lgps and the pension regulator - norfolk pension fund · •role of the reporter in relation to the...
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LGPS and the Pension Regulator
(Do not pass “Go”, do not go to “Jail”)
Mark AlexanderEmployer ForumDecember 2017
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• 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
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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
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Data Quality
Benefits of good data quality
• Correct member benefit calculations!
• Correct employer contribution rates!
• Slicker administration - cheaper!
• Better service to members and employers
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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
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Data Quality
Measuring Data Quality
Annual Report on actual data heldCommon data Names NI Numbers Addresses Dates of Birth
Conditional data CARE pay Contributions FTE pay GMP data
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LGPS 2014
LGPS Regulations2013
LGPSRegulations 2007 – saved
provisions
Statutory Guidance 2013
Transitional
Provisions
Regs 2013
LGPSRegulations 1997 – saved
provisions
Legislative Jigsaw!
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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
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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
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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
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Keeping on the right side of the law!
Pension Administration Strategy
Pension Fund Responsibilities and Employer Responsibilities
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PAS – Employers Key Responsibilities
Function / Task Performance Expectation / Target
Provide details to NPF of a person to be the main point of
contact for LGPS pension matters (the Pensions Liaison Officer
– PLO)
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,
Employer Forum, Employer Briefing held by NPF
Attendance at such events
Implement correct or amended Employer Contribution Rate or
monthly deficit payment
From the appropriate date notified by NPF
Pay over monthly employee and employer contributions to
NPF by BACS or similar electronic method and provision of
SR71 form
By date shown on SR71 forms (e.g. 7th or 15th (or earlier
working day) of the month following the deduction of
employee contributions)
Pay over monthly employee AVC contributions to the relevant
AVC provider by BACS or similar electronic method
By 15th (or earlier working day) of the month following the
deduction of employee contributions
Remit the Annual Contribution Return to NPF in required
format
By 30 April following 31 March year end
Issue New Member Packs to new or prospective scheme
members
Preferably before employment begins, but within 1 month
of starting
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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)
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Supporting Employers
New EmployersAppropriate 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
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Employer Handbook and Guides
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Employer Events – Advance NoticeLawrence 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….
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Other Employer SupportLGA 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:
www.local.gov.uk/events
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Internal Dispute Resolution Procedure (IDRP)
Member Guide and Form (G071)
Employer Guide (G070)
2 Stages
1st stage considered by body making original decision
2nd stage by Norfolk Pension Fund (NCC’s Executive
Director of Finance and Commercial Services)
External Resolution – Pensions Ombudsman
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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
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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
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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
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Thank you for listening!Any Questions?
www.norfolkpensionfund.org
Mark Alexander
Norfolk Pension Fund
Email [email protected]
Telephone 01603 495781