will accompany the batch of members’ RBS issued to a fund.

    Membership highlighted the absence of the RBS data in electronic format has significant impacts for funds:

    • managing the increased paper flow whether as correspondence or items (image) in a work management system
    • increased resourcing requirements to process rollover payments, manually process any PVA (in paper or electronically) for rollovers that can’t be accepted, and reconciliation of each fund payment to the batch of RBS
    • high risk to integrity of member accounts and reconciliation of RBS to fund payment given the absence of the ATO Payment Reference Number (PRN) on the paper RBS and cover letter, particularly if batches of paper RBS are not received or become separated as paper or as work items in a system.

    Action item

    04122013/10

    ATO to confirm that Rollover Benefit Statements will issue in accordance with the correspondence hierarchy applicable to similar superannuation paper based correspondence (eg Statement of Accounts, etc.).

    Responsibility  

    Beverley Easton

    Feedback from fund members reviewing the covering letter and paper RBS included:

    • the covering letter and RBS do not cite:
      • the ATO PRN representing a significant risk to reconciliation.
       

    The PRN is critical to funds:

    • in linking EFT payments to correspondence issued, both RBS and Statement of Account (SoA)
    • to return (PVA) any member rollovers they cannot accept
    • the total payment amount or the number of members in the batch.

    Note: the RBS will feature page x of y notations similar to a Sec 20C; which will assist funds with reconciliation processes.

    • one member RBS per page would enhance funds workflow management
    • a recommendation that email advice (eg CRT) to Fund receiving payment advising total amount, number of members and expected date of payment and correspondence being delivered.

    Action item

    04122013/11

    Review member feedback on covering letter and Rollover benefit Statement (RBS) and amend where possible to improve fund process of rollovers:

    • single member RBS per page
    • total amount of payment and payment reference number to be included on the cover letter
    • CRT email to funds advising payment process has been completed indicating which fund, total payment amount, number of members, payment reference number, anticipated payment date and delivery of paper based Statement of Account and RBS
     

    Responsibility  

    Beverley Easton

    1. Statements of Account (SoA) will be issued in ATO enterprise wide format

    Funds were advised the SoA will be issued in the same format (in paper) as other Superannuation products (eg Co-contributions, etc.).

    1. Other changes

    7.1 Superannuation Guarantee (SG) to Integrated Core Processing (ICP) system

    Elizabeth de Koning (A/g Director, SG Design and Systems, Superannuation) discussed progress with the transition of SG to ICP and a number of impacts for funds from early 2014.

    From December 2013, SG processing is transitioning to ICP. Unlike our other Superannuation products, existing Quarterly Superannuation Guarantee system (legacy) data is not being migrated to the new platform. This means there is a requirement for a period of time where debts and credits will be managed in both systems.

    1. Correspondence

    Funds will commence receiving SoA for SG payments (paid from ICP) in the same format (in paper) as other Superannuation products (eg Co-contributions, etc.).

    Note: There is no SG SoA for funds provided from the legacy system

    • Recovery Notices

    Processing SG in ICP will enable the ATO to undertake SG recoveries. The correspondence for this is still in testing. A copy of the correspondence will be provided to members for information in early 2014.

    There will be no retrospective Recovery of SG action through ICP for SG payments made from the legacy system.

    The ATO clarified with members whether industry require the ATO to include a value in the Financial Year Data Field of the Contribution Info Data Record, Remittance Advice and Recovery Notice electronic reporting specification. Feedback from members was that no value was required.

    Given the recovery of superannuation guarantee, is not legally dependant of the provision of the year of payment, this feedback resolves outstanding action item 18092013/12.

    Action item

    04122013/12

    ATO to provide examples to members of Superannuation Guarantee Recovery Notices

    Responsibility  

    Elizabeth de Koning

    The ATO advised recovery of an SG entitlement that has been rolled over to another fund will not be undertaken. Funds sought clarity on the requirement to populate the “Amounts transfer-out data record” of the Payment Variation Advice electronic reporting specification for SG recoveries.

