NHS pension superannuation scheme

When the NASGP was founded in 1997, GP locums were not entitled to contribute to the NHS superannuation scheme. So we made it our first priority to lobby the BMA to ensure we could, and two years later we succeeded.

The issue of pensions is complex and the administration of contributions can be frustrating, but the benefits of NHS pension scheme are still widely regarded as excellent. With anything so crucial as your pension, we also advise you to seek expert advice from an independent financial advisor.

In a nutshell

  • If you work freelance and are paid directly by the practice, not via a limited company or an agency, you can pension the pay you get for locum work in GP practices into the NHS pension scheme.
  • You cannot pension income in the NHS scheme for locum work carried out for Independent Providers.
  • You cannot pension pay for GP locum work carried out more than 10 weeks ago.
  • Your pensionable pay  is 90% of your NHS locum earnings - there is a 10% allowance for expenses.
  • In England & Wales, the employing practice must pay you the 14.38% employer contribution which you must pay into the pension scheme - it is illegal to keep the employer contribution.

How to do it

  • You need to get a Locum Form A signed once a month for each practice you worked in that month, certifying that you carried out eligible NHS work. It is usual to send this to the practice with your invoice. NB NASGP LocumDeck - free with NASGP membership - handles all this for you, complete with online paperless e-signatures.
  • At the end of the month, as soon as you can, use GP Locum Form B to record all the pay you received that month, and use it to calculate the total pension contribution you need to pay, combining your employee contribution with the employer contributions (all handled automatically by LocumDeck).
  • Your Locum Form B, plus accompanying Locum Form A and pension payment, should be sent to your relevant pension agency within 7 days of the end of the month e.g. Your January Form B, certifying your pensionable pay received in January, would be sent by 7 February.
  • Your employee contribution rate tier is based on all your Practitioner income, which means all NHS GP income (all handled automatically by LocumDeck).
  • If you're a locum, you may be estimating your tier at the start of a pension year (1 April) and reviewing whether you paid the correct contribution rate at the end of the pension year (31 March).
  • Note that Locum Form As are based on the date the work was done, whilst Locum Form Bs are about when payment was received, regardless of the date the work was carried out. This is a common cause of confusion, but basically if you work a session 2nd July, send an invoice and Locum A form at the end of July and receive payment in August, this payment would be included on your August Locum Form B (not July) - all handled automatically by LocumDeck.

Pension FAQs

General

No. This is one of the questions we get asked most at NASGP, since there's been a lot of conflicting advice over the years, not helped by some very strong opinions on social media. We've received exclusive clarification from the Technical Consultancy Team, NHS Business Services Authority (NHS Pensions).

Exclusive clarification from the Technical Consultancy Team, NHS Business Services Authority (NHS Pensions)

The regulations state that “a Locum practitioner may apply to join this Section of the scheme by sending an application [Locum Form A and Form B] to the Employing Authority.”

Members have 10 weeks to pension this work. If they do not submit the forms in time then this work cannot be pensioned. So in effect they do have a choice, if they choose not to pension the work they do at Practice A then they just have to let the practice manager know that they are not going to pension it so that the 14.3% is not included in the cash envelope.

It's complicated. The bottom line is that, in most cases, if you contribute to the NHS Pension scheme and all the NHS work you perform is as a GP locum, then the DIS payout your dependents receive on your death could be much less than if you were working in other roles. Kirsty McGaun and Nigel Farrar from Legal & Medical explain what to do in this article.

NASGP member BD has raised this very important question, since NASGP's LocumDeck excludes travel costs from the Locum A pension calculation.

The NHSBSA, in its 2017 factsheet for GP locums, states:

Q. Are travel expenses, i.e. motor mileage allowance, pensionable?

A. No. Deduct 10% of your gross pay first which accounts for expenses.

So is it just a plain fat 'no'? Does one include one's charges for travel as 'gross pay', or include it? And is NASGP correct in not including expenses i.e. travel costs/mileage in our automated Locum A forms within LocumDeck?

