CONTRIBUTIONS Overview of the implementation strategy Philip Hind First Assistant Commissioner Data Standards & E-Commerce Australian Taxation Office August 2013 V1.0e (short) Contents Core Strategy Timetable Elements of the Strategy Onboarding Support Resources Next Steps 2 Contributions Strategy - Overview 1. Core strategy focuses on progressive waves, while fostering bridging solutions and providing timely support 2 1 Support 3 2014 Waves of Adoption Encourage progressive waves of adoption over the two phases of implementation – beginning with early adopters Compliance 2016 Bridging Solutions Foster bridging solutions in the first two years of implementation, while maintaining focus on getting to end-state benefits Support First Place emphasis and education and support first, before ramping up compliance action – tailor strategies to composition of the tail 2. Work with ‘prime movers’ to drive the leading wave 3. Work through ‘key influencers’ to drive the second wave 4. Address ‘tail’ with tailored support & increasing compliance Top 20 funds Top 40 industry associations Top 50 employers Top 20 media channels Target struggling groups with tailored help strategies and solutions Top 10 clearing houses and payroll bureaux Top 10 opinion leaders Top 10 payroll software houses Top 20 regions Signal end-dating of bridging solutions Ramp up compliance action based on risk assessment Top 10 SMSF channels Contributions Implementation Strategy 3 Timetable The strategy is designed to deliver phased and progressive implementation against a set of key milestones Large/Medium Employers to meet Standard Small Employers to meet Standard Wave A3 Employer on-boarding > Wave A1 Wave A2 Dec Jun 2013 2014 SMSF on-boarding > SMSFs (large/med employers) update Choice details (May-June) Contributions Implementation Strategy > Dec 2014 Wave B3 Wave B1 Jun 2015 Wave B2 Dec 2015 Dec 2016 Jun 2016 > SMSFs (small employers) update Choice details (May-June) Exit bridging solutions 4 Review tail strategies Encourage Waves of Adoption 2 Adoption of the standard from an employer perspective needs to be envisaged as occurring in three continuous waves – – Waves of Adoption This group appeals to employers with a high capability and highly willingness to participate They are likely to be toward the larger end of the employer spectrum, although not exclusively They are likely to follow payroll solution and clearing house based pathways Special effort is required to make this a ‘good experience’ – for employers and funds – particularly in managing the ‘onboarding build-up’ process and the ‘first-time’ through process ( In order to manage risk, funds will need to constrain and spread out their take-on rate of employers/intermediary points over a cycle (of say 90 days) Many of the key learnings for adoption will fall out of this group – and need to be shared with others Wave 2 - Follow the Leader – – – 3 Wave 1 - Encourage early adopters – – – – 1 This group will pick up employers who will struggle to be fully ready by the 1 July 2014 start date Some payroll solutions may not be ready for installed upgrades by 1 July 2014, adding to delays in employer’s readiness (even though they may be ‘willing’) Many employers will also be reluctant to move ahead with implementation until proven solutions and success stories emerge (see Wave 1) Wave 3 - Manage the Tail – – – The ‘tail’ will include a complex mix of employers including those struggling to fit this in with other competing change priorities in their business, those lacking in capability and direction and those openly resistant to change Some will need encouragement to get on with the task of making onboarding arrangements with their fund; while others will need help with more innovative or tailored approaches A progressive ratcheting up of active compliance work will be needed by the ATO to deal with those unwilling to make the changes required Contributions Implementation Strategy 5 Foster Bridging Solutions The second element of the core strategy seeks to foster bridging solutions, while retaining the focus on moving to enduring solutions aligned with end-state benefits 2014 What are bridging solutions? – – – Bridging Solutions Bridging solutions refer to existing solutions which meet some, but not all of the characteristics of the new standard The legal instrument (S.4) makes allowance for contribution transitional arrangements These cover alternate electronic file formats which can be used between 1 July 2014 and 1 July 2016 (but not beyond) – These arrangements must be documented between an employer and trustee and require terms and definitions, data mappings, business rule s and payment methods to conform with the standard Types of bridging solutions – Typical solutions include employer portals provided by funds, fund specified payroll interface file upload facilities and native payroll interface file upload facilities – Clearing house and registry software vendors offer application interfaces or managed facilities to funds which are often re-badged as a fund ‘portal’ or application – Some administrators have developed their own solutions Benefits and limitations – With appropriate adjustments, these facilities offer the potential to bring many employers quickly and relatively seamlessly into the new standards-type environment – However significant limitations exist including: • The benefits of straight-through processing and error flows back to source payroll systems for employers are not generally provided • Lock-in to proprietary formats and proprietary vendor solutions is perpetuated • Funds will need to maintain two processing environments rather than one • Pass through arrangements become complicated and more susceptible to fee charging on employers. Contributions Implementation Strategy 6 2016 Move from support to compliance The third element of the core implementation strategy focuses on gradually transitioning ATO’s role from ‘education & support’ to ‘active compliance’ Compliance Support First Education and support first… – Support The ATO will first and foremost place emphasis on education and support