LGPS and the Pension Regulator

(Do not pass “Go”, do not go to “Jail”)

Mark AlexanderEmployer ForumDecember 2017

• 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

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

Data Quality

Benefits of good data quality

• Correct member benefit calculations!

• Correct employer contribution rates!

• Slicker administration - cheaper!

• Better service to members and employers

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

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

LGPS 2014

LGPS Regulations2013

LGPSRegulations 2007 – saved

provisions

Statutory Guidance 2013

Transitional

Provisions

Regs 2013

LGPSRegulations 1997 – saved

provisions

Legislative Jigsaw!

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

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

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

Keeping on the right side of the law!

Pension Administration Strategy

Pension Fund Responsibilities and Employer Responsibilities

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

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)

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

Employer Handbook and Guides

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….

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

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

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

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

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

Thank you for listening!Any Questions?

www.norfolkpensionfund.org

Mark Alexander

Norfolk Pension Fund

Email mark.r.alexander@norfolk.gov.uk

Telephone 01603 495781