EQUALITY IMPACT ASSESSMENT (EIA) ON PROPOSED REFORMS TO THE USS September 2018 1
a) What is the workforce profile in relation to employees declarations on being covered by one or more of the nine protected characteristics; race, disability, age, gender reassignment, marriage and civil partnership, pregnancy and maternity, religion and belief, sexual orientation and gender according to scheme membership? (Report as individuals irrespective of hours worked, including fixed term contract staff employed at the time of the Assessment) USS Members 1,947 regular 489 irregular 6 Enhanced Optout 3 Voluntary Salary Cap USS eligible members 199 regular 1,713 irregular L G P S T P S S A T 3. Other Scheme Members SAUL 1,364 regular 185 irregular Non-Scheme Members 35 regular 1,947 irregular Total TOTAL: 4,357 0 0 0 TOTAL: 1,549 2 1 1 TOTAL: 1,982 N H S P S N E S T V A N T A G E Disability Disability No % Unknown 2343 53.8% No Known Disability 1780 40.9% Prefer not to say 68 1.6% Long-Standing Illness/Health Condition 37 0.8% Specific Learning Disability 35 0.8% Mental Health Condition 28 0.6% Type of Disability not listed 19 0.4% Physical Impairment or mobility issues 17 0.4% Deaf or serious hearing impairment 12 0.3% Some categories have less than 8 staff so this information has been redacted <8 2
Age Age Band No % Over 65 296 6.8% 56 to 64 685 15.7% 46 to 55 1202 27.6% 36 to 45 1152 26.4% 26 to 35 837 19.2% 25 or less 185 4.2% Race Race No % White 2133 49.0% Unknown 1633 37.5% Other White Background 110 2.5% Prefer Not To Say 83 1.9% Chinese 70 1.6% Asian or Asian British- Indian 58 1.3% Black or Black British- African 51 1.2% Other Asian Background 51 1.2% Other Mixed Background 40 0.9% Other Ethic Group 32 0.7% Arabic 29 0.7% Asian or Asian British- Pakistani 16 0.4% Asian or Asian British- Bangladeshi 15 0.3% Black or Black British- Caribbean 12 0.3% Mixed-White and Asian 9 0.2% 3
Some categories have less than 8 staff so this information has been redacted <8 Gender Reassignment NO DATA NO DATA Marriage and Civil Partnership Marriage and civil partnership No % Unknown 3773 86.6% YES 353 8.1% NO 221 5.1% PNTS 10 0.2% Pregnancy and Maternity Maternity No % Yes 23 0.5% No 4334 99.5% Religion and Belief Religion and belief No % Unknown 1839 42.2% No religion 1234 28.3% Christian 767 17.6% Information refused 283 6.5% Muslim 81 1.9% Any other religion or belief 38 0.9% 4
Spiritual 30 0.7% Hindu 29 0.7% Buddhist 27 0.6% Jewish 18 0.4% Sikh 11 0.3% Sexual Orientation Gender Sexual Orientation No % Unknown 2097 48.1% Heterosexual 1670 38.3% Prefer Not To Say 443 10.2% Bisexual 51 1.2% Gay Man 39 0.9% Gay woman/lesbian 37 0.8% Other 20 0.5% Gender No % F 1920 44.1% M 2437 55.9% 5
b) Gaps in data Institutions to identify any gaps in the data and the possible reasons for the gaps. For example: The above data excludes hourly paid staff due to high turnover. There is also insufficient disclosure on staff records to provide meaningful data on x and x (insert relevant protected characteristics). Much of the data for protected characteristics at the University of Kent has been returned as unknown due to the high proportion of staff that have chosen not to answer the questions and this prevents meaningful analysis, particularly for the following categories: race, disability, marriage and civil partnerships, religion and belief, sexual orientation, and pregnancy and maternity. For gender reassignment, the University of Kent does not request this information and therefore cannot comment on this. The only categories where full data is held are age and gender. As data is inconclusive when considering the impact of the proposed reforms it has been necessary to make some assumptions when considering the impact on protected characteristic groups. 6