Our advice from Honey Barrett accountants (4th May 2017), and confirmed by their pension experts from the Association of Independent Specialist Medical Accountants, has confirmed NASGP's position by pinning down the actual legislation:

1995 regulations, schedule 2, regulation R1, paragraph 6(3):

"In the case of a locum practitioner, "pensionable earnings" means all fees and other payments made to the locum practitioner in respect of the provision of locum services (but excluding payments made to cover expenses or for overtime), less such expenses as are deductible in accordance with guidance laid down by the Secretary of State."

Honey Barrett conclude "...[pensionable earnings] excludes expenses, so just the locum fee x 90% (which is the allowance for expenses as stipulated by the Secretary of State)."

You can not pay any contributions in to the NHS superannuation scheme that were paid to a limited company - so that means that if you're employed by a company (such as a locum agency or your own private company), you'll have to use an alternative pension scheme. Locum GPs who are members of a NASGP Locum Chambers continue to work as either self employed or through their own Limited Company, so those that are self employed can still contribute into the NHS Pension Scheme.

SD86 statements were phased out in 2014 and have been replaced by the annual benefits statement which can be viewed online, annually.

This benefits statement contains all the information that was previously included on the old SD86 form.

 

As a Type 2 practitioner, your self assessment will be used by PCSE to determine whether you have paid the correct tiered contributions across all of your GP pensionable posts. 

A Type 2 medical practitioner is a:

  • Salaried GP formally employed by a GP surgery, APMS Contractor, or a LHB (Wales).
  • Long-term fee-based GP who worked for a GP surgery, APMS Contractor, or a LHB.
  • GP who solely performs OOHs either on an employed or self-employed basis.
  • GP ‘with special interests’ (GPwSI) employed or engaged by NHS England or a LHB.

As a rule of thumb, any GP who is not a GP partner, or not solely working as a GP locum, will probably be considered a Type 2 practitioner.

Every Type 2 medical Practitioner in England and Wales is required by law to complete an annual self-assessment form and arrange for any arrears of employee contributions to be sent to the relevant NHS Pension Scheme ‘employer’. If contributions have been overpaid, the Type 2 GP must also be pro-active in recovering these.

The form must be sent to the relevant local area team in England or LHB in Wales by no later than the last day of February each year.

If a Type 2 medical Practitioner fails to complete the form and subsequently pays employee contributions at the wrong rate, they are acting in breach of statutory pensions legislation; this may affect their NHS pension benefits at retirement. There is more detailed guidance on the form.

Do I need to list all practices, even ones I've locumed in (Personal details TAB - Tab E)?

  • No. You only need to list the practices where you were Type 2 (salaried) - it's referring to the practices in which PCSE made deductions direct from via the practice budget (therefore excludes locum posts, so they are aware of where any corrections need to be made if appropriate).

No. Payment of the employer’s contributions is a statutory requirement and those practices that do not comply can be referred to the Pensions Regulator and legal action taken against them.

NASGP strongly condemns the behaviour of booking platforms that facilitate practices to behave in this way, and is one of the many reasons we have developed LocumDeck to rebalance the control that locums need in order to determine the way in which they choose to practice as a GP.

Partner - NHS Pensions

PCSE say you must not pension this work through locum Form A or Form B, so you'll have to pension this extra work according to your existing NHS pension arrangements.

Partner - HMRC

If you perform GP locum work in the practice where you're a partner, this always has to be worked as overtime (and adjusted on your profit share), and not as a self-employed locum.

Salaried - NHS Pensions

There is a provision that, under the NHS Pension scheme, you may be able to pension locum work in the practice where you're salaried.

Salaried - HMRC

But you must check first with the practice that these locum sessions can be classified as self-employed work - not overtime - to comply with UK HMRC tax law and to avoid any fines.

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Employer's contribution

If you are a GP locum in the NHS scheme, the practice must pay a 14.38% contribution to you, and you then pay that to NHS pensions along with your personal contribution using Form A and Form B (fully automated in LocumDeck).

