Pensions General practitioner General Practitioners Committee

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Sessional GPs guidance on NHS pensions and Capita

Since Capita took over the pensions contract in November 2015, it had been supported by a team from NHSE (NHS England) to help deliver the contract. NHSE made the decision to withdraw that support in January 2018.

This has brought unease as to how the service will continue and whether Capita will be able to deliver. This guidance aims to address the main questions that sessional GPs have raised.

This information was updated by the BMA sessional GPs subcommittee in January 2019 following meetings with Capita (PCSE) and NHS England.

  • Bank details

    The bank details for sending pension contributions have not changed and you can continue to use those you have used for previous months/years. They remain absent from the website, however, partly due to a security concern from NHSE and partly due to unallocated cash in its bank account.

    NHSE has advised that rather than give these details on the website, they would rather keep control over who has them, so the current approach will continue: individuals who do not know the bank details should contact PCSE either by phone or its online form.

    This raises concerns over how much of the unallocated cash is sessional GPs’ pension money. The BMA has stated previously that ‘there is no risk to your pension’, but this statement caused some confusion. To clarify, we have had guarantees from NHSE that no individual will be disadvantaged due to the processing of their pension, ie that funds paid to your pension are safe even if they have not been processed correctly yet.

    We recommend keeping a copy of all forms and money that you send to PCSE in case you need to provide evidence in future.

  • Emailed forms

    On 20 December 2017, PCSE went live with its online enquires form for all submissions, and is now accepting forms only through that channel or by post. The BMA first became aware of this in early December. We were not consulted and get the impression NHS Pensions was not either.

    We had previously raised concerns that their guidance notes advised that submissions could only be done from an NHS.net email account, yet many locums still do not have access to one. After much persistence, Capita (PCSE) have now changed their guidance notes to state: 'You will need to enter your email address when prompted (NHS.net email accounts are preferred)'. We can assure you that an NHS.net email address is not required, but preferred.

    When submitting your monies please use the reference number of your SD number, followed by LOC for locum work or SOL for SOLO work, followed by the month in the three characters and finally the year in two characters. 

  • Unallocated funds

    As mentioned above, these funds remain ring-fenced until they can be allocated to individuals.

    The easiest way to identify unallocated funds would be if individuals were to receive a statement of their pensionable earnings and a statement of contributions for each year, then members would be able to detect if any money was missing from their pension record and PCSE could begin the process of having it allocated.

    We are pushing for this harder than ever and now feel there is recognition from NHSE that this is a necessary step. NHSE continues to agree it is about doing the right thing for sessional GPs.

  • No mechanism of receipt

    Currently, there is no mechanism of receipt of:

    a. Locum A and B forms and payment
    b. SOLO forms
    c. Type 2 annual self-assessment forms
    d. Appraisers pension contributions (via Locum A/B forms or SOLO forms).

    Since the launch of the PCSE online enquiries form there should be a case reference number automatically generated for your submission. This was a small step in the right direction, but we did not believe it was sufficient. It was not a receipt that our records held by PCSE or NHS Pensions had been updated.

    Capita (PCSE) have now advised that individuals should start receiving an email receipt with values and to which month the contributions relate for locum work. There are standardised templates that Capita (PCSE) will now use.

    There is a difference between PCSE records being updated and the records held by NHS Pensions.

    As an example, for the year ending 31 March 2017, PCSE will submit its records to NHS Pensions around April/May 2018. This is in line with the requirement for Type 1 and Type 2 practitioners and their forms.

    NHS Pensions will then update its records, which will be visible on the total reward statements (TRS) in August 2018 – 18 months after the pension year end of 31 March 2017.

    For further clarity, NHSE holds the money, PCSE only processes it and updates NHS Pensions. PCSE does not have access to the funds.

  • Total rewards statement (TRS)

    The TRS is an online record of your Practitioner Pensionable pay and benefits.

    There is a difference between PCSE records being updated and the records held by NHS Pensions.

    As an example, for the year ending 31 March 2017, PCSE will submit its records to NHS Pensions around April/May 2018. This is in line with the requirement for Type 1 and Type 2 practitioners and their forms. NHS Pensions will then update its records, which will be visible on the total reward statements in August 2018 - 18 months after the pension year end of 31 March 2017.

    For further clarity, NHSE holds the money, PCSE only processes it and updates NHS Pensions. PCSE does not have access to the funds.

    Therefore at any given time your TRS statement (if available) will be at least 18 months in arrears.

    To further clarify, if the TRS is not updated, it does not mean that your pension record is not.

    There are a number of reasons why a record may not be updated, for example the cut-off date for Capita (PCSE) to send data to NHS Pensions was in April 2018. If Capita (PCSE) had received anything after this they will not be able to upload the data. Another example: the system requires data for sequential years so for instance, if there is data missing for one year, no subsequent years will show.  

    There is work happening to look at these issues to better understand how to resolve them.

  • Contacting Capita

    All queries are now to be submitted via PCSE online.

