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  • How to amend an MCS and what can go wrong when you do

    The process for amendment of an MCS should involve picking up very precisely what was reported in the original MCS and then changing only the fields that are the subject of the amendment. Whether it is an automated process or an ad hoc manual one, it’s very important to have systems and procedures that let you get this right consistently.

    A very common error we see is where this process fails for the key fields in the ATO’s identification of distinct member accounts – ‘Provider member account number’ and ‘Provider client identifier’. If these are not identical in the amendment, it will never be matched with and cancel the original MCS in our internal systems and will appear as a new original.

    The fund also needs to ensure the file creation date, which is reported under the supplier information, is a later date than the file creation date in the original MCS file. If the fund provides an earlier file creation date, the amended MCS form will be automatically cancelled by the ATO systems despite the fund receiving advice the amended MCS form has been lodged successfully.

    Is it possible to remove an MCS from the ATO system?


    Original MCS (incorrect MCS)

    Provider member account number – 5570

    Amended MCS (correct MCS)

    Provider member account number – 05570

    ATO systems would treat this as two separate accounts. In this scenario, the ATO cannot remove the incorrect MCS form (original MCS). To rectify this situation the fund/administrator would be required to lodge another amended MCS, quote the incorrect provider member Account Number (reported in the original MCS) and ensure they report $0.00 member contribution amounts.

    Example: Manual entry of amended MCS details not accurate

    A member has come to a defined benefit fund in relation to a Division 293 tax assessment complaining of incorrect reporting. Her claim is investigated, verified and accepted – part of her notional taxed contribution was misreported as an employer contribution. An employee enters information into your systems to generate lodgment of an amended MCS.

    The original MCS had:

    Provider member account number = 007054

    However they entered this in the amended MCS in error:

    Provider member account number = 07054 (with just a leading zero missed off)

    The consequence was that the amendment was not matched up with the original and so was treated as a new original MCS for a new account. The member’s contributions were effectively doubled and a new and even more incorrect Div. 293 tax assessment issued automatically.

    Example: Records not available, so details in original MCS unknown

    A super fund had migrated member accounts for a particular product from one platform to another. An MCS amendment is required for one of the migrated accounts (let’s assume it the same situation as in the previous example). The employee generating the amended MCS does not have access to data archived from the previous platform but believes the new platform has the same account numbers. In fact, the original MCS had:

    Provider member account number = SANTUS7005

    However the new system shows the following and so this is what was entered:

    Provider member account number = 7005

    The member complained again, this time about duplicated reporting. Client service staff had no idea what the issue could be and directed the member to the ATO again. Eventually the ATO (SuperCRT) advised the super fund of the account number to use in order to amend successfully.

    End of example
      Last modified: 05 Apr 2018QC 42279