NHS England is planning to go ahead with asking the highest-earning GPs to declare their income next year, including partners, salaried and locum GPs.
NHS England is understood to have shared draft guidance on the pay transparency requirement with the BMA’s GP Committee and the Association of Independent Specialist Medical Accountants (AISMA).
The draft guidance sets the threshold for earnings at which GPs have to declare at £156,000 for 2021/22; £159,000 for 2022/23; and £163,000 for 2023/24.
GP practices will need to include the requirement in new employee and sub-contractor contracts, and take reasonable steps to update existing ones, the guidance said, although they will not be responsible for ensuring it is adhered to.
The pay transparency requirement was originally delayed due to the pandemic and then again in November and April this year, when GPs faced the first and second deadlines to submit declarations.
The BMA most recently said it was pushing for a further delay, so as to not trigger the requirement from April next year.
However now the BMA’s GP Committee has been told: ‘NHSE plan to publish the guidance at the end of January/start of February 2023 to allow around three months for individuals to complete the self-declaration.’
This timeline would mean GPs covered by the requirement would need to make their first declaration by the end of April or early May.
According to the 2020/21 GP contract, partners, salaried GPs and locums who earned more than £150,000 per year in pensionable income would be ‘listed by name and earnings bands’ publicly, although later BMA guidance had stated that only GP partners would be covered to begin with.
But the new draft guidance from NHS England lists those who will be covered by the mandate as:
- GP contract partners and contractors who are individual medical practitioners
- Partners of clinical sub-contractors and sub-contractors who are an individual (including: partners of any onward clinical sub-contractors, and any onward clinical sub-contractor who is an individual)
- Individuals who work for (are engaged by) either a contractor or clinical sub-contractor (including any onward clinical sub-contractors) under either a contract of employment; a contract for services; or or as a company officer (directors and any company secretary).
- Individuals engaged by a third party to provide clinical services (e.g. a locum engaged via an employment agency)
GP contractors are ‘required to pass on (or in some circumstances to use reasonable endeavours to pass on) the pay transparency obligation to the individuals’, the draft guidance said.
Upon announcing the pay transparency contractual change when it was first agreed with the BMA’s GP Committee, NHS England had said it came as part of a drive to ‘increase transparency on NHS earnings’.
GPs have been required to publish average individual net earnings on their practice website since 2016/17, following a previous move to increase transparency on earnings.
In response, Dr Kieran Sharrock, acting chair of GPC England at the BMA, said that ‘GP earnings need to be treated with extreme caution’ due to the current workforce crisis.
He also highlighted that many GPs will be working extra hours, thereby increasing earnings, just to keep up with high levels of patient demand.
‘Unable to hire more doctors, this means GPs are having to spread themselves more thinly, often working longer hours and putting their own welfare at risk as they try to keep up with soaring patient demand,’ he said.
He went on to argue that singling out GPs for earnings publication was unfair and without grounds.
He said: ‘There is simply no reason to single out GPs for this special treatment and it will leave GPs worried about the deliberate vilification of the profession.’
‘The BMA has repeatedly advised NHS England and the Government that this policy will only drive more doctors away from the NHS – at a time when we need staff more than ever – and that it must be scrapped to ensure that patients can continue to get the care they need,’ he added.