HR

PEAM and Bad Maths

PEAM and Bad Maths

PEAM (Police Earnings Assessment Matrix)

“The Police Earnings Assessment Matrix (PEAM) was independently developed by Grantwood Consulting to enable the force to arrive at fair, reasonable and defensible assessments of the earnings potential of Police Officers. PEAM’s underlying principle is that there are a number of generic job levels in the police, public sector and the wider job market. The job levels enable:  The size of jobs to be assessed, particularly jobs in different functions or disciplines.  Base salary levels for a number of different market sectors or geographies. The job levels allow police officer positions to be compared with jobs of comparable size or weight in the public sector, private sector or police support staff populations. PEAM therefore combines best practice from both outside and within the police sector. It has also been tested to ensure compliance with equal opportunities requirements.”

Why is this bad maths.  Well its contrary to regulations for a start.  The regulations are quite simple and split the degree of disablement of earning capacity into 4 bands: slight, minor, major and severe:

Degree of disablement Gratuity expressed as % of average pensionable pay Minimum income guarantee expressed as % of average pensionable pay
Less than 5 years’ service 5 or more but less than 15 years’ service 15 or more but less than 25 years’ service. 25 or more years’ service.
(1)       (2) (3) (4) (5) (6)
25% or less (slight disablement)         12.5% 15% 30% 45% 60%
More than 25% but not more than 50% (minor disablement)         25% 40% 50% 60% 70%
More than 50% but not more than 75% (major disablement)        37.5% 65% 70% 75% 80%
More than 75% (very severe disablement)          50% 85% 85% 85% 85%

What the PEAM manages to do is turn a % given by a medically qualified selected practitioner  into another lesser % used by HR for the award.  For example, 75% (major and band 3) once put into the Police Earnings Assessment Matrix can be magically distorted into a minor band 1.  Basically PEAM is a device that is used to reduced an IOD banding into its lowest factor.  This fallacy was spotted in a Senior Counsel review of Injury on Duty Awards commissioned by the Northern Ireland Policing Board where Mr David Schofield QC stated in section 1.35

“I also recommend that, in the course of such a further review of Northern Ireland specific policy guidance in this area, serious consideration should be given to abandoning the currently recommended method of calculating percentage disablement, including detailed reliance on the ASHE survey and comparison with the officer’s notional uninjured police salary, in favour of a much more basic approach, whereby the relevant medical authority would simply make a judgment in the round as to the severity of the impact of the duty injury on the officer’s earning capacity, so as to select the officer’s appropriate band without the need to calculate a specific percentage disablement figure”.

chapters_1_and_14_of_the_scoffield_report__website_version_

In other words the injured former officer should be placed in band 1,2 3 or 4 based on a judgement ‘in the round’.  The regulations do not allow for inclusion of any manipulation by use of an invented earning matrix therefore this PEAM device has no de jure.

So the use of PEAM (or any convoluted matrix) is unlawful.  PEAM and other methods involving wage comparison resulting in a figure which purports to reflect future loss of earnings. An injury pension is paid as compensation for loss of the capacity to work, and the Regulations are blind as to how much or how little an individual might be earning, or be capable of earning.

The SMP (selected medical practitioner) is not permitted to look to the future when deciding degree of disablement. He must make his decision on the medical evidence at the time he makes that decision. The wording of the Regulations is,

‘Where it is necessary to determine the degree of a person’s disablement it shall be determined by reference to the degree to which his earning capacity has been affected as a result of an injury received without his own default in the execution of his duty as a member of a police force.’

Note, ‘has been’ not ‘will be’.

Note also, ‘capacity’ not ‘earnings’.

The SMP must make a decision in the here and now, and should relevant circumstances alter substantially in future, then the Regulations allow for a police pension authority to review the degree of disablement and revise the amount of pension paid.

Finance Managers gone Rogue part 1

Finance Managers gone Rogue part 1

The delegated Administrator for Police pensions according to Avon & Somerset’s Joint Scheme of Governance is named as the HR Director.  The HR Director resigned suddenly in May 2014.  In mid-May 2014 the Chief Constable was suspended by Commissioner Mountstevens following allegations of ‘inappropriate behaviour towards female officers and staff’.  In this organisational maelstrom, the Finance Director took on the extra duties of the HR Director in a grandly sounding re-badged dual role now called the Director of Resources.

But the authority of delegation ( the Chief Constable is the Police Pensions Authority but he is able to delegate the administration to a named other) wasn’t signed until September 2014 and with a clumsy attempt to back-date it by 3 months.  So who was steering the ship and allowed the reviews to start?  …

Letter from John Long to Julian Kern

It wasn’t on the say so of the PCC’s finance officer was it?  Nah, that’ll be just plain wrong … reviews of IOD awards should surely be solely a medical question under suitable intervals relevant to the individual.  Not because the force is broke, penniless, without means, on the’ bones of yer arse’, etc etc.

HR gone rogue Part 1

HR gone rogue Part 1

Serve as a police officer and you are treated as number, as a ‘human resource’ not as a person.  If you are retired on an IOD award then you become an ex-number that still costs them … and the HR departments will try to collect the pound of flesh as to balance the books of their Director of Resources. Like Portia said to Shylock – you can’t take what you aren’t lawfully allowed to take. Poor metaphor, sorry – can I qualify it by claiming the blood Shylock isn’t allowed to draw is the same as the case-law and police regulations they aren’t allowed to contravene? No? .. I’ll get my coat.

Rhetorical question, but why are IOD awards administered by HR departments ?

When HR has the same director as the Head of Finance then chaos shall reign …  To misquote Jessy J – “It’s all about the money, money, money”

31/01/2013 JOINT FINANCE MEETING

“Pension and retirement costs are significantly overspent due to the large
number of medical retirements; 26 cases to date with a possible further 27
cases identified by the Human Resources department. This overspend will be
funded through Reserves and the number budgeted for within the 13/14
budget remains at 12 cases”.

08/07/2013 Email from HR Director  FOI 1102 email

Edit note: (Why have case-law when you can try to ask the Home Secretary to revoke it !  And they subsequently denied that there is a ‘HR v2’ – the version that needed ‘damping down’)

24/07/2013 JOINT FINANCE MEETING

“The PCC’s attention was also drawn to the Injury on Duty Payment which is a recurring payment for someone who is medically retired but was injured whilst on duty (this includes the commuting journey). This is payable every year until death and currently accounts for £5.6m of the central pay budget (half). The Head of Retained Finance has raised this issue with Winsor following the Winsor Review, which did not pick this issue up, and the Constabulary suggests that consideration should be given to this ceasing at national retirement age. The PCC will write to Winsor to raise this issue again. […]

  1. Finance should consider managing medical retirements through a reserve rather than budgeting for it.
  1. The PCC will write to Winsor regarding the issue of the Injury on Duty Payment being payable until death”.

29/11/2013 HR/OPCC Meeting

“The College of Policing will be hosting an IOD training event on 31 January for SMP’s. A meeting of the National Attendance Forum will look at the agenda for the training day. MS asked if David Bulpitt looked at who is tier 1/2 etc. CW advised that the pension’s team is looking at this”.

14/02/2014 JOINT FINANCE MEETING

“Central pay overspend will be allocated to departments where possible in future reports. Medical retirements was discussed and the potential need to accrue this spend at the end of the financial year dependent on advice from

  1. The PCC sought clarification on the advice given to retiring officers on thelength of time they have to be retired before they can return to a staff role –this is dependent on how different the staff role is to that of the Officer rolethey were in”.

29/05/2014

16 letters are sent to youngest band4s (highest disablement) informing them they are subject to a Regulation 37 review.