If you are not in the NHS scheme, you can still pay into a private pension scheme from your income, although there is nothing contractual in place for non-NHS schemes.

No.

You've got 10 weeks from the first date worked in that month to pay your NHS pension payment. Go beyond that, and PCSE can reject your payment.

But strictly speaking you're not free to spend all that un-cashed money; the employers contribution must to be returned to the practice. That said, if you're using NASGP's T&Cs built into LocumDeck, there is a clause that allows you to reserve the right to charge an extra 20% to compensate you; in which case you can then keep what would have been your employer's contribution, and use this and what would also have been your personal contribution, and you'll be wise to invest it in a private pension pot - but it'll be unlikely to accrue the same benefits as it would have inside your NHS pension.

If practices are not paying you in time, please refer them to the Locum Forms A that remind them to pay you promptly.

If you simply forgot to make the payment, you are free to try submitting it anyway, advisably with a covering letter apologising for the delay and including any unforeseen circumstances.

The statutory NHS Pension Scheme Regulations and section 49 of the Pensions Act 1995 states that the employer has to pay the employer's contribution if you're contributing to the NHS superannuation scheme.

The BMA is also very clear on this.

Legal obligations

Failure to remit contributions to the Scheme, complete relevant paperwork, update member pension records, or deny employees access to the Scheme constitutes a breach of the statutory NHS Pension Scheme Regulations and section 49 of the Pensions Act 1995. Section 48 of the Pensions Act 1995 and section 70 of the Pensions Act 2004 states that NHS Pensions has a legal duty to report any ‘breaches of law’ to the Pensions Regulator. If an individual is found guilty of a ‘breach of law’ they may be subject to a heavy fine, imprisonment, or both.

And also, according to the BMA, if that practice is a GMS practice it is also acting in breach of the statutory GMS SFE (Statement of Financial Entitlement). The SFE has penalty clauses including giving the PCO powers to withhold monies it pays to the practice if any part of the SFE has not been complied with.

Since early 2013, in England and Wales, since funding is provided for all superannuation contributions, including those of GP locums, it is now the responsibility of practices in England and Wales to pay the employer’s contribution for locums.

If a practice therefore refuses to pay, the NHS Pensions Division, the Pensions Division can withhold monies from a GP Provider’s pension benefits if they decide they have been acting illegally.

The NHS Pensions Division also have a duty to inform the Business Services Authority, at NHS Counter Fraud Services, if they believe that fraud may have taken place in the NHS. NHS Counter Fraud has already investigated several Practices who are allegedly breaking the law.

Exclusive advice from NHSPA

If you are an employed sessional GP (an assistant, retainer, or salaried) working for an organisation that qualifies as a NHS Pension Scheme Employing Authority (GP Practice, CCG, LHB, etc) your employer must, in law, ensure your employment is pensionable. If you are a self-employed freelance GP locum working in the NHS you have been entitled to ‘pension’ your income since April 1st 2001. Your scheme membership is ‘triggered’ by completing (and submitting) forms A and B.

If you are a freelance GP locum working for an agency (or a commercial deputising agency) or have set yourself up as a limited company you fall outside of the NHS Pension Scheme and cannot ‘pension’ your NHS income; you should therefore consider alternative pension arrangements.

Once you’re paying regular Scheme contributions into the Scheme, keep an eye out in your bank statements to ensure your cheques have been cashed as not all authorities send monthly statements.

Meanwhile, for GP locums, practices are responsible for paying the 14.38% employer’s contribution.

LocumDeck does not have a "pension included" button as we believe that enabling practices to set "pension inclusive" rates has a pernicious, negative impact on the NHS pension rights of GP locums.

NASGP has received reports from many colleagues that "pension-inclusive" rates can enable practices to lower the fee paid to locums who are claiming pension compared to those who are not claiming pension.

