Memorandum submitted by Citizens Advice
Bureau (PC 14)
SUMMARY
1. Citizens Advice welcomes the establishme
of the Pension Service as the delivery arm of DWP for people over
the age of 60. The Pension Service has a clear focus on ensuring
that older people get the benefits to which they are entitled.
The take-up target for Pension Credit provides a clear (but unduly
modest) incentive for the Pension Service staff to adopt a positive
approach to their customers.
2. We consider that the business model is
excessively telephone-based, and makes inadequate provision for
the significant proportion of pensioners who are unable or unwilling
to use the telephone.
3. We welcome the Government's commitment
to increase the incomes of poor pensioners, but are concerned
that the complexity of Pension Credit, and the fact that it involves
a means test, puts many eligible older people off applying. We
are disappointed with take-up so far, and consider that the Pension
Service take-up target, 75% by 2008, is much too modest. There
is a need for much more face-to-face work with older people to
increase take-up, which the Pension Service may be unable to deliver
because of the proposed job cuts.
4. We consider that the Government was over-ambitious
in introducing the Pension Service as a new organisation, Pension
Credit as a new benefit and direct paymentsall over a very
short period. The Pension Service has struggled to cope, leading
to delays and mistakes.
5. The Government's decision to close 10
pension centres is very worrying, and is likely to result in further
disruption, delays and lost case files. There is still a great
deal to do, with over 1 million eligible households not receiving
Pension Credit.
6. The Government should simplify the policy
and procedures on Pension Credit, to: pay savings credit from
age 60, exempt all pension credit recipients from health charges,
reduce the assumed income from capital, remove the housing benefit
savings limit for all pension credit recipients, relax the overseas
travel rules and provide automatic flow-through from income support
at 60.
7. We welcome the concept of local authorities
and voluntary organisations being partners of the Pension Service,
but consider that the concept was inadequately thought through
before it was applied. DWP and the Pension Service should review
the ways in which they relate to "partners" to allow
consultation at an earlier stage, and to develop more reciprocal
relationships.
1. INTRODUCTION
1.1 The Government introduced Pension Credit
in October 2003 to respond to pensioner poverty that arose from:
The declining relative value of the
basic state retirement pension;
The failure of more than a quarter
of the pensioners who were eligible for Income Support (branded
as Minimum Income Guarantee) to claim it.
1.2 It sought to achieve this through a
benefit that met a number of policy aims:
To target available resources on
the poorest pensioners;
To lessen the disincentive to save
for retirement that was provided by the Minimum Income Guarantee
means test;
To provide a benefit for older people
that did not incorporate the work-seeking conditionality being
brought in for most benefit recipients of working age; and
To administer the new benefit more
cheaply, having regard for the stable circumstances of most pensioners.
1.3 The establishment of the Pension Service
in April 2002 was an important part of the preparation for Pension
Credit. The concept of a DWP delivery agency devoted to providing
benefits for older people is very positive, because it enables
staff to have a wholly committed approach to ensuring that their
customers get the benefits to which they are entitled. The introduction
of take-up targets for Pension Credit means that Pension Service
staff actually encourage their customers to claim benefitsa
world away from the old approach of the Benefits Agency.
1.4 Research was carried out to determine
how the new Pension Service should go about its business. This
showed that most older people hated going to Benefits Agency offices,
and most of them had telephones and some form of bank account.
So the Pension Service was set up as a largely telephone based
service, operating out of 26 newly established pension centres
where processing would be carried out and which would deal with
most customer queries. There are no pension centres in London
or the South Eastthese parts of the country are served
from distant locations such as Glasgow, Cwmbran and Newcastle
on Tyne. These centres have been phased in over a two-year period,
during which time the pattern of service has varied across the
country, with some processing continuing in local social security
offices. The implications of the decision to phase 10 of the new
centres out over the next 18 months are discussed in Section 7.
1.5 The Pension Service recognised that
some older people would be unable to do business with them by
telephone, and established a local service to run drop-in surgeries
and conduct home visits. Local service has no caller offices and
customers can only gain access to local service through the pension
centre that serves that area. It appears to be variable whether
Jobcentre Plus offices are prepared to offer pensioners any practical
assistance with their benefitsfor example, the provision
of forms, use of the telephone to contact the pension centre,
and document verification. We consider that Jobcentre Plus offices
should be geared up to provide assistance to pensioners who approach
them, and we suggest that the Pension Service and Jobcentre Plus
should develop and publicise a protocol to achieve this.
1.6 From its inception, the Pension Service
has had a policy of working with "Partners" at national
and local levelsthat is with local authorities and any
other organisations that work with or involve older people. Citizens
Advice is a National Partner, and individual Citizens Advice Bureaux
are local partners. We welcome the concept of partnership, but
have been disappointed in some aspects of its implementation.
1.7 To the extent that the Pension Service
has consulted and involved partners in making its plans and carrying
them through, we welcome this as a valuable new approach. We have
valued our involvement in the group Partnerships Against Poverty,
England and Wales, and its Pension Credit Subgroup. But we believe
these groups could have been much more valuable if DWP and the
Pension Service had been willing to share and discuss proposals
at a much earlier and more formative stage.
1.8 For example, all the national organisations
participating in the Partnerships Against Poverty Pension Credit
Subgroup pointed out that the Pension Service needed to initiate
local face-to-face take-up work, in addition to the direct mail
and mass media promotion, in order to get claims from harder to
reach groups, but it took a long time for this advice to be accepted.