for adoption of the standard by employers – This will take the form of: • Building an education and support library of resources (see the ‘Supporting Processes’ section) • Providing information registers and links to solution providers • Running a three-year communications program built around the ‘Key Messages’ set out in that section and utilising the Key Influencers network • Building partnerships and collaboration with the Key Influencers network to encourage syndication, re-use and re-purposing of ATO materials • Information about the help and support processes in the ATO. …then gradually strengthening compliance responses – The ATO’s compliance messages will reinforce the education and support first theme • It will highlight key dates for action and the consequences of inaction, including exposure to possible penalties, and how late payments for SG will be managed during implementation • On a risk management basis, ramping up compliance action against those wilfully ignoring their standards obligation. As time passes, we will expect employers to… • Develop awareness of their obligations under the new standard and to appreciate the opportunities it provides • Familiarise themselves with market offerings and solutions which are relevant to their business • Develop a standards implementation plan and agree a phase-in period with their default fund • Undertake the necessary onboarding and trials processes, leading up to a settling in period. Contributions Implementation Strategy 7 Getting employer on-boarding right How APRA funds on-board employers to the new data standard is likely to be the single most important determinant of success (or otherwise) in the implementation strategy Key onboarding tasks – ‘Onboarding’ refers to the process by which a default fund (or major partner fund) proactively engages an employer in getting ready and transitioning through to successful implementation of the standard – Some of the most important tasks are outlined in the side-bar – These will take time, care and thoughtful engagement. Choice fund onboarding requirements – The process for handling new members choice selection and registration needs strengthening – Funds will need to start communicating data associated with the choice form more directly and reliably with the employer (print out vs manual entry/electronic comms) with employer – SMSF member arrangements need special attention. Best practice tips (for APRA funds) – – – – Understanding employer capabilities and preferences is critical – segmentation and analysis is fundamental to this understanding Developing and executing a strategy in progressive waves and which takes account of this segmentation is needed Face to face dialogue will be important in laying the groundwork for change with many employers Publish FVS data and any other helpful information in an easily accessible place on a fund website (not hidden behind login walls). Contributions Implementation Strategy Onboarding Tasks* 1. Provide employer with pack setting out: Fund identifiers mapping of products/SPINS to USI’s electronic service address Security credentials process bank account details 2. Proposed implementation approach including: Implementation windows Onforwarding approach ‘First time’ through approach Proposed testing and trials approach * Assuming employer is a candidate for adoption of the standard. If not, information re bridging solutions changes will be required. 8 Education and Support Resources The ATO is building a library of educate and support resources to leverage the implementation effort – other intermediaries and influencers will re-use this material and add their own Legal Framework Superannuation Data and Payment Standard 2012 (Legal Instrument) Superannuation Data and Terms(Schedule 2 of Legal Instrument) Payment Methods (Schedule 3 of Legal Instrument) Contributions Message Implementation Guide (Schedule 4(A) of Legal Instrument) Message Orchestration & Profiles (Schedule 5 of Legal Instrument) Error Management (Schedule 6 of Legal Instrument) User Guidance Contributions & Member Registration - User Guide Contributions & Member Registration - Business Scenarios Contributions & Member Registration – Compliance Statement Employer Fact Sheets Employer FAQs Employer Video Employer Contributions Animation – Payroll Scenario Employer Contributions Animation – Service Provider Scenario Fund Fact Sheets Fund FAQs SMSF Fact Sheets SMSF FAQs Technical documentation Contributions – Schematron files Contributions – Sample XBRL instance documents Contributions – Test and Conformance Guide Contributions – Interoperability Guide Fund Validation Service – User Guide Fund Validation Service – Terms and Conditions EmployerTIC Service – User Guide EmployerTIC Service – User Guide TA Subgroup website – Issues Tracking, Minutes, Notifications Solution Links Payroll Register Gateway Register Testing & Certification Register Powerpoint presentations Contributions & the Data Standard: 1 – Understanding the Law Contributions & the Data Standard: 2 – Understanding Messaging & the Standard Contributions & the Data Standard: 3 – Getting Ready for Implementation DataStandards website (ato.gov.au/datastandards) Latest news, subscriptions, topic summaries and links Contributions Implementation Strategy 9 Next steps By 30 September 2013: Key support resources finalised by the ATO to support the implementation of contributions data and e-commerce standards All substantial changes to technical documents will be flagged and baselined inherit relevant changes from rollover implementation (either as interpretation or doc changes) – refer SILU site documentation update the Message Orchestration and Profile Guide (Sch. 5) MIG to include a mandatory part-property in the message header that specifies the employer’s (sender) electronic service address Through September – November 2013: Progressive series of workshops with industry stakeholders One-on-one sessions with ‘prime mover’ groups Ramp up media campaign © COMMONWEALTH OF AUSTRALIA 2013 This presentation was current 10 September 2013 Contributions Implementation Strategy 10