In our view, this is a dubious practice and arguably breaches the practice's legal obligation to pay the employer's pension contribution in addition to the locum's fee, without lowering the locums fee solely for the purposes of avoiding pension payments.

So NASGP believe it is far more transparent to clearly separate out the session fee and employer contribution elements so that it is clear to all parties that a pensioning locum is accepting a lower fee in comparison to a non-pensioning locum.

Calculate pension-inclusive rate

But there are still going to situations where, despite all of this, a figure for a pension-inclusive rate is needed.

In which case, if you divide your rate by 1.12942, you'll arrive at the exact pension inclusive rate, which you can then round to two decimal places.

  • NB if you round to 1.12942 to 1.13 or even 1.129, you can get a wrong final figure e.g. for £1,000
  • £1,000/1.13 = £884.96
  • £1,000/1.129 = £885.73
  • £1,000/1.12942 = £845.41

Bank: Nat West
Account name: NHS England
Account Number: 10014896
Sort Code: 60-70-80

Reference: You will be asked to provide your UIR, which LocumDeck automatically stamps on both your Form A and Form B.

Once payment has been made, submit Locum A and B forms online or by post to

Primary Care Support England,
PO Box 350,
Darlington,
DL1 9QN.

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Pension tiers

Advice to NASGP as part of our membership of the NHSPS Stakeholder Engagement Group

As a freelance GP locum, if you're a member of the 1995 or 2008 NHSPS, your tiered contributions rate is based on your actual freelance GP locum Practitioner pensionable pay.

However, if you're a member of the new 2015 NHSPS, your tiered contributions rate is based on your annualised freelance GP locum Practitioner pensionable pay.

If, as 2015 scheme members, you don't have any breaks, then your actual and annualised pay would both be the same.

So long as, as a freelance GP locum, you perform pensionable work at least once every three months, your pension record will be kept open and so, for the purposes of tiered contributions only, will be regarded as being continuous, meaning that actual and annualised are the same.

Beware the NHS pension annualisation booby trap

England, Wales and Northern Ireland

The table sets out the member contribution rates that will apply in both the 1995 and 2008 Sections, as well as the new 2015 Scheme from 1 April 2015 until 31 March 2022.

 Tier Range Amount
 1 Up to £15,431.99 5.0%
 2 £15,432.00 to £21,477.99 5.6%
 3 £21,478.00 to £26,823.99 7.1%
 4 £26,824.00 to £49,845.99 9.3%
 5 £49,846.00 to £70,630.99 12.5%
 6 £70,631.00 to £111,376.99 13.5%
 7 £111,377.00 and over 14.5%

Scotland

The table sets out the member contribution rates that will apply in both the 1995 and 2008 Sections, as well as the new 2015 Scheme from 1 April 2019 until 31 March 2020.
 Tier Range Amount
 1 Up to £17,864 5.2%
 2 £17,865 to £23,112 5.8%
 3 £23,113 to £28,747 7.3%
 4 £28,748 to £53,025 9.5%
 5 £53,026 to £75,703 12.7%
 6 £75,704 to £116,360 13.7%
 7 £116,361 and above 14.7%

The NHS superannuation scheme is open to NHS employees and self-employed GP locums employed by NHS practices.

This explains why the LocumA form stipulates that, in relation to the NHS pension scheme:

  • Non-NHS (i.e. private) work is not pensionable
  • Freelance GP Locums trading as limited companies cannot pension their income

If you're employed by a locum agency, you are working for a private (non-NHS) company, and are therefore unable to pension your work in the NHS pension scheme for the same reason. But you can pension your work into a private scheme.

GP locums working through chambers can generally pension their work using the NHS pension scheme since they remain self-employed (unless they trade as a limited company through the chambers, or for some reason they are employed by the chambers).

GPs in England and Wales who are seeking reimbursement of some of their tiered 2015 NHS Pension Scheme contributions, or need to more than they'd expected to because they underestimated their income, will need to email nhsbsapensionmember@nhs.net.

