Self declaration of earnings for GP Practices - PKF Francis Clark
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Self declaration of earnings for GP Practices

The NHS has issued long-awaited guidance on pay transparency for General Practice. It has been in the pipeline for some time, with the practicalities under negotiation by BMA/NHS England. However, the sudden announcement appears to have taken even the BMA by surprise and short reporting timescale have shocked and worried many GPs. The timing of the announcement, given the vast amount of pressure on the profession, has been particularly unwelcome.

Below we try to simplify the 9 page guidance, but the main points are (i) the measures of earnings included within the £150k+ requirement to self-declare exclude certain sorts of earnings and (ii) we have already determined that the vast majority of GPs we act for will not have to self-declare.

Who is affected?

Those with NHS earnings (see below) over £150,000 for 2019/20 are required to declare this to the NHS by 12th November 2021. The guidance was issued on 5th October, leaving just under 6 weeks for GPs/advisers to review the guidance, gather/analyse the data and then self-declare – fairly unreasonable and unrealistic.

Those affected are:

  • A contractor who is an individual medical practitioner or each member of a Partnership who holds a GMS contract
  • All named parties on a PMS agreement
  • A contractor who is an individual medical practitioner or each member of a Partnership who holds an APMS contract
  • A clinical sub-contractor who is an individual medical practitioner or each member of a Partnership

Or in simple terms, mostly partners in GP practices.

In addition to NHS earnings, the GP (or other contractor etc. in General Practice) is required to list the organisation from which they receive the greatest proportion of their NHS earnings, as well as their job title. The list will be publicly available, hence the concern that journalists/local patients will pay close attention – most unwelcome given the tough time that GPs and Practice staff are already having.

Moving forward, those affected will need to make declarations by 30th April in the financial year following the year in question, so declarations for 2020/21 will need to be submitted by 30th April 2022 – this makes sense, as the annual deadline for the submission of GP’s pension certificates is 28th February so this provides a further two months to declare based on that information.

The definition of NHS earnings is clearly fundamental, and this is where many GPs’ concerns can be allayed. In  simple terms, only NHS pensionable profits over £150,000 are affected and, as many might be aware, this is not a straightforward as taking the GPs’ profit allocation from the Practice accounts and for most GPs, their pensionable profits (unless they have additional NHS roles outside the practice) are considerably lower than their ‘accounts’ profits. For a start, the NHS GP contract negotiated back in 2004 means that NHS income received by GP Practices is deemed to include Employer’s Superannuation of 14.38% hence reducing the pensionable profit from that allocated in the accounts by around 13%. In addition, income from non-pensionable sources (private medical examinations, some training, etc.) should be excluded. GPs are also able to deduct personal expenses incurred in the course of their work.  The combination of these usually results, in our experience, in pensionable profits being substantially lower than those shown in practice accounts. Of course, GPs won’t know the impact of these adjustments until they review pension certificates or discuss the position with their accountants, but we feel many will prove to have worried unnecessarily when they will not actually be affected.

What should you do?

Clearly GPs/others listed above are required to self-declare, though you have to wonder whether all will be able to by 12th November, or indeed willing given the commentary below. The guidance does not state if there are penalties or consequences for not declaring earnings by the 12th November deadline (or indeed thereafter).

Many have highlighted concerns about compelling GPs to publicly declare NHS earnings over the threshold, especially in the current climate of threat, aggression and violence towards GPs. This will be damaging to morale among the profession, could lead to an increase in abuse towards individual GPs and is probably counterproductive to the ability to recruit and retain GPs. We have already received enquiries from GPs potentially reducing their hours to remain under the threshold. GPs need to consider carefully the implications before making a self-declaration.

As GPC England did not agree to this amendment to the regulations, many consider these to have been imposed on the profession and in breach of the original agreement. In addition, GPCE has agreed that it will seek support from BMA Council to formally ballot members for industrial action over the Government’s decision to impose this solely on GPs.

Your accountant should be able to provide the financial details you need. We will be emailing all the Practices and GPs we act for to either provide comfort they aren’t affected (we are a large way through this exercise and, as we say, can see already this is the vast majority) or to give them the details they need.

Individuals declaring will need to register with the ‘NHS Digital Strategic Data Collection Service (SDCS). The SDCS is responsible for registering those users and granting access to the relevant pages. Detailed information on this is in the guidance.

If you have any questions, or need any support, please let your local contact know.

Detailed guidance here.

FEATURING: Kieran Hancock
Kieran predominantly looks after our Healthcare clients, which include GP surgeries and hospital consultants. Kieran is able to advise on all aspects of these, not… read more
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