NOTE: For all data, G6 is heavily influenced by PT workers due to the presence of Graduate Teaching Assistant (GTA) roles. USS Gender by Grade Pension USS Count of EMPLOYEE_NUMBER Column Labe F F Total M M Total Grand Total Row Labels FT PT FT PT UCEA Grade 6 1.81% 47.23% 49.04% 0.84% 50.12% 50.96% 100.00% UCEA Grade 7 32.44% 23.96% 56.39% 32.44% 11.17% 43.61% 100.00% UCEA Grade 8 33.27% 20.89% 54.16% 37.73% 8.11% 45.84% 100.00% UCEA Grade 9 31.25% 13.25% 44.50% 42.75% 12.75% 55.50% 100.00% UCEA Grade 10 33.07% 6.30% 39.37% 55.91% 4.72% 60.63% 100.00% Managerial and Professorial 26.94% 6.53% 33.47% 49.39% 17.14% 66.53% 100.00% Grand Total 23.01% 26.43% 49.44% 28.08% 22.48% 50.56% 100.00% Notes: The percentage split between male and female is relatively balanced, with a deviation of no more than 6.39% on either side up to G9. Whilst there is a more significant lean towards men at the higher grades, peaking at 66.53% for the Managerial & Professional grade (M&P), this data becomes less significant due to the comparable number of roles at this grade; the weighting of roles at G6, G7 and G8 in terms of staff numbers dilutes impact across gender as a whole. There is however a noticeable difference in percentages of part time workers that are male and female at G7 and G8, of which the numbers of staff still carry significant weight. At 23.96%, there is over twice the percentage of female part time workers than male and this is also true for G8. It could therefore be suggested that proposal reform affecting affordability could more likely impact female part time workers at lower grades. As this assessment is looking largely at affordability due to the proposals only considering contribution cost rises and not rules or benefit change, the lower grades will take more scrutiny in terms of impact owing to the assumption that lower paid grades will be more affected due to less disposable income (it should be noted that we do not have data relating to personal circumstances and this may not be true in every case). 7
USS Age by Grade Pension USS Count of EMPLOYEE_NUMBColumn L under 25 under 25 To 25 to 34 25 to 34 Tot 35 to 44 35 to 44 Tot 45 to 54 45 to 54 Tot 55 to 64 55 to 64 Tot 65 and over65 and over TGrand Tota Row Labels FT PT FT PT FT PT FT PT FT PT FT PT UCEA Grade 6 0.12% 12.29% 12.41% 1.33% 56.39% 57.71% 0.84% 15.42% 16.27% 0.36% 7.59% 7.95% 0.00% 4.34% 4.34% 0.00% 1.33% 1.33% 100.00% UCEA Grade 7 0.40% 0.00% 0.40% 26.24% 7.40% 33.65% 21.27% 12.79% 34.05% 11.98% 7.54% 19.52% 4.31% 5.79% 10.09% 0.67% 1.62% 2.29% 100.00% UCEA Grade 8 0.00% 0.00% 0.00% 10.75% 1.62% 12.37% 29.21% 7.71% 36.92% 21.91% 7.71% 29.61% 8.32% 8.32% 16.63% 0.81% 3.65% 4.46% 100.00% UCEA Grade 9 0.00% 0.00% 0.00% 4.25% 0.25% 4.50% 32.50% 7.25% 39.75% 24.75% 6.25% 31.00% 11.50% 5.75% 17.25% 1.00% 6.50% 7.50% 100.00% UCEA Grade 10 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 29.92% 2.36% 32.28% 41.73% 5.51% 47.24% 14.96% 3.15% 18.11% 2.36% 0.00% 2.36% 100.00% Managerial and Professo 0.00% 0.00% 0.00% 0.00% 0.00% 0.00% 10.20% 1.63% 11.84% 31.43% 6.94% 38.37% 29.39% 7.76% 37.14% 5.31% 7.35% 12.65% 100.00% Grand Total 0.14% 3.59% 3.74% 9.73% 18.75% 28.47% 17.69% 10.47% 28.15% 15.12% 7.26% 22.37% 7.40% 5.85% 13.25% 1.02% 3.00% 4.02% 100.00% Notes: There is clear correlation between age and grade: for the 25 to 34 age group, 57.71% are at G6 but only 4.5% at G9. Furthermore, there are no G10 or M&P for this group. Conversely, for the 55 to 64 age group there are only 4.34% at G6 but 18.11% for G10 and 37.14% for M&P. This data pattern is unsurprising as it would represent the greater level of knowledge, skill and experience required at higher grades which are generally gained over time. A further influence of this pattern is the number of roles in each grade; there are many more roles at G6 and G7 compared to G10. 8
