ECH7022 - Commencing the Compliance Check: The Intervention Plan, Systems Template and Work Programme Template

Intervention Plan

The Intervention Plan is mandatory in all Employer Compliance Checks and provides a strategic view of the case. It should

• form a clear audit trail of how each of the risks identified before and during a compliance check are tackled, and
• what the final outcome is for each risk

The Intervention Plan contains statistical information such as

• potential yield, or
• expected outcome

which must be completed.

The detail recorded in the plan must be proportionate to the risk and the work undertaken.

All compliance checks require a plan to

• provide a strategy for proposed actions, and
• to record the outcomes.

A good intervention plan will provide a structure for

• looking ahead to ensure all relevant information is obtained
• ensuring potential problems are anticipated
• taking the time to be clear about the actual risk of tax/NIC loss
• anticipating the likely response to the initial enquiry
• recording the steps that you would expect to take to address the risk
• planning what you intend to do and when you intend to do it
• maintaining focus on the progress of the case
• ensuring that the compliance check is cost effective and reduces the customer burden

You should use the intervention plan to record

• specific risks to be addressed
• key steps planned to address those risks
• results of work/tests undertaken
• outcomes and conclusions, yield and
• where papers are kept

When completing the template you should

• ensure that risks are clearly identified. Single word entries are not sufficient
• the potential yield or expected outcome should also be entered
• record how it is expected to respond to each identified risk (this may include tests selected from the Testbank). The response should be cost effective and consider the customers perspective
• record and comment upon tests/checks carried out to include any open points.
• record the final conclusion for each risk with comments to support the result and details of any underpayment identified
• record the substantive actions taken during the course of the compliance check, for example.

The Intervention Plan is accessible via SEES and should be maintained in the SEES Casebook. Help on completing the template is also available on SEES.

You should

• update the Intervention Plan regularly so that it remains a comprehensive, up to date record of the compliance check and
• print off a hard copy of the template at the end of the compliance check, and

The Systems Template

The Systems Template was introduced to support the RBSA approach ( ECH7042) and to enable you to record details of the employers/contractors systems during the compliance check.

Its purpose is to ensure that

• there is an auditable system of recording
• which of the systems are robust, and
• which of the systems have weaknesses.

For details on completing the Systems Template see ECH7045.

Work Programme

Although the Work Programme is recommended as good practice on full compliance checks and complex cases, its use is not mandatory. Where you choose not to use the Work Programme, your manager should ensure that

• the Intervention Plan contains sufficient detail to give assurance, and
• all risks identified on the case are being robustly addressed