In this first blog I talk about prospective pension remedy and what stakeholders in the Police Pension Scheme need to know.
It should be common knowledge by now that with effect from 1 April 2022 all protected members will be treated as members of the Police Pension Scheme (PPS) 2015. This is actioned by Clause 88 and 89 of the The Public Service Pensions & Judicial Offices Bill (PSPJO Bill) - newbook.book (parliament.uk). The closing of the legacy schemes was first consulted on by HMT in July 2020, confirmed in their consultation response in February 2021 and enshrined into policy when the bill was first introduced into the Lords in August 2021.
Home Office have also consulted on the amendments necessary to amend the Police Pension Schemes to cease membership of the legacy scheme from 1 April 2022, the consultation response is due in early March and no surprises are expected. - Amendments to police pension schemes in England and Wales 2022 - GOV.UK (www.gov.uk) As a result of both the bill and the secondary regulations, no-one can remain in the legacy scheme from 1 April 2022.
Actions to take now, must include
1. Payroll and administration systems must show the member in the reformed scheme from 1 April 2022. Any member self service system must reflect that the member is in the 2015 scheme, in the event that the member self service system does not show the member in the reformed scheme from 1 April 2022, it must be disabled until the system amendments can be made.
2. The correct PPS 2015 contributions must be deducted from 1 April 2022 and members must be informed of any change in their contribution banding.
3. You must also ensure that members are clear on which scheme they are in from 1 April 2022. To assist you with this, we have provided a suite of letters which we recommend are used when communicating with members.
Failure to comply with the above direction would constitute a legal risk for the FRA which could result in further litigation.
A member booklet which confirms the changes of the scheme from 1 April 2022 has been circulated and is provided in the library - Remedy Communications - Library - Police Pension Administrators' Community - Knowledge Hub (khub.net)
If you have any queries over the content of this blog or would like to contact me, please email clair.alcock@npcc.police.uk
Views expressed in this blog are an informal view of the interpretation of the Police Pension Scheme as only a court can provide a definitive interpretation of legislation. It is the responsibility of each police pension authority to interpret and apply the scheme regulations as they see fit, and to seek legal advice where necessary. This blog should not be interpreted as legal advice.