Sometimes it has felt as if the key decisions have already been
made, and partners are being consulted only about the detail,
or worse simply informed of decisions that have been made already.
We consider that the Pension Service still has some way to go
to operate the partnership in the reciprocal manner that is the
essence of real partnership.
1.9 The operation of the partnership approach
at local level is discussed in section 6.
1.10 The introduction of Pension Credit
has involved a great deal of work for Citizens Advice Bureauxexplaining
how the complex rules affect an individual's eligibility, helping
people to claim, sorting out problems with claims that have been
made and incorrect awards, explaining obscure award letters, and
taking urgent action on behalf of people who have been left penniless
when their income support has stopped without warning at the age
of 60. Bureaux have sent in well over a thousand reports of issues
that have arisen for their clients. In the remaining sections
of this document, we set out the experiences of CAB clients with
Pension Credit and suggest improvements in policy and practice
that we consider that DWP and the Pension Service should make.
2. POLICY ISSUES
2.1 In Citizens Advice's response to the
Pensions Green Paper, we expressed concern about the long-term
viability of the government's policies for financial support for
low-income pensioners. [84]Broadly
this policy is that the basic state pension will increase by 2.5%
a year, or price inflation, whichever is the higher, and the Pension
Credit guarantee level will increase by the percentage increase
in earnings. People will be able to enhance their state pension
through the State Second Pension, and also be encouraged to make
their own provision through occupational and private pensions.
2.2 The effect of this approach, on the
Government's own figures is that the proportion of pensioner households
that will qualify for means tested Pension Credit will increase
from the current 50% to 65% by 2050. Our experience is that most
pensioners consider that their State Retirement Pension should
provide an adequate basic income for their retirement, and they
should not have to submit to a means test in order to have enough
to live on.
2.3 In his speech on Reforming the Welfare
State on 11 October 2004, the Prime Minister indicated that the
Government would bring forward proposals for pension reform in
the light of the final report of the Pensions commission under
Adair Turner, and would seek consensus as far as possible. We
welcome this approach. We hope that the Government will work towards
raising the level of the Basic State Pension to that of the Pension
Credit Guarantee Credit and up-rating in line with earnings thereafter.
We also consider that the National Insurance contribution requirements
for State Retirement Pension should be greatly simplified so that
most people will qualify for the full pension, and that the practicalities
of a citizen's pension should be fully examined. There should
also be an enhanced pension for disabled pensioners and pension-age
carers.
This approach would be:
seen as fair by most people,
make it easier for people to plan
how to save for their retirement because they will have more clarity
about the retirement income they will have from the state,
avoid the problem of under claiming
that causes means tested benefits to fail to reach many of the
poorest people, and
be much cheaper to administer than
Pension Credit.
2.4 The resource implications of this approach
will need to be addressed through the tax system, for example
by reducing tax concessions surrounding pension contributions
for wealthier people, re-examining the contracted-out rebate and
reviewing the tax treatment of wealthier pensioners. The recent
Pensions Policy Institute paper suggests that these radical changes
that are manageable and affordable. [85]
2.5 For the immediate future, Pension Credit
will continue to exist. We welcome:
the extra money that Pension Credit
is putting into the pockets of less well-off pensioners;
the removal of the savings limit
and the reduction of the tariff income on savings that applied
to Minimum Income Guarantee; and
the introduction of longer Assessed
Income Periods, and the requirement for local authority housing/council
tax benefit departments to use the Pension Credit assessment of
means rather than submit pensioners to a further means test.
There are, however, a number of policy problems
that we consider that the Government should address.
2.6 It is unfair that people who do not
receive a full basic State Pension get no benefit, or less benefit
than those with full basic State Pension, from any other savings
or income that they have. The calculation of the savings credit
should be amended so that people with less than the basic State
Pension should get the same amount of savings credit as they would
if they were getting full basic State Pension.
2.7 The different qualification ages for
the guarantee and savings credits add to the complexity of an
already over-complex benefit. Women in their early 60s who are
living alone and have supplemented their basic State Pension consider
the non-availability of the savings credit to be unfair. It is
also a disincentive to their doing some part-time work.
A client of a bureau in Staffordshire had been
receiving incapacity benefit when she reached 60, and moved on
to State Retirement Pension. She had an occupational pension that
made her income too high for the guarantee credit, but if she
were over 65 she would have been entitled to receive savings credit.
A man in similar circumstances would retain his IB to age 65 and
then qualify for savings credit at the same time as receiving
his State Retirement Pension.
We consider that the savings credit should become
payable at 60.
2.8 The relaxation of the tariff income
for savings is welcome, but the rate of £2 per week for each
£1,000 of savings above £6,000 still represents over
10% per annum, more than double the income that the pensioner
is actually likely to be receiving. Pensioners resent this, especially
as this income has been re-titled "assumed income" which
they consider dishonest. They point out that no financially literate
person would make such an assumption.
A client of a bureau in Derbyshire had savings
valued at £38,949 and his Pension Credit calculation showed
an assumed income of £66 per week. The client felt this was
very unfair as the actual interest he received (and which had
been notified to the Pension Service) was far less.
The Government should reduce the assumed income
on capital to a rate that reflects the income that is actually
likely to be obtained. If it is not prepared to do this, and considers
that pensioners with savings over £6,000 should have to run
these savings down, it should revert to the old description of
"tariff income".
