Triage – definition and history
The concept of triage comes out of the need for finite military medical resource to be used efficiently in the heat of battle – it seeks to ration the priority of patients’ treatments based on the severity of their condition where there is insufficient resource for all to be treated immediately. The term comes from the French verb ‘trier’, meaning to separate, sift or select and is believed to have originated during the Napoleonic Wars but has been applied by military doctors in all conflicts since and is also used in any Accident and Emergency Hospital for the same reasons, essentially to identify: 

• those who are likely to live, regardless of what care they receive;
• those who are unlikely to live, regardless of what care they receive;
• those for whom immediate care might make a positive difference in outcome.

Transfer triage
In CP18/7 ‘Improving the quality of pension transfer advice’, published in March 2018, the FCA acknowledged that many firms giving advice on defined benefit transfers operate a triage process in their initial conversation with potential clients. In this context, the purpose of triage should be to give the client sufficient information about safeguarded and flexible benefits to enable the client to make a decision about whether to take advice on the transfer or conversion of the safeguarded benefits.

However, the FCA has found that some forms of triage may be inadvertently crossing the advice boundary. For example, if an adviser tells a client that they should not be transferring their DB benefits at the end of the triage service, this is likely to be regulated advice. Similarly, if an adviser tells a client that it is unlikely that a transfer would be recommended if the client took regulated advice, this in itself may be an implicit recommendation to stay in the ceding scheme.

The FCA have indicated that, for triage to be a non-advised service, it should be an educational process so that clients can decide whether to proceed to regulated advice. Firms can achieve this by providing generic, balanced information on the advantages and disadvantages of pension transfers.

Ideally, if the firm wishes to avoid giving advice, no information should be gathered about the client. However, even if a client tells a firm about their personal circumstances, the firm should not comment at the triage stage on whether the client should consider a transfer based on this information, If an adviser gives an opinion on how a consumer’s individual circumstances may affect advice on transferring, it is more likely that regulated advice is being provided.

The FCA also recommends that firms should:

• explain the transfer process and the total charges that might be incurred, both if a transfer proceeds and if it does not;
• keep records where triage has been provided and the form that it took as this is likely to be in firms’ interests in case of future complaints.