This depends on several factors, see our full article on NHS pension annualisation.

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Completing and sending Locum A and B forms

Our popular locum pension spreadsheet has now become LocumDeck  - completely free to NASGP members. Within seconds, generate online automated pension forms, complete with paperless electronic signatures, including invoicing, bookkeeping, T&Cs, document manager and optional online 'Instant Book' booking.

The NHS pension websites are not the easiest to navigate, so we've provided direct links to all locum GP Form A and B here for you.

Better still, we've completely automated all these forms and embedded them into NASGP's LocumDeck - completed within seconds, then even include the ability for practice managers to instantly sign them electronically.

There is a specific section for locum GPs, which towards then end gives the correct link to find the forms you'll need. Or more specifically, you can download the forms direct here.

NB LocumDeck, NASGP's online invoicing and booking system, includes automated Locum A and B forms with the new unique identifying reference.

For May 2017 there is a new GP locum factsheet too.

For use from 1 April 2019

Form Solo for use from 1 April 2017

See more NHS pension FAQs from NASGP

There's a general section for all GPs, and also links to the forms you'll need if you're a locum GP. Links to the specific forms are here:

NB NASGP's online invoicing system includes automated Locum A and B forms for Scotland.

See the list of locum forms on the NI HSC pensions website.

NB NASGP's online invoicing system will include automated Locum A and B forms for Northern Ireland beginning September 2016.

LocumDeck user?

LocumDeck handles this all entirely automatically. You can leave this page and go and make yourself a nice cup of tea.

Not a LocumDeck user?

You're going to need that cup of tea. The process by which a GP locum needs to aggregate their Locum A and B forms together so that they all have the same Unique Payment Reference (UPR) number (previously UIR) caused some confusion when this change was first released in May 2017. But after communications with the NHS pension Stakeholder engagement team, it has been clarified that the UPR is created when you are generating your Locum B form, ready to submit your pension payment, and you then retrospectively add this same UPR to all the Locum A forms included with that Locum B form.

One of LocumDeck's most popular features is that it does all this for you, stamping all associated Locum A and B forms with the same unique UPR.

So, although the box for the UPR on Locum A form is in the section that usually needs to be completed before posting to the practice for them to complete Section 2, the UIR must in fact *not* be added here until the Locum A form has been received back from the practice with your payment. It's only then that you can confirm what month the payment was received in, and therefore, which month's Locum B form it will be included on. The UPR on the Locum B form and all its corresponding Locum A forms uses the first three digits of that month as part of that UPR.

For example, if you receive a Locum A form and its associated payment in June, your UPR will be xxxxxxxxLocJun17 (xxxxxxxx is your 8-digit SD pension reference number that begins SD).

The Locum B form that goes with this Locum A, and all other Locum As relating to payments received in June, will also have the same xxxxxxxxLocJun17 UPR, and all must received by NHSPS by the 7th July.

LocumDeck automatically generates the UPR for all Locum B forms. For Locum A forms, LocumDeck generates the first part of the code xxxxxxxxLoc for you, leaving five blank boxes for you to complete by hand when you get them back from the practice.

*If you have entered a UPR before sending it to the practice, and the practice has paid you in the same month as the three-character month reference that you gave in your UPR, then of course you will have entered the UPR correctly. If the UPR is wrong, NHSPS have confirmed to NASGP that you simply draw a line through the wrong UPR, write the correct UPR next to it, and then countersign it.

See more NHS pension FAQs from NASGP

No problem. You can generate another Form B for the month - as many as you need. It will be called [Month][Year] Supplementary in Your Locum B Forms archive.

More LocumDeck FAQs

Pensioning your work

The Locum Form A is for pensionable NHS work, usually carried out as either a freelance GP locum or for NHS appraisal work.

  • It’s not for private work,
    • or if you trade as a limited company
    • or for work performed more than 10 weeks ago.
    • You can still pension non-NHS work, but only into a private pension scheme.