2.9 The differential passporting arrangements
from guarantee credit and savings credit are inconsistent and
confusing.
guarantee credit passports to full
remission of all health charges, but savings credit recipients
must submit themselves to the means test of the NHS low-income
scheme. But the generally more restrictive Social Fund allows
applications from all Pension Credit recipients. We consider that
all Pension Credit recipients should be exempt from health charges.
guarantee credit recipients are automatically
entitled to full Housing Benefit and Council Tax Benefit, regardless
of their savings, but people who are only getting savings credit
are excluded if their savings exceed £16,000. This results
in a cliff-edge, so that a small change of circumstances could
lead to the loss of all housing benefit and council tax benefit.
We consider that all Pension Credit recipients should be eligible
for housing benefit and council tax benefit, subject to the usual
income calculations but not the capital limit.
2.10 The longer assessed income period,
during which Pension Credit recipients do not have to report changes
in circumstances, is welcome. However, cases are being reported
to us of pensioners who lose their Pension Credit because they
go on a holiday abroad that lasts for more than four weeks. To
reinstate their Pension Credit they have to go through the full
application process again. For example:
A client of a bureau in Norfolk illustrates the
problems clients face if they go abroad for over four weeks. The
family of a 76 year old client paid for her to visit them abroad,
and as she would be away for six weeks she was obliged to inform
the pension service. She was worried to hear that she would lose
two weeks of Pension Credit and was especially concerned about
the effect this would have on her other benefits.
The policy fails to recognise that it is quite
usual for a pensioner with family abroad to go for an extended
holiday visit to see them. It is likely to be a particular problem
for pensioners from ethnic minorities, who are more likely to
have family abroad. We consider that Pension Credit should remain
payable in full during a 13 week absence abroad, and should only
be suspended rather than cancelled, provided the pensioner returns
to live in the UK within one year.
2.11 Pensioners who are local authority
sponsored residents in care homes are amongst the poorest people
in society, having only £18.10 a week personal expenses allowance.
Those who receive savings credit are also allowed to keep whatever
they get, up to a maximum of £4.65. Any additional savings
credit up to the single person maximum of £15.51 is clawed
back for the care home fees. This is contrary to the intention
of Pension Credit, to reward people for saving for their retirement,
and we consider that all savings credit should be disregarded
when assessing contributions to care home fees.
2.12 In one respect the arrangements for
Minimum Income Guarantee were better than those for Pension Credit.
Recipients of Income Support moved automatically to Minimum Income
Guarantee on their 60th birthday, receiving more money each week
but not having to make a new claim. All people receiving Minimum
Income Guarantee when Pension Credit was introduced in October
2003 were moved automatically to Pension Credit. But anyone on
IS who has reached the age of 60 since then will only get Pension
Credit if they apply for it. This is a step backwards, and we
consider that all recipients of Income Support should be automatically
transferred to Pension Credit when they reach the age of 60.
2.13 A number of inconsistencies apply to
the new arrangements:
2.13.1 Notional capital. Regulation 21
deals with notional capital. It has already been changed in April
2004 to remove ambiguity, but there are still problems, particularly
around Regulation 21(2). For example, it is unclear how disposal
of capital by partners of claimants will be treated.
2.13.2 Notional income. If someone chooses
to defer their state pension, the pension they would have received
counts as notional income for Pension Credit. This is a disincentive
to deferment.
2.13.3 One of a couple in a care home.
People in permanent care who wish to pay occupational pension
to their spouse cannot contribute more than 50% of the occupational
pension. It is not clear how this income has to be treated in
calculating the Pension Credit of the spouse at home. If it is
treated as maintenance, it counts for guarantee credit but is
ignored for savings creditwhich is disadvantageous to the
spouse at home. Couples in this situation usually have additional
costs, for example for visiting the spouse in the care home, and
would benefit if the 50% of occupational pension was ignored for
assessing the Pension Credit of the partner at home.
2.13.4 Temporary care/Hospital. Couples
where one is temporarily in care lose their severe disability
premium of Pension Credit when the DLA/AA stops after 28 days,
but this does not happen when one of a couple is in an NHS hospital.
The difference is unfair.
2.13.5 Permanent care/Sheltered accommodation.
If a person moves into permanent residential care, the AIP ends,
and any equity from a house sale is counted as capital for the
next AIP. This does not happen if someone goes into permanent
sheltered accommodation. This is unfair on those going into residential
care.
2.13.6 Pension Credit and Tax Credits.
WTC is ignored for savings credit, which, for most people reduces
the incentive to work. There may be a small number of people who
benefit from the current rule but we consider that DWP should
consider changing the current rules.
2.13.7 Pension Credit and housing benefit/council
tax benefit. There has been considerable convergence between Pension
Credit and housing benefit/council tax benefit for those aged
60 and over, but there are still differences. For example, in
lone parent working disregards, and the treatment of maintenance.
We consider that all the inconsistencies should be removed.
2.13.8 Pension Credit and housing benefit/council
tax benefit. Some people aged 65+ have extra housing benefit/council
tax benefit because of the up-rating of housing benefit/council
tax benefit applicable amounts when Pension Credit was introduced.
Some who would only receive savings credit feel that it is not
worth the bother of applying, because 85% of their savings credit
award will be clawed back from housing benefit/council tax benefit.
This means lack of access to passported benefits from Pension
Credit, such as the social fund.
