We have been alerted to some problems regarding the late submission of the above and thought it would be useful therefore to remind practices of the NHS Pensions Agency `rules’ surrounding around timescales for submission of these.
Timescales for submission of Forms GP Locum A & B
There is a 10 week time scale set for forms to reach the PPSA/FHSA/WSSC and the criteria states “You cannot apply to your PCT/LHS for Scheme membership for any GMS/PMS/APMS period of locum GP work that ended more than 10 weeks before the date they receive the application.”
If Locums have not had their Locum A forms signed by the practice, and been paid for the work, they are unable to send their forms in until after the cut off date. It does not seem fair to penalise the Locum for late signing by the practice of the form. GP Locums are requested to stress to the practice the importance of signing the forms.
The criteria states “Please pay NHS GP Locums and provide forms GP Locum A within at the most one month of receiving their invoice so that they can calculate their NHS Pension Scheme contributions and forward them to their host PCT/LHB promptly.” This is also a stipulation set out on the Completion Notes for Locum Form A.
If forms arrive after this time scale and the GP Locum A Forms have been signed on time, then the PCT have to be approached for guidance as to whether these should be accepted.
Locums working at the same practice as either Salaried GP or Principal
Principals providing locum cover at their own practice cannot complete GP Locum Forms A & B as this is not allowed. The Regulations say:- “There are no provisions under the NHSPSA Regulations for a GP Provider to ‘pension’ income as a GP Locum in their own Practice. They should regard this income as additional GP Provider income and declare it as so on the annual Certificate.”
Salaried GPs can only do emergency cover at the practice where they are employed and this is classed as very short term and must not exceed 6 months or over. If a Salaried GP is required to do more sessions than set out under his/her contract with the practice, then they can do ad-hoc sessions and this will make them a Type 2 practitioner and the practice have to pay the 14%. They cannot complete GP Locum A and B Forms for this type of cover. The Pensions Agency state:-
“If the practice wish to engage the Salaried GP on a fee based arrangement for this ad hoc work, the Salaried GP is then classed as a Type 2 practitioner and the practice is responsible for the 14% employer’s contributions. This is good news for the GP as it means that, as a Type 2 practitioner they get 24/7 death in service cover from the National Health Service Pension Scheme and they are also cover by the National Health Service Injury Benefits Scheme whilst performing this ad hoc work. GP Locums are not afforded these rights.”
If you have any concerns about the pensionable status of their Salaried or fee based GPs should contact NHS Pensions. The following webpage provides contact details. http://www.nhsbsa.nhs.uk/2590.aspx
Locums performing cover at the same practice for a long period
There are cases where Locums are working in a practice on a month to month basis. This is NOT classed as temporary cover and they should possibly be employed by the practice as a Type 2 practitioner. The Regulations say:- “The NHSPS Regulations state that a GP (who is not a Provider or a Salaried GP) working at a Practice on a regular long term fee based sessional basis is a Type 2 (assistant) Practitioner; i.e. they are treated the same as a salaried GP. They are not a GP Locum even if that GP may be regarded locally as a GP Locum; if in doubt contact Ross Mathieson Pension Compliance Manager”.
December 2010 | 