    Action item

    04122013/13

    ATO to confirm obligations to populate ‘Amounts transfer-out data record’ for SG payment variation advices in relation to a Recovery Notice issued for a member whose entitlement has been rolled over to another fund.

    Responsibility  

    SASG Secretariat

    1. Payment Variation Advice (PVA) functionality

    Further clarification is to be provided in relation to implications for funds of ATO processing PVA’s of payments provided from either the legacy or ICP systems.

    Action item

    04122013/14

    Incorporate PVA processing information (outlining implications for funds from ATO processing of fund’s payment variation advice statements (PVA) of SG payments released from either legacy or ICP) in anticipated SG processing update to funds for release in early 2014

    Responsibility  

    Elizabeth de Koning

    1. Scheduling of SG Remittances and Recoveries

    There will be two SG remittances in separate weeks each month.

    • Legacy remittances will be released in the first week of the month, while
    • ICP remittances and recoveries in the third week of each month.

    8 Super Guarantee Reform Update

    Michael Gleeson provided members with an update on Super Guarantee Reform.

    1. SG Rate Rise Deferral

    Draft legislation to delay Super Guarantee rate increases for a period of 2 years has been released; however this measure is linked to the Mineral Resource Rent Tax repeal.

    The ATO is engaging with Treasury for advice to Government that progression of the legislation is vital for early in 2014 to allow sufficient lead time for industry (including software developers) to implement required changes. Updates will be provided to employers and all stakeholders when the law change is implemented.

    1. Fund Notification

    This reform measure proposed that super funds would provide more regular reporting to members of employer super contributions received. The measure did not progress and the implementation date of 1 July 2013 has passed. A recommendation has been made for this measure not to proceed, subject to further consultation.

    Confirmation of this will be provided when further information is available on the government decision.

    1. MySuper Update

    The current ATO communication strategy targeting employers (through professional and industry associations) is increasing awareness of MySuper arrangements in the employer community.

    The ATO is maintaining a key message for employers:

    • the introduction of the MySuper product
    • that they should hear from their existing default fund; and
    • if the employer hasn’t heard from the funds, or have questions, they should contact their fund.

    It is important that there is still the right balance of messages to not cause unnecessary concern for employers who do not need to make changes to their current arrangements.

    Action item

    04122013/15

    Provide copies to members of ATO messages for MySuper reminders issuing to employer associations and media.

    Responsibility  

    Michael Gleeson

    Several questions raised by members were taken on notice:

    • What treatment should a fund apply to an ATO payment to a non-compliant MySuper employer default fund?
    • Martin Mikulcin asked if the fund can accept or should it reject an ATO payment of:
      • an individual’s entitlement (eg co-contributions) based on existing ATO payment hierarchy to
      • the individual employer’s default fund that does not offer a MySuper compliant product
       
    • if the fund must reject the payment, what PVA code is to be used?

    Kelly Kerr added that the same question has been previously posed and response is still pending.

    Action item

    04122013/16

    Investigate and advise members on required treatment on individual entitlement paid by the ATO to a non-compliant MySuper employer default fund.

    Responsibility  

    Michael Gleeson

    • The ATO advised the current focus on ATO communication strategies with the employer community was focussed on the MySuper arrangements. In 2014 there will be a major shift in focus towards the implementation of the Data Standards and e-commerce requirements.

    The ATO acknowledged issues raised by Robert Hodge regarding MySuper arrangements and stated that these will continue as part of on-going SG messaging and compliance activities. The issues raised include:

    Employers with default arrangements with a fund that does not intend on offering a MySuper compliant product are the employers that should be focussed on; they need to take action to make changes to their default fund arrangements.

