This page is updated following deputy chair of the BMA pensions committee Krishan Aggarwal's regular meetings with NHS England, NHS Pensions and Capita (PCSE). This is also a summary of his previous blogs. If there is anything you would like us to cover please email us at [email protected].
You can also find our general pensions guidance for locum GPs.
What pension tier to use
Whether you are a type 1, type 2 or a locum GP it is your responsibility to pay the correct tier.
The correct tier will be based on your income after adding all your pensionable roles together. You need to apply the same tier for all these roles.
Officer roles do not count towards your tier.
If you have underestimated your tier during the year, you would need to ensure that you top this up to the correct tier at the end of the year. If you were to overpay, at the end of the year you would need to claim it back, either from your provider or from Capita (PCSE) depending on your role.
Exclusive GP locums have no end of year certificate but will still need to ensure that the correct contribution tier has been paid.
GP trainees are officers in the NHS pension scheme. They become practitioners when they become a GP. When you are an officer, the tier is based on the whole time equivalent. In the first year of being a GP, a trainee will not have a full pension year, so they will always be annualised (see below).
When working for a CCG as a GP you can either be in the officer or practitioner scheme.
If you are employed you are an officer. If you are self-employed, providing contract for services, you are a practitioner and the CCG will need to complete a SOLO form for your pension contributions.
If you are solely a locum you cannot pension your CCG income unless you become employed.
Many CCGs have been doing this incorrectly and this has many implications. For example, placing someone as an officer when they should have been a practitioner and vice versa. This can affect which tier a GP has been on their employee contributions and therefore have implications on tax.
NHSE are currently reviewing all 193 CCGs.
Locum A and B forms
A freelance GP locum can choose to pension their work. If they wish to do so they must complete a locum A and B form and submit.
We have negotiated that the 10 week window that you have to submit your forms by is being waived until 31 March 2021 .
These are completed for particular type 2 work by your organisation. Your organisation will ask you to sign the form to check that the values are correct and for you to return. Your organisation will then submit this on your behalf to the relevant body.
Type 2 forms
This is a mechanism for NHS Pensions to ensure that you have paid the correct pension contribution tier across all your pensionable roles. Officer roles are not taken into account.
Completing the form is a legal requirement of the NHS pension scheme.
Your organisation will have submitted your SOLO form on your behalf, however, completion of the type 2 form is the responsibility of the individual GP.
NHS Pensions, however, may not know if you do other pensionable work, so the purpose is to collate it all on one form and apply the correct tier.
You might be concerned that, despite your organisation submitting this data, your record is not up to date. It may be that they have not received your type 2 form and so cannot confirm your tier is correct.
The forms are due to be submitted 11 months after the pension year end, ie for any given year the pension year ends on 31 March, the forms will need to be submitted by the following 28 February.
Forms are submitted via the PCSE portal.
Who needs to complete a type 2 form
Anyone that is a type 2 GP.
A type 2 GP is:
- a salaried GP formally employed by a GP surgery, APMS contractor, or a local health board (Wales)
- a GP who works solely for an OOH service either on an employed or self-employed basis
- a self-employed GP working for a CCG.
If you are not a type 1 GP (principal) or solely a locum you are more than likely a type 2 GP.
The exception is where you may have an officer role.
Working in England and Wales
If you work in both England and Wales, you will need to send your type 2 form to which ever 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 local health board.
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 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.
We negotiated an amnesty for previous years where members may not have completed their forms.
The amnesty form covers from 2009/10 through to 2014/15. 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, if older years are missing the more recent years cannot be updated. It is therefore more important to 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. Annualisation does not apply to these forms.
Annualisation was brought in from 1 April 2015 and applies only to members of the 2015 NHS pension scheme.
In the 1995 and 2008 NHS pension scheme, the tier you pay is based on your actual pensionable earnings. This is no longer the case for those who transitioned into the 2015 scheme.
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 if you have taken breaks within the pension scheme year (1 April to 31 March).
Annualising rules changed in 2019. In addition to this, the updated regulations remove the one month concession for type 1 and type 2 GPs and remove the three month concession for locum GPs.