Exceptions

  • Notable Locum Form A exceptions include GP partners or providers locuming in their own practice, where they’ll need to pension their work in their usual way.
 Or OOH or CCG work, where you’ll need to use Form SOLO.
  • The NHS locum pension ‘six month rule’ now no longer exists. You are free to either continue using Form A beyond six months, or in arrangement with the practice you can arrange to pension your work as a Type 2 practitioner, which means you can pension 100% of your income as opposed to the 90% allowed as a locum.

Getting it done

  • You’ll need to send a completed Form A with your invoice to every practice that you’ve chosen to pension your work in that month.
  • In any one month, you need to pension either all the work in a practice, or none of it. You can’t just pension some of it.
  • Each Form A must include your unique identifying number, which is based on your SD number and the month and year in which you receive the corresponding invoices payment for the Form A.
  • There are currently only four spaces to include each period of work within a month, and any extra periods will need to be added to an additional supplementary form.
  • LocumDeck automatically generates paperless Form As for all applicable sessions, including generating a professional invoice, e-signatures, storing a copy, adding the data to your bookkeeping area and passing it all to your Form B form instantaneously. You and your practice managers will never need to post, print, scan, upload or download a Form A ever again.

See more NHS pension FAQs

Locum Form B Basics

  • The GP Locum Form B tells you exactly how much pension contribution you need to pay to cover a specific calendar month.
  • It records all that month’s Locum A forms for income received (not work performed).
  • Form B’s unique identifying reference (its UIR) must be identical to the UIRs on each of the corresponding Form As.

Pension tiers

  • You need to choose a pension tier at the beginning of the financial year, and stick with that tier for the whole 12 month period from April to March.
 Your pension tier is usually based on your global Practitioner income (i.e. the total of all your different pensionable Practitioner scheme NHS work),
    • but if you’re in the 2015 scheme and take breaks out of the NHS pension scheme longer than three months, it’s based on your annualised (i.e. full time equivalent) income.
  • If at the end of the year it turns out that you’ve made contributions using the wrong tier, simply notify primary care support services who will either reimburse you, or ask you to pay them the difference.

Getting it done

  • Work performed more than ten weeks ago cannot be pensioned.
  • Payment needs to be received by primary care support services by the 7th day of the following month the seventh day of the following calendar month. For example, a January Locum B form is for income received in January, and needs to be received by NHS pensions by the 7th of February.
  • If you send your paperwork by email, that will count as your receipt
  • In England, you can Pay by cheque, or phone 0333 014 2884 for the sortcode and account number to pay by BACS.
 If using BACS, you can email the forms, or post to Primary Care Support England, PO Box 350, Darlington, DL1 9QN
 In Wales you can at the moment only pay by cheque, payable and sent to your LHB.

NASGP’s LocumDeck automatically generates all your Locum B forms and keeps a really helpful accountant-friendly summary in your personalised online bookkeeping area.

See more NHS pension FAQs

England

From December 2017, all Locum A and B forms must be submitted either by an online form or by post.

Online

  • Pay by Bacs (See sortcode and account number).
  • Submit electronically via the PCSE contacts page.
    • Select "Type of enquiry" = GP pensions
    • "GMC code" = your GMC number (leave "Practice code" blank)
    • "BACS reference code" = Unique Identifying reference
  • Ensure that all your pension forms include the new unique identifying reference based on your SD number. If your paperwork does not contain this reference, your pension payment will not be processed.

By post

  • Or send your pension forms by post to Primary Care Support England, PO Box 350, Darlington, DL1 9QN.
    Mark the envelope ‘Locum payments’.
  • Even without an NHS email address, you can still pay by BACS - just remember to add that unique identifying reference to your BACS payment and post the forms on time!
  • The bank account details you require can be obtained by calling PCSE on 0333 014 2884.

Wales

Send your completed forms and payment to your relevant Local Health Board. GP-one Wales maintains a partial list of the 7 Health Boards with their pension contacts for GP locums.

