Thank you for your request for information about the following:

Request

PART 1 - Pension Agency Circulars

2. If available, please break this down by staff category.

[On 4 October 2025 we sent you the following clarification request]

PART 1 - Pension Agency Circular

Please could you clarify for both of these questions whether they are specific to Locums or is it in relation to all employees of the organisations listed?

[On 24 October 2025 you clarified the following]

• “Pension Agency Circulars (PACs)” – I am referring to NHS Pensions / NHSBSA circulars, bulletins or guidance notes issued between 2000 and 2015 concerning administration of Added Years contracts in the 1995 Section, and any later guidance that replaced them.

• SD502 opt-outs / PCN Locum A rejections – please include all employees in scope of the organisations listed, not only locums.

The NHS Business Services Authority (NHSBSA) received your request on 2 October 2025, with clarification received on 24 October 2025.

We have handled your request under the Freedom of Information Act 2000 (FOIA).

Our response

I can confirm that the NHSBSA holds some of the information you have requested.

PART 1 - Pension Agency Circulars

a. Handling of missed or late Added Years deductions and arrears (employee and employer);

Please see the attached documents, specifically: • Increasing your benefits booklet 2004 - page 16 • Increasing Your Benefits Booklet historical – page 8, • Increasing pension benefits technical guide-20241223-(V4) - page 103.

b. Break in membership rules (e.g. the 12-month rule) affecting Added Years contracts;

Please see the attached booklets as well as the reverse side of the AB54 for details regarding 12-month breaks

c. Termination of Added Years contracts when contributions stop, and any exceptions;

The requested information is not held by the NHSBSA.

However, please refer to page 107 of the attached Increasing pension benefits technical guide-20241223-(V4). This includes relevant information in relation to what happens if the full amount of intended contributions have not been made, which may help you.

If a member wanted to stop paying instalments, they would need to contact us by emailing apavcreferrals@nhsbsa.nhs.uk and ask for the added years contract to be terminated. The added years contract would stop, and they will be credited with the proportion of the added years that they have paid for.

d. Employer instructions on SD502 opt-outs and auto-enrolment. –

Please see the following links which are available on our website, on the Employer Hub:

•:https://www.nhsbsa.nhs.uk/employer-hub/technical-guidance/options-leaving-scheme

•:https://www.nhsbsa.nhs.uk/employer-hub/technical-guidance/joiners

Please be advised that if a member opted out of the scheme all contributions would stop which would include the AVCs.

2. Any later guidance (2016–present) that superseded or clarified the above.

The NHSBSA does not hold any additional information other than the documents attached.

Additional documentation and information is available from the National Archives website - https://webarchive.nationalarchives.gov.uk/ukgwa/timeline/http:/www.nhsbsa.nhs.uk/Pensions.aspx

For each document, please provide: title, date, version number, and intended circulation

Where this is held by the NHSBSA, this information is included either in the title or the content of the documents provided.

PART 2 – Added Years

For each of the scheme years 2022/23, 2023/24 and 2024/25 (to date): 1. The total number of Added Years contracts terminated in each year.

Part 2 (part B)

Each AVC contract is counted individually (i.e., if a member may hold multiple contracts, they would be counted multiple times).

2. A breakdown of the reasons for termination, e.g.: 1. “Nil contributions / zero pensionable earnings” 2. “Formal opt-out (SD502 received)” 3. “Other (please specify)”

The NHSBSA does hold the requested information; however, we estimate that the cost of compliance with the request would exceed the appropriate limit under section 12 of the FOIA.

We estimate that the cost of complying with your request would exceed the non-central Government limit of £450. The limit has been specified in The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 and represents the estimated cost of one person spending 18 hours in determining whether the NHSBSA holds the information, and locating, retrieving, extracting and checking the information.

The reason for termination is not recorded in an easily extractable format and would therefore require manually interrogating each record to determine the reason for early termination (for example whether the member proactively contacted us to end the contract or had a disqualifying break).

We estimate that it would take approximately 10 minutes per case to manually interrogate each record. Therefore, for the 632 records this would take 105.3 hours.