2.13.9 AIP Requirements. The respective
AIP systems run by Pension Credit and housing benefit/council
tax benefit are a mess. For example, in a savings credit only
case, a person does not have to tell Pension Credit if their capital
exceeds £16,000, but does need to tell the local authority,
even though an AIP exists from the local authority. This is very
confusing, especially since the Pension Service and local authorities
are supposed to be sharing information (as the housing benefit/council
tax benefit Pension Credit Guide stresses). There is a lesson
to be learned from the Tax Credits fiasco, that making complex
reporting requirements is a recipe for disaster. Simple and consistent
requirements for reporting changes of circumstances during an
AIP need to be put in place.
2.13.10 Overpayments. The position on
overpayments arising from the failure of the Pension Service to
report facts to the local authority is unclear. We consider that
they should always be non-recoverable, so that people do not face
demands to repay housing benefit or pay back payments of council
tax when the Pension Service has failed to inform the local authority
of a revised Pension Credit assessment that reduces the person's
housing benefit/council tax benefit entitlement.
2.13.11 When a couple separate. If a
couple receiving Pension Credit separate, and one continues to
live in their jointly owned home, the other may claim Pension
Credit. The value of the property should be disregarded for six
months from the date s/he left the property as this was due to
relationship breakdown. Additionally, if the Pension Credit claimant
is taking "reasonable steps" to dispose of the property,
its value can be disregarded for as long as it is considered reasonable
to do so. If s/he's taking no steps to dispose of the property,
then half of its capital value will be taken into account for
means tested benefits. This is likely to leave the partner who
has moved out with insufficient income to live and unable to pay
rent and council tax.
3. TAKE UP
3.1 We very much welcome the commitment
of the Pension Service to try to maximise take-up of Pension Credit,
and the introduction of take-up targets, which are a desirable
innovation in social security practice. However, we believe that
the targets, which envisage take-up reaching 75%, are unduly modest.
They do not appear to be higher than the take-up levels of MIG
which the Government found unsatisfactory (see paragraph 1.1 above).
We do not find it acceptable that, by 2008, over a million eligible
households, around 1.3 million pensioners should not be receiving
Pension Credit. DWP and some local authorities now have sophisticated
data matching capabilities to identify people who are claiming,
for example, housing benefit and/or council tax benefit but not
Pension Credit. Some local authorities have run systematic take-up
campaigns using data that they hold, and have achieved high take-up
rates. For example, Tameside Council have achieved guarantee credit
take-up above 91%. We consider that the Government should be seeking
take-up of Pension Credit of at least 90% or higher.
3.2 Initially, the Pension Service adopted
a cautious approach to the promotion of Pension Credit, concentrating
on transferring people on Minimum Income Guarantee in the period
before Pension Credit came into being on 6 October 2003. Some
1.8 million households were transferred automatically. Mostly
this operation went smoothly, with few people not receiving their
first payment of Pension Credit on time. There were, however,
three areas of difficulty:
Many people found the notification
letters incomprehensible and were worried that they would get
less money, when in fact they were going to get the same or more.
Pension Credit is not paid for dependent
children, and the 27,000 Minimum Income Guarantee recipients who
had dependent children were also automatically transferred to
Child Tax Credit in October 2003. This was poorly communicated.
As a consequence people were getting letters that appeared to
show huge reductions in their incomeover £100 a week
for bigger families. Many of these people consulted Citizens Advice
Bureaux and we had the impression that a disproportionate number
of people from ethnic minorities were affected.
Many local authority sponsored residents
in care homes received an addition to their Minimum Income Guarantee
in the form of the Residential Allowance of £65.50 a week.
They did not see any of this money as it was fully transferred
as part of their contribution to the care home fees. With the
introduction of Pension Credit the Residential Allowance was abolished,
and the money paid directly to local authorities. Again the change
was poorly communicated. Both by DWP to customers and by many
local authorities to care home owners. As a consequence many care
home residents were unnecessarily worried that they would no longer
be able to afford their contribution to care home fees, with some
fearing that they would be evicted. Many of these people and their
relatives consulted Citizens Advice Bureaux about their worries.
3.3 At the start of 2003, about 1.8 million
households were receiving Minimum Income Guarantee. A further
two million households were reckoned to be eligible for Pension
Credit. The Pension Service sought to manage the take up of these
extra households by phasing publicity for Pension Credit so that
it did not get swamped with more claims than it could process.
A major part of the Pension Service's take-up effort was to write
to every pensioner household to inform them about Pension Credit
and invite them to apply if they thought that they might qualify.
The letters were phased over the period from April 2003 to June
2004, with less than 20% being sent out in advance of the introduction
of Pension Credit. All awards for applications made before 5 October
2004 will be backdated to 6 October 2003 or the date the person
qualified, if later.
