Agenda item

Introducing the item the Chair said that he thought the Board should give a high priority to improving employer performance. The report gave cause for concern as some matters, if material, could be reportable breaches. There was a judgement to be made as to whether they were material or not.

The Pensions Manager presented the report and responded to questions and comments from Members.

A Member asked why performance was so low in so many cases. The Pensions Manager replied that SLA targets were much tighter than the regulatory standards. As shown by the table at the top of agenda page 30, the vast majority of cases were dealt with within five days of the SLA target. He noted that the Chair had previously suggested that it might desirable to reduce the SLA targets to statutory levels. In addition there was one staff vacancy.

A Member said that the performance report should give a balanced view, and that perhaps the more stringent standards failed to do this. The Chair said that it should always be made clear whether a target was statutory or an internal one and whether there was a difference between the statutory target and the internal target.

Members were concerned about the poor performance of employers as indicated by the table at the top of agenda page 34. They noted the poor performance of Bath and North East Somerset, which ought, as the administering authority, to be a beacon of excellence.

The Chair said that there ought to be a hierarchy of measures for dealing with repeated poor performance by employers, which would include additional training, the imposition of administrative charges, or ultimately reporting them to TPR. It was important that the Fund and the Board understood whether or not there was a genuine reason for poor performance, such as staff shortage. If there was no genuine reason, that was a legitimate cause for concern.

The Chair said that in some cases it might be appropriate to invite an employer’s HR manager or payroll provider to a meeting. The Board would have the opportunity at the next meeting to see whether the improvements anticipated by the Pensions Manager materialised. He requested the Pensions Manager to highlight in the next report any issues or employers that were causing him particular concern.

Members agreed with the suggestion of the Head of Audit West that the Section 151 Officer should be invited to the meeting so that she was aware how poor the performance of the administering authority has been.

The Chair noted that there were a number of APF fund delivery projects in the Pensions Administration Team workplan (agenda pages 41-42) and said that it was important for the Board to monitor these, so that it had a balanced view of the Administration Team/employer interface and did not just focus on poor performance on the employer side.

RESOLVED :

1. To note Membership data, Employer Performance and Avon Pension Fund Performance for the three months to 30 June 2017.

2. To note progress on the TPR Data Improvement Plan.

3. Future compliance reports should state the statutory and internal target and show performance against statutory as well as internal APF targets, and the LPB should focus on those employers with repeated poor performance

4. The Fund should develop and implement a hierarchy of measures for dealing with repeated poor performance by employers, which would include additional training, the imposition of administrative charges, or ultimately reporting them to TPR.