Newsflash: Consultation on further changes to the NHS Pension Schemes

The Department of Health is currently consulting on further changes to the regulations governing the NHS Pension Schemes. These build on the quick fire amendments made in April 2016 which permitted income from an NHS standard sub-contract to be pensionable where the main contract holder held an NHS standard contract.

The further changes reflect the Department’s attempts once again to deal with the reality of the Five Year Forward View and New Care Models and their impact on NHS pensions.

The current consultation is in light of the introduction of the Multispecialty Community Provider Contract which is a new form of contract which will be used to commission a mix of primary, community, mental health and social care services. A draft form of the contract was published in December 2016.

Historically, the NHS Pensions Scheme has had to deal with traditional GP partnerships, trusts and other members of the NHS family. However, the emergence of New Care Models is beginning to dramatically change the provider landscape.

There is a visible shift to service provision at scale and on a whole population basis. This is leading to GPs operating through federations and super-partnerships and to the development of innovative collaborations between primary and acute care providers, often involving lead/sub-contractor arrangements. This type of contracting arrangement, where the contract holder is not the only service provider, is now recognised by the Department as an emerging model.

The Consultation seeks to amend the various NHS Pension Scheme regulations to include the MCP contract and MCP standard sub-contract in the list of qualifying contracts giving ‘Independent Providers’ access to the Scheme.

Organisations seeking to hold an MCP contract or MCP standard sub-contract will need to consider the implications of these proposed changes to their pension arrangements.

The consultation will run to 26 January 2017.

Please contact us if you would like advice on the implications of the proposals.