Reply To: over 65’s non-deps
Yes, we have read that dear Benefits Manager letter with interest too.
Our first thought, and that of our software suppliers was – jolly good. On reflection, however, we are not so sure. Leaving aside the confusion which may be caused to some with the paragraph on “normal change of circs rules”, we are actually a bit concerned that two of the “three big advantages” may not, in fact, be achieved. Our understanding was that, despite its complexity, at least the Anniversary date would consolidate all the changes and one level of ND deduction would then apply. The revised arrangement suggests that will not be the case, I.E. we will have to map each adverse change with a 26 week time delay. So, (an actual case from last month) e.g. a non-dep, looking for work moves to our area 27 year old on Jsa, she moves in with Gran, ten weeks later she secures employment – so, all other things being equal, a low deduction applies after 26 weeks and a higher one kicks in 36 weeks after the move in (26 weeks after employment). Previously we thought we would check, with Gran at the Anniversary date, as to what the current position is , assess the deduction and issue the decision. Now we will simply check that the non-dep is still there because we will be issuing a decision based on the facts as they used to be knowing that in ten weeks we are to supersede with the facts as we know them to be. Will advantage (i) and (ii) really be achieved by this?
Are we also correct in thinking that our software will simply have to live with the resulting mismatch during the 26 week period when CTB is increased (when the C-tax liability increases immediately the non-dep moves in and the 25% discount is lost), while no non-dep deduction applies?