    Liaison with the Australian Prudential Review Agency (APRA), indicates that fund that have not applied for a MySuper licence (or have indicated they are not seeking a licence) will be questioned by the Trustee’s APRA Supervisor to determine what action has been taken to carry out their Trustee duty to advise contributing employers that they are unable to enrol new members or accept contributions.

    • Employers without default fund arrangements.

    9 ebMS Roadmap discussion

    Shane Moore provided an update to members on ebMS changes for SuperStream services and Reporting to Government, focusing on:

    • the proposed timeframes for converting existing SuperStream enabling services and reporting requirements to ebMS
    • the SuperTICK and EmployerTICK service including upcoming service design changes
    • Fund Validation Service - timing and preliminary design questions
    • ebMS timeframes for Superannuation reporting forms.

    Action item

    04122013/17

    ATO to provide members with copies of the presentations being delivered at the SASG meeting held 4th December 2013

    Responsibility  

    SASG Secretariat

    9.1 SuperTick

    SuperTick service matches the members TFN, Name, DOB and address details to validate the TFN of the member and provides either a matched, unmatched or corrected TFN response.

    A single web-service for real time requests was deployed on 1 July 2013.

    As at 3 December 2013, 160 funds were using the service and there have been over 1 million transactions to date.

    The more information that funds can provide will speed up the matching process and processing through SuperTick. For example, providing a member’s full name not only complies with the law but it increases the response times and improves likelihood of a successful match.

    It is expected that a bulk version of the service will be available from early April 2014.

    Sally Druhan asked members what they thought about the ‘Bulk Service’. Members advised that it was too early to determine impacts at this stage, however; some members questioned if it was necessary. For example: If an MCS is lodged and no TFN Notification (Sec299 TA, Sec 299TC or Sec299TB) is received, then it is considered matched.

    Message Header changes will occur from SBR1 to SBR2. The existing SuperTick service will continue to run in SBR1, however; from July 2015 funds will need to rebuild for SBR2.

    Sally Druhan advised members that this is a great opportunity to revisit they operate, review existing processes and look for efficiencies.

    SuperTick is scheduled for release into ebMS on 1 July 2015.

    Action item

    04122013/18

    ATO to send all members the response provided by Shane Moore to SASG Meeting Action Item 18092013/06 pertaining to SuperTick

    Responsibility  

    SASG Secretariat

    9.2 EmployerTick

    Members were advised that use of the EmployerTick service is optional.

    • Scheduled for release on 1 July 2014 as a web-service in SBR and also a bulk channel via BDE to align with the contributions data standard for large and medium employers.
    • Message structure similar to SuperTICK, with TFN, Full Name and Date Of Birth compulsory data elements and address optional
    • The service will provide a matched and unmatched response only.
    • Use of the service will be authorised by AUSkey
      • Outstanding design question still in progress to allow access to intermediaries acting on behalf of small employers without AUSkey.
       

    A draft message implementation guide is available for review on the PSR website.

    9.3 Fund Validation Service (FVS)

    FVS deployed on 1 July 2013 to help funds and their administrators to validate details about a particular APRA fund product for rollovers.

    During the transitional year, the ATO provides a template spreadsheet to funds, who submit their date through authenticated session of business portal’s secure messaging.

    The ATO consolidates the data and makes it available for funds by uploading to Bulk Data Exchange (BDE) mailbox on a fortnightly basis.

    The FVS has two functions, both expected to be deployed by 1 July 2014:

    • Submit: Whereby funds provide product details to the ATO to be published in a Fund Details register via the portal, and
    • Lookup: Whereby funds and employers retrieve information from the Fund Details register for a product to make an electronic payment as part of a rollover or contributions processing.

    Members were advised that the current FVS process may extend beyond 1 July 2014. Members expressed their concerns because the existing FVS service is not considered ideal post 1 July 2014.