Please be advised that due to the way that the information is held by the NHSBSA, it is not possible to submit a refined request under the appropriate limit.

Please see the following link to view the section 12 in full - https://www.legislation.gov.uk/ukpga/2000/36/section/12

3. Any available guidance or policy documents provided to administrators/employers on how Added Years contracts should be treated where contributions are missing or service is later credited.

Please find attached the following documents:

• Increasing pension benefits technical guide – 20241223-v4

• Added benefits – AVC calculation guide for retrospective application – 20210820- (v1)

Part B – Added Years Reinstatements / Appeals

For each of the scheme years 2022/23, 2023/24 and 2024/25 (to date): 1. The number of appeals or complaints received in relation to the termination of an Added Years contract. 2. Of those, how many resulted in the reinstatement of the contract. 3. The average time taken between termination and reinstatement.

The NHSBSA does hold the requested information; however, we estimate that the cost of compliance with the request would exceed the appropriate limit under section 12 of the FOIA.

We estimate that the cost of complying with your request would exceed the non-central Government limit of £450. The limit has been specified in The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 and represents the estimated cost of one person spending 18 hours in determining whether the NHSBSA holds the information, and locating, retrieving, extracting and checking the information.

The complaint root cause is not recorded in an easily extractable format and would therefore require manually interrogating each complaint to extract this information.

We estimate that it would take approximately 10 minutes per case to manually interrogate each record. Therefore, for the 8,571 complaints and formal stage 1 complaints records this would take 1,428.5 hours.

We are however able to provide the total number of complaints and formal stage 1 complaints cases for the years requested:

Part 3 (1)

Please note that each complaint is counted and members may have multiple complaint in the same year.

Details regarding the complaints process can be found at the following link: https://www.nhsbsa.nhs.uk/pensioner-hub/contact-nhs-pensions-pensioners

Part C – Locum A Form Processing (PCNs / AVS Roles)

For 2023/24 and 2024/25 (to date): 1. The total number of Locum A forms submitted by Primary Care Networks (PCNs). 2. Of those, how many were accepted and pensioned. 3. How many were rejected or marked as non-pensionable.

Following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA.

The NHSBSA does not receive Locum A forms. These are submitted to PCSE who determine whether these are accepted or rejected.

They can be contacted at: https://pcse.england.nhs.uk/contact-us

4. Whether NHSBSA or PCSE hold any guidance issued to PCNs or practitioners on how Locum A income should be treated.

I would prefer to receive the information in electronic format (Excel or CSV for data tables; PDF for guidance documents).

Please find attached the following documents:

• 2025/26 Locum Form A and guidance - NHS Pensions - GP Locum A 1 April 2025 to 31 March 2026 - 20250923 - (V3) • 2025/26 Locum Form B and guidance - NHS Pensions - GP locum B 1 April 2025 to 31 March 2026 - 20250923 - (V3)PCN NHS Pension Scheme Access document: Primary_Care_Networks_and_NHS_Pension_Scheme_Access_20240111-(V4) • Information re Primary Care Networks in the GP Member Guide - GP Member Pension Guide-updated 22.11.2023 - v4

PART 3 – NHS Pension Scheme (SD502 opt-outs & PCN Locum A rejections)

I am seeking the following information: 1. NWAS / ELFS SD502 opt-outs • The number of SD502 opt-out forms recorded in NHSBSA’s pension administration system for employees of North West Ambulance Service (NWAS), processed via ELFS payroll, between December 2021 and September 2024. • Please break this down by scheme year if available, and confirm if the figure is nil (i.e. no SD502 forms recorded).

Please note that SD502 forms are submitted to and processed by the employer. The NHSBSA does not hold copies of these forms, therefore we are unable to provide information relating to the number of forms processed.

We are however able to provide the following information about the number of members who have had an opt-out in the relevant scheme year. A member will be counted once in each year they have opted out (they may have opted out of multiple post or multiple times in the same year)

Part 2 (part B)

For 2023/24 and 2024/25 (to date): • The total number of Locum A forms submitted by Primary Care Networks (PCNs). • Of those, how many were accepted and pensioned. • How many were rejected or marked as non-pensionable. • Whether NHSBSA or PCSE hold any guidance issued to PCNs or practitioners on how Locum A income should be treated.