USS Disability by Grade Pension USS Count of EMPLOYEE_NUMBER Column La Disability declared Disability d No Known DisabilitNo Known Prefer not to say Prefer not Grand Tota Row Labels FT PT FT PT FT PT UCEA Grade 6 0.00% 7.11% 7.11% 2.65% 87.71% 90.36% 0.00% 2.53% 2.53% 100.00% UCEA Grade 7 4.04% 1.62% 5.65% 59.35% 33.11% 92.46% 1.48% 0.40% 1.88% 100.00% UCEA Grade 8 4.26% 1.83% 6.09% 64.71% 26.98% 91.68% 2.03% 0.20% 2.23% 100.00% UCEA Grade 9 4.25% 1.00% 5.25% 67.00% 24.25% 91.25% 2.75% 0.75% 3.50% 100.00% UCEA Grade 10 4.72% 0.00% 4.72% 83.46% 9.45% 92.91% 0.79% 1.57% 2.36% 100.00% Managerial and Professorial 1.22% 1.63% 2.86% 74.29% 21.22% 95.51% 0.82% 0.82% 1.63% 100.00% Grand Total 2.71% 3.10% 5.81% 47.15% 44.68% 91.83% 1.23% 1.13% 2.36% 100.00% Notes: The percentage of people who have declared a disability is consistent across all grades. It can be assumed that there is insignificant impact on any particular grade in comparison to another, therefore the impact to disability can be considered equal in the context of affordability. Additionally, those that have declared a disability are grouped to make data more meaningful, so if data was split into corresponding individual disabilities the impact would be even less significant in terms of percentage. 9
USS Race by Grade Pension USS Count of EMPLOYEE_NUMBER Column Labels BAME BAME Total Not Known Not Known Total White White Total Grand Total Row Labels FT PT FT PT FT PT UCEA Grade 6 0.72% 21.57% 22.29% 0.00% 7.95% 7.95% 1.93% 67.83% 69.76% 100.00% UCEA Grade 7 8.61% 4.17% 12.79% 5.79% 3.23% 9.02% 50.47% 27.73% 78.20% 100.00% UCEA Grade 8 14.20% 3.25% 17.44% 5.48% 1.22% 6.69% 51.32% 24.54% 75.86% 100.00% UCEA Grade 9 13.00% 2.25% 15.25% 4.75% 1.75% 6.50% 56.25% 22.00% 78.25% 100.00% UCEA Grade 10 13.39% 0.00% 13.39% 3.94% 0.79% 4.72% 71.65% 10.24% 81.89% 100.00% Managerial and Professorial 17.96% 2.86% 20.82% 9.80% 3.27% 13.06% 48.57% 17.55% 66.12% 100.00% Grand Total 8.91% 8.53% 17.44% 4.16% 3.95% 8.10% 38.02% 36.43% 74.45% 100.00% Notes: There is a higher percentage of part time BAME staff at G6 however as previously noted this figured is heavily influenced by the presence of part time GTA staff within this grade. 10
USS Sexual Orientation by Grade Pension USS Count of EMPLOYEE_NUMBER Column Labels Heterosexual Heterosexual Total LGBO LGBO Total Unknown Unknown Total Grand Total Row Labels FT PT FT PT FT PT UCEA Grade 6 2.05% 63.25% 65.30% 0.36% 7.35% 7.71% 0.24% 26.75% 26.99% 100.00% UCEA Grade 7 33.92% 19.38% 53.30% 3.10% 1.62% 4.71% 27.86% 14.13% 41.99% 100.00% UCEA Grade 8 39.96% 17.04% 57.00% 1.01% 1.22% 2.23% 30.02% 10.75% 40.77% 100.00% UCEA Grade 9 47.75% 14.25% 62.00% 4.25% 1.50% 5.75% 22.00% 10.25% 32.25% 100.00% UCEA Grade 10 65.35% 7.09% 72.44% 3.94% 1.57% 5.51% 19.69% 2.36% 22.05% 100.00% Managerial and Professorial 29.80% 10.20% 40.00% 2.04% 0.41% 2.45% 44.49% 13.06% 57.55% 100.00% Grand Total 28.65% 29.74% 58.39% 2.04% 3.10% 5.14% 20.40% 16.07% 36.47% 100.00% Notes: There is not enough data relating to sexual orientation to make a meaningful analysis due to the high percentage of unknown. 11
USS Marriage by Grade Pension USS Count of EMPLOYEE_NUMBER Column Labels NO NO Total NULL NULL Total PNTS PNTS Total YES YES Total Grand Total Row Labels FT PT FT PT FT PT FT PT UCEA Grade 6 0.24% 5.30% 5.54% 2.29% 90.60% 92.89% 0.00% 0.36% 0.36% 0.12% 1.08% 1.20% 100.00% UCEA Grade 7 6.86% 2.15% 9.02% 47.24% 27.05% 74.29% 0.54% 0.00% 0.54% 10.23% 5.92% 16.15% 100.00% UCEA Grade 8 6.29% 1.62% 7.91% 49.70% 22.31% 72.01% 0.20% 0.00% 0.20% 14.81% 5.07% 19.88% 100.00% UCEA Grade 9 8.75% 1.00% 9.75% 55.25% 22.25% 77.50% 0.00% 0.00% 0.00% 10.00% 2.75% 12.75% 100.00% UCEA Grade 10 14.96% 0.79% 15.75% 56.69% 8.66% 65.35% 0.79% 0.00% 0.79% 16.54% 1.57% 18.11% 100.00% Managerial and Professorial 3.27% 1.63% 4.90% 58.37% 17.55% 75.92% 0.41% 0.00% 0.41% 14.29% 4.49% 18.78% 100.00% Grand Total 5.14% 2.71% 7.86% 37.03% 42.49% 79.53% 0.25% 0.11% 0.35% 8.67% 3.59% 12.26% 100.00% Notes: There is not enough data relating to marriage to make a meaningful analysis due to the high percentage of unknown. In addition, as there is no change to partner and dependant benefits this category is not considered relevant for the assessment. 12
