We anticipate that the Greenbury functionality within Pensions Online (POL) will be available from Wednesday 4 January 2023. Requests for disclosure information should be received by NHS Pensions between 4 January 2023 and 28 February 2023 to enable us to provide you with the necessary disclosure information to meet your reporting timescales.
Who should employers request Greenbury figures for
The Department of Health and Social Care Group Accounting Manual (GAM) 2022-23 states that the remuneration report must disclose information on those persons in senior positions having authority or responsibility for directing or controlling major activities within the group body. This means those who influence the decisions of the entity as a whole rather than the decisions of individual directorates or departments.
The GAM states that the chief executive or accounting/ accountable officer must be asked to confirm whether this covers more than the executive and non-executive directors. It is usually considered that the regular attendees of the entity’s board meetings are its senior managers.
The NHS Foundation Trust Annual Reporting Manual (ARM) defines senior managers as ‘those persons in senior positions having authority or responsibility for directing or controlling the major activities of the NHS foundation trust. The ARM goes on to say, ‘such persons will include advisory and non-executive board members.’
Information NHS Pensions will provide
NHS Pensions will provide disclosure information for executive directors and other senior managers, as confirmed by the Chief Executive. We will not carry out any calculations for non-executive directors because they do not receive any pensionable remuneration.
Where an executive director is also a medical General Practitioner (GP)
Disclosure information will only be provided where the GP is an employed senior manager or executive director. If the GP is employed (i.e. contract of service) as a senior manager or executive director and pays pension contributions then they will be classed as an officer for pension purposes and Greenbury disclosure will apply.
If the GP is also engaged under a contract for services arrangement (i.e. self-employed) then Greenbury disclosure will not apply to this element of their work. Under this arrangement the GP is afforded practitioner status which is not included in the calculation of the accrued pension, lump sum and cash equivalent transfer value (CETV).
Where NHS Pensions is asked for disclosure information for a GP and their pension record holds practitioner membership only then we will assume they are a non-executive director, and no information will be provided. It is important for employers to check that the pension records of their senior managers are completely updated.
NHS Pensions will provide information based on calculations using NHS staff (officer) membership only.
This exercise only relates to remuneration in public bodies which means GP practices and most direction bodies are not required to take part.
How to submit disclosure information requests for the 2023 exercise
- Employers must request Greenbury senior manager remuneration disclosures for the 2022/23 financial year via Pensions Online (POL).
- These screens will also be used by NHS Pensions to return the requested pension, lump sum (where applicable) and CETV to each employer.
- Employers will only be able to view their own disclosure requests.
Employers will need to nominate a user and allocate Greenbury access to that user before disclosures can be requested. Employers will be able to use the previous year’s user and password details. If you have any queries about registering a user on POL, please visit www.nhsbsa.nhs.uk/employer-hub/pensions-online
The Greenbury screens will also support:
- communication between employers and NHS Pensions concerning Greenbury queries
- requests for re-calculation of Greenbury disclosures
- comparison of this year’s disclosure figures with last year’s figures
Full guidance on how to register and use the POL system to make your requests is now available on our website at: http://www.nhsbsa.nhs.uk/Pensions
You should avoid using the comments box on POL unless necessary as this prevents cases running through the system automatically. If a member was part of the exercise last year, the previous year’s figures will be provided. Employers do not need to request this information via the comment box.
Reducing comments will mean more submissions will run through automatically and therefore speed up the process.