Please see the response given above in Part 2, Part C

PART 4 – Scheme Designations and contributions

Primary Care Networks

Since July 2019, every Practice in England must be part of a PCN (Primary Care Networks). A typical PCN will comprise of several practices covering 30,000 to 50,000 patients.

Although a practice is part of a PCN it retains its own identity as a GMS/PMS/APMS contractor.

Staff employed by a practice to undertake PCN work have access to the NHS Pension Scheme as Practice Staff, or as type 2 medical Practitioners if they are salaried GPs. The GP Providers must pension the profitable element of their PCN income.

Where a Federation is involved in a PCN the staff may have access to the NHS Pension Scheme under certain circumstances.

1. The NHS Pension Scheme SD (Scheme Designation) number allocated to South Sefton Primary Care Network (PCN), if one exists.

Following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA.

Please be advised that unless they are set up a legal entity, PCNs do not have their own EA code. The PCN is simply a name that a group of practices are under.

South Sefton PCN is not a legal entity and therefore does not have its own EA code.

2. If South Sefton PCN does not have its own SD number, please confirm which employing authority (e.g. GP practice, Trust, or host organisation) has been designated to act as the employing authority for NHS Pension purposes on its behalf.

Following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA. This is because the NHSBSA does not need to know which GP practice within each PCN is the host practice.

3. Whether NHSBSA has received any pension contribution remittances under this SD number (or associated host employer SD number) from October 2023 to September 2025, covering staff employed within South Sefton PCN.

Not applicable as South Sefton PCN does not have its own EA code.

4. The NHS Pension Scheme SD (Scheme Designation) number allocated to Blundellsands Surgery, who act as host practice and paymaster for South Sefton PCN Respiratory Hub sessions.

This surgery is under the banner of South Sefton PCN but has its individual GMS contract. The EA code is H141 and only staff working on the GMS contract (i.e. employed by the practice) are eligible for membership under this EA code. GPs must pension via PCSE.

5. Whether NHSBSA has received any pension contribution remittances under this SD number from October 2023 onwards.

Yes, contributions have been received under EA code H141.

6. A list of all current NHS Pension Scheme SD (Scheme Designation) numbers and employing authority names for Primary Care Networks (PCNs) and/or their host practices in Cheshire & Merseyside ICB.

Following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA as we do not hold PCN details.

NHS Digital’s ODS Portal records all PCNs within Cheshire & Merseyside ICB and their Host practice (nominated Payee). However, this is not a list of EA codes relating to NHS pensions. See link below. https://www.odsdatasearchandexport.nhs.uk/

PART 5 – Complaints

2. If available, please break this down by staff category.

Following a search of our paper and electronic records, I have established that the information you requested is not held by the NHSBSA. This is because a member will be employed by an individual employer under a unique EA code. Additionally, staff pension contributions is not a category of complaint.

Staff category is not held as we record complaints by capacity code not job title or role.

Data Queries

Please contact foirequests@nhsbsa.nhs.uk ensuring you quote the above reference if you have any specific questions regarding this response; or, if you feel you may be misunderstanding or misinterpreting the information; or, if you plan on publishing the data.

Reusing the data and copyright

If you plan on producing a press or broadcast story based upon the data please contact
communicationsteam@nhsbsa.nhs.uk. This is important to ensure that the figures are not misunderstood or misrepresented.

The information supplied to you continues to be protected by the Copyright, Designs and Patents Act 1988 and is subject to NHSBSA copyright. This information is licenced under the terms of the Open Government Licence detailed at:

http://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/

Should you wish to re-use the information you must include the following statement: “NHSBSA Copyright 2025”. Failure to do so is a breach of the terms of the licence.

Information you receive which is not subject to NHSBSA Copyright continues to be protected by the copyright of the person, or organisation, from which the information originated. Please obtain their permission before reproducing any third party (non NHSBSA Copyright) information.