General Practice Pay Transparency - new contractual obligation to report NHS earnings exceeding prescribed threshold


As of 1 October 2021, the Government has amended the NHS (General Medical Services Contracts) Regulations to require a contract with a medical practitioner or partnership to contain a term requiring the contractor to make a self-declaration to NHS Digital should their NHS earnings exceed the prescribed threshold for a given year. This requirement is also applicable to contractors with PMS agreements and / or an APMS contract. Furthermore, if a sub-contractor is used to deliver NHS services, whether this be an individual or partnership, they too will be required to make a self-declaration if they exceed the threshold income for a given year. The contractor is required to use reasonable endeavours to ensure all new and any existing sub-contracts are amended to reflect this new contractual requirement. (Please note that this does not include locums, or other, who are contracted through a third party such as an agency).

General Practice have been given until 23:59 on 12 November to declare their NHS earnings from 2019/20 if they exceeded £150,000.

Future year’s NHS earnings must be declared by 30 April in the financial year beginning immediately after the end of the next financial year.

Self-Declaration Income Thresholds and Reporting Deadlines

Year NHS Earnings
Deadline for
2019/20 £150,000 12 November 2021
2020/21 £153,000 30 April 2022
2021/22 £156,000 30 April 2023
2022/23 £159,000 30 April 2024
2023/24 £163,000 30 April 2025

Individuals exceeding the annual threshold are required to confirm their name and job title and declare the following information:

  • NHS earnings for the relevant year
  • All organisation(s) from which NHS earnings were drawn within the relevant year, with specific reference to the organisation from which the individual drew the greatest proportion of NHS earnings [by inclusion of the ‘Organisational Data Service (ODS) code’].

What is the definition of NHS Income?

NHS income is not just superannuable earnings from the practice but any income [including any form of remuneration and any salary, wages, fees, director’s remuneration or dividends] earned by a GP [or non-GP provider] as defined within Schedule 10 of the NHS Pension Scheme Regulations 2015:

The exclusion in Schedule 10 of salaried income from ‘other NHS bodies or providers’ should be ignored for the purpose of determining NHS earnings for inclusion within the self-declaration.

The definition of practitioner income applies to all individuals including locums, whether a member of the NHS Pension scheme or not. Paragraphs 3 and 7 of Schedule 10 relate to dental practitioner income and can be ignored for the purposes of this self-declaration.

How to make the self-declaration

Individuals are required to make the ‘general practice pay transparency self-declaration’ using NHS Digital’s Forms Platform via the NHS Digital Strategic Data Collection Service [SDCS]. Firstly, individuals will need to register with SDCS and then create an account to gain access to the Forms Platform.

To register, you will need to contact:  with the following information:

  • Name of the collection the individual requires access to i.e. the General Practice Pay Transparency data collection
  • Full name 
  • A personal, professional e-mail address to register the account to.
  • The Organisational Data Service (ODS) code [also known as an organisational code] of the organisation from which the individual drew the greatest proportion of NHS earnings for the relevant year in which they exceeded the threshold. Please note that if NHS earnings are equally split between organisations, then individuals are able to choose which organisation to register with SDCS.

If a code does not exist, then individuals should register their organisation as ‘NHS Digital - X26’ code. During the self-declaration process individuals have an opportunity to list the organisation from which they drew the greatest proportion of NHS earnings for the relevant year plus the names of any other organisations from which they drew NHS earnings.

Further guidance to register for access to NHS Digitals Forms Platform can be found within NHS England’s guidance on General Practice ay Transparency:

How will the information be used?

NHS Digital will publish the self-declared information on an annual basis [this will be in the summer for 2020/21 self-declarations onwards] which will include for each individual:

  • Name
  • Job title
  • NHS earning in £5,000 bandings
  • Name of the organisation providing largest portion of NHS earnings plus the number of other organistion contributing to the total NHS earnings declared.

Armstrong Watson LLP

We have a Specialist Healthcare Sector Team who are dedicated to proactively support the financial needs of our healthcare clients. Our membership of AISMA [Association of Independent Specialist Medical Accountants] endorses our knowledge and commitment to this sector.

Please contact the healthcare team to arrange a non-obligatory meeting to discuss the accounting, taxation and advisory services we can offer to help you and/or your business.

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