27 October 2021
Our medical practices specialist, James Gransby, comments on the guidance around the earnings declaration for GPs.
Despite very little news of the £150,000 earnings declaration since it was first announced well over a year ago, it appears that it hadn’t left the government’s radar. It amended the General Medical Services (GMS) and Primary Medical Services (PMS) contract agreements on 7 September 2021, and the changes came into force on 1 October 2021.
Details regarding the October Statutory Instrument, including the provisions relating to the declaration of NHS earnings, can be found here.
So, what does this mean for a GP partner?
Essentially, by 12 November 2021, any GP with pensionable earnings over £150,000 for the 2019/20 tax year will need to upload to a portal their:
- job title;
- sources of income; and
- total earnings.
Details about the exact process are due to be released soon. For subsequent years the threshold rises, and the deadline would normally be 30 April of the following year – so 2020/21 figures will be reportable by 30 April 2022.
Using pensionable income is a logical step because this figure is already captured as part of the preparation of Type 1 superannuation certificates and excludes non-NHS income. Seniority ended on 31 March 2020, so now there is no real need for deferred pension members, or those drawing their NHS pension, to complete a certificate. However, given this earnings disclosure requirement, it may be advisable for some people to continue having this figure calculated.
An extract from the legislation says:
the disclosure obligation, in relation to a relevant financial year, is the requirement for an individual (“I”) to submit the following information for publication to the Health and Social Care Information Centre by the disclosure date
(ii)I’s job title,
(iii)the details of each organisation from which I has derived NHS earnings in that financial year, and
(iv)the amount of I’s NHS earnings for that financial year;
(b)“relevant financial year” means a financial year ending –
(i)on or after 31st March 2020, but
(ii)on or before 31st March 2024;
(c)“relevant threshold” means –
(i)for the financial year ending on 31st March 2020, £150,000;
(ii)for the financial year ending on 31st March 2021, £153,000;
(iii)for the financial year ending on 31st March 2022, £156,000;
(iv)for the financial year ending on 31st March 2023, £159,000;
(v)for the financial year ending on 31st March 2024, £163,000.
Once more is known, we will publish further details on how to comply with this requirement and the figures.
Whether there will be full compliance with this condition by the profession is yet to be seen, but as a condition of the GMS/PMS contract, this obligation to report should not be overlooked.
If you would like help to determine your earnings declaration and reporting obligations, please contact James Gransby, our medical practices specialist.