Operating Model Review: Reflections on our achievements this year

In the latest in our series of blogs, The Pensions Ombudsman, Dominic Harris, reflects on the organisation’s progress over the last year and updates on the latest developments on our Operating Model Review. He also shares more about our focus on older complex cases, as well as our lead case approach – both examples of how we’re tackling our high caseload.   

As we approach the end of a busy year, I've been reflecting on the success of our key Operating Model Review workstreams. With incoming complaints up 53% compared to this time last year, the sharp increase could have overwhelmed us. Instead, the whole organisation rose to the challenge and worked hard to implement improvements that are already making a real difference to the important service we provide.

What’s changed?

We know that lots of the pension complaints we receive could and should be resolved much earlier – most often under schemes’ own IDRP or similar complaint process. That's why we now require all complainants to try resolving their complaint through their pension scheme's own process first, before they come to us. This approach has already shown promising results in reducing unnecessary escalations.

So, if you’re managing a pension scheme, now is a good time to check your website and templates to make sure you're pointing members in the right direction at the right time. Our factsheet includes some ready-made wording you can use to signpost to TPO. 

In September 2024, we also launched our expedited decision-making process – a significant step forward in our efficiency drive. Issuing expedited decisions, and expedited determinations if required, on cases we have assessed as having a clear outcome allows us to resolve disputes more quickly for all parties involved. In many cases, it reduces the amount of time customers wait in our queues by as much as 18 months.

While we don’t publish these shorter-form expedited determinations in the usual way, I wanted to share an example of a recent case to illustrate the process. In the future, we will also be publishing a periodic summary of the types of cases we have resolved using expedited decision-making.

Case management initiatives

Complex cases

Separately, I’m also proud of the progress we are making in reducing the number of older and complex cases in our historical caseload. We've achieved this by expanding our specialist working groups to include members of our legal team and upskilling adjudicators to enable them to deal with the most complex case topics, such as disputes about overpayments and transfer due diligence issues. This means we'll be able to assign and resolve these types of cases more quickly.

Lead cases

A standout success has been our 'lead case' approach, which we’re now using more than ever. When we identify an industry-wide issue, or a scheme-specific issue affecting multiple members, we select a representative ‘lead case’ to accelerate through our processes. This allows us to set out our position clearly and quickly in a comprehensive determination, which in turn supports the timely resolution of other complaints.

There are two ways we can achieve that:

1. The first is by taking on a single case while the others remain in the scheme’s own IDRP. My determination then informs the trustee’s own IDRP cases. This is the approach we are proposing to take with the current Boots Pension Scheme dispute.

2. The second applies when the cases have already completed a scheme’s formal complaints process and applications have been submitted to us. Where the material facts of a group of cases are very similar, in some circumstances my findings and directions in the lead case can be applied equally to all the linked cases. This was the approach we took in a recent transfer due diligence case concerning Rowanmoor Trustees Limited.

However, it will not be possible to use the lead case approach in all circumstances – for example, where it is necessary to look at the specific and unique defences that each member might have in a scheme-wide series of overpayments.

What this means for you

If you're managing a pension scheme, these changes mean:

• You'll need to ensure your IDRP or complaint process is robust and well-communicated
• Your signposting to TPO should be clear and up-to-date
• If you have an issue affecting multiple members, let us know at an early stage, and we will explore with you whether a lead case approach is appropriate.

Looking ahead

As we enter 2025, our performance continues to be strong. But these changes couldn't have come at a better time. 

We've experienced an unprecedented rise in demand for our service this year but our enhanced operating model is helping us to resolve more pension complaints than ever. That said, continued support from both the industry and government will be vital for us to make significant inroads into our historical caseload and reduce customer wating times. 

Have questions about these changes? Don't hesitate to get in touch with our stakeholder team.