Declaration of earnings – an unwelcome return!

Casting our minds back to late 2021, notice was given by the NHS England that medical practitioners would be required to publicly disclose their relevant earnings – this requirement was for the 2019/20 year and for anyone who had relevant earnings in excess of £150,000, with the deadline for submission in November 2021.

Of course, this announcement caused uproar and the thought of many medical practitioners being ‘named and shamed’ clearly came with a poor response. This created a shockwave that saw many GPs reducing hours, giving up their partnership positions and all in a bid to ensure earnings were below the threshold. The thought of being publicly named was a step too far for many.

As you will no doubt be aware, the requirement to disclose earnings was removed (slightly after the planned submission deadline!). This came as welcome news, and the hope was that the requirement would not return in the future. Unfortunately, the requirement is back!

The requirement is virtually identical to the previous announcement and cover NHS contractors and sub-contractors. Essentially this means that if you are a) a Partner in a partnership or a single-hander, b) an employed GP or c) a locum GP, and your earnings are over a certain threshold, you will be required to self-declare.

Relevant earnings

The relevant earnings threshold for 2021/22 is £156,000 (increasing to £159,000 for 2022/23) – A 4% increase on the original threshold for the 2019/20 year. Relevant earnings are essentially earnings for pension purposes.

Given the nature of the earnings that are compared against this threshold, it might be that you are not caught and do not need to disclose – Taking an example, to exceed the threshold, a Partnership profit share (the number you see in the accounts) would need to be something like £188,000 – This is on the assumption that 5% of Partnership income is non-NHS related. Clearly that’s likely to remove the requirement for most GPs, particularly those who do not work full time, but some could still be caught.

Deadline

Moving forward, the deadline for reporting will be the 30 April following the end of the next financial year (being a 31 March year). As an example, for a 31 March 2022 year-end, the deadline for submission is 30 April 2023 – There is clearly method to this, as for many practitioner GPs their annual pension certificate disclosing pensionable earnings for that year is due by 28 February following the 31 March financial year. For those who do not have March year-ends, it is their accounts year-end that ends before 31 March, that will be due at the same time. For example, 30 September 2021 year-end would still require earnings to be disclosed by 30 April 2023 (28 February 2023 for their pension certificate).

This is clearly not going to be welcome news and you have to question whether General Practice needs any more bureaucracy, or pressure. The news is filtering out slowly and it’s yet to be seen how the BMA will respond to this.

If you’re concerned about the impact of this on you, please do let your usual medical contact know.