The Forgotten Certificate
“Every Type 2 medical Practitioner in England and Wales is required by law to complete 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 above statement is something that appears to slip the minds of many; whether GPs are unaware of the requirement or just find the paperwork cumbersome, the changing NHS Pension environment is making completion of these forms a pressing matter that cannot be avoided.
We have seen many cases of GPs being unable to access their Total Rewards Statement, with a subsequent phone call to the NHS Pensions Agency advising that the pension record is not up to date. It can be found that GPs have missing history because the correct certificates have not been submitted.
It is also important to highlight the interaction of the pension record with the Performers List. PCSE will not accept a submission of a Type 2 certificate unless the Performers List has been updated to reflect a Type 2 position i.e. a salaried practitioner position. At each change of circumstance, GPs are required to update their position through a NPL3 form submitted to PCSE. This could be the move from a salaried position to a partner or a locum GP to a salaried position say.
Missing history from a pension record delays the availability of information that can be used to calculate exposure to annual allowance and lifetime allowance charges. All the while, interest is accruing on any tax charges that may be applicable should they not be paid at the correct time. The generation of Pension Savings Statements from the NHS Pensions Agency, should they apply, are halted when records are not up to date.
There is the option to elect for the NHS Pensions Scheme to pay any annual allowance charges that may apply. The below illustrates the deadlines applicable for 2017/18 as an example:
2017/18 Tax Return deadline – 31 January 2019 –> 2017/18 Type 1 and Type 2 Superannuation Certificate deadline – 28 February 2019 –> 2017/18 Scheme Pays Election deadline – 31 July 2019
If the deadline for the certificate is not met and pension records not updated in timely fashion, the probability of having the information available to complete a Scheme Pays election before the deadline is unlikely. With no scheme pays election in place, the entire tax charge is payable by the individual via their Self-Assessment tax return.
If you would like any information on the Type 2 certificate or any assistance in preparing the form, please contact email Charlotte Gardner or call us on 01253 404404.