NHS pension scheme under and over payments
The SPPA administer the NHS Pension scheme (Scotland). This means that we are responsible for ensuring that your pension is calculated correctly and paid on time, based on information provided to us by NHS Employers.
Our data has highlighted some discrepancies with practitioner member employment records, which means some members may either have over or under paid into their pension. We are working with a number of employers including Health Boards, National Services Scotland, and GP Practices to assess affected members’ employment contribution data and implement processes to ensure the issue of widespread over and under payments does not happen again.
Why this has happened
The under and over contributions have been caused by issues around incomplete and inaccurate employment data and an inconsistent approach to applying guidance on practitioner pension contributions.
NHS employers, including self-employed GPs, dental practitioners and ophthalmic practitioners, who deliver services for the NHS are responsible for ensuring that they deduct the correct contribution rates depending on their total pensionable pay.
It is the scheme member’s responsibility to inform all their employers of all earnings to ensure they can calculate and deduct the correct contribution rate.
Assistant and salaried GP practitioners, including locums who are not principal GPs, as well as dental and ophthalmic practitioners, are required to ensure that aggregate earnings from all NHS employment are taken into account when setting the contribution rate.
The amount you pay towards your pension scheme depends on your ‘pensionable pay’ (which is your salary, wages, fees and any other regular payments, but not any bonuses, expenses or overtime payments).
As a practitioner, your contribution rate is based on your total pensionable income. This is the total of all earnings from:
- the Practice
- Out of hours contract
- Locum work
Your pensionable income does not include any bonuses, expenses or overtime payments.
In the short term we recommend that you check that you are paying the correct contribution rate on all of your Practitioner earnings and inform your employer(s) if you think this rate needs to be changed. You can find the latest contribution information in Circular 2024-03. Once the correct rate has been established, this must be applied to all earnings.
Next steps
If you are affected, you will have received a letter informing you that you may have over or under paid contributions. We won’t be able to share any more information until we have finished comparing our data with employers. Once this is complete, we will write to you again with more information about amounts that you have either over or underpaid.
If the data shows you have underpaid pension contributions, we will share the total amount you owe and explain how to organise payment. There will be options to repay contributions over time, as well as one off payments.
Members who have underpaid will only have to pay back contributions from the past five years. Anything prior to 2019 will not be included in the calculation and there will be no detriment to your future pension.
If the data shows you have overpaid pension contributions, we will explain how much we owe you and how and when you will be reimbursed. Members who have overpaid will be reimbursed all money owed (going back as far as 2008).
The under and over contributions have been caused by issues around incomplete and inaccurate employment data and an inconsistent approach to applying guidance on practitioner pension contributions.
We know you’ll want assurance that your future contributions are accurate. That’s why the team will also be working with all employers to implement prevention strategies. In future, we will encourage consistent application of processes which will ensure the issue of widespread over and under payments does not happen again.
In the short term we recommend that you check that you are paying the correct contribution rate on all of your Practitioner earnings and inform your employer(s) if you think this rate needs to be changed. You can find the latest contribution information in NHS Circular 2024-03.
Please take note of the entire document, including the Annexes (A, B, C and D) as these provide additional information and explanation regarding the aggregation and contribution rates for Practitioners. It is a condition of a GP’s NHS Pension Scheme (Scotland) membership that practitioners proactively liaise with relevant NHS organisations to ensure they have paid the correct tiered contributions across the board.
There is nothing for you to do now and no need to contact us at this stage. We will be in touch with more detail later this year.