2 Cost basis for schemes
Cost
neutrality
12. One of our central criticisms of the reviews
has been the Government's insistence that any new proposals should
cost no more than the schemes currently in place. As a result,
the reviews have been, in the Government's own words, no more
than "reshuffling the pack". [28]
In our report last year, we concluded that "the pension review
was hamstrung almost from the outset by the decision that the
new proposals should be cost-neutral",[29]
and that "the MoD needs to do a great deal more work on its
proposals
taking best practice as its starting point, rather
than cost-neutrality".[30]
As the MoD's written evidence makes clear, however, and much to
our disappointment, the Ministry's "prime objective"
has remained "to produce a new scheme broadly equal in value
to the current one".[31]
INTERPRETATION: MORTALITY ASSUMPTIONS
13. Moreover, the MoD's definition of 'cost neutrality'
has changed, to the disadvantage of personnel.
14. In a memorandum in 2002, the MoD explained, in
answer to our questions about cost-neutrality, that
the same actuarial assumptions have been used
to calculate the costs of the existing and proposed schemes, except
that, under the proposed arrangements allowance was made for the
expected changes to exit rates close to the Immediate Pension
point.[32]
The memorandum also explained what those assumptions
were, stating that the allowances for pensioner mortality were
"derived from standard tables", with the mortality of
officers assumed to be lighter than that for other ranks.[33]
15. The Ministerial Statement of September 2003,
however, states that "Overall, the changes will be broadly
cost-neutral, taking account of the steps taken to cover increasing
longevity costs."[34]
The MoD has provided tables from the Government Actuary's Department
(GAD), showing the demographic assumptions used, and the revised
costs. The table below shows the GAD's estimate of how much the
scheme, and elements of the scheme, will cost the MoD as an average
notional percentage of pensionable salary for each member of the
scheme:
AFPSFinal Scheme Design
Cost of scheme expressed as a level per
cent of pensionable salary
Benefit
| Existing Scheme
| Existing Scheme with Revised Actuarial Assumptions(4)
| New Scheme
|
Retirement:
Pension
Lump Sum
|
12.8
2.4
|
15.2
2.4
|
14.3 (see note 2)
|
Preserved Benefits:
Pension
Lump Sum
|
2.5
0.7
|
3.7
0.7
|
2.7
0.7
|
Ill-health Benefits
| 1.2 | 1.2
| 1.6 |
Spouse's Benefits
| 2.3 | 1.2
| 2.3 |
Death in service (lump sum)
| 0.1 | 0.1
| 0.4 |
Total
| 22.0 | 24.5
| 22.0 |
Source: Ev 45
NOTES:
(1) In calculating the above figures it has been
assumed that Officers account for 25 per cent of total pensionable
pay and Other Ranks comprise the remaining 75 per cent.
(2) Early retirement packages are still to be
finalised. Cost shown is the amount provided for retirement pensions
and lump sums and early retirement packages.
(3) A cost of 1 per cent of pensionable pay (as
at 31st March 2003) is roughly equivalent to a cost
of £50 million.
(4) The effect of revised actuarial assumptions
is an increase in the cost of the scheme due to the allowance
for increased longevity. This increased longevity allowance reduces
the value of spouse's benefits as it delays the point at which
the member is assumed to die and the payment to their spouse commences.