3.4 It is very welcome that DWP has published
monthly take-up figures for Pension Credit. Unfortunately however,
the figures themselves are not all easy to interpret since they
are a mixture of activity figures (calls to claim-line, applications
returned to the Pension Service) and to-date totals (household
and persons receiving Pension Credit, average award). This is
illustrated by the following table:
Month | Total Applications Returned (monthly
applications)(thousands, totals rounded)
| Households Receiving (monthly addition)(thousands, totals rounded)
|
October 2003 | 370 | 1970 (82)
|
November | 490 (120) | 2060 (90)
|
December | 590 (100) | 2120 (60)
|
January 2004 | 700 (110) |
2180 (62) |
February | 840 (140) | 2260 (83)
|
March | 1030 (190) | 2400 (138)
|
April | 1130 (100) | 2450 (44)
|
May | 1230 (100) | 2500 (51)
|
June | 1320 (90) | 2550 (52)
|
July | 1400 (80) | 2580 (33)
|
August | 1450 (50) | 2610 (25)
|
| | |
3.5 The figures in the first column indicate the workload
for pensions centres in processing Pension Credit applications,
with the February and March figures presumably reflecting a push
by the Pension Service to meet the target of 2.4 million households
receiving Pension Credit by the end of March. The figures in the
second column are less easy to interpret, as they are net figures
of awards made minus households leaving Pension Credit (presumably
mainly through death). In our view it would be preferable for
DWP to publish the number of new Pension Credit awards made every
month and the number of awards ending.
3.6 The total number of households receiving Pension
Credit is disappointing. 3.75 million households are estimated
to be eligible, so that 1.14 million eligible households (1.68
million pensioners) were not receiving their entitlement at the
end of August 2004. The number of households being added each
month is in decline, with only 25,000 added in August 2004. The
numbers of eligible households is set to increase by 350,000 to
4.10 million over the next three years, [86]so
that a net 10,000 households need to be added each month just
to keep up with the newly eligible. It is clear that large numbers
of eligible pensioners have not been persuaded to apply for Pension
Credit by the Government's direct mail campaign.
3.7 Belatedly the Pension Service has recognised that
much more focused work is required to attract applications from
many of the pensioners who are entitled to Pension Credit. We
welcome the establishment of the Partnership Fund to provide financial
support for local take up work by voluntary agencies and local
authorities. [87]We also
hope that the introduction of Joint Teams of local authority and
the Pension Service staff will increase take-up of Pension Credit,
and also attendance allowance, housing benefit and council tax
benefit by older people. Work by the Pension Service to use its
databases to identify people who are likely to be eligible for
Pension Credit, to send them further material about Pension Credit
and, in some cases to visit them, has the potential to be valuable.
3.8 Citizens Advice Bureaux have a long history of encouraging
people to take up benefits to which they are entitled. The Citizens
Advice research report "CAB campaigns for benefit take-up
among older people" (December 2002) drew together the experience
of over 100 bureaux in carrying out targeted benefit take up campaigns
with older people. Successful targeting involves advisers going
to places where older people live or gather regularly, such as
pensioner groups, sheltered housing and GP surgeries. Targeting
is often most successful when it involves face-to-face contact
to help overcome the perceived stigma of claiming. The average
benefit gain from these campaigns was £85 for every £1
spent.
3.9 We consider that DWP should fund research to show
what interventions with potential Pension Credit recipients are
most cost effective. This research will need to identify the characteristics
of the pensioners who are not applying, so that take-up strategies
can be devised for these "hard to reach" people. We
are concerned that the capability of local Pension Service staff
to promote take-up will be adversely affected by the proposed
staff cuts at the Pension Servicesee Sections 6 and 7.
4. THE CLAIMING
PROCESS
4.1 The Initial Claim
4.1.1 Citizens Advice has already documented the poor
performance of telephone services in the delivery of services.
[88]This report details
some of the reservations we have about the use of telephone based
services for the delivery of Pension Credit. DWP has decided that
telephone claiming for Pension Credit is its preferred method
and has retained Ventura to provide a free application line. We
welcome the extended hours offered and provision of this as a
free serviceunlike calls to pension centres that are charged
at local rates, which can prove very expensive. Along with other
organisations, we have been concerned that some of the staff taking
claims are inadequately trained. Key areas of concern are:
Poor knowledge of Pension Credit premiums,
leading to applicants being told that they do not qualify for
Pension Credit because their income is too high, when in fact
they do qualify.
A bureau in Lincolnshire reported that the telephone
operator who dealt with their client's claim had no understanding
of the Severe Disability Premium. The client had not received
the money, two months after it was due, and an adviser had to
spend 15 minutes explaining the entitlement to the call centre
operator who had no idea how it worked.
Poor knowledge of the rules for savings credit,
with applicants whose income qualifies them for savings credit
by virtue of their income being told that they do not qualify
because they have insufficient savings.
A client of a bureau in Surrey was told on the
phone that she would not qualify for savings credit because her
savings are less than £6,000. But she does qualify because
of her incomeshe would have missed out on £7 a week
if she had followed the advice from the Pension Service.
Poor understanding of the different effects
that guarantee and savings credits have on the capital limit for
claiming housing benefit/council tax benefit, resulting in poor
advice.
A bureau in the Midlands was concerned that
the claim line agent insisted that a couple with savings of over
£40,000, who qualified for savings credit, but not guarantee
credit would be able to get Council Tax Benefit. In fact they
do not qualify because their savings are more than £16,000.
Staff who appear not to have been trained
to quickly identify applicants who are struggling with the telephone
claims process, so that they can offer them an alternative means
of applying.
This lack of knowledge has caused many clients to experience
difficulties in getting the money to which they are entitled.
4.1.2 The Pension Service says that the average claim
call only takes 20 minutes. We find this surprising, given the
large amount of information that the applicant must supply, especially
with respect to savings. Citizens Advice Bureaux that have made
claims for clients have often found the process straightforward,
but there are also reports of claim calls taking one hour or more.
Many frail older people would find such a long call a great strain.
4.1.3 Using the telephone is obviously not a feasible
way to claim Pension Credit for those who are hard of hearing.