USS Religion by Grade Pension USS Count of EMPLOYEE_NUMBER Column Lab Christian Information refused No religion Other Unknown Grand Total Row Labels FT PT FT PT FT PT FT PT FT PT UCEA Grade 6 0.60% 23.73% 0.00% 10.36% 1.81% 47.35% 0.24% 11.93% 0.00% 3.98% 100.00% UCEA Grade 7 18.30% 8.34% 5.11% 4.44% 29.34% 15.88% 5.11% 2.15% 7.00% 4.31% 100.00% UCEA Grade 8 19.68% 11.16% 5.48% 1.83% 31.24% 9.94% 4.26% 2.84% 10.34% 3.25% 100.00% UCEA Grade 9 20.50% 7.25% 9.00% 3.25% 29.00% 9.00% 5.00% 1.25% 10.50% 5.25% 100.00% UCEA Grade 10 26.77% 3.94% 11.81% 2.36% 37.01% 3.15% 4.72% 0.00% 8.66% 1.57% 100.00% Managerial and Professorial 16.73% 6.12% 6.12% 2.86% 22.45% 7.35% 3.67% 0.00% 27.35% 7.35% 100.00% Grand Total 13.92% 12.79% 4.62% 5.32% 21.32% 21.78% 3.38% 4.72% 7.86% 4.30% 100.00% Notes: The highest proportion within the data is at G6 declaring no religion at just under 50%. Furthermore, there is no impact on any one particular group as the data is evenly spread across grades and groups. 13
The 1% Match data There is a clear pattern indicating affordability as less people take the match at lower grades compared to the greatest density of people taking the match at age 45 to 54. 14
Form for full Equality Impact Assessment of changes to the USS Name of person completing this form: Job title: Department: Wendy Green Reward Manager Human Resources Telephone number: 01227 824982 Email address: w.green@kent.ac.uk STEP 1 The proposed revisions to the USS are as follows: 1. DB section on salaries up to 57,216.50 Salary link for past service Increased annually by CPI (capped* in relation to post October 2011 service) Member contribution From 1 st April 2019 8.8% of salary below threshold of 57,216.50 From 1 st October 2019 10.4% of salary below threshold of 57,216.50 From 1 st April 2020 11.7% of salary below threshold of 57,216.50 Employer contribution From 1 st April 2019 19.5% of salary below threshold of 57,216.50 From 1 st October 2019 22.5% of salary below threshold of 57,216.50 From 1 st April 2020 24.9% of salary below threshold of 57,216.50 Pension accrual rate Lump sum accrual rate 1/75ths 3/75ths 15
Increases in salary threshold No increase until future valuation 2. DC section above the salary threshold of 57,216.50 Employee contribution From 1 st April 2019 8% of salary above threshold of 57,216.50 Employer contribution From 1 st April 2019 12% of salary above threshold of 57,216.50 3. Matched contributions above and below the salary threshold Matched DC contributions From 1 st April 2019 No match from employer *the capped basis means that the rate of increase in official pensions (currently based on CPI) will be applied in full so long as it is up to 5% a year. If such increases in official pensions are more than 5% in a year, the increase would also include one half of that year s increase above 5% up to a maximum of 10%. 16
Additional information required For example: Comparability data for the proposed changes to the USS from the other pension schemes to which employees of the institution belong. The data should cover all 5 areas of proposed change and the elements set out below are by way of example. This institution has employees in the following schemes: Scheme Employee Contribution Rate(s) Normal retirement age(s) Flexible retirement available TPS (or regional equivalent) LGPS (or regional equivalent) SAT SAUL 6% 65 No NHSPS Other e.g NEST, NOW Pensions, GPP etc (please specify) NEST 2% None Yes (government flexibilities-all in cash lifetime annuity or draw down) Vantage 5.08% None Yes (government flexibilities-all in cash lifetime annuity or draw down) 17
STEP 2 Analysis of the proposed reforms to the USS Having regard to the duty to promote equality and eliminate discrimination, do the proposed reforms to the USS minimise unfairness? Do they have a disproportionate negative effect on people with one or more of the nine protected characteristics? In completing the impact assessment using this form, if it is anticipated that the proposed reform will have a negative impact on one or more of the protected groups, note the likely impact including whether there is direct or indirect discrimination and whether such discrimination can be justified, identify the range of options to address it in order to meet the general equality duties, identify the effect of each option, the preferred option and