In Scotland

Send your completed forms and cheque to NHS National Services Scotland to the Practitioner Services Office of your host Health Board.

In Northern Ireland

  • Send your completed forms and cheque to HSC Pension Service.
  • Email contact for locum pension enquiries is gplocums@hscni.net

See more NHS pension FAQs from NASGP

Yes. The process by which a GP locum needs to aggregate their Locum A and B forms together so that they all have the same Unique Payment Reference (UPR) number caused some confusion when this change was first released in May 2017. But after communications with the NHS pension Stakeholder engagement team, it has been clarified that the UPR is created when you are generating your Locum B form, ready to submit your pension payment, and you then retrospectively add this same UPR to all the Locum A forms included with that Locum B form.

So, although the box for the UPR on Form A is in the section that usually needs to be completed before posting to the practice for them to complete Section 2, the UPR must in fact *not* be added here until the Locum A form has been received back from the practice with your payment. It's only then that you can confirm what month the payment was received in, and therefore, which month's  locumForm B it will be included on. The UPR on the Form B and all its corresponding locum Form A uses the first three digits of that month as part of that UIR.

For example, if you receive a locum Form A and its associated payment in June, your UPR will be xxxxxxxxLocJun17 (xxxxxxxx is your 8-digit SD pension reference number that begins SD).

The locum Form B that goes with this Form A, and all other Locum As relating to payments received in June, will also have the same xxxxxxxxLocJun17 UPR, and all must received by NHSPS by the 7th July.

*If you have entered a UPR before sending it to the practice, and the practice has paid you in the same month as the three-character month reference that you gave in your UPR, then of course you will have entered the UPR correctly. If the UPR is wrong, NHSPS have confirmed to NASGP that you simply draw a line through the wrong UIR, write the correct UPR next to it, and then countersign it.

See more NHS pension FAQs from NASGP

'SD' stands for Superannuation Division and is also known as "NHSPS reference number". You can find your SD number on any correspondence sent to you from NHS pensions, on some payslips and your online Total Reward Statement; it's an eight digit figure and starts SD. If you can't find your SD number, you can call the NHS pensions helpline on 0300 330 1346.

Once you have your SD number, add it to your settings in LocumDeck so that it will automatically populate all your locum Form A and Form Bs every month, along with your invoices - all free with NASGP membership.

See more NHS pension FAQs from NASGP

LocumDeck-2-gif

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Long-term work and Form SOLO

As a freelance locum GP, the only way that you can pension CCG work under the NHS superannuation scheme is if you bite the bullet and become a salaried CCG employee. At retirement, you may get a separate Officer pension, or the CCG post may convert to Practitioner under what is known as the 'flexibilities'.

So why can't I pension my CCG work without becoming a CCG employee?

A GP (Dr X) who is solely a freelance GP locum cannot superannuate CCG work on locum forms A and B. This is because a freelance GP locum is defined under the NHSPS regs as follows....

"Locum practitioner" means a registered medical practitioner (other than a specialist trainee in general practice) whose name is included in a medical performers list and who is engaged, otherwise than in pursuance of a commercial arrangement with an agent, under a contract for services by:

  1. a GMS practice; 
  2. a PMS practice; 
  3. an APMS contractor; 
  4. an OOH provider; 
  5. or Local Health Board,

to deputise or assist temporarily in the provision of essential services, additional services, enhanced services, dispensing services, OOH services, commissioned services, certification services, Board and advisory work, health related functions exercised under section 75 of the 2006 Act, NHS 111 services or collaborative services (or any combination thereof)"

In particular, note that there is no scope for Dr X to superannuate CCG work if working directly for a CCG. Nor can Dr X superannuate their CCG work in any other way; i.e. as a type 2 (assistant) Practitioner.

A type 2 medical Practitioner is defined in the NHSPS regs as follows....

