Operating Model Review - A blog by Dominic Harris

It is no secret that demand for our services has been increasing significantly for a number of years, and that this trend is forecast to continue. I believe that high demand is a reflection of the important role we play in the sector – providing a fair and impartial service to help resolve complaints and disputes about workplace and personal pension schemes. We are proud to use our expertise to ‘level the playing field’ between parties with very different levels of knowledge and resources, making sure that pension scheme members have free access to redress when things go wrong.

However we are at the point, and have been for some time, where the demand for our services is outstripping our capacity to resolve cases for complainants and respondents in a timely fashion. In light of this, we have carried out an in-depth review of our operating model, exploring all potential options for improved efficiency across our ‘customer journey’ – and we now have a clear plan for tackling our historical caseload and reducing our queue lengths and waiting times.  

We will be talking about these changes over the next few months – and, in our series of blogs, highlighting specific aspects of how we will work in the future. The first of these looks at how we interact with schemes and providers’ own complaint processes.

A requirement to go through IDRP before coming to TPO 

One of our priority workstreams is focused on tightening up our requirements for new complaints coming to us. Our respondents are generally required to have a formal complaint handling process, such as the Internal Dispute Resolution Procedure (IDRP) that the trustees of an occupational pension scheme must put in place – and the vast majority of our respondents engage constructively during that process in an effort to resolve members’ complaints. In light of this, our legislative framework sets out that, generally, TPO will not investigate complaints until the IDRP process has been exhausted. However, that requirement was relaxed in 2018 when the Pensions Advisory Service moved its (informal) dispute resolution function to TPO. Individual complainants could choose to use our informal resolution service, which could include engagement before, or during, the scheme’s own IDRP process.

But, going forward, we will be requiring all complainants to exhaust the respondent’s formal complaints process before we will consider investigating a complaint. This will bring the conditions for our Resolution Team investigating a complaint in line with those of our Adjudication Team.

We know that many of the pension complaints we currently receive could and should be resolved under an internal resolution process, without the need for TPO input – and this change will empower schemes to do just that. The consistent increase in complaint volumes is a shared challenge and one we must all play our part in improving. This change to when we accept complaints looks to all those in the industry to step up and take greater ownership of their dispute resolution process, as most respondents already do.  

Although our Resolution Team will only consider investigating complaints that have completed an internal resolution process, our team of volunteer advisers who so generously give their time and pensions expertise to help people (as you will know if you followed our Volunteers’ Week celebrations earlier this month!), will continue to offer their impartial support to individuals prior to, or during, the IDRP process. This will be focused on supporting vulnerable members and cases, for example where the risk of financial harm is high or where there is a time-critical situation.

Timescales for implementation

As one of our priority workstreams, we will be moving from piloting some aspects of the change to full implementation by autumn this year. In the meantime, we have lots to do to prepare ourselves, the industry and future complaints for the changes ahead. 

We’re keen to hear the industry’s views on implementation, including any impacts on internal processes and member communications. I would therefore encourage you to come along to our Stakeholder Forum on Thursday 27 June to have your say. My colleagues Robert Loughlin (Chief Operating Officer) and Jennifer Ryans (Deputy Chief Operating Officer – Casework) will be discussing our plans in more detail and answering any questions. Register online to secure your place.

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