Whilst a textphone number is provided, not all older people will
be able to use this either.
The clients of a bureau in Surrey both had hearing difficulties
and could not use a text phone. They had tried to submit an application
for Pension Credit over the phone but had given up as they found
that "the girl spoke too fast". With the help of the
bureau they made a successful claim, but would have been unable
to do this on their own.
4.1.4 Once a telephone claim has been made, the applicant
is sent a completed claim form to check and sign. Problems at
this stage include:
Incorrectly completed forms, including in
cases where advisers have made the claim and are certain that
correct information was supplied.
Long delays in forms being sent out, or no
form being sent out at all.
4.1.5 No written claims were allowed before Pension Credit
started in October 2003, which caused frustration to people who
wished to apply early but were unable or unwilling to claim by
phone. Citizens Advice Bureaux were not able to obtain claim forms
during this period, although this would have been helpful in assisting
some clients. For a number of months after October 2003, some
Citizens Advice Bureaux reported continuing difficulties in obtaining
paper claim forms. These difficulties have now been sorted out.
4.2 Submission of Financial Documents to Pension Centres
4.2.1 Applicants have to sign a claim form whether this
has been generated by a telephone claim, or as a written claim
by the applicant or an adviser. They must then submit the signed
form to the pension centre that deals with their area. The Pension
Service ask applicants to submit a whole range of original documents
concerning income and savings to support the claim. Many people
are understandably reluctant to do this, as they fear, with some
justification, that the documents may be lost at the pension centre
or in the post. People are also reluctant to part with items such
as passbooks, even for a short time, because they will be unable
to access any money without the passbook.
A client of a bureau in Devon visited the bureau after making
an application for Pension Credit. She had been asked to forward
financial information, including savings books, to the pension
service. The client was worried about how safe this would be but
was unaware that she could have visited her local Jobcentre to
have these processedhad she not visited the bureau she
may not have proceeded with her claim.
This is likely to be an increasing problem as the move towards
the direct payment of benefits into bank accounts is completed
early in 2005. These problems are likely to be a major reason
why large numbers of pensioners fail to return telephone completed
claim forms even though they appear to be eligible for Pension
Credit. DWP has not published information on the numbers involved.
It would be helpful if DWP did so, and also set out what action
is being taken to help these pensioners complete the application
process.
4.2.2 In order to meet its take-up targets, the Pension
Service does offer alternative document verification procedures,
but it only tells people about them if they object to sending
valuable documents through the post. A statement that we received
from the Pension Service about verification is reproduced in the
Annex. We find the Pension Service's current policy and practice
on document verification is obscure and unhelpful. We consider
that there should be simple and accessible local document verification
arrangements available to all pensioners, and that these procedures
should be open and clearly publicised.
4.2.3 The CAB service is keen to assist clients who have
concerns about document verification. We have agreed that bureaux
will not be required to act as agents for the Pension Service,
and will not verify the legality and authenticity of documents.
However, they will continue to certify copies of documents and
will gather the appropriate information about the client necessary
to make the claim.
4.3 Assessing the Award
4.3.1 At pension centres, the details from the claim form
have to be input to a computer system to calculate if the applicant
qualifies for Pension Credit, and if so to calculate the award.
This process has thrown up a lot of problems:
Claims classified as dormant or closed when
they are not.
Delays of weeks or sometimes months, and advisers
told by pension centre staff that they have huge backlogs and
several weeks of unopened mail.
Long delays when the pension centre requires
additional information or documents from the applicant.
Incorrect entry of financial details leading
to incorrect awards.
Difficulty for clients and Citizens Advice
Bureaux in finding out why a claim is delayed. Initially pension
centres were often engaged. This is unusual now, but Citizens
Advice Bureaux often find that a simple enquiry involves a lot
of holding on the phone, and can take up to 20 minutes.
The Pension Service told a client of a London bureau early
in 2004 that he did not qualify for Pension Credit. When the bureau
followed this up, Glasgow pension centre said that the claim was
still open but they were awaiting proof of the date of birth of
the client's wife. The client had sent the information twice by
registered post. Two months later the claim had still not been
processed. Glasgow admitted that they could not locate the file,
and said that they would arrange a home visit to complete another
claim. This was only arranged when the bureau chased up two weeks
later. Ten days after the visit the client received acknowledgement
of his application, but he then received another set of claim
forms. Glasgow told the bureau that the client would have to complete
the third application as they could not locate the set of forms
completed at the visit. This meant that this man was still without
pension credit more than four months after his initial application,
and he and his wife are forced to live on a small occupational
pension and DLA, as he is not yet old enough to receive the state
pension.
4.4 The Award Letter
4.4.1 People should not receive letters that are so poorly
drafted and presented that they find the contents worrying and
have to bring them to Citizens Advice Bureaux for an explanation.
Yet many recipients of the Pension Credit award letter, generated
by the DWP's "legacy" computer system, find the letters
incomprehensible, confusing or just plain wrong. Common problems
are:
An inconsistent approach to informing the
client of their total income from DWP after the Pension Credit
award. Some letters simply show how much Pension Credit they will
get, leaving the recipient worried that their State Retirement
Pension has stopped. Other letters show the total of pension and
pension credit payments.
Internal inconsistencies, with the letter
and calculation sheet showing different amounts.
More than one award letter sent out on the
same day presenting information differently.
