GP Survival campaign lead Dr Nicholas Grundy outlines the steps GPs should take to identify and address any issues with their NHS Pension record – including when to make a complaint and claim compensation
Usually the first time NHS doctors suspect they have a problem with their pension is when they log on to the government Total Rewards Statement (TRS) website, and find their record is blank. The error message is unhelpful, stating that ‘we have been unable to produce an estimate of your NHS Pension benefits through the automated process’ and directing members to contact their (unspecified) NHS employer.
For GPs, your ‘employer’ for pensions purposes is NHS England but the body likely responsible for the errors is Capita, the company contracted to administer GP pensions by Primary Care Support England (PCSE). Neither should be your first port of call.
Understanding the system
Before outlining who to contact first, it is worth understanding the three separate organisations involved in that TRS message:
1. Your actual employer, who pays you your salary and the pension contributions from it to PCSE.
2. PCSE, who should process those payments and the associated forms, and pass them to NHS Pensions.
3. NHS Pensions – sometimes referred to as the NHS Business Services Authority, which they’re part of – who should then collate those payments annually and update your pensions record on TRS.
The problems almost always lie with the second player – PCSE. However, I suggest approaching the organisations in reverse, starting with NHS Pensions, as follows.
Step 1 – Contact NHS Pensions
Firstly, put in query with NHS Pensions to find out why your TRS is blank – and asking specifically what, if any, historical data are missing from your pension record.
Do this by e-mailing [email protected].
In some circumstances, the TRS will be blank because a manual calculation is required to provide the statement, specifically:
If either of the above applies, don’t request that calculation yet – it is very important you ask NHS Pensions me for any missing data first, as you are only entitled to one free manual calculation of your pension each year, and for the majority of GPs, we know there will be errors and inaccuracies in your pension record.
The TRS is most commonly blank because PCSE have lost data for a given year, or because a member hasn’t completed the necessary end-of-year forms. If, for instance, I don’t submit a type 2 form as a salaried GP in 2013/14 (or if I do and PCSE lose it), that and every subsequent year will be blank in TRS.
Ask NHS Pensions specifically for your ‘Statement of Contributions’ (SoC). This is a year-by-year list of your pensionable pay, and the contributions paid into your NHS pension by you and your employer, split between the two main types of GP role. You can see an example on the GP Survival website.
You can in most circumstances ignore the contributions, and just check that the record of your ‘pensionable pay’ matches what you earned in the relevant year. If so, and if NHS Pensions says no data are missing, you will receive pension based on that pay figure.
If there are years which show no contributions at all, ask PCSE whether relevant pension forms are missing and check you completed them. If you haven’t done this, the SoC will show nothing for the relevant years, and there is no way round this except to complete the forms – they are a legal requirement. The BMA and NASGP, among others, have helpful guides on how to complete these. Once you have completed and submitted any forms as required, the SoC should then identify any years in which there is nevertheless an issue with PCSE.
Problems underlying missing data usually relate to:
1. The Performer’s List (PL)
Various issues with the PL can result in your pension record being wiped, mainly:
2. PCSE losing forms
This is very common, and essentially stems from cost-cutting by Capita when it took over GP Pensions work – many GPs who had accurate pensions data prior to 2015 have since seen years of that data vanish.
Step 2 – Contact PCSE
Once you’ve identified the data NHS Pensions say are missing, raise a case through PCSE’s web portal asking them to find the forms you’d previously submitted.
The key point here is to be prepared. Keep copies of everything you submit to PCSE, and track when they were submitted.
In a number of cases I’ve dealt with, GPs have had a full investigation into their pensions history carried out, and received written confirmation from NHSE, PwC and PCSE that the issues have been fixed, only to be told a year later that the exact same historical data have been lost. The standard response from PCSE is to ask for everything to be submitted again. If this happens, you should refuse to submit anything you can demonstrate you have already submitted, and raise a complaint as outlined below.
Be mindful also that the contact centre (web portal) is unreliable. It crashes, refuses to accept repeat CAS references (the PCSE identifiers for calls raised), and repeatedly closes cases that have not been completed – the only way to then get that case re-opened is to raise another CAS.
Step 3 – Putting in a complaint
Most GPs will receive back a list of forms or payments that PCSE has no record of. It is up to you what you do here. If they are asking for a small number of recent forms that you can easily send, then even if you’ve submitted these before it is probably worth doing so again, keeping a record, to get the issue resolved if possible.
If, however, they ask for large amounts of data, from years or decades ago, or information you cannot easily obtain (for example, cheque numbers and payment dates, copies of forms from practices or employers you no longer work for or which no longer exist), then you should complain.
There is now a process in place to claim compensation:
It is important for GPs to make a claim for compensation where appropriate, to compensate for their time and inconvenience but also to help provide leverage to ensure the issue is rectified long term.
Dr Nicholas Grundy is a GP in London and campaign lead for GP Survival
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