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My latest instalment is a rather long one, writing this feels more like a short story rather than a blog. I hope that you find these updates helpful. As always, if there is anything specific that you would like me to cover let me know by emailing [email protected]
As you will see, I have kept to a similar format as my previous blogs so it’s easier for you to see the issues that were raised and how we are progressing with them.
These updates follow meetings with NHSE, Capita (PCSE), NHS pensions and PWC which occur on average every four to six weeks.
Type 2 forms
I appreciate there is a lot of anxiety around these forms. So I am going to start with the basics and bring you up to the current situation. Some of this I have covered in my previous blogs however, I feel it may be helpful to go over it, to make it a more comprehensive guide.
What is a Type 2 form and what is its purpose?
This is a mechanism for NHS pensions to ensure you have paid the correct pension contribution tier across all your practitioner roles. Officer roles, which include GP registrar roles and CCG work undertaken under a formal contract of employment, are not taken into account.
Completing the form is a legal requirement of the NHS pension scheme.
Many of you will have diligently submitted your SOLO forms or the organisation (e.g. GP practice, CCG, OOH provider etc) that you work in would have done so on your behalf. Completion of the Type 2 form is the responsibility of the individual GP.
NHS Pensions, however, may not know if you do other practitioner work, so the purpose is to collate it all on one form and apply the correct tier.
Many of you are concerned that despite your organisations submitting this data, your record is not up to date. It may be the fact that they have not received your Type 2 form, so they cannot confirm your tier is correct.
Who needs to complete one?
The short answer - anyone that is a Type 2 GP.
A Type 2 GP is:
Essentially if you are not a Type 1 GP (principal) or solely a locum you are more than likely to be a Type 2 GP.
The exception is where you may have an officer role. This should not be included on the Type 2 form at all and does not contribute towards your tier.
If you work in both England and Wales, you will need to send your Type 2 form to the country you hold the Type 2 role in. If you hold a Type 2 role in both, you will need to send it to Capita (PCSE) and your LHB.
What about locum-ing?
If you are solely a locum, you do not need to complete a Type 2 form. You only need to do your locum A and B forms.
If you have a Type 2 role and you locum, you will need to add your locum income to the form, as this will form part of your pensionable pay and may change your practitioner tier.
Do I need to list all the individual practices I have locumed in?
We have been pushing for this for a long time as logically, there is no way to determine from the Type 2 form which practice has paid what monies as it is all lumped together in one sum, so there is no useful information that can be gained by this.
This information will be readily available on the locum A and B forms that a GP would have submitted.
We have this in writing from PricewaterhouseCoopers (PwC).
As you may know, we have been negotiating the amnesty forms for nearly three years.
The amnesty forms are live. These cover the years 2009/10 through to 2014/15.
To clarify, the first year these became a requirement was 2009/10. There was no requirement prior to this.
Your NHS Pension record can only be updated sequentially, thus if older years are missing the more recent years cannot be updated.
It is therefore imperative you complete the oldest forms that you need to do first.
If you have submitted these forms in the past, you do not have to resubmit them.
These forms were prior to the annualisation rules, thus annualisation does not apply to these forms.
We have received a few queries where Capita (PCSE) have advised members that they cannot process their amnesty forms. This should not be the case. Where the forms have not been completed correctly, PCSE should go back to the GP concerned to correct any errors. If however, there are no errors and the forms have been returned for another reason, please let us know and we will raise this again.
Annualisation was brought in from 1 April 2015 and applies only to members of the 2015 NHS Pension Scheme (i.e. not a 1995 or 2008 section protected scheme member).
This is essentially a regulation that will result in certain members having to tier their pension contributions at a higher rate based on their annualised earnings rather than their actual earnings.
This is dependent on whether you have taken breaks within the pension scheme year (1 April to 31 March).
The application of the annualising rules have changed. Previously, the rules would annualise locum GP roles separated from other GP roles and then add them together. The new rules allow you to add all your roles together and then annualise.
If you were adversely affected by the old rules of annualisation, you can go back and resubmit your forms for those years and claim a refund.
If you are happy with the previous calculations or just simply do not want to, NHS pensions have advised you do not need to resubmit the forms.
To help assess whether your tier would be lower under the revised annualising rules, NHS pensions will be releasing an annualisation calculator. There has been a delay in releasing this as it is still currently being tested.
Those who were worse off under the old annualising rules can complete the reimbursement claim form (also yet to be released). As the calculator has not been released yet you may miss the 28 February date. Please see the section below on this.
To clarify, the calculator is to enable those GPs who completed forms that applied the old annualising rule of ‘annualise then add’ rather than ‘add then annualise’ to see if they need to resubmit forms and claim reimbursement.
If you are a solely a locum in the years 2015/16 and/or 2016/17 and you would have paid a lower tier under the new ‘add then annualise’ method, once the calculator becomes available you should complete the same reimbursement claim form and your overpaid contributions will be reimbursed directly from PCSE.
Up until 23 January 2019, the Type 2 forms for 2015/16 and 2016/17 incorrectly used the original ‘annualise then add’ rather than the ‘add then annualise’ method.
If you have submitted the incorrect form but the calculator shows that you would have paid contributions on the same tiered rate under the ‘add then annualise’ method, you do not need take any further action.
