in the implementation strategy

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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
–
–
–
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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
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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?
–
–
–
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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
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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.
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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.
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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)
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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
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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
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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
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© COMMONWEALTH OF AUSTRALIA 2013
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This presentation was current 10 September 2013
Contributions Implementation Strategy
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