the reasons for preferring it. Possible options include feeding back to the USS on the basis of the impact that the reforms have at this institution that: (i) there should be no change to the proposed reform; (ii) the proposed reform should be adjusted in a particular way; (iii) that it should continue with the proposed reform; or (iv) that it should abandon the proposed reform. Any options chosen must be informed by the evidence available. Evidence may need to be supplemented by consultation, where appropriate, with affected groups. Sufficient evidence will be required to allow conclusions to be drawn. If the evidence is insufficient, consultation with affected groups is likely to be necessary. Institutions must retain a record of evidence relied upon. 18
1. Proposed reform: Current defined benefits to remain the same, but member contributions required to fund them to increase from 8% to 8.8% of salary from 1 April 2019. Further increases to member contributions to be phased in from 1 October 2019 (10.4%) and 1 April 2020 (11.7%). N.B. This proposed reform will have a blanket impact across all groups as indicated below. However, the impact is particularly significant for sex and age in comparison with the others and this has been indicated by highlighting the characteristics impacted more than the others with a double cross marked in red. Race Disability Sex Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation Anticipated impact of proposed reform on existing USS members Positive Negative Neutral x x x x x x x x x x x x If it is anticipated that the proposed reform will have a negative impact on one or more of these protected groups, please provide below the: Range of options for addressing anticipated negative impact: Preferred option for addressing likely negative effect: Reason for preferring this option Anticipated negative impact of proposed reform on existing USS members Range of options Preferred Option Reason for preferred option / rationale Race Disability Flexibility around contribution payments throughout the calendar year. Flexibility around contribution payments throughout the calendar year. It has been highlighted from the Chair of the Kent Disability Network Group that some chronic conditions have extra financial pressures at certain times of life when their condition is exacerbated. The proposed reform could cause further 19
Sex Change timeline of contribution rate phases beyond April 2020 to improve affordability. Tiered contributions relating to Grade / spine point. Contribution flexibility to offer a benefit relative to contribution rate (e.g. 50% contribution for 50% benefit as in the LGPS scheme). Change timeline of contribution rate phases beyond April 2020 to improve affordability. financial hardship which could be alleviated by contribution flexibility. Part time female staff are highly represented in lower income groups and could be more affected by the proposals as they could earn significantly less income and earnings can be variable. By changing the timeline and end-loading the contribution rises, this will enable a longer period of time for a new proposal to be agreed at the JNC by USS before the October 2019 increase has been implemented. Age As above As above Younger generations will need to pay the higher contribution costs for longer during the course of their career to receive the same benefits. Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation By changing the timeline and end-loading the contribution rises, this will enable a longer period of time for a new proposal to be agreed at the JNC and implanted by USS before the first rise has been imposed. 20
