Public Service Pensions Bill

Memorandum submitted by British Dental Association (PSP 15)


The British Dental Association is the professional body representing dentists in the United Kingdom. It has 19,000 dentist members and 4000 student members. The vast majority work in the National Health Service and are members of the NHS Pension Scheme. Others are employed by the Ministry of Defence and are in the Armed Forces Pension Scheme; yet others work in academic institutions and they are members of the Universities Superannuation Scheme. Our members have been very concerned at the attack on their pensions.

We appreciate the opportunity to submit written evidence to the Committee scrutinising the Public Service Pensions Bill. Our detailed observations appear below.

Detailed comments

We have a number of concerns about the wording of the Public Service Pensions Bill which is the vehicle to give effect to the final ‘agreement’ concerning the future shape of NHS Pensions with effect from April 2015.

Our principal concerns relate to:

· Issues surrounding Future Normal Pension Age

· The extent of the increase in power and control by the Treasury

· The reference to negative revaluation.

1. Future Normal Pension Age

We are greatly concerned regarding the decision in the new NHS Pension Scheme to make Normal Pension Age equivalent to State Pension Age.

This will lead to a large group of dentists, and other health workers, having to work to age 68 for example, rather than age 60 - eight years longer.

This makes no allowance for the possible deterioration in clinical skills and manual dexterity of surgeons as they age and opens up the very real possibility of danger to patients occurring in extreme cases.

The BDA can see no reference in Clause 9 of the Bill to the establishment of the Working Longer Group which was set up to conduct a scientific study of the pressures of working longer and whether particular occupational groups were likely to be especially disadvantaged by having to work longer.

It seems as if no cognisance is to be taken of the work of that group even prior to the publication of its report.

2. Treasury control

There are a number of places in the Bill where power is reserved to HM Treasury to exercise control.

Examples of this power appear in Clause 11 – Employer cost cap - where the cap is to be set in accordance with Treasury directions .The valuation methodology in Clause 10 is also subject to Treasury control: there appears to be no involvement of the Department of Health in the NHS Pension Scheme on these matters.

This places unprecedented power and control into the hands of one Government department rather than Parliament.

3. Revaluation

A reference appears in Clause 8 (2) to ‘a revaluation is to be such percentage increase or decrease as a Treasury order may specify in relation to the period’.

This opens up the possibility of negative revaluation that does not appear in the text of the Final Agreement of March 2012.The word ‘decrease’ should be removed.


There are other points that we could make in addition to the aforementioned main concerns that we have already expressed. However, they can best be expressed by the following comment:-

Although we understand that the bill is of necessity an ‘umbrella’ bill covering as it does most public service schemes, the fact that it does not correspond in detail to the wording of the final ‘agreement’ that was reached regarding the NHS Pension Scheme gives us considerable cause for concern as to the extent to which detailed secondary legislation will mirror the terms of that ‘agreement’.

November 2012

Prepared 21st November 2012