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 pensionable 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.
The BMA has never agreed to the practice of annualisation and we disagree with the way that the regulations are being interpreted and applied. We continue to lobby against this unfair regulation.
Type 1 and type 2 GPs who are in a contract for the whole year will not be annualised, even if you are part time.
For example, a GP is a partner/salaried one day a week from 1 April 2019 to 31 March 2020. They are not annualised despite working one day a week.
If their contract is not for the whole pension year, then they will be annualised. Any break between contracts will also lead to annualisation.
It is mainly locums who are affected by annualisation.
To continue with an example like the above, if a GP were to work in a practice as a locum one day a week, under a locum arrangement, they would be annualised.
If you are a sole locum, the more days you are in the scheme, the less 'worse' annualisation will be because a GP is annualised over 365 days.
If a locum GP were to pick up an OOH session, they become a type 2 GP. As long as this role is pensionable and the SOLO form is completed for the whole year, then the GP would be removed from annualisation. You should do at least one hour in April and the following March to ensure the SOLO form spans the whole year.
If you do a locum session for a practice on a particular day you would normally complete the locum A form to state that you have worked the single day.
However, if the practice may need to contact you and you would need to make yourself available either by phone or email for the next week, you can include those additional planned days on your locum A form.
You may wish to include this in your fee for the original day, at no extra cost to the practice. The advantage would be that the practice may be able to contact you to discuss a patient you have seen and you would be removed from annualisation for the period that the locum A form covers.
You should agree this in advance with the practice in case the worst happens.
Where a GP (including a freelance GP locum) has passed away and therefore cannot complete their pension forms, their legal personal representatives must complete the forms. NHS Pensions would obviously assist with the delicate process.
If you were to locum at a particular practice for a long period, you and the practice may regard you as a type 2 GP. They would administer your pension contributions for you as they would for a salaried GP. This would remove the effect of annualisation if you work a full year.
Your TRS (total rewards statement)
As your NHS pensions record is updated sequentially, you should complete the oldest forms you are required to do first, so that your TRS can be updated.
When your TRS will be updated
The purpose of the 28 February date is that it would usually allow the forms to be processed and your TRS be updated in August of the same year. Any forms that are not updated should be updated in the December update to TRS.
The TRS is therefore updated 18 to 22 months after the pension year end.
For example, for the year ending 31 March 2019, the type 2 form will need to have been submitted by 28 February 2020 and the TRS will be updated in August or December 2020.
If your TRS is blank
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 is not.
There are many reasons why your TRS may not be up to date. If you have added years for example, TRS will not be updated and you can contact NHS pensions for a copy of your record.
Submitting forms and money
When submitting your monies please use:
- the reference number, that we designed, of your SD number
- followed by LOC for locum work
- followed by the month in the three characters
- followed by the year in two characters.
For example someone with an SD number of 12345678 submitting their locum forms in October would use 12345678LOCOct20.
We are unable to share NHS England’s bank details - you can get them from PCSE’s customer support centre on 0333 014 2884.
Forms are currently submitted via the PCSE portal. We negotiated that wet signatures would no longer be required. This process to submit pension forms will be changing soon.
PCSE are developing a new system for submitting pension payments which is due to be launched in September 2020. It will also allow you to see your pension record for the previous six years and the current year. This will help you to identify any gaps in your record.
Once PCSE have processed your forms, they update NHS Pensions where the final record is kept. There has been no change to how your pension is processed in the devolved nations.
We have had repeated assurance from NHS England that no individual will be disadvantaged due to the processing by PCSE of an individual’s pension, ie that monies paid to your pension are safe even if they have not been processed correctly at present.
Always 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.
Issues with PCSE
If your case is closed
PCSE should not be closing cases until a matter is resolved. If PCSE request further information, it should be possible to use the same reference number. If this is not the case please let us know at [email protected].
If your complaint has not been fully resolved within 40 working days, then you can escalate it to NHS England at england.pen[email protected]
NHSE are conducting a holistic review of the pension records to identify any gaps in records.