Update 9th April

I hope this bulletin finds you all well.

I hope those of you who joined the webinar last Friday found it useful, it was certainly a positive experience for me and I hope to do more as and when required.

I have had a number of people ask whether it was recorded and the answer is yes, the issue is how we share this recording. As the file size is to big to e-mail this will be hosted on our website. With this in mind, and with everything that has been going on I made the decision yesterday to create a " CBRS - Covid 19 Resource Hub " within the CBRS subscriber area of the website so you have access to all the information you need in one place.

I have added a number of links to resources as well as previous bulletins and the intention is to add last Friday's and future webinars as well.

Wishing you all a safe and happy Easter.

Adrian

2019-20 Accounts Deadline

Although not a direct impact on Revenues and Benefits teams the decision has been made to push back the deadline for 2019/20 accounts.

The Accounts and Audit (Coronavirus) (Amendment) Regulations 2020 were laid before Parliament on the 7th April and push back the deadlines for the completion of the 2019-20 accounts to 31st August for draft accounts and 30th November for audited accounts.

These dates are the deadlines and it is possible for the accounts to be done earlier.

2019-20 NNDR3

With the date of the accounts being pushed back MHCLG have also pushed back the deadline for the NNDR3 return.

The submission deadline for the NNDR 3 will be 31 July for the unaudited version and 30 November for the audited. Caroline from our FAN team has spoken to MHCLG and they will endeavour to get the form out to authorities by 1 May.

You may wish to start your collection fund accounting before receiving the form, in which case the NNDR 3 form for 2018/19 is a good guide to the calculation of NDR Income which doesn’t change from year to year as it follows the definition in regulation, just make sure you pick up any new reliefs in the calculation of Net Rates Payable.

You can also prepare your accounts earlier than 31 August and submit your NNDR 3 form before 31 July. In fact if you are still aiming to close your accounts down by the original deadline then you will probably need to prepare the NDR Income figure and balances without the form but will need to make sure that your final accounts are in line with your final NNDR 3 for 2019/20 otherwise you will need to correct this at some point in the future.

Also if you are in a pool or pool pilot then your fellow members of those arrangements may be shutting their accounts down faster than you and so wanting the pool/pilot benefit accrual figures quicker than the NNDR 3 deadline would suggest, as may your preceptors want notification of their shares, so its probably worth having a conversation locally on what works for your area.

Business Grants - Guidance

Version 4.1 of the guidance and a series of faq's has been published by BEIS. I understand that there are two versions of the faq document, one intended to be shared with business and one for local government use.

I am not aware of the faq's being available online so I have saved a copy in the new resource hub, just be aware this is the local government version rather than the one to share with businesses.

Business Grant - Appeals

I have been asked by a number of subscribers about the appeal process for grants. I raised this issue with BEIS and the response is below:-

"I assume all LAs have existing appeals processes and we would look to those to resolve this issue."

Therefore you will need to establish, if you haven't already got a mechanism in place, a process for dealing with disputes.

Business Grants - Counter Fraud

I have been made aware of a counter fraud fact sheet produced by Cabinet Office, distributed to local government last week. I have added this to the resource hub.

I am also told a further fact sheet will follow in the next few days.

Retail Discount - Repair Garages and MOT testing Stations

A particular property type which has been raised with me and an area where CIPFA and the IRRV have conflicting views.

I have asked for a wider opinion from within CIPFA and the consensus is that these types of properties could fall into the group of properties providing services to visiting members of the public, likening them to properties being used for PC/TV/domestic appliance repair.

As with all decision like these the ultimate decision on whether you think these properties fall into a qualifying purpose is yours.

Unoccupied Properties - Prohibited by Law

I am receiving intelligence that a number of organisations are requesting that their properties be treated as unoccupied from the date Government ordered all non-essential premises closed and some asking for a prohibited by law exemption be applied.

The advice I have been giving is as follows:

In order to consider whether “prohibited by law” is applicable the property must fall to be unoccupied.

There were discussions between MHCLG/CIPFA/IRRV/LGA etc on the issue of whether properties which closed due to government advice were to be classed as unoccupied and Gary Watson of the IRRV came up with the most sensible comment, rating law hasn’t changed. We can’t change the law and the interpretation of decades of case law just because of the current situation.

If the property was locked up at the end of the day with everything left in situ it is not unoccupied and therefore prohibited by law cannot apply.

What I would suggest is that you consider what your stance would have been prior to the pandemic, if you would have accepted the property as being unoccupied then, continue to do so now, if you would have argued it was not, continue to do so.

Retail Discount - Additional Data Capture

MHCLG will be requesting additional data on the current position with retail and nursery discount to monitor progress. This will be added to the weekly delta requests for BEIS on the grant schemes.

I am not clear on exactly what data will be captured, however, this is likely to include things like an estimate of number and value of qualifying properties and the number and value of relief awarded to date.

Nursery Discount

One of the areas that was flagged in my webinar last week was some people are struggling to access the Ofsted early years register.

I raised this with MHCLG who have in turn raised it with Ofsted.

My initial understanding was that billing authorities were to be given access to the register, however, this does not seem to be the case.

In unitary authorities there will be someone within your children's services who has access to the register, the bigger issue appears to be within two tier authorities where district authorities are not being given information by the County.

I am told that MHCLG will be issuing a BRIL in due course, however, they have asked me to provide the following contact details for Ofsted, I have taken the liberty of pre-populating the link below with a subject line as these enquiries need to be for the attention of Grace Rodgers.

extranetqueries@ofsted.gov.uk

Valuation Office Newsletter - Issue 2

The Valuation Officer have issue the second of their Covid 19 newsletters. If you haven't received the document it is available in the CBRS - Covid 19 resource hub.

BRIL 7-2020

Just as I was about to issue this bulletin, MHCLG have published BRIL 7 of 2020.

This gives a little more information than I have included above on nursery discount and the monitoring arrangements for the reliefs.