2019/20 Declaration of GP earnings
Friday, 08 October 2021
On 5 October, NHS England issued their belated “General Practice Pay Transparency” guidance following a 2019/20 contract change for the publication of individual earnings over £150,000. The full guidance can be found here.
The requirement is for GPs & non-GP providers, who hold GMS/PMS/APMS contracts, to self-declare their NHS earnings where they are over £150,000. The deadline for making the declaration in respect of 2019/20 is 12 November 2021. The deadline for declaration of 2020/21 earnings will be 30 April 2022 and annually thereafter.
Please note that, if you sub-contract any services, for example to a locum GP, then you are required to amend relevant sub-contract arrangements to ensure that the sub-contractor is bound by these self-declaration rules. Locums who work through a third party are not included in this requirement. If you are a locum GP, you will be required to make a self-declaration under this legislation.
The self-declaration, which has to be submitted by the individual, is made through NHS Digital’s Forms Platform. Page 6 of the guidance explains that individuals will first need to register to create an account to make the self-declaration by contacting email@example.com.
It appears that the information required in the self-declaration portal will be limited to your name, job title, NHS earnings (in £5,000 bands) and the organisations from which those earnings were received. The guidance provided in terms of what represents NHS earnings is far from clear, but our interpretation is that the following is reportable:
- Pensionable income as reported on your superannuation certificate for the year. GP providers (type 1) complete one certificate for each separate contract held, whereas non-GP providers are only permitted to pension income from one source. The certificate is used to report pensionable pay earned by GMS, PMS, SPMS and APMS providers who are partners or “single-handers”.
- If a provider holds shares in a limited company which holds a GMS, PMS, SPMS or APMS contract and is also an “employing authority” for pension purposes, a further certificate of pensionable income is required and that too is reportable within your individual earnings.
- Other income from an NHS organisation which is treated as practitioner income for NHS Pension purposes. This would include income that is pensioned via a GP SOLO form (such as appraisal income) and any locum work where Locum A & B forms are completed.
- We believe that any salaried income (dealt with through PAYE) where it is classed as “officer” pay (for example, an employment with a CCG with a contract of service being in place), is not reportable.
If you were an active member of the NHS Pension Scheme for the 2019/20 year, your pensionable income has already been calculated and can be taken from your own superannuation certificate. However, if you were not an active member, i.e. you had opted out of the Scheme for either part or all of the year, you will need to calculate your pensionable income. We would be very happy to assist you with this.
Page 9 of the guidance sets out how the information collected will be used. In summary, it will be published in a national publication by NHS Digital on an annual basis, showing your name, job title and your NHS earnings in £5,000 earning bands as noted above. Therefore, it will not show your exact pay, but your name will appear in a very narrow banding. It will also state the name of the organisation from which you drew the greatest proportion of your NHS earnings, together with the number of other organisations from which NHS earnings were drawn in the year.
Please note that Primary Care Network (PCN) income is part of your pensionable earnings and any share of surplus from PCN activities should be shown annually in your practice accounts, even if it is intended to be spent on PCN services the following year. Therefore, this could distort the publication of earnings figures and you may wish to consider spending plans at PCN level for future years which could distort further any figures you may have to publish.
Please let us know if you would like us to provide or calculate the figures for you and/or the partners at your practice to consider your reporting requirements for 2019/20. You can find contact details on the Our People section of the Larking Gowen website. Alternatively, call 0330 024 0888 or email firstname.lastname@example.org.