Clearly incorrect references to payments going
back to the 19th century, for example"from 22 January
1811 you will get £163,168.66 a week."
A bureau in the South West reported that their client, who
they described as "very numerate" was left unsure of
how much Pension Credit she would get after receiving an award
letter. The client felt that phrases such as "we reward 60
pence of the pound of the qualifying income" were unclear
and that less jargon should be used if the letter was to be comprehensible
to claimants.
4.4.2. We have drawn these problems to the attention of
DWP, and some of the problems have been addressed, but we are
very concerned that DWP appears to give low priority to ensuring
that these important letters are as well presented and comprehensible
as possible.
4.5 Urgent Claims
4.5.1 It is regrettable that the old arrangement whereby
Income Support recipients transferred automatically to Minimum
Income Guarantee at the age of 60, no longer applies for Pension
Credit. These benefit recipients, whose circumstances Jobcentre
Plus is fully informed about, are obliged to claim Pension Credit
from the Pension Service in order to continue to receive any income.
This is a nonsense and we consider that an automatic flow through
from IS (and when appropriate JSA and Incapacity Benefit) should
be instituted.
4.5.2 The DWP foresaw that the current arrangements
have the potential to cause client hardship and instituted a procedure
for Jobcentre Plus to alert benefit recipients approaching their
60th birthday that they need to claim Pension Credit. In a number
of places this procedure has not worked well. Citizens Advice
Bureaux report clients in many parts of the country who have had
their IS stopped when they reach 60 without receiving any advice
to apply for Pension Credit. Most simply received a letter from
Jobcentre Plus to say that their IS had stopped or would stop
next week, with no reference to applying for Pension Credit. Some
just discovered that there was no new order book when they went
to collect it at the post office. In some cases this meant that
disability benefits that were on the same order book also stopped
being paid, leaving the client in severe financial hardship because
of the incompetence of DWP.
A bureau in the North East reports the extreme hardship that
a disabled couple suffered. Mr P is in his late 60s and receiving
State Retirement Pension and DLA. Mrs P is in her 40s and, prior
to the introduction of Pension Credit in October 2003, she was
claiming IS for both of them and receiving DLA on the same order
book. When Mrs P went to get a new order book at the beginning
of October, she found that the post office did not have one. Jobcentre
Plus said that Mr P had to apply to the Pension Service for Pension
Credit for both of them. He did so quickly but the Pension Service
failed to make regular payments and the couple's income fell by
£115 a week. The bureau had great difficulty sorting the
correct payments out because they had to deal with three delivery
arms of DWP, none of which was keen to accept ownership of the
couple's benefit problems.
A client of a bureau in Surrey had been in receipt of income
support and disability living allowance, which were paid together.
When she reached her 60th birthday her DLA stopped along with
her IS. There was a delay in processing her Pension Credit claim,
and due to this and other administrative errors there was a three-month
delay between her income support ending and the client receiving
all the benefit to which she was entitled.
4.5.3 In response to this situation the Pension Service
has instituted a fast track procedure for people with an urgent
need for Pension Credit payments. This aims to get Pension Credit
into payment within about three weeks, rather than two months
or more for a normal claim. This will still leave some people
who have been let down by Jobcentre Plus forced to seek a crisis
loan from the social fund.
4.6 Correcting Awards
4.6.1 When a Pension Credit award is incorrect, Citizens
Advice Bureaux find that this can involve a need for lengthy phone
calls to the relevant pension centre and substantial delay for
clients in receiving a correct award.
A disabled widower who receives Attendance Allowance, Housing
Benefit and Council Tax Benefit, in addition to Pension Credit
consulted a Kent bureau. His pension credit award had not taken
account of a private pension of £116 per month. This was
pointed out to Liverpool pension centre, who then put in a figure
of £355.12 per week as his private pension. They then informed
him that he no longer qualified for pension credit and his housing
and council tax benefits stopped as a consequence. The bureau
is seeking to get the error corrected but was concerned to be
told that the client's file has now been sent to Wolverhampton
pension centre as part of the reorganisation of the Pension Service
to deliver the staffing cuts.
4.6.2 Citizens Advice Bureaux have seen a number of
overpayments of Pension Credit caused by errors by the Pension
Service. Such overpayments are not recoverable, but many older
people find the situation of receiving money that they are not
entitled to extremely worrying and are concerned that they will
get into trouble if they have spent this money.
A bureau in the South West reports that a woman who had been
receiving her State Retirement Pension paid into her bank, started
to receive further payments of Pension Credit plus State Retirement
Pension. By the time she realised the mistake she had been overpaid
by over £1,000. She was very perplexed about what to do when
the Pension Service told her that it was "up to her conscience"
whether to repay this.
A man in Wales was upset when deductions of £8.10 a week
were made from his benefits for an alleged overpayment, and was
then bemused to receive a giro for £324 from the Pension
Service for an underpayment while the deductions were still being
made.
4.7 The Pension Service has done much to make claiming
Pension Credit as simple as possible. The free telephone claim-line
is convenient for many applicants, and in many places the willingness
of the local staff of the Pension Service to make home visits
is helpful for people who cannot use the phone. But, inevitably
with an elderly customer group, there will continue to be significant
numbers of people who need an alternative to the phone when dealing
with the Pension Service. We would like to see telephone staff
at Ventura and the Pension Service much better trained to spot
clients who are having difficulty with a telephone claim or enquiry,
so that these people can be offered an alternative service.
