NHS Pensions have confirmed directly with NASGP that, with effect from 1st April 2019, annualisation for freelance GP locums pensioning their NHS income in 2015 Scheme (England and Wales) will come into effect if any breaks of any length are taken.
In practice this means that, unless you are locuming from the 1st April 2019 all the way through to the 31st March 2020, and working every day, you will be subject to annualisation under these new rules.
Freelance GP Locums
Freelance GP locums who are members of the 2015 Scheme and who are not in pensionable service on 1 April 2019 , or on 31 March 2020, or who have breaks of any length during the year, must annualise their pensionable income to set their tiered employee contribution rate. Therefore all breaks must be factored in by a 2015 Scheme freelance GP when annualising their pensionable income under the 'add then annualise' method when setting their tiered rate.
Freelance GP locums who are members of the 1995 Section or the 2008 Section are not subject to annualising. Their tiered rate in year 2019/20 is based on their aggregate GP pensionable income.
Salaried GPs are subject to the same annualising rules as freelance GP locums. That is, if they are 2015 Scheme members they are subject to annualising and if they are 1995 or 2008 Section members they are not.
This means, for example, if a 2015 Scheme salaried GP commences their first pensionable post on 10 April 2019 (i.e. has non-pensionable service of nine days) and remains in continuous pensionable employment until 31 March 2020, they would annualise as follows;
- Actual 2019/20 salaried GP pensionable income ÷ 356 days pensionable service in 2019/20 x 365 days
2015 Scheme portfolio GPs (i.e a GP who is both a salaried GP and a freelance GP locum in 2019/20) are subject to annualising. In accordance with the ‘add then annualise’ rule they must aggregate their total GP pensionable income in 2019/20 and divide this amount by actual days of pensionable service, and then multiply by 365 days. For example, if a 2015 Scheme salaried GP has a pensionable post from 10 April 2019 until 31 August 2019 (144 days) and then has several freelance locum GP posts from 1 November 2019 until 31 March 2020 totalling 90 days pensionable service, their total pensionable service in 2019/20 is 234 days. They would annualise as follows;
- Actual 2019/20 portfolio GP pensionable income ÷ 234 days pensionable service in 2019/20 x 365 days
1995 or 2008 Section portfolio GPs are not subject to annualising.
- December 2018 - NHS Pension Scheme: proposed changes to scheme regulations (original consultation)
- March 2019 - Consultation Response (The National Health Service Pension Scheme, Additional Voluntary Contributions and Injury Benefits (Amendment) Regulations 2019)
- April 1st 2019 - New Draft regulations from April 1st 2019.
See section 38 and 39 which both relate to the changes for the 2015 scheme that causes this new ruling to apply to any break:
Amendment of regulation 38
82. In regulation 38 (members’ contributions: supplementary: medical practitioners and non-GP providers), in paragraph (3), in sub-paragraph (a) for the definition of “NDPS” substitute “NDPS is the number of days of M’s group D service in the scheme year”.
Amendment of regulation 39
83. In regulation 39 (members’ contributions: supplementary: dental practitioners), in paragraph (3), in sub-paragraph (a) for the definition of “NDPS” substitute “NDPS is the number of days of dental practitioner service in the scheme year”Draft amended regulations (published April 1st 2019) regulations 38 and 39 of the 2015 Scheme
NHS Pensions will be publishing detailed annualising guidance (including a calculator) for all types of GPs in the Practitioner webpage of its website.