"type 2 medical practitioner" means a GP performer who

  1. is not a GP provider, and
    1. is employed (whether under a contract of service or for services) by a GMS practice, a PMS practice, an APMS contractor, an OOH provider, or a Local Health Board, and 
    2. in that employment is engaged wholly or mainly in assisting his employer in the discharge of the employer's duties as a GMS practice, a PMS practice, an APMS contractor, an OOH provider, or a Local Health Board; or 
  2. is participating in a Doctors' Retainer Scheme"

In summary, a type 2 is a salaried GP or long term fee based GP working for a GP Practice, an APMS contractor, an OOH provider, or a Local Health Board. By virtue that there is no reference to a CCG means that Dr X cannot superannuate their CCG income.

If Dr X has been an existing type 1 (GP Partners, single-handed GPs, and GP shareholders in GMS, PMS, sPMS, and APMS are regarded as type 1 medical Practitioners) or 2 (in addition to working as a GP locum) there would be no problem.

Updated 13th March 2018

This advice has now been superseded by clarification from NHSBS in light of new advice on annualisation.

Freelance GP locums who are also appraisers are able to superannuate their appraisal income using Form A and Form B - and can all be done through your NASGP LocumDeck account.

A freelance GP locum has the flexibility of not ‘pensioning’ their income if they don’t want to.

When working as a GP locum you must bear in mind that there are multiple legal and technical statuses applied to you:

  • Legal employment status
  • HMRC tax status
  • GMC registration
  • NHS pension scheme regulations
  • Medical indemnity
  • Performer's List

This FAQ applies only to the NHS pension scheme regulations and assumes that you have been paying contributions using the appropriate locum Form As in that practice.

Advice from NHSBSA (NHS Pensions) to NASGP

"In light of a recent decision by the Department of Health and Social Care regarding the annualisation of pensionable pay, GP locums now have two choices regarding how they pension their locum work from the seventh month onwards.

New - using locum Form A and Form B for more than six months

This method was introduced March 6th 2018, and may prevent your freelance locum GP contributions being subject to annualisation rules under the 2015 scheme.

  • Simply continue contributing to the NHS pension scheme as a Locum GP using locum Form A and Form B  is the same way as you were for the previous six months.
  • From 01/04/2018, you must decide how this income is going to be pensioned, either as a GP locum through the usual GP Locum Form A ten-week deadline rules or as a Type 2 practitioner; you will not be able to convert any GP locum work that has been pensioned via the Form A and Form B into Type 2 practitioner work.

Via the practice as a Type 2 practitioner if your sessions have been 'regular'.

Going in to month seven there is, or has been, a planned regularity to the cover you are providing i.e. the dates and/or times and/or lengths of session that you have been asked to work.

  • In this case, the NHS Pension scheme regulations allows you to contribute 100% of your earnings via the practice, with the practice paying the employer's contribution direct.
  • You will need to liaise with the practice manager, for them to administer.
  • These payments may be subject to the new NHS 2015 pension scheme annualisation rules for Type 2 practitioners.
  • You can pension all the work at this practice as a Type 2 practitioner if you know from the outset that your work will exceed six months."

What if you pensioned your locum work as Type 2 in 1026/17?

What about GP SOLO forms?

  • GP SOLO forms are no longer an option for a GP Locum carrying out practice work.
  • If the GP is asked to do regular work at the same practice GP SOLO forms do not apply.
  • GP SOLO forms are to be used to capture ‘ad-hoc’ additional work outside of the practice contract, as per guidance notes on GP SOLO form.

See also | Can I just not pension some of my locum work?

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  • There is a strict 10-week deadline (based on the last day in that month for which you're submitting a Locum B form) for declaring your pensionable GP Locum work.
  • You also must submit a month's Locum B form by the 7th day of that Locum B form's following month (e.g. if you've created a Locum B form for March, you have to submit it by the 7th April).
  • Your tiered employee contribution rate is based on your total Practitioner (GP) pensionable income for the year, so this may need to be reviewed at year-end. It's apparently up to you to assess this and actively liaise with your relevant pension agency to arrange any corrections of under or over-payments.

 Pension blogs

A C