4.8 It is also essential that staff who deal with the
public are equipped to give accurate advice about all aspects
of Pension Credit, including issues such as premiums, and the
treatment of savings. The Pension Service attempts to monitor
the accuracy of Pension Credit awards, and reports accuracy levels
of over 93%. We are concerned that the checking systems may not
identify all mistakes as we continue to deal with significant
numbers of clients with incorrect Pension Credit awards. We suggest
that the Pension Service seeks an independent audit of its arrangements
for checking the accuracy of Pension Credit awards.
5. DIRECT PAYMENTS
5.1 The introduction of direct payments of benefits into
bank accounts as order books are phased out on a timetable that
overlaps with the introduction of Pension Credit has subjected
both the Pension Service and its clients to stresses that it would
have been better to avoid. Many pensioners are happy to have their
state retirement pension and Pension Credit paid into a bank account.
There are also a substantial number who like the order-book system
because it allows them to collect cash at their local post office.
Pensioners who find it difficult to get to the post office often
rely on someone else to collect the money for him or her. Those
who live alone may have to rely on a paid carer, who may not be
the same person from week to week, to collect their money. For
example:
A CAB in Yorkshire reported that a client who had contacted
her local Pension Service office about continuing to be paid by
order book had been told that there was no option but to be paid
by direct payment. The client currently had home-helps from Social
Services to collect her pension and get her shopping every week,
but there was no guarantee that she would get the same person
twice, so a second card on a card account would not be suitable
for her. When the CAB phoned, the Pension Service agreed she could
continue with her book for the present, if she wrote in to request
it.
5.2 Many older people find it difficult to understand
why the order book system, with which they are familiar, is being
abandoned. Those without suitable bank accounts for direct payments
may resent having to set up an account at such a late stage in
life, and will need to have time taken with them to explain the
pros and cons of their banking options, and of the post office
card account. They may find having to make these changes worrying
and stressful:
A CAB in Sussex reported that a woman in her 80s sought advice
about the letters she had received from the Pensions Service about
direct payment. She told the CAB that she wanted to continue with
her order book, and not have to change. Occasionally the client
needed someone else to go to the Post Office to cash her state
pension for her.
5.3 The process for opening an account, especially the
Post Office card account seems complicated to many people, adding
to the stress of the situation.
A CAB in Cumbria reported that an elderly couple, both of
whom were disabled, both needed to open a Post Office card account
with a second card so that either could withdraw cash on behalf
of the other. The clients were worried about being able to remember
two PINs, and were concerned that joint Post Office card accounts
were not possible. The husband came to the CAB for help phoning
the Conversion Centre to set up his card account. The Conversion
Centre insisted that he give security details before they could
speak to the CAB. However, the client found it difficult to hear
them due to deafness, and the stress caused him to have an asthma
attack.
5.4 For some older people the problems are more acute.
People with sight, dexterity or memory problems will find it difficult
to key in a PIN number to get their money at the post office or
from a cash machine.
5.5 The DWP has always acknowledged that there needs
to be an alternative method of payment for those who genuinely
cannot open or cope with any sort of account and for urgent payments
of benefits which cannot wait to go through the bank clearing
system. They delayed working on the details for some time to concentrate
on the implementation of direct payment itself, and, in any case,
the payment system would not need to be in place until October
2004 when the last order book will be printed. The DWP also wanted
to use the time to consult groups working directly with benefit
claimants so that their views could be taken into account in the
design of the service.
5.6 The DWP has never intended that the alternative method
of payment would be a payment option for all claimants, and so
initially omitted any mention of it in their direct payment leaflets.
As a result, advisers reported a large number of vulnerable and
disabled clients worried about how they would cope with direct
payment. Following representations from Citizens Advice and others,
DWP has changed the text of the leaflet to encourage those who
cannot cope with any kind of account to ring the Conversion Centre.
5.7 Following consultation with consumer and welfare
groups, the DWP has recently announced the details of cheque payment.
They have concluded that cheques will provide the flexibility
needed, particularly for third party encashment. Cheques will
be issued to the claimant at the same frequency as they used to
receive their order book or giro payments. They have also announced
that there will be no formal application process for cheque payment.
5.8 However, a purely cheque-based system will disadvantage
those housebound benefit claimants who needed third parties, such
as neighbours or home-helps, to collect their benefit for them.
There is no guarantee that the cheque would arrive on the same
day of the week and the third party might not be available to
collect the money if the cheque was late one week. Several consumer
groups, including Citizens Advice, have called on the DWP to continue
to offer order books, or make advance cheque payments to those
people who need their benefit to be collected by third parties.
The DWP has rejected these suggestions as costly and have expressed
concerns about security.
5.9 It is welcome that the DWP has clarified that all
those who have not provided account details by April 2005 will
be automatically transferred to cheque payment. However, the DWP
have also pointed out that they want to restrict access to the
cheque payment system only to those who genuinely need it.
5.10 It remains to be seen how cheque payment works out
in practice. There will need to be rapid and straightforward arrangements
to enable clients to obtain money urgently if the cheque fails
to arrive, for example because of postal delays, or because the
cheque has been intercepted and stolen. There will also need to
be contingency plans for the eventuality of postal strikes.
6. LOCALLY BASED
SERVICES
6.1 Staff of the local pension service have a vital role
in promoting the take-up of Pension Credit, through:
Working with local partner organisations in voluntary
and community agencies and local authorities.
Carrying