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Disclosure of senior managers’ remuneration – Greenbury 2024

We anticipate that the Greenbury functionality within Pensions Online (POL) will be available from Monday 15 January 2024. This is slightly later than last year as we found we were receiving initial requests early and then amended pay figures at a later date when we had already completed the calculation. Therefore, please provide the best estimated pay figure, as you can only make one submission. Requests for disclosure information should be received by NHS Pensions between 15 January 2024 and 28 February 2024 to enable us to provide you with the necessary disclosure information to meet your reporting timescales.  

Key Points to note for this year 

  • McCloud Rollback Impact-For a member affected by rollback you will notice a difference between the benefits and Cash Equivalent Transfer Value (CETV) we quote for this year as compared to the benefits and CETV we quoted for year ending 2023.   You will need to include a disclosure note in your report to explain these differences.  We will provide some commentary to assist with this early next year. Additionally, the factors used to calculate CETVs for all members increased in March 2023, this will also affect the calculation of the real increase in the CETV. 

  • You should avoid using the comments box on POL unless necessary as this prevents cases running through the system automatically.  

  • Employment should be updated to 31/03/23. Please make sure have checked this before you submit, as this will cause a delay to us processing your calculations. 

  • We do not anticipate any queries from you until you have received your calculation as these will also cause a delay to our processing. If you then have a query about an induvial member, please submit on the POL Comments box. 

  • If a member was part of the exercise last year the previous years figures will be available to view by pressing the ‘show / compare button’.  

  • We received several queries asking for help with technical POL issues, please call the Employer Helpline on 0300 330 1353 (press option 2 for POL). 

  • If you require a detailed understanding of the calculation, please refer to the technical link on our website which will soon be updated.  

Who should employers request Greenbury figures for:  

The Department of Health and Social Care Group Accounting Manual (GAM) 2023-24 at 3.72 states that the remuneration report must disclose information on those persons in senior positions having authority or responsibility for directing or controlling major activities within the group body. This means those who influence the decisions of the entity as a whole rather than the decisions of individual directorates or departments.  

The GAM states that the chief executive or accounting/ accountable officer must be asked to confirm whether this covers more than the executive and non-executive directors (for ICBS – attendees at Governing Body meetings). It is usually considered that the regular attendees of the entity’s board meetings are its senior managers. 

The NHS Foundation Trust Annual Reporting Manual (ARM) defines senior managers as ‘those persons in senior positions having authority or responsibility for directing or controlling the major activities of the NHS foundation trust. The ARM goes on to say, ‘the chief executive should confirm whether this covers more than the chair, the executive and non-executive directors of the NHS foundation trust)”. 

Information NHS Pensions will provide:

NHS Pensions will provide disclosure information for executive directors and other senior managers, as confirmed by the Chief Executive. We will not carry out any calculations for non-executive directors because they do not receive any pensionable remuneration.  

Where an executive director is also a medical General Practitioner (GP)  

Pension disclosures relating to GPs serving on the Governing Body are discussed in Chapter 3 ICB Appendix 2 – Pension Disclosures in the GAM. Pension disclosure information will only be provided where the GP is an employed senior manager or executive director. If the GP is employed (i.e. contract of service) as a senior manager or executive director and pays pension contributions then they will be classed as an officer for pension purposes and Greenbury disclosure will apply. 

If the GP is also engaged under a contract for services arrangement (i.e. self-employed) then Greenbury disclosure will not apply to this element of their work. Under this arrangement the GP is afforded practitioner status which is not included in the calculation of the accrued pension, lump sum and cash equivalent transfer value (CETV).  

Where NHS Pensions is asked for disclosure information for a GP and their pension record holds practitioner membership only then we will assume they are a non-executive director, and no information will be provided. It is important for employers to check that the pension records of their senior managers are completely updated.  

NHS Pensions will provide information based on calculations using NHS staff (officer) membership only.  

This exercise only relates to remuneration in public bodies which means GP practices and most direction bodies are not required to take part. 

 How to submit disclosure information requests for the 2024 exercise  

1. Employers must request Greenbury senior manager remuneration disclosures for the  2023/24 financial year via Pensions Online (POL).  

2. These screens will also be used by NHS Pensions to return the requested pension, lump sum (where applicable) and CETV to each employer. 

 3. Employers will only be able to view their own disclosure requests. 

Employers will need to nominate a user and allocate Greenbury access to that user before disclosures can be requested. Employers will be able to use the previous year’s user and password details. If you have any queries about registering a user on POL, please visit www.nhsbsa.nhs.uk/employer-hub/pensions-online  

The Greenbury screens will also support:  

• communication between employers and NHS Pensions concerning Greenbury queries 

 • requests for re-calculation of Greenbury disclosures 

 • comparison of this year’s disclosure figures with last year’s figures. 

Full guidance on how to register and use the POL system to make your requests is now available on our website at: http://www.nhsbsa.nhs.uk/Pensions.