There has been a lot of anxiety and confusion around the type 2 self-certificate forms and the incorrect annualisation calculations resulting in disputes between GPs and the NHS Business Authority. Due to concerns raised around legitimacy and application of Annualisation regulations Dr Krishan Aggarwal has made it his mission to resolve and seek clarity from NHS Pensions.
How do I know if I am a type 2 medical practitioner?
- A salaried GP formally employed by a GP practice, Alternative Provider Medical Services (AMPS) contractor or by a Local Health Board
- A long-term fee based/self-employed GP who works for a GP practice, APMS contractor, Local Health Board for a period of, generally, six months or more
- A GP who works solely on an employed or self-employed basis for an Out of Hours Provider that is not an NHS Trust/Foundation Trust
“Annual Type 2 certificates are for GPs who may have multiple sources of income and therefore be paying variable pension contributions for each stream of work. One example of this could be a GP who does out of hours locum work as well as a salaried role at a practice. The purpose of the form is to ensure the correct tier has been correctly calculated across all their roles for the year. The type 2 form is a legal requirement however many GPs are unaware of the need to complete these forms,” reports Krishan. “An amnesty was granted from 2009/10 all the way through to 2014/15. As a result members will be able to complete a single form to capture all these pension years cumulatively. I have tested the initial draft and having made suggestions am yet to see the revised version; we are still yet to agree how and when this will be implemented.”
For the years spanning 2015/16 and 2016/17 GPs were asked to complete and submit their type 2 certificates by 28th February 2018. In response to growing concerns, just last week the BMA pulled their guidance on annualisation and have been pursuing NHS Pensions for clarity regarding consequences of GPs failing to submit by tomorrow’s deadline.
The official statement:
The BMA has escalated their concerns regarding the legitimacy and application of the Annualisation regulations for this time period urging NHS Pensions to extend the deadline and just today have received the following statement:
“NHSBSA does not intend to apply any punitive measures to any type 2s who may miss the deadline.The errors on the form are currently being updated and any queries regarding annualising should be sent to firstname.lastname@example.org.”
Krishan and the pension team have said, “It is, therefore, our considered advice based on the above categorical statement from NHSBSA that if you have concerns you do not submit your form by tomorrow and further guidance will be provided in due course. GPs do not need to submit their forms and monies until further BMA guidance is released in due course.”
Dr Krishan Aggarwal, Deputy Chair of the Sessional Subcommittee within GPC UK, BMA & Vice Chair, Westminster, K&C LMC