LGPS and the Pension Regulator

Transcription

1 LGPS and the Pension Regulator (Do not pass Go, do not go to Jail ) Mark Alexander Employer Forum December 2017

2 Data Quality Regulatory Framework of Compliance Reporting Breaches to the Pension Regulator Keeping on the right side of the law Pension Administration Strategy REMINDER to use Online Services ONLY Supporting Employers Internal Disputes Resolution Procedure Year End 2017/2018

3 Data Quality Risks of Poor data quality Incorrect member benefit calculations Overpaid / Underpaid Incorrect assessment of liabilities by scheme actuary Employer Contributions too much or insufficient Delays in processing benefit payments Breach of the Law Pension Regulator fines Loss of confidence in service Loss of reputation

4 Data Quality Benefits of good data quality Correct member benefit calculations! Correct employer contribution rates! Slicker administration - cheaper! Better service to members and employers

5 Data Quality What do NPF do to ensure good data quality? Online submission of data by employers Immediate validation of data Poor quality data rejected Person responsible for data ensures it is correct Authorisation and Audit Trail Consistency Checking Cross checking of data (FTE pay) Contribution posting Mortality Screening Pensioners Monthly Address Checking / Tracing Pensioners and Deferred Members

6 Data Quality Measuring Data Quality Annual Report on actual data held Common data Names NI Numbers Addresses Dates of Birth Conditional data CARE pay Contributions FTE pay GMP data

7 Legislative Jigsaw! LGPS Regulations 2013 Transitional Provisions Regs 2013 LGPS 2014 Statutory Guidance 2013 LGPS Regulations 1997 saved provisions LGPS Regulations 2007 saved provisions

8 Regulatory Framework of Compliance Public Sector Pensions Act Pensions Regulator s Code of Practice Number 14: Governance and Administration of Public Sector Pension Schemes Data Protection Act / General Data Protection Regulations Pensions Acts Finance Acts Occupational Pension Schemes (Disclosure of Information) Regulations

9 Reporting Breaches to the Pension Regulator What needs to be reported? Where a legal duty relevant to the administration of the scheme hasn t been or isn t being complied with Deciding whether to report Material significance Recording the breach even if not reported Further support available on the Pension Regulator website

10 Reporting Breaches to the Pension Regulator The information that should be supplied: full name of the fund description of the breach or breaches any relevant dates name of the employer or scheme manager (where known) name, position and contact details of the reporter role of the reporter in relation to the fund

11 Keeping on the right side of the law! Pension Administration Strategy Pension Fund Responsibilities and Employer Responsibilities

12 PAS Employers Key Responsibilities Function / Task Provide details to NPF of a person to be the main point of contact for LGPS pension matters (the Pensions Liaison Officer PLO) Performance Expectation / Target Notify NPF 1 month before a new employer joins the scheme. Notify NPF within 1 week of any change to the PLO Publish a Pensions Policy Statement and send a copy to NPF Within 1 month of employer joining the fund or within 1 month of any changes to the policy Nominate an adjudicator for disputes Within 1 month of employer joining the fund or within 1 month of any changes Nominated representative(s) attend Employer Training Events, Attendance at such events Employer Forum, Employer Briefing held by NPF Implement correct or amended Employer Contribution Rate or From the appropriate date notified by NPF monthly deficit payment Pay over monthly employee and employer contributions to NPF by BACS or similar electronic method and provision of SR71 form Pay over monthly employee AVC contributions to the relevant AVC provider by BACS or similar electronic method Remit the Annual Contribution Return to NPF in required format Issue New Member Packs to new or prospective scheme members By date shown on SR71 forms (e.g. 7 th or 15 th (or earlier working day) of the month following the deduction of employee contributions) By 15 th (or earlier working day) of the month following the deduction of employee contributions By 30 April following 31 March year end Preferably before employment begins, but within 1 month of starting

13 REMINDER - Online Services ONLY Maintain employer contact details Notification of New Starters in bulk Notification of Changes Early Notification of Retirement Notification of Leaver Secure transmission of standard spreadsheets for Year End Return, notification of TUPE transfers, any other documents No more paper forms.except New Member Form (completed by scheme member) Opt Out Notification (part completed by the scheme member) Ill Health Certificate (completed by the Medical Advisor)

14 Supporting Employers New Employers Appropriate support and training including online services for staff who will deal with pensions G001 - Employer Handbook G080 - Prospective Employer Guide All Employers Newsletters Employer Forum Employer Training Events Employer Guides Policy and Strategy Documents

15 Employer Handbook and Guides

16 Employer Events Advance Notice Lawrence House, Norwich Jan/Feb/Mar 2018 A number of Clinic Days are being arranged Individual Employers (may send more than one representative!) Shorter Sessions (too much of a good thing!) Specifically for: Year End 2017/2018 Return Online Services More details to follow.

17 Other Employer Support LGA provide training that might interest employers Regular national and regional training events: Understanding auto enrolment and the LGPS Understanding the employer role Further details can be found on:

18 Internal Dispute Resolution Procedure (IDRP) Member Guide and Form (G071) Employer Guide (G070) 2 Stages 1 st stage considered by body making original decision 2 nd stage by Norfolk Pension Fund (NCC s Executive Director of Finance and Commercial Services) External Resolution Pensions Ombudsman

19 Internal Dispute Resolution Procedure (IDRP) Ill Health Employer decision (not IRMP) Based on evidence and advice from IRMP Stage 1 IDRP Review Was the correct process followed? Was the medical evidence consistent? Has the employer documented their decision clearly? Has the medical evidence been taken into account in the decision? Was everything provided to the independent medical practitioner to enable them to make an accurate assessment? Is there anything that should have been clarified further? May need to revisit original decisions as if they were taken at the time May need to get a second opinion from another IRMP

20 Year End 2017/18 No changes from last years requirements - so should be easy! Submit online BEFORE 30 April 2018 We will send out countdown bulletins starting in the New Year to remind employers We will issue Updated Guide Ensure you reconcile the Year End submission to monthly payovers Ensure FTE pay data is correct Ensure your Payroll Provider submits on time

21 Year End 2017/18 Watch out for. Clinics for Employers Help in completing and Submitting Year End Return Revised Employee Contribution Bands for 2018/19 Revised Employer Contribution Rates from April 2018 See SR71

22 Thank you for listening! Any Questions? Mark Alexander Norfolk Pension Fund Telephone