APPENDIX 10
Memorandum submitted by Norwich Union
General Insurance (EDP 14)
1. INTRODUCTION
1.1 Norwich Union is pleased to respond
to this inquiry in our capacity as a liability insurer dealing
with claims involving injured persons, many of whom can benefit
from the availability of structured assistance in returning to
work. Whilst our comments do not deal with all of the issues covered
within the remit of the inquiry we concentrate on those areas
where we believe that we may be able to assist the debate on the
relevant issues.
1.2 Our experience is both within the field
of disability arising from trauma in motor or employment accidents,
and as an Income Protection insurer encountering all types of
disability.
1.3 We welcome this inquiry and the recent
Green Paper, "Pathways to Work" as we believe:
1.3.1 that early and timely intervention
to assist workplace and social re-integration of disabled people
is crucial; and
1.3.2 that a person should be restored to
as productive and independent a lifestyle as may reasonably be
achieved, and that the best long-term outcome will be achieved
with early intervention and effective treatment.
1.4 This requires a collaborative and non-confrontational
approach between all stakeholders, including insurers/tortfeasors
where relevant, to ensure that the needs of disabled people are
met expeditiously, with interaction between medical, care, social
and vocational agencies as appropriate to the individual's case.
1.5 We currently adopt this early intervention
approach wherever possible, with the injured person at the centre
of our claims process to ensure that they can be restored as closely
as reasonably possible to their pre-accident level of lifestyle
and economic activity. Our experience as a general liability insurer
has demonstrated that early effort on rehabilitation brings effective
results.
2. PROVISION
OF ASSISTANCE
2.1 We agree that in the UK there is insufficient
provision to assist disabled people, whether with short-term or
long-term disability, in returning to work, and we support any
initiative to promote this objective.
2.2 The needs of the short-term disabled
should not be ignored in this context. Despite eventual medical
recovery from injury, they too may suffer job loss during the
recovery period and become unemployed. It is desirable to prevent
injured people becoming locked into a cycle of dependence and
a "disability mindset" where they believe that they
are abandoned or have no future.
3. RESOURCE AND
PROCESS
3.1 It is our experience that there is very
limited public resource available to assist disabled people to
get back to work.
3.2 There is a failure in the public sector
to take a holistic view. There should be a fully-integrated approach
to the wider picture, aimed at the restoration of the disabled
person into the workplace and society. There is not, in our experience,
any practical example of "joined up" provision by all
public sector agencies, namely NHS, Local Authority, Social Services
and DWP.
3.3 In the UK public services tend to follow
a medical model of rehabilitation, dealing with medical and care
needs first before considering vocational needs and long term
lifestyle. Where they exist, NHS Case-Managers and Physiotherapy/Occupational
Therapy services provide excellent support assisting where they
can with issues that arise on discharge from the "hospital"
stream. Once into the "benefits" stream, the DWP focus
is on advisory and counselling support eg under the "New
Deal for Disabled People", help is provided with looking
for a job and any support or training that is needed, but it is
unclear whether generally this translates to any practical effect.
3.4 The big gap in the current approach
is a failure to ensure access to meaningful training and/or retraining
programmes which deliver real skills of use in today's market-place.
The problem is two-fold:
(i) lack of adequate facilities, and funding
thereof;
(ii) lack of employment placement facilities
post-rehabilitation.
3.5 There is some very excellent private
resource (for example, St Loyes College), where individuals follow
tailor-made action-plans with the support of highly skilled case
managers who engineer routes back into employment, but good examples
of vocational providers are few and far between. There is a lack
of resource in many areas and, where it does exist, resource can
be of inconsistent quality, with instances of unregulated private
provision giving poor value for time and money.
3.6 The role of the employer in returning
disabled people to work should not be underestimated. However,
existing employers require support and guidance in taking disabled
employees back onto their workforce as do potential new employers
need assistance in creating opportunities for training/permanent
placement facilities. Both require help with organisation of work-place
access and adaptation. We understand new legislation in Holland
puts the employer central to the Dutch rehabilitation process.
3.7 We strongly believe that more vocational
rehabilitation facilities are needed and that there should be
greater geographical spread and access to these facilities. Whether
private or public, access to facilities and provision needs co-ordination
and regulation.
3.8 Norwich Union has contributed to the
ABI/TUC Discussion Paper "Getting back to Work" and
we will be pleased to share the summary report with you when this
is released by the ABI/TUC.
4. THE GREEN
PAPER
In the Green Paper, the Government proposes
updating their Welfare to Work strategy with:
(i) a "better framework of support"
through Jobcentre Plus with the creation of skilled "specialist"
personal advisers who can work with the disabled person in work-focused
interviews and creating action-plans and make discretionary grants
for eg interview suits;
(ii) "direct access to a wide range
of provision" with "groundbreaking rehabilitation programmes"
via for instance the new pilot joint DWP/NHS programmes. However
these programmes appear to be directed at certain chronic disabilities
and it is unclear how "direct access to a wide range of provision"
is to happen;
(iii) "improved, visible financial incentives"
with tax credits on return to work.
We will be responding to the Green Paper in
detail at a later date.
5.0 We support the EDM tabled by Dr Brian
Iddon (EDM No. 433—Acquired Brain Injury: Provision of Rehabilitation,
18 December 2002) insofar as we agree that the Government should
introduce a national funding structure for rehabilitation and
vocational support services for acquired brain injury. We would
suggest that Government funding should underpin such services
for all disabled persons.
6. CONCLUSION
Norwich Union would welcome the opportunity
to present our opinions orally to the committee should it wish
to understand further the role of the insurer in assisting people
with health problems and disabilities into work.
Richard Ackworth
Public Affairs Manager
3 January 2003
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