NHS Providers responds to the Department of Health and Social Care’s consultation on extending pension easements.

Key messages:

• We agree with the government’s proposals to extend pension rule suspensions, including:
• The 16-hour rule;
• Abatement of Special Class Status (SCS) members, including mental health officers; and
• Abatement of 2008 section and 2015 scheme members
• We feel strongly that the NHS pension scheme, and other elements of the total reward package for staff, should not offer routine disincentives for our most senior and experienced staff to continue working, or to return from retirement to support the NHS if they are seeking to do so
• Our survey on operational pressures last summer found 48% of trust leaders saying they’d seen evidence of staff leaving their organisation due to early retirement, COVID-19 burnout, or other effects from working in the pandemic
• We particularly support abatement for Mental Health Officers, having received concerning feedback from trust leaders around the potentially very detrimental impact of removing the provision from the Act at this time
• In response to the department’s proposal to extend suspensions to 31 October 2022, our response was inconclusive given that the full impact of this proposed continuation period will depend on other policy developments. Principal among these is any reform to partial retirement provisions within the NHS pension scheme. Additionally, it is important to highlight the need for the government to consider broader pension taxation reform, and to closely monitor evidence of senior NHS staff reducing hours or retiring early as a result of pensions issues
• Broader reform via changes to taxation or scheme rules and structures must also ensure fairness across the workforce and a focus on the costs and benefits of membership for lower banded NHS staff and new starters.

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