16. The very important actuarial assumption on pensioner
mortality has been changed in the course of the consultation process,
to allow for "the cost of pensioners living longer".[35]
From the table above, it can be seen that the expected cost of
the existing scheme to the MoD in 30-40 years from now has been
recalculated from 22 per cent to 24.5 per cent of pensionable
salary, because of the changed demographic assumptions. The new
scheme, however, will return the estimated cost to 22 per cent,
over the same timescale, by when the Government will be starting
to make payments under the new scheme to substantial numbers of
personnel. Using the original actuarial assumptions, the
cost of the new scheme has been calculated at 20.3 per centthat
is to say, the total value of the new scheme today is 1.7
per cent of pensionable salary less than the total value
of the existing scheme.[36]
In other words, the
Government intends to use savings that it is making within the
pension scheme not only to improve other benefits to personnel,
but also to cover the estimated cost of personnel and their dependants
living longer. This conflicts
with what the Minister told us in evidence, that "all of
any money that is saved
from one part of the scheme will
be used in benefits on other parts of the scheme".[37]
17. We requested, and have received, further written
information from the MoD on the revised mortality assumptions:
Comparison of the costs for existing and
new schemes under revised and 1997 valuation mortality assumptions
|
Cost of scheme expressed as a level % of pensionable salary
|
| 1997 Valuation Mortality assumptions
| Revised
mortality assumptions
|
a) Existing scheme |
22.0% | 24.5%
|
b) Scheme proposed in original consultation exercise
|
22.0% |
24.1%
|
c) Saving from deferral of pre IP preserved pension age from 60 to 65
|
0.9% |
1.0%
|
d) Additional costs beyond b) for the following improvements: see Note (2)
- 4 times death benefit
- Partners pensions
- Spouses' benefits increased by 25%
see Note (3)
Continued accrual over 35 years see Note (4)
|
0.1%
0.4%
1.0%
<0.1%
|
0.1%
0.2%
0.6%
<0.1%
|
e) Additional savings if benefits for exits between IP point and age 55 restructured
|
Assumed 2.0% |
Assumed 2.0%
|
f) Total cost of revised scheme including restructured benefits below age 55.
|
20.3% |
22.0%
|
Source: Ev 44
Notes:
(1) In calculating the figures it has been assumed
that Officers account for 25% of total pensionable pay and Other
Ranks comprise the remaining 75%
(2) The effects of these improvements are cumulative
in the order shown i.e. as an example, spouses' benefits are
increased by 25% after allowing for partners pensions. Totals
are affected by rounding errors.
(3) Partners' benefits are also increased to
62.5% of member's pension.
(4) For members who continue in service, continued
accrual up to 37 1/3 years will apply to spouses' benefits and
partners' pension and up to 40 years for the member's normal pension
and lump sum. Any enhancement formulae for death in service and
ill-health will be limited to 35 years' prospective total service,
so members who have completed 35 years service or more will not
receive an enhancement.
(5) A cost of 1% of pensionable pay (as at 31st
March 2003) is roughly equivalent to a cost of £50 M.
18. This information reveals that the assumptions
are based not on mortality rates now, but on projected mortality
rates in the future, taking into account assumed further improvements
in life expectancy up to 40 years ahead. The MoD has stated that
the recosting is based on looking at the expectation
of life of new entrants currently coming into the scheme.
In terms of the overall cost of the scheme, taking account of
the full spectrum of ages of current scheme members, it therefore
most accurately reflects a scheme cost some years away, after
the retirement of existing, more mature Service personnel who
cannot expect to benefit to the same extent from improving life
expectancy.[38]
The GAD has indicated to the MoD that it should account
to the Treasury for an increased sum of employer contribution[39]
as soon as this can be factored into budget plans, as a result
of these changed mortality assumptions.[40]
The MoD is currently negotiating with the Treasury and the GAD
how this should be reflected in the cost the MoD will pay for
the accruing scheme liabilities.[41]
19. The MoD tells us that it is "reasonable
that members should bear some of the burden of the increased costs
given that they will benefit through longer enjoyment of a pension
in retirement".[42]
Since there is no direct contribution from members of the AFPS
to the costs of the pension scheme (although the level of their
pay is reduced, currently by 7 per cent, to take account of the
value of the scheme), the MoD has not been able to take the route
of increasing members' contributions that has been adopted in
a number of cases. Other ways of passing on this cost are to reduce
the benefits available under the scheme, or to make personnel
work to a higher retirement age. One of the corollaries of people
living for longer is that in the public services more widely they
will be expected to work for longer. The Government has proposed
that the retirement age for many public servants should be increased
from 60 to 65. The option of working for longer in the Armed Forces,
however, is rarely available to personnel. This is a circumstance
particular to the manning needs of the Armed Forces. Thus the
Government is proposing to reduce benefits to Armed Forces personnel
on the basis that they will live for longer, without also giving
them a real opportunity to work for longer within the public service.
This is not reasonable.