2. Proposed reform: Current defined benefits to remain the same, but employer contributions required to fund them to increase from 18% to 19.5% of salary from 1 April 2019. Further increases to employer contributions to be phased in from 1 October 2019 (22.5%) and 1 April 2020 (24.9%). Race Disability Sex Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation Anticipated impact of proposed reform on existing USS members Positive Negative Neutral (due to lack of data) x x If it is anticipated that the proposed reform will have a negative impact on one or more of these protected groups, please provide below the: Range of options for addressing anticipated negative impact: Preferred option for addressing likely negative effect: Reason for preferring this option Anticipated negative impact of proposed reform on existing USS members Range of options Preferred Option Reason for preferred option / rationale Race Disability Change timeline of contribution rate phases beyond April 2020 to improve affordability for the employer. Change timeline of contribution rate phases beyond April 2020 to improve affordability for the employer. Sex As above As above As above By increasing the affordability for the employer, this will provide the opportunity for greater sustainability of flexible and part time working patterns for staff as there are certain costs that are double counted when employing staff on a flexible basis. 21
Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation 22
3. Proposed reform: 8% of member contributions from salary above the defined benefit threshold ( 57,216.50) to continue to be saved in the USS Investment Builder. Race Disability Sex Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation Anticipated impact of proposed reform on existing USS members Positive Negative Neutral (due to lack of data) x x If it is anticipated that the proposed reform will have a negative impact on one or more of these protected groups, please provide below the: Range of options for addressing anticipated negative impact: Preferred option for addressing likely negative effect: Reason for preferring this option Anticipated negative impact of proposed reform on existing USS members Range of options Preferred Option Reason for preferred option / rationale Race Disability Sex Change timeline of contribution rate phases and defer the payment of the higher contribution rate so that the 0.8% deficit contribution commences in October 2019 or later, to allow consideration of the JEP proposals. Raise the earnings threshold and percentage contribution so Change timeline of contribution rate phases and defer the payment of the higher contribution rate so that the 0.8% deficit contribution commences in October 2019 or later, to allow consideration of the JEP proposals. Deferment will reduce the detriment on males as there is a great proportion of men in G10 and M&P: the grades that will be affected by the threshold. 23
that only the very highest earners are paying a higher contribution towards the USS Retirement Income Builder. Age As above As above Deferment will reduce the detriment on the 36-55 age group. The data shows that this group will be most adversely affected because this age group is a significant proportion of the salary grades that will exceed the DB threshold. There is still a significant amount of pension accrual time for this age group who will directly lose the 0.8% from their DC pot; this will mean they are paying 0.8% more into their DB pot for the same benefit, and supplementing the deficit payment. Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation 24
4. Proposed reform: The employers contributions to the USS Investment Builder on salary above the threshold ( 57,216.50) to remain at 12%. Kent has suggested an anticipated impact of this reform on Age and Sex as incomplete data is held for the other characteristics, and therefore it is not possible to comment. Race Disability Sex Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation Anticipated impact of proposed reform on existing USS members Positive Negative Neutral (due to lack of data) x x If it is anticipated that the proposed reform will have a negative impact on one or more of these protected groups, please provide below the: Range of options for addressing anticipated negative impact: Preferred option for addressing likely negative effect: Reason for preferring this option Race Disability Sex Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation Anticipated negative impact of proposed reform on existing USS members Range of options Preferred Option Reason for preferred option 25
