On Wednesday 16th January, I met NHS England in relation to the ongoing issues with Capita/PCSE and their mishandling of GP pensions. Present were Nikki Kanani (acting director of primary care at NHSE), Jill Matthews (MD for Capita recovery at NHSE), Caroline Greenwood (head of PCS pensions at NHSE), and Peter Sparshott (partner at PriceWaterhouseCoopers).
While some of the current problems predate Capita/PCSE taking over the management of pensions in 2015, a lot don’t, and NHSE acknowledged (as they did in the letters from September 2018) that there have been serious issues with PCSE’s delivery of pensions work. Those problems have caused a loss of confidence in the scheme among GPs, with the associated knock-on effects on workforce retention, and NHSE have begun to address these, including by appointing PwC.
Agreements
The below points have been agreed by NHS England and GP Survival following on from the meeting. While I think we all accept that changing the way organisations work can take time, if any of the below happen to you in future, please email me grundyn@gmail.com and NHSE at england.gppensions@nhs.net, and ask PCSE to note the outcomes of the meeting on 16/01/19.
- Closing cases: PCSE have been told they must not close complaints until they have been resolved, so you should not be asked to open another case if you have previously done so and the issue remains outstanding (PCSE can pause the case instead). This had been previously agreed by Krishan via the GPC, per item 7 in his blog, but a member’s case I raised made clear this was still an issue.
- Performers’ list issues: If you are told that your pensions records cannot be updated until your employment dates are reconciled with the performers’ list, PCSE should handle that under the case you have raised, even if you raise the case with the pensions part of PCSE; their teams should pass information between each other internally. The same should happen if you raise a case with NHS pensions, though this may take longer; again, this had been previously discussed by Krishan.
- Wet signatures: provided forms have been sourced from your nhs.net email account they are acceptable. If you submit forms and are told to resubmit them with wet signatures, you should not have to resubmit forms nor to provide them again in signed form.
- Late contributions: if you submit type 2 pension forms (pretty much everyone except partners and locums working <6m at a practice), there is currently an amnesty in place allowing you to complete them now for every year going back to the 2009/2010 year. This is covered in Krishan’s appropriately-titled blog – but the amnesty ends on 28th February. If you are a locum working <6m, you have 10 weeks to submit payment, and as long as the payment is with PCSE by 10 weeks after the employment, your pension will be credited.
In as much as any of this is quick or easy, these should help make the process of interacting with PCSE easier over the coming months. NHSE and GP Survival also intend to draw up short flowcharts, aimed at GPs and at PCSE and the NHS pensions agency, explaining which teams handle queries on particular areas, both so that members can contact the right team to begin with, and so that if they don’t the other teams can easily pass queries between themselves.
Ongoing work
Medium-to-long term, there is still a significant amount of work to do, but NHS England have agreed to work towards:
- Improving communications, particularly with locum doctors. Locum and sessional doctors often don’t receive announcements relating to pensions and other national issues, and are less well covered by current communications strategies than other groups. GP Survival will be working with NHS England, and groups representing and supporting locum work, to keep members informed on their pensions and other issues.
- Casework. PwC are looking at nine individual cases which members kindly gave me details of to raise, and which highlighted several of the major issues with the current system for both GPs and their employing organisations. It’s enormously encouraging that two have already been resolved in the ten days since the meeting; the intention here is to identify where and why errors are happening and to address these at a system level within PCSE, and NHS pensions.
- Reducing the burden of paperwork on locums, by replacing multiple type A forms and the type B form with a single monthly form covering all locum work. This would dramatically reduce the burden of paperwork on locum doctors, and NHSE and PwC are eager to see it happen; whilst no timescales have been committed to, 2020 was mentioned and I hope to have further information on this in due course.
- Online access to records: the ideal situation would be one in which members can log on to a website and check their annual contributions throughout the duration of their membership. This is a significant piece of work, but it is something which we would like to see.
There are areas where we have yet to reach agreement, particularly around the major issue of missing pensions data:
- What happens where an individual has submitted cheques (typically as a locum) along with the relevant paperwork and these have not been cashed?
- What happens where historical pensions contributions have been made but not credited to a member’s pension?
- Where a member has overpaid pensions contributions, what is a reasonable timeframe within which they can expect repayment, and what interest should be charged on such overpayments and from what point? Regulation T8 of the NHS pension regulations means the pension scheme is obliged to pay interest where there’s a delay in receiving benefits, but this doesn’t cover overpayments.
- How can the process around members needing statements for divorce purposes be improved?
- How can the current burden of submitting and resubmitting forms be minimised for employers and employing organisations? We are testing whether something works here which I’ll come back to you on in due course.
- On annualisation, how can the absurdity of the current situation be addressed? The problem here is that members in the 2015 pension scheme who take breaks within a tax year, e.g. due to maternity leave or illness, may end up paying pension contributions as if they had earned every month of the year, even though they didn’t. Further meetings involving those who understand the issues better than I do are needed here.
Summary
As above, missing data is the largest issue. We know from the SARs campaign that there is data missing in some cases from decades ago, and while NHSE are required by law to have the forms to process pensions contributions, it cannot be fair to put the burden of making good historical and recent errors onto members or employing organisations.
There is particular work needed to reduce the disproportionate impact on locum doctors relative to other GPs. Everyone but locums can currently submit pensions contributions and forms for the past decade, locums can for the last ten weeks; everyone else can submit one form per year for each employment, locums do an average of 55.
What I would advise everyone to do from now is to keep proof of submission of pensions forms and contributions; the biggest problems will arise if member contributions were paid 20 years ago but records of those have been lost by Capita and its predecessors, and not kept by the member.
Overall, however, I was much more encouraged by the meeting than I expected to be. I got the impression that there is a genuine sense of frustration within NHSE at the human impact of PCSE’s handling of pensions, and an accompanying willingness to work to fix it.
Thanks are due to Krishan Aggarwal of the BMA’s general practitioner’s committee and Richard Fieldhouse of NASGP for their time and advice prior to the meeting, to Nikki Kanani at NHSE for arranging the meeting, to the 400+ of you who’ve submitted SARs and got us to this point, particularly to those of you who’ve gone into your data in detail and told me where it’s wrong, and those who’ve agreed to let me raise their cases with NHSE on their behalf.