Bah Humbug!

Transport yourselves back to early October 2021 when all GPs were given six weeks’ notice that the declaration of pensionable earnings over £150,000 would be due via an NHS Digital data collection website. We spent hours collating data for all our clients who exceeded the £150,000 self-declaration threshold and we had hundreds of emails from our anxious GPs wondering what the implications would mean if the likes of the tabloid newspapers got their hands on the data.

The BMA formally came out and stated they were strongly opposed to the legislation as not only did they believe it contravenes the original agreement made as part of the five-year GP contract package it threw up a major safety issue. For us at RBP, our client’s safety is of upmost importance and we had genuine concerns for many of those who would be declaring their earnings.

On the day of the deadline (12^th November 2021) it was announced that GPs did NOT need to declare via the NHS Digital website leaving many of you disgruntled that you had contacted us to get the information and submitted it in advance of the deadline. The last we knew was that the matter had been passed to Parliament and we had hoped that it would not return. When the contract updates were released in November 2022 the self-declaration of earnings is still there and the current declaration (2021/22) now needs to be submitted by 30^th April 2023. It is worth noting that the declaration figure is now for pensionable earnings over £156,000 (a 4% increase on the 2019/20 declaration despite inflation from 2019/20 to 2021/22 being over 10%).

At present, each year HMRC provides anonymised tax data to NHS Digital which in turn is used by the Doctors’ and Dentists’ Remuneration Body (DDRB) to make recommendations for doctors’ and dentists’ pay. The latest report, issued by NHS Digital in September 2022 for the 2020/21 financial year, can be found online. Please click here for the link.

On page 9 of the report, a table of GPs’ income before tax can be found. (Please note that this is an interactive page). Interestingly (and please bear in mind this financial year includes Covid support monies, Covid capacity expansion funds, Covid vaccine rollout income and for many practices, fixed enhanced service payments despite the level of activity), the table shows that, in the sample across England, 37% of GP’s had income before tax of over £150,000. Whilst this does not quite give us the same data as pensionable pay, it gives us a good indication of how many of our clients may need to declare; especially considering the number of clients we have who receive London Weighting or are in areas of high deprivation driving their core funding over and above the national average.

Given that it is not ideal that the above information is available for public view, no individual GPs are singled out. For the self-declaration of earnings, the contract and the NHS Digital website both state that the information submitted will need to include the GP’s full name; whilst we do not know what they will do with this data the fact that it is not anonymous is of great concern for many and as above, raises a significant safety issue.

Although you would be in breach of your GMS or PMS contracts if you do not self-declare, the only advice we can give at this stage is to sit tight and do not declare until the actual deadline in case there are any further changes in respect of the information to be provided.

In February 2023, we will be preparing all our clients’ superannuation certificates and will be writing to all our clients (both in and out of the NHS Pension Scheme) whom we believe will exceed £156,000 pensionable income for 2021/22. At that stage, we will advise what you are required to do but we sincerely hope the requirement to provide your name will be lifted and that this unnecessary and stressful exercise can be done anonymously.