02/09/2026
When a Trust directly employs or engages a locum doctor, the visible hourly rate is only one part of the operating model.
Depending on the legal arrangement, terms and eligibility, the Trust may also need to fund or administer employer National Insurance, pension obligations, holiday pay, statutory sick pay, statutory family payments, PAYE and RTI, worker records, queries, corrections, grievances, termination and internal governance.
That does not make Direct Engagement wrong. It means the comparison must include the full cost and responsibility stack rather than treating VAT as the only measure.
For qualifying GMC doctors, the new HMRC position creates the opportunity to keep the Trust as hirer and move the agreed payroll and employment operation to PGS, while the agency retains its client and assignment relationship.