    We are not convinced that all historic queries have been resolved; we have heard that a number of individuals received emails to say their query had been resolved when they had not. In our last meeting, Capita (PCSE) recognised that the closing and re-opening of cases has not been beneficial for all involved. As a result, they will now not close cases until issues are resolved.

    We recommend resubmitting your query – you will now have an automatic reference number that will allow you to follow it up.

    If your query needs escalating please contact first point of contact (FPC) at the BMA.

    The BMA pensions team and the sessionals subcommittee have negotiated access to a specific team that is dealing with all the queries that members have asked us to resolve on their behalf. We have been successful in resolving hundreds of complicated queries. 

  • Type 2 annual self-assessment

    A Type 2 form is a mechanism for NHS Pensions to ensure that you have paid the correct pension contribution tier across all your practitioner roles. Officer roles are not taken into account.

    This is a legal requirement of the NHS pension scheme for Type 2 GPs. Many sessional GPs are unaware of the requirement to complete these forms.

     

    Who should complete the form?

    A Type 2 GP is:

    • A salaried GPs formally employed by a GP surgery, APMS contractor, or an LHB (Wales)
    • A long-term fee-based/self-employed GP who works for a GP surgery, APMS contractor, or an LHB for a period of, generally, six months or more may choose to be regarded as a Type 2 GP. Choosing to be regarded as a Type 2 GP after an initial period of locum work at a practice will render you subject to annualising but will also mean that 100% of your income is pensionable and that your life cover provision is improved. Alternatively, NHSBSA have agreed that it is possible to continue completing locum forms A and B beyond a period of six months continuous work with one practice. If this is chosen and locum work is undertaken exclusively for a scheme year then a Type 2 certificate is not required. 
    • A GP who works solely OOH either on an employed or self-employed basis.

    Essentially, if you are not a Type 1 GP (principal) or solely a locum, you are likely to be a Type 2 GP.

    If you do not complete the form, there is no risk to your pension, but your pension record may not be updated.


    When should I complete the form?

    The deadline is 28 February each year – 11 months after the previous pension year end of 31 March.

    This year, due to technical problems experienced by those completing the Type 2 form, there will be no punitive action taken by NHSBSA (NHS Business Services Authority) for those who miss the deadline. The errors on the form are currently being updated and any queries should be sent to [email protected]

    The TRS is then updated, usually once a year in August – effectively 18 months after the pension year end.

    For example, for the year ending 31 March 2017, the Type 2 form will need to be submitted by 28 February 2018 and the TRS will be updated in August 2018. (Last year, however, NHS Pensions decided to do a second update to TRS on 13 December 2017.)

  • Annualisation

    In the 1995/2008 NHS pension scheme, there is an officer scheme and a practitioner scheme. In the officer scheme, an individual’s tier is based on their whole-time equivalent (WTE) income. A practitioner's tier is based on actual earnings. The Government has tried to apply this WTE rule to practitioners in the 2015 scheme, but the regulations are extremely complicated.

    Essentially, this regulation means that certain members – those who have transitioned to the 2015 scheme and who have taken breaks within the pension scheme year – may have to tier their pension contributions at a higher rate based on their annualised earnings, rather than their actual earnings.

    We have withdrawn our guidance on annualisation until we obtain further clarity from NHSBSA as to the legitimacy and application of these regulations.

    Further to the agreement not to penalise anyone who returns the Type 2 certificate late, the Department for Health and Social Care has agreed that annualising should not apply (in relation to the completion of the 2016/17 Type 2 certificate) to long-term locums who have worked beyond six months in one practice and were previously deemed to be locums for the first six months and type 2 GPs thereafter. If you have been required to annualise your earning due to this rule alone, you can resubmit your form and your contribution tier will be corrected and any overpayment repaid to you. Read the statement from NHS pensions.

    If you are in the 1995 or 2008 scheme you do not have to annualise your pensionable earnings – the tier you pay is based on your practitioner earnings. Having raised this as a concern the Type 2 form has been updated to include a tab for these members.

    We have many unanswered questions about these unfair regulations, and NHS Pensions’ responses are unclear on how they are being applied. Until we receive clarification, we suggest directing all queries about annualisation to NHSBSA, which administers the scheme: [email protected]

    For other pension queries, please contact the BMA pensions team: [email protected]

    We are currently in the process of seeking legal opinions on the options available to us to challenge these regulations. 

    Read the BMA's latest statement regarding annualisation

  • Further reading

    Deputy chair of the sessional GP subcommittee, Krishan Aggarwal has written a series of blogs highlighting the impact of this issue.

    Capita and the NHS pension fiasco - what is going on?

    ...Part 2

    ...Part 4

    ...Part 5

    ...Part 6

    ...Part 7

    ...Part 8

    ...Part 10

    Pensions, where are we?

    Type 2 Forms and Annualisation – ARRGGGHHHH!

    Have you been affected by annualisation?