This report (LPB8) follows up on the discussion by the Board at their last meeting in respect of concerns regarding employer data, and the issuance of pension information to scheme members including annual benefit statements. The report covers the specific issues raised by the Board, as well as the subsequent report to the Pension Fund Committee.
The Board is invited to note the latest position on employer management
and to offer any further comments. As
the full performance model is developed following completion of the 2016
Valuation, further reports will be brought to the Board for their information
and consideration.
Minutes:
The Board considered a report (LPB8) which covered the
specific issues raised by this Board during its discussion at the last meeting
in respect of concerns regarding employer data, and the issuance of pension information
to scheme members, including annual benefit statements.
At its last meeting, the Board raised concerns about the
lack of information on how many scheme members were missing more than just
their last annual benefit statement, and suggested options to improve
communication with such members going forward. Other proposals were raised to
improve the overall performance in this area. As requested, an update on the
position was before the Board (LPB8), including details of the subsequent
discussion and decisions of the Pension Fund Committee when it discussed this
issue at its December meeting. The Officer report to the Committee was also
included as an Annex to this report (LPB8).
Mr Collins reported that since the initial report to the
Regulator, 1,298 more statements had been issued, the majority of which were to
Oxford City Council staff. This left 8,197 outstanding, or 42% of the active
membership. Within this outstanding figure were 3 significant groups of
employee, the Academies (3,187), Oxford Brookes (2,310) and the balance on
Oxfordshire County Council (989).
During discussion the
Board noted that:
·
most authorities had struggled after the
scheme changes in 2014 to issue their statements but there was a need to
ascertain the reasons why Oxfordshire’s statistics appeared worse than other
authorities;
·
noted that this year’s breach had been
reported to the Regulator and a further response was awaited;
·
Brookes had employed more staff to rectify
the problems with their data, and, following recent discussions, a clear way
forward had been determined;
·
The issues with Academies had been compounded by a
recent change in their payroll provider. Errors on final pay data had recently
been reported impacting 2,700 staff, with a further 470 statements delayed due
to queries on CARE data;
·
just under 1,000 queries were waiting for a
response from Oxfordshire County Council; and
·
of the
9,459 people who had not yet received a statement on 14 November for the
2015/16 year, 2,572 had not received a statement for the previous year,
representing 13.3% of active members. 655
members (3%) were missing more than 2 statements whilst 193 had not received
one since annual benefit statements had been introduced in 2005. This group
presented the biggest challenge in trying to resolve, given the passage of time
since the initial query.
Mr
Collins then explained what measures had been taken to address the above
concerns:
(a) the
Committee had agreed to increase staffing in OCC Pensions by 5.81fte staff.
This would enable a team to be established specifically to work with employers,
to ensure earlier intervention where accurate data was not received regularly
on a timely basis;
(b) officers
were reviewing the way data was asked for from employers, seeking a more
standard, automated approach which would assist in a better flow;
(c) more training and
support was to be given to employers in a bid to improve the process as a
whole.
(d) The
escalation process would be reviewed to ensure earlier escalation to senior
staff in employers; and
(e) summary data would be
brought to the Board so that it could hold the Committee to account if there
were concerns.
Mr Collins asked
the Board how it would like to see the data, including the number of records
deemed to be accurate and key reasons/employers behind incomplete or inaccurate
records. A Board member asked whether other annual data checks could be
utilised to find out, for example why a record had been suspended for more than
a year. Mr Collins responded that contracts were already in place with the
electoral registration offices and other providers were used also, for example,
to find missing people. Officers were also working more closely with the
County’s Registration Service.
Mr Collins
confirmed that the Pensions Service was now looking to claim costs for the
reworking of statistics in accordance with the Committee’s Administration
Strategy. The Chairman of the Pension Fund Committee had also undertaken to be
involved in the escalation process. He added that these were part of a
combination of factors to be considered with a view to ensuring that the
employers take problems seriously.
Mr Collins
confirmed that a realistic target, if the key employers were to be concentrated
on, would be 70% - 80% of the 2016/17 statements sent by the statutory deadline
of the end of August 2017.
The Board made the
following suggestions for the Committee to consider:
·
To establish a set of Performance Indicators
(PIs) for employers, in order to strengthen the importance of correct
submissions of data. If the PIs were not met, then the Board could invite
particular employers to meetings;
·
A report be submitted to the Board clarifying
where Oxfordshire Pension Fund was in relation to other Pension Funds, perhaps
to start with other authorities within the Brunel Partnership;
·
The Board requested to see what was being
reported to the Pension Regulator;
·
To suggest to the Pension Fund Committee that
it liaises with other Pension Fund Committees, asking what was the level of
tolerance, the level of risk they were prepared to accept and how many checks
were made.
Mr Collins stated
that as the Brunel Pension Partnership was developed, the Pension Fund
Committee’s Agenda would be freed up so that more attention could be given to
the above issues. He reminded the Board that if liability was not understood,
then there was a danger that the asset allocation would be incorrect.
The Board was asked
what it would like to see in the administration report in the future. The
response was as follows:
·
To include comparative data when available,
as detailed above. This would be easily available from the Brunel Group to
begin with. Mr Collins agreed that the Brunel Group could be used as it would
give a good cross-section of practices, some authorities having already
automated some of their data collection processes;
·
What data was accepted, what wasn’t and risks
and tolerances in order to ensure that the escalation process was working
properly.
The
Board felt it important to notify members of the LGPS of the reasons why their
statement was late. Mr Collins agreed to implement this stating that it would
encourage correct returns.
Supporting documents: