‘Pay Transparency for General Practice’ was initially introduced (and set out in legislation) in October 2021. However, shortly thereafter, as a consequence of the work demands of covid, the Department for Health and Social Care put it on hold… until now! The data collection has resumed and will commence with NHS Earnings for 2021/22.
The Headlines
All GP contractors/‘job holders’ (whether a GMS contract holder, party to a PMS contract or APMS contract) are obliged to conform to the requirement as set out in legislation.
Individuals (medical practitioner, locum practitioner or non-GP provider) are required to self-declare their NHS earnings where the specified threshold is exceeded.
Reporting threshold for NHS Earnings in 2021/22, above which a self-declaration must be made, is £156,000 (2022/23: £159,000 and 2023/24: £163,000).
Deadline for the declaration is 23:59hrs on 30 April 2023.
The self-declaration applies to current GP contractors. Those who have retired or subsequently been appointed to this position, do not need to declare in this year.
Clinical contractors are required to pass on the self-declaration requirement to sub-contractors (companies or individuals) and include the reporting obligation in future contracts. As with GP Contractors, sub-contractors are not required to comply with the pay transparency self-declaration for any relevant financial year which either ends before or after they enter into the clinical sub-contract.
Individuals who are in scope are required to confirm their name, job title and declare their NHS earnings for the relevant year and the organisation(s) from which the earnings were drawn.
The definition of income is dependent upon the role an individual has, but in most cases it will follow the definition as set out in Schedule 10 of the Pension Scheme Regulations (excluding dental income). Income from other NHS organisations, ordinarily ignored with regards to Schedule 10, is to be included: https://www.legislation.gov.uk/uksi/2015/94/schedule/10/made
The declaration is to be made by individuals on the ‘Forms Platform’ via the Strategic Data Collection Service (SDCS).
Please note that information submitted for prior years has been destroyed and any person who may have set up an account with SDCS previously will need to do so again to submit earning information for 2021/22.
Clear instructions are provided in the guidance notes (General Practice Pay Transparency: guidance) as to how to set up an account with SDCS and how to submit the NHS earnings information along with the facility to add ‘other organisations’ where NHS earnings are drawn from more than one source.
The Publication
It is planned that the information submitted to SDCS will be included in a national publication to include the following for each individual and relevant year:
Name
Job title
NHS earnings in £5,000 earning bands
Names of organisations from which the NHS earnings were drawn
As yet, no timeframe has been provided as to when this information will be in the public domain.
Armstrong Watson is a member of AISMA (Association of Independent Specialist Medical Accountants) and we have a wealth of experience and knowledge servicing the needs of medics working in general practice within both primary and secondary care settings. If you require assistance with this self-declaration (determining your NHS earnings to report, for example), please contact us at help@armstrongwatson.co.uk