If, however you have submitted the incorrect ‘annualise then add’ version of the forms, through no fault of your own, and you would have paid contributions at a lower tier under the ‘add then annualise’ method, you will need to submit the new reimbursement claim form when it becomes available on the NHS Pensions website.
Please do not shoot the messenger.
We have raised our concerns loud and clear, in a system where GPs confidence is wearing thin, these sorts of errors should not be occurring in any way or form.
How do I submit my forms and what about wet signatures?
Forms need to be submitted via PCSE Online.
We have been negotiating the issue of wet signatures for over two years, and NHS Pensions have agreed that if the email address provided on PCSE online is an nhs.net email address, a wet signature is not required. If however, you do not yet have access to NHS mail you will need to sign, scan and upload the form to PCSE online.
28 February 2019 deadline?
As your NHS Pensions record is updated sequentially, you will want to do the oldest forms you are required to do first, in order that your Total Rewards Statement (TRS) can be updated.
Furthermore, you will want to ensure that any forms that you submit are correct to the best of your ability, thus if you think you may be annualised for years 2015/16 and 2016/17 you may wish to wait for the calculator to be released to ensure that the forms you submit are correct.
Once previous years forms are complete, the final form to complete for this year is the 2017/18 form.
The deadline is to enable PCSE to update records with NHS Pensions and tallies with the tax year end. PwC have advised that ‘after discussion’, 28 February should be regarded as a ‘target date’.
PwC have stated, ‘it is accepted that late publication could mean that some GPs may miss the “target date” of 28 February 2019, and the’re will be no punitive action taken against those GPs - such as “zeroing” their pensionable income.
NHS Pensions have been clear, no GP will be penalised for the late submission of forms after the target date. However, delayed submission may impact on the ability of NHS Pensions to provide a TRS, an Annual Allowance statement and other records.
The main consideration should be that you do not fall foul of any HMRC liabilities and if you can, to submit your forms as early as possible.
When will my TRS be updated?
The purpose of the 28 February date is that it would usually allow the forms to be processed and the data transferred to NHS Pensions, in order that TRS can be updated in August of the same year.
NHSE, Capita (PCSE) and PwC have advised that they cannot guarantee that if you submit your forms by 28 February 2019, that your TRS will be updated in August 2019. We have subsequently been advised it may also not be updated in December 2019 either.
The important thing to remember is you must do everything within reason to submit your forms as soon as possible considering the delays described above.
My TRS is blank. What do I do?
There are two points to note here. First, the records need to be sequential, thus if a previous years records are missing, TRS cannot be updated beyond that.
Second, if TRS is not up to date, it does not mean that your pension record also is not. There are many reasons why your TRS may not up to date. A simple example: if you have added years, TRS will not be updated in which case you can contact NHS pensions for a copy of your record
What about the risk to my pension?
We have had repeated assurance from NHSE that no individual will be disadvantaged due to the processing of an individual’s pension, i.e. that monies paid to your pension are safe even if they have not been processed correctly at present.
My advice is as previously, keep a copy/evidence of all forms and monies that you send to Capita (PCSE) just in case you are required to provide them as evidence in the future.
Due to the Government’s recent change to the annual allowance due to tapering, there is greater risk that high earners may be subject to a tax liability. The annual allowance looks at your total income from all sources not just your NHS Pensionable income. Thus, it is vital that pension records are up to date.
We have raised our concerns that the delay in updating members records could result in a member receiving a tax bill relating to their annual allowance. The delay could also mean that an individual may miss the deadline for applying for ‘Scheme pays’. Thus, it is important that forms are completed as soon as possible with the proviso of my comments above.
If the delays of Capita (PCSE) processing your forms and updating your TRS this results in you having a tax liability, you can submit a claim via PCSE Online. Similarly, GPs who are looking for compensation as a result of additional accountancy fees can claim via the same process. All claims will be considered so long as there is no fault on your part.
Capita (PCSE) closing of cases
In the past (as discussed in blog number seven), we had agreed with Capita that cases would not be closed unless the issues were resolved. Unfortunately, we are aware that this is still occurring.
I would be grateful if you could let us know if this is the case and I can raise this directly. Please contact us at [email protected]
NHSE, PwC and Capita (PCSE) are embarking upon a new process.
Capita (PCSE) have been given a Service Level Agreement (SLA) to respond to all queries within 10 working days, and high priority queries within two working days.
If an individual has not received a response within this time period, the member can raise a complaint.
Capita (PCSE) will have 40 working days to respond.
If they have not responded by within this time, an individual can escalate the issue to [email protected]
If you would like to get in touch, email [email protected]. For specific pension queries contact [email protected]
I will continue to provide updates for you.
Krishan Aggarwal is deputy chair of the sessional GPs subcommittee, GPC UK and a member of the BMA pensions committee.
You can follow him on Twitter @Krishanx
Thank you for all this information. I have recently found out that Capita / PCSE did not process my 2016/17 certificate even though was submitted on a timely basis. This has impacted on my taxable income ( greater liaibilty for 2018/19 due to no balancing superannuation deduction) and income tax and in turn will lead to a tapered personal allowance. Can I claim for the increased tax liability through the claim portal ?