NHS-focused NMW support: deductions, unpaid time, salary sacrifice and rostering. Practical fixes and audit-ready evidence.
Meeting National Minimum Wage (NMW) obligations is challenging in NHS settings. Complex rotas, variable allowances, uniforms, training time and salary sacrifice arrangements can all affect whether pay meets the legal threshold. The financial and reputational consequences of getting it wrong are significant: arrears, penalties and sustained operational disruption. We help NHS organisations establish clear rules, apply them consistently and retain evidence that satisfies internal audit and HMRC.
Where risk typically arises
The most common pressure points include deductions for uniforms or equipment; treatment of unpaid time such as briefings, handovers or mandatory training; the impact of salary sacrifice on hourly pay; and elements of travel, subsistence and accommodation where costs are recharged. For bank and agency arrangements, the interplay between engagement terms, rostering systems and payroll cut-offs often creates gaps in documentation. A structured approach is required to prevent isolated errors becoming systemic non-compliance.
Our approach
We begin with a concise review to confirm scope, identify high-risk staff groups and map how data flows from rostering to payroll. We test representative samples against NMW rules and quantify any exposure. From there, we implement practical controls: clear policies on deductions and unpaid time; guidance for managers and payroll; and simple checklists that ensure issues are captured before pay is finalised. Where salary sacrifice is offered, we help design processes that protect NMW while maintaining staff benefits. If HMRC involvement has commenced, we prepare your position, evidence calculations and support proportionate resolution.
Outcomes
Greater certainty on compliance. Fewer retrospective adjustments. Clear documentation able to withstand internal/external audit and HMRC enquiry. A fair and consistent approach to staff, without accidental breaches caused by process gaps.
Typical deliverables
- NMW policy and guidance tailored to NHS workforce models.
- Controls for deductions, unpaid time and salary sacrifice with pre-payroll checks.
- Sampling methodology, evidence pack and remediation plan where needed.
- Targeted training for payroll, HR and line managers.
Next steps
If you would value a focused review, we can confirm priority risks, set immediate actions and provide a realistic implementation timetable aligned to your payroll cycles.
Go to: Employment Taxes for NHS Organisations (hub) · IR35 for NHS · Expenses & Benefits (P11D/PSA) for NHS · VAT Services (hub)
National Minimum Wage (NMW) NHS FAQs
Deductions for uniforms/equipment required for work, certain meal or transport charges, and other employer-required costs reduce pay for NMW purposes. Apply clear rules and pre-payroll checks.
Yes. Salary sacrifice reduces cash pay used in the NMW calculation. You must ensure hourly pay remains at or above NMW after sacrifice; build automatic checks into payroll.
Often yes. If time is required for the role, it typically counts toward hours for NMW. Capture and evidence policies on unpaid time and rostering.
Confirm how hours, allowances and deductions are captured from rostering to payroll. Use sampling to test representative groups and fix data gaps before pay is finalised.
Rostering exports, payroll inputs, deduction policies, salary-sacrifice agreements, sampling results and remediation actions. Retain in line with statutory/audit requirements.