    Action item

    04122013/19

    ATO to provide members updates regarding the timing of FVS changes

    Responsibility  

    SASG Secretariat

    For 1 July 2014 the intended design of the FVS will:

    • Provide an authenticated service for funds and/or administrators to provide fund data (including product details) to the ATO.
    • Contain industry provided data (for example, the USI, bank account details and electronic address), which will be held by the ATO. When bank account information is updated, the ATO will confirm the change with the fund before it becomes effective.
    • Provide a look-up facility for funds, employers and intermediaries to locate electronic payment and message details for a superannuation product. Although this design is still being finalised, our preferred option is via an authenticated channel.

    FVS is scheduled for release in ebMS on 1 July 2015. Shane advised members that any FVS software already in production prior to this date will need to be re-certified in ebMS.

    9.4 USI Payments

    Following on from the last industry consultation, payment at the USI/product level will move from January 2015 to January 2016 to align with the introduction of electronic contribution data messages.

    10 Other Business

    1. Obligation for funds to update member records upon receipt of a Sec 299TC Notification

      General discussion amongst members resolved that funds should exercise a business design / risk management decision in regard to updating a member account record with a TFN, unless the member has specifically requested this not occur.
    2. ATO Electronic Fund Transfer (EFT) payment codes

    Members are unable to identify the type of product payment from the EFT associated payment reference number.

    Action item

    04122013/20

    Provide information to assist funds identify the product payment type from the associated EFT payment reference number data

    Responsibility  

    SASG Secretariat

    1. XBLR software sub-licensing arrangements

    Action item

    04122013/21

    Email SASGSecretariat@ato.gov.au with questions regarding XBLR software sub-licensing arrangements

    Responsibility  

    Garry Powell

    1. Updated Pay as you go (PAYG) payment summary specifications due to Privacy requirements.

    Alan Harvey highlighted concerns about the impending changes to PAYG payment summary specifications from 1 April 2014, due to changes with Privacy requirements. This change has the potential to impact funds capability to conform with the requirements due to the lead time required to update software packages.

    It is understood that the Privacy changes will impact all ATO electronic reporting specifications and forms.

    Action item

    04122013/22

    Provide advice to funds on the timeline and impact on the changes to the PAYG Payment Summary specifications

    Responsibility  

    Linda Cheesman

    1. Extension of time to process Low Income Superannuation Contribution (LISC) Payment Variation Advice (PVA)

    Linda Cheesman advised members that a fund had sought clarity on an ATO decision not to provide an extension of time to lodge a LISC PVA. The extension was sought based on the exceptional circumstances associated with specific request – a larger file due to ATO delays in paying the member’s entitlement, high number members that had exited the fund, as previously notified to the ATO through PVA for other products, etc.

    Action item

    04122013/23

    Review decision not to provide an extension of time to lodge a PVA.

    Responsibility  

    Linda Cheesman

    1. Superstream Gateway

    Martin Mikulcin sought clarity on two issues:

    • Can a role statement of Gateways be provided?
    Feedback from software clients about some of the process applied by their Gateway provider is of concern.
    Specifically, should Gateways be:
    • unpacking business documents and checking record structures
    • checking business document validations (eg does the payment amount equal the sum of contributions)?

    Action item

    04122013/24

    Review the issues raised in relation to the role of gateways and provide a response to members

    Responsibility  

    Shane Moore

    11 Close

    Sally Druhan thanked all attendees for their contribution to a very successful meeting.

    The next meeting is scheduled for Wednesday 12 March 2014.

    Summary of action items from this meeting

    Reference

    Action Item

    Allocated To

    04122013/01

    Tax Office to provide an outline of anticipated workflows of Division 293 Assessments and Release authorities based on anticipated passage of Regulations.

    SASG Secretariat

    04122013/02

    Provide an update on the repeal of LISC.

    Michael Gleeson

    04122013/03

    Review File Transfer Functionality performance during the week ending 29 November for issues creating slowness with uploading and downloading files including error messages to try again.

