Response to the Department of Health and Social Care's proposed pension scheme flexibilities

Our submission is based on member feedback, and has been developed utilising views, comments and documentation from well over 100 of the 223 trusts across England. Views have been gathered predominantly in the past three months, in which time trust boards have made clear to us that the impact of pensions tax issues are among their most critical concerns.

• We welcome the government’s renewed urgency in responding to the pensions tax issue, and support the principle of providing additional flexibilities to NHS pension scheme members to mitigate the impacts of the scheme on individual members of staff and on frontline care.

• We believe that the proposals outlined in this consultation may have a generally positive effect on senior clinicians’ ability to manage annual tax liability, in cases where they can show a reasonable expectation of incurring a charge.

• However, pension flexibilities need to be made available to all staff affected by, or at risk of being affected by, annual allowance taxation. This must include NHS managers who have been excluded from these proposals, despite being equally susceptible to large and unpredictable tax bills. Moreover there is an argument for extending a range of flexibilities across the whole workforce.