5. Proposed reform: The 1% employer match into the USS Investment Builder to be discontinued from 1 April 2019. Race Disability Sex Age Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation Anticipated impact of proposed reform on existing USS members Positive Negative Neutral (due to lack of data) x x If it is anticipated that the proposed reform will have a negative impact on one or more of these protected groups, please provide below the: Range of options for addressing anticipated negative impact: Preferred option for addressing likely negative effect: Reason for preferring this option Anticipated negative impact of proposed reform on existing USS members Range of options Preferred Option Reason for preferred option / rationale Race Disability Sex Age Defer the removal of the match to October 2019 or later, to allow consideration and implementation of the JEP proposals. End-load contributions if necessary. Defer the removal of the match to October 2019 or later, to allow consideration and implementation of the JEP proposals. End-load contributions if necessary. Reduce impact on age groups. The data shows that there is more impact towards younger members who will not benefit from the 1% match over a longer period of time and are less likely to be able to afford this benefit. There is a greater proportion of members taking the match in the age band of 46-65 who are nearer to retirement age and would 26
Gender reassignment Marriage and civil partnership Pregnancy and maternity Religion and belief Sexual orientation lose out on this benefit at a crucial time in their working life. 27
STEP 3 Could the impacts identified in Step 2 above be minimised or removed or equality be promoted in some other way? 1. Proposed reform: Current defined benefits to remain the same, but member contributions required to fund them to increase from 8% to 8.8% of salary from 1st April 2019. Further increases to member contributions to be phased in from 1st October 2019 (10.4%) and 1st April 2020 (11.7%) Group Disability Action required Flexibility around contribution payments throughout the calendar year. Age Gender Minimise effect by changing timeline of contribution rate phases beyond April 2020 to improve affordability. As above. 2. Proposed reform: Current defined benefits to remain the same, but employer contributions required to fund them to increase from 18% to 19.5% of salary from 1st April 2019. Further increases to employer contributions to be phased in from 1st October 2019 (22.5%) and 1st April 2020 (24.9%). Group Gender Disability Action required Change timeline of contribution rate phases beyond April 2020 to improve affordability for the employer As above. 3. Proposed reform: 8% of member contributions from salary above the defined benefit threshold ( 57,216.50) to continue to be saved in the USS Investment Builder. Group Age Action required Change timeline of contribution rate phases and defer the payment of the higher contribution rate so that the 0.8% deficit contribution 28
commences in October 2019 or later, to allow consideration of the JEP proposals. Gender As above. 4. Proposed reform: The employers contributions to the USS Investment Builder on salary above the threshold ( 57,216.50) to remain at 12%. Group Age Gender Action required Not applicable neutral effect As above. 5. Proposed reform: The 1% employer match into the USS Investment Builder to be discontinued from 1 April 2019. Group Age Action required Defer the removal of the match to October 2019 or later, to allow consideration and implementation of the JEP proposals. End-load contributions if necessary. 29
STEP 4 How will the reforms to the USS be monitored in the future and by whom? (consider a five-yearly review of membership demographics and a repeat of the EIA?) Kent to undertake a triennial EIA in line with outcome of USS valuation. September 2018 30