Submitting your contributions
- The bank details that you submit your contributions to is still the same, if you need those details, contact PCSE (Primary Care Support England).
- We recommend keeping a copy of all forms and money that you send to PCSE in case you need to provide evidence in future.
- When submitting your monies please use the reference number of your SD (superannuation division) 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.
PCSE have unallocated funds in this bank account. These funds have been ring-fenced until they can be allocated to individuals.
It has been guaranteed by NHS England that funds paid to your pension are safe even if they have not been processed correctly yet.
We are pushing for PCSE to provide individuals with statements of sessional GPs pensionable earnings and a statement of contributions for each year. This way members would be able to detect if any money was missing from their pension record and PCSE could begin allocating it.
We have recognition from NHS England that this is a necessary step.
Confirmation of receipt of forms
Currently, PCSE automatically generate a case reference number when you submit your forms via their online enquiry form.
We do not believe this is sufficient as it is not a confirmation that the records held by PCSE or NHS pensions have been updated.
All queries are now to be submitted via the PCSE online enquiry form.
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. 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 BMA pensions, who have access to a specific team at PCSE and have been successful in resolving hundreds of queries.
Type 2 annual self-assessment
A type 2 form is a legal requirement 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.
Many sessional GPs are unaware of this.
A type 2 GP is:
- a salaried GP 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, NHS pensions 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 (out of hours) 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 by 28 February each year, there is no risk to your pension, but your pension record may not be updated.
When the Department of Health and Social Care advised that the method of calculating ‘annualised income’ should change from ‘annualise then add’ to ‘add then annualise’ they advised that the concessions regarding breaks in service would be removed.
From 1 April 2019 any break in pensionable service, for any type of GP, is required to be taken into account when calculating annualised income in order to arrive at your pension tier.
We have delayed releasing our guidance as NHS pensions have not responded to our queries.
For full details on annualisation rates and tiered employee contributions, see this guidance from NHS pensions.
SOLO forms and number of days worked
NHS pensions have suggested that any SOLO pensionable work is treated as underlying pensionable work for the full scheme year. This is because the SOLO form is completed for the period 1 April to 31 March. This implies that if an exclusive locum were able to undertake even one day of SOLO pensionable work then for the purposes of annualising they could detail 365 days worked in the scheme.
As NHS pensions have so far failed to engage further on this matter we would suggest that you contact them directly to confirm the position on the SOLO form and then complete your type 2 certificate accordingly. The harsh impact of annualising may be avoided in this way.
We understand that NHS pensions have also advised that appraisal work could detail the number of days worked on that appraisal, rather than as the one day of the appraisal.
Similarly, we understand that NHS Pensions have also advised that any locum work could detail the number of days worked on administration or follow up tasks, rather than as the actual day of work at the practice.
Again, we would suggest confirmation of this directly with NHSBSA and then completion of the type 2 form accordingly.
The impact of annualising may be significantly reduced should NHSBSA formally confirm this guidance.
We still have 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.
We are currently in the process of seeking legal opinions on the options available to us to challenge these regulations.