    Linda Cheesman

    04122013/04

    Investigate and advise members on issues identified with File Transfer Validation process.

    Does the process present:

    • all identified errors across the file, or
    • only the first (limited range) errors identified.

    Where the process identifies an error with the file structure, can the error message produced be amended to identify where the error exists (eg data line xxx).

    Linda Cheesman

    04122013/05

    Investigate the timeframe of successful files being listed in the File Transfer Functionality “Lodged File” display.

    Linda Cheesman

    04122013/06

    Review the 3 outstanding OOLRs identified by Anne Dixon.

    Linda Cheesman

    04122013/07

    Review and advise members on ATO policy direction to payments of ATO held USM to funds without holding a valid direction from an individual to pay a fund of choice.

    Beverley Easton

    04122013/08

    ATO to confirm no plan to introduce a limit on the number of USM Rollover Payment Variation Advice from funds not able to accept the rollover.

    Beverley Easton

    04122013/09

    Provide advice on a number of technical issues being considered in relation to USM Recoveries

    Beverley Easton

    04122013/10

    ATO to confirm that Rollover Benefit Statements will issue in accordance with the correspondence hierarchy applicable to similar superannuation paper based correspondence (eg Statement of Accounts, etc.).

    Beverley Easton

    04122013/11

    Review member feedback on covering letter and Rollover Benefit Statement (RBS) and amend where possible to improve fund process of rollovers:

    • single member RBS per page
    • total amount of payment and payment reference number to be included on the cover letter
    • CRT email to funds advising payment process has been completed indicating which fund, total payment amount, number of members, payment reference number, anticipated payment date and delivery of paper based Statement of Account and RBS.
     

    Beverley Easton

    04122013/12

    ATO to provide examples to members of Superannuation Guarantee Recovery Notices.

    Elizabeth de Koning

    04122013/13

    ATO to confirm obligations to populate “Amounts transfer-out data record” for SG payment variation advices in relation to a Recovery Notice issued for a member whose entitlement has been rolled over to another fund.

    SASG Secretariat

    04122013/14

    Incorporate PVA processing information (outlining implications for funds from ATO processing of fund’s payment variation advice statements (PVA) of SG payments released from either legacy or ICP) in anticipated SG processing update to funds for release in early 2014.

    Elizabeth de Koning

    04122013/15

    Provide copies to members of ATO messages for MySuper reminders issuing to employer associations and media.

    Michael Gleeson

    04122013/16

    Investigate and advise members on required treatment on individual entitlement paid by the ATO to a non-compliant MySuper employer default fund.

    Michael Gleeson

    04122013/17

    ATO to provide members with copies of the presentations being delivered at the SASG meeting held 4 December 2013.

    SASG Secretariat

    04122013/18

    ATO to send all members the response provided by Shane Moore to SASG Meeting Action Item 18092013/06 pertaining to SuperTick.

    SASG Secretariat

    04122013/19

    ATO to provide members updates regarding the timing of FVS changes.

    SASG Secretariat

    04122013/20

    Provide information to assist funds identify the product payment type from the associated EFT payment reference number data.

    SASG Secretariat

    04122013/21

    Email SASGSecretarat@ato.gov.au with question regarding XBLR software sub-licensing arrangements.

    Garry Powell

    04122013/22

    Provide advice to funds on the timeline and impact on the changes to the PAYG Payment Summary specifications.

    Linda Cheesman

    04122013/23

    Review decision not to provide an extension of time to lodge a PVA.

    Linda Cheesman

    04122013/24

    Review the issues raised in relation to the role of Gateways and provide a response to members.

    Shane Moore

    Summary of un-finalised action items from 18 September 2013 meeting

    18092013/01

    Review scheduling of meetings for 2014 to maximise membership interaction and ensure appropriate industry segments are identified to facilitate specific issue teleconferences with the appropriate audiences.

    SASG Secretariat

     

      Last modified: 04 Aug 2014QC 41683