20. Furthermore, only a minority of personnel can
actually expect to "benefit through longer enjoyment of a
pension in retirement", those personnel, mostly senior officers,
who retire at or after the age of 55. This is because for the
vast majority of personnel who leave the forces before 55, the
age at which they will receive their pension is to be raised from
60 to 65,[43] matching,
more or less, their increased life expectancy.
21. The MoD's budget is under pressure, and the costs
of the revised mortality assumptions appear to have come as an
unexpected extra pressure on this budget. To provide context,
each percentage point of pensionable pay that the MoD pays annually
under the pension scheme costs about £50 million. The full
2.5 per cent, if it had to be paid now, would cost about £125
million each year.
22. What the actuarial assumptions disguise, however,
is that the MoD's gross pensions bill is actually expected to
decrease in 30 to 40 years' time, as a result of the reduction
in Service numbers from around 330,000 in 1975 to about 200,000
now.[44] What this means
is that the MoD is currently making payments to pensioners drawn
from a workforce much larger than that to which the Ministry is
currently paying salaries. However, by the time the actuarial
assumptions on life expectancy are realised, the MoD will be making
payments to pensioners drawn from a workforce of roughly today's
strength. The Government is
basing its decision to reduce the cost of the pension scheme on
the expectation that each individual member of the pension scheme
will cost the MoD more in future because of increased longevity.
However, because of the reduction in Service numbers over the
last two decades, we would expect the MoD's total pensions
bill to decrease just as the financial effects of increased life
expectancy kick in. In terms of the total cost to the public purse,
there is no need to adjust the pension scheme to reflect increased
longevity in order to achieve 'cost neutrality'. It is only fair
to point out that any cost increases as a result of pensioners
living for longer are likely to be more than compensated for by
the reduction in the total number of pensioners.
23. The MoD claims that "members should bear
some of the burden of the increased costs" (our italics).
However, the value of benefits available under the new pension
scheme has been adjusted downwards to the full value (2.5
per cent of pensionable pay) of the expected cost of the new mortality
assumptions. The MoD expects the cost to its budget of the new
assumptions to be "somewhat less than" 2.5 per cent,
with the rest of this cost likely to be borne by the Treasury.[45]
As a matter of principle, we
are not convinced that it is right that the financial cost of
increased life expectancy should be borne by service personnel,
particularly not through reduced benefits. But even if the MoD
can justify its claim that personnel should bear some of
the burden of the increased costs brought about by improved longevity,
it should not have devised the new scheme as it has, on the basis
that personnel in the scheme will bear the entirety of
costs, particularly where it appears that these costs are almost
certainly in excess of what the MoD itself will have to bear.
24. Mortality assumptions change over time. Presumably,
the Government actuary has from time to time recalculated the
cost of the existing pension scheme, and, on various occasions
since 1973, when the last major changes were made to the scheme,
the MoD's superannuation liability costs have increased as a result.
But the benefits available under the scheme have not previously
been altered to keep the cost of the scheme down.
25. Substantial numbers of claims under the new scheme
will not be made for several decades. This makes it possible for
the MoD to start afresh. Mortality assumptions are different for
personnel of different ages, and cannot easily be applied to a
scheme which is already in operation. This will be much less of
a problem with the introduction of a new scheme. With
the introduction of the new pension scheme, the MoD has changed
its definition of 'cost neutrality' to seek to ensure that the
future cost of an average member of the new scheme should not
exceed the current cost of an average member of the existing scheme.
26. The new mortality assumptions will only marginally
affect benefit entitlements under the existing scheme.[46]
What this means is that the existing scheme will be substantially
more valuable than the new scheme.[47]
The MoD justifies this because those personnel in the existing
scheme "cannot expect to benefit to the same extent from
improving life expectancy" as future service personnel.[48]
This has a certain logic, but in broad terms is likely to operate
for many personnel as an incentive to remain in the existing scheme.
We note, however, that the structure of benefits in the new scheme
is quite different from the existing scheme, and that a comparison
of the value of the schemes in broad terms will often not reflect
how they would impact on individual personnel. A serving member
of the forces may face a choice, for example, between a scheme
which provides more valuable personal benefits in terms of Immediate
Pension and preserved pension, and one which provides more valuable
benefits to his spouse or partner in the event of his or her death.
Nonetheless, personnel transferring
to the new pension scheme will receive benefits of a lesser overall
value than those remaining on the existing scheme. This would
in many circumstances seem to be a fairly obvious disincentive
to transfer.
27. We have always
been unhappy that the Government in its review of Armed Forces
pensions has imposed on itself the constraint of how much current
benefits cost, rather than looking more generally at what Armed
Forces personnel deserve. We are even less happy now that it emerges
that the Government proposes to reduce the overall value of benefits
under the new scheme, compared with the existing scheme. The goalposts
of 'cost neutrality' have been shiftedto the disadvantage
of future personnel.
INTERPRETATION: CHANGE IN THE PRESERVED PENSION AGE
28. The more general context within which the MoD
has been working has changed since the initial stages of the review
and consultation, with the publication of the Government's Green
Paper, Simplicity, Security and Choice; Working and Saving
for Retirement, published in December 2002,[49]
and the later document, Simplicity, Security and Choice; Action
on Occupational Pensions, published in June 2003.[50]
The more general impact of these wider public pension policy changes
is discussed below. But the proposal to raise the preserved pension
age from 60 to 65 has implications for cost neutrality, which
need to be addressed.
29. Preserved pensions are pensions payable to personnel
who leave service before the age of 55. These personnel do not
receive a pension as soon as they leave service (except where
this is for reasons of ill-health), whereas personnel who stay
on until age 55 do receive a pension on retirement. The consultation
proposals envisaged the payment of preserved pensions at age 60.
In line with more general Government policy, however, the new
scheme envisages payment of these pensions at age 65, both for
those who opt into the new scheme and for those who stay in the
existing one (for future service).
30. We discuss below the implications of this change
for Armed Forces personnel.[51]
From the Government's point of view, however, it will generate
cost savings. In about 30-40 years' time, a man of 60 who is a
member of a public service pension scheme will, according to the
Government actuary, live on average for about a further 26 years[52]by
not paying preserved pensions until age 65, the Government will
save about one fifth of its total bill on preserved pensions.
Although it will also mean making early departure payments for
longer to personnel who leave service after the age of 40 (or
18 years' service), these payments are to be reduced (as we discuss
below), and are already (in the form of the Immediate Pension)
of lesser value year on year than the preserved pension.
31. These changes have not been factored into the
Government's calculations of how much the existing pension scheme
will cost, as there has been "no final decision by Government
on how such a change might be applied to current public service
pensions schemes and from what date any such change might be effective".
However, savings are, according to the MoD, likely to be "low".[53]
We note that this, however, will depend on how many personnel
choose to transfer to the new scheme; the MoD's expectation seems
to be that relatively few will. The
Government should ensure that any money which would have been
paid to pensioners in the existing scheme were it not for the
rise in the preserved pension age is used to improve other pension
benefits.
28 HC (2001-02) 666, Q 154 Back
29
HC (2001-02) 666, para 149 Back
30
HC (2001-02) 666, para 149 Back
31
Ev 39, para 1 Back
32
HC (2001-02) 666, Ev 39 Back
33
HC (2001-02) 666, Ev 53 Back
34
Ev 19 Back
35
Ev 19 Back
36
Ev 43 Back
37
Q 48 Back
38
Ev 39 Back
39
The Accrued Superannuation Liability Charge Back
40
Ev 43 Back
41
Ev 39, para 1 Back
42
Ev 39, para 2 Back
43
See paras 28-31 below Back
44
HC (2001-02) 666, Ev 40 Back
45
Ev 39, para 1 Back
46
As discussed below, the preserved pension age for members of the
existing scheme is to be raised to 65, but only for future service. Back
47
The value of the existing scheme is set at 24.5 per cent, the
value of the new scheme at 22 per cent of pensionable pay, making
the existing scheme 11.36 per cent more valuable. Back
48
Ev 39, para 1 Back
49
Cm 5677 Back
50
Cm 5835 Back
51
See paras 101-106 below Back
52
Ev 43 Back
53
Ev 41, para 11 Back
|