Graham Crossley (NHS Pension Wonk) Profile picture
Jan 29, 2022 22 tweets 8 min read Read on X
1) A thread on Pension Record errors

#MedTwitter - if you've ever had an annual allowance charge, it is worth checking your #nhspension

Lots of good #MedEd threads on this subject from @goldstone_tony

Here's a round up of the major errors, and a few of the niche ones too
2) Annual Allowance in #nhspension is measured by the growth in the benefits that you've accrued (NOT based on contributions)

Your benefits are based on your pensionable pay

👉If your pensionable pay is wrong, then accrued benefit calcs & annual allowance calcs will be wrong
3) Best of Three error

Before June 2020, the 95 scheme AA statements were based on previous year's pensionable pay, rather than 'Best of the last 3 years'

If your pay went down then up again, your AA statement would reflect an artificial pay rise and increased growth 👇
4) Best of Three error

Applying 'Best of Three' gets rid of the artificial growth and in this example, saved £35,380 AA charge 🤯

Revised AA statements for McCloud (covering 2015-2022) should fix this for 2015 members

However, check 2010/11 - 2014/15, to get McCloud ready
5) Misallocated Arrears error

If you receive pensionable pay arrears for a previous year, then your pension record should be adjusted so that the pay is credited to the correct year

Historic Clinical Excellence Awards are the biggest culprit here (plus backdated On Call pay)
5) Inordinate Pay error

Inordinate rules allow NHSBSA to reduce your pensionable pay at retirement if it is considered too high

I proposed this could apply during member's career - NHSBSA agreed🥳

Can apply if you take on short term work that artificially increases your pay
6) Inordinate Pay

There are many members who receive annual allowance charges for pension benefits that never manifest

Whilst not an "error", I've proposed to NHSBSA that inordinate rules be extended to ameliorate this - just awaiting response from DHSC
7) Carry Forward error

Not really a pension record error

You can carry forward 3 years unused Annual Allowance, but those years are impacted by the years before them

You need to use your growth figures back to 2010/11 (you'll also need them for the McCloud AA re-assessment)
7) Hokey Cokey error

When opting out & re-joining within the same year, sometimes the pre-opt out pay on your record is added again to the pay after you re-join

Easy way to check - compare total pensionable pay on your March payslip against the TRS
8) Less Than Full Time Standard Contract error

Pay contracts are recorded based on either Sessions (typically 10 per week) or Hours (typically 37.5 per week)

If the standard contract is recorded incorrectly this can artificially inflate your pensionable pay (& AA Charge)
9) GP (with part time Officer) Wrong Contract error

If you work sessions, but your contract has been recorded as hours, this can artificially inflate your pensionable pay, which ultimately artificially increase your annual allowance charge
10) Incorrect Return Date error

Pensionable pay is based on chunks of 365 days active service

If the wrong date of return is used with the correct pensionable pay, you can end up with artificially high pay, leading to higher growth and AA charges
11) Exceeding Full Time error

When a member has multiple Less Than Full Time roles that add up to more than 10 PAs, errors can creep in if both employers pension each role

The record can be trimmed by NHSBSA, but this can sometimes lead to artificially high pay & AA charges
12) Incorrect Management Responsibility error

Some historic management responsibilities that should have been pensionable were recorded as non-pensionable

This leads to reduced benefits, impacting lifetime allowance protection & AA charges

Good case study with @DB_Wales👇
13) Incorrect Increment error

Errors can occur with recording the correct increment progression (particularly new consultants or when moving to/from University employer)

Can sometimes leave the consultant on a lower salary

I have corrected some records going back 5+ years🤯
14) Incorrect On Call error

This is where member is paid the 'Cat B' on call rate, when working under 'Cat A' definition

Also On Call payment is a percentage of basic pay, sometimes this has been inflated to include CEA payments
15) Incorrect Added Years errors

Sometimes added years payments are collected, but the contract has not been reflected on the Annual Allowance statement or TRS

Some have their contract ceased (as out the scheme for 12 months+) but payments still being collected on re-joining
16) University / Direction Status Employer errors

Employer typically has no direct access to pension record, so data can get lost / mistyped when the data is transferred to NHSBSA and manually rekeyed
17) National Clinical Excellence Awards enhancement error

Occurs where member receives full NCEA, but works less than full time - particularly in University sector

Whole Time Equivalent calculations result in increasing pensionable value of the NCEA

(saved £54k AA fixing this)
18) Missing MHO / Special Class status

Occurs where 1 or many historic employments miss the correct MHO/SC status

Can result in the wrong doubling date for MHO (resulting in less benefit)

Worse cases can result in unnecessary actuarial reduction at 55
19) GP pension record errors

Too many issues to mention in one tweet over the handling of GP pension data and the subsequent errors that occur with Annual Allowance amongst many things

Some great work by @nick_grundy shining a light on these issues
20) The cost of errors is astounding

I've worked with many doctors, nurses, accountants & advisers, fixed well over £1m AA errors (£11m LTA)

AA is not fit for purpose, I hope a fix will come🤞

But, we still have to deal with the current set up, so check your pension record👍

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More from @gdcuk

Sep 22, 2022
@FeenanKate @goodyrob 1) Government are trying to fix CPI disconnect

But, instead of adopting the sensible solution from @BMA_Pensions @AISMANewsline @Policy_Exchange to fix the Finance Act, that could have resolved CPI disconnect and -ve growth for all, they are looking to amend NHS regs instead
@FeenanKate @goodyrob @BMA_Pensions @AISMANewsline @Policy_Exchange 2) Unfortunately we are lacking in detail

My guess would be moving revaluation date of benefits to Day 6 of scheme year

Pushes back the growth we were going to see on 1st April to 6th April, a new tax year, which would align CPI used for AA & Growth, rough example below
@FeenanKate @goodyrob @BMA_Pensions @AISMANewsline @Policy_Exchange 3) BMA sum it up nicely as a sticking plaster

It's OKish as a solution😬(in that it's better than nothing)

But, many will be wondering why government didn't go for the much better solution put forward by many experts

This is a short term fix, a longer term fix is still needed
Read 5 tweets
May 7, 2022
1) Good article by @pensions_expert

@BMercer91 covers the exchange between MP Dan Poulter and health minister Edward Argar

The minister's response highlights the government's lack of understanding of how NHS pension & pension tax work

pensions-expert.com/Law-Regulation… Image
2) "Vast majority" are expected to fall within £40k allowance

True: In 2019/20, at least 14,242 NHS members declared AA charges

1,619,853 active NHS pension members, so only 0.88% had an AA issue, ergo, pension tax has little impact🤥

Let's look a little closer at the numbers Image
3) I am concerned that ministers @DHSCgovuk @CommonsHealth are not being given the right information and they don't understand how NHS pension and taxation interact

(@sajidjavid - if you want a view from FS/Accountancy, @medicaccountant and I would be happy to brief you)
Read 9 tweets
Apr 24, 2022
1) I've been asked about -ve growth

This is particularly relevant to GPs, but can apply to all

Previously shared a quick calc showing impact of CPI and potential for -ve growth👇
grid.is/@gdcuk/impact-…

This short thread explains the maths behind it

@nick_grundy
2) Quick reminder that Annual Allowance in #NHSpension is NOT based on contributions

AA is based on the growth of your NHS pension benefits over the tax year, called Pension Input Period

Calculation method👇

Important bit, you get an adjustment to Opening Value for inflation
3) If the CPI rate from the September BEFORE the tax year starts is particularly high, then the Opening Value can be higher than the Closing Value, which results in a negative growth figure🤯

Growth is then set to zero and can't be offset against 2015 scheme or previous years👇
Read 6 tweets
Apr 23, 2022
1) Been a busy week!

I picked a fight with HMRC over LTA protection

Met the awesome @theRCN who agreed to help a nurse who's missed £,000s in pension

Had some FOI data on the lack of pay protection

More on those soon

In the meantime, a thread on how it went in Westminster👇
2) First of all, it felt cool going through the airport style security into Portcullis House lobby, seeing some of the more famous politicians milling around

Then being walked down the tunnel into the Palace of Westminster - absolutely stunning building
3) Overall, the meeting went well

They were genuinely interested in listening to why 34% of individuals who paid a 2019/20 AA charge are in NHS

2019/20 is a good year to analyse due to AA Comp Policy - most NHS AA charges should be paid via Scheme Pays

Breakdown of the data👇
Read 14 tweets
Jan 15, 2022
1) Thread on cessation of temporary abatement rules

From 25th March some who gave up their retirement to help the NHS will have their NHS pension reduced if they carry on working🤦‍♂️

FOI data I've obtained shows there are 7,470 doctors and nurses who could be adversely impacted🤯
2) Abatement is the process that restricts the pension in payment for certain members who retire & return to work before 60

Abatement was suspended to encourage experienced workers with Special Class or Mental Health Officer status to return to work to help in the pandemic
3) Those impacted will have few options and there are no good choices

This will either reduce the workforce or reduce the worker’s pension in payment which will impact morale

Why put staff, who gave up retirement to help, in this position?
Read 9 tweets
Jan 13, 2022
1) Short thread on Threshold Income errors I've seen & raised at last night's webinar for @CwmTafMorgannwg

Some have incorrectly added salary sacrifice arrangements to their taxable income to assess Annual Allowance Taper causing a potential overpayment of £,000s in tax
2) Annual Allowance Taper applies only if:

Threshold Income is more than £200k (previously £110k - 2016/17 to 2019/20), AND
Adjusted Income is more than £240k (previously £150k)
3) Annual Allowance Taper can reduce your annual allowance down to £4,000 (previously £10k)

The Annual Allowance Taper rules are set out in the Pension Tax Manual PTM057100, which can be found here:

gov.uk/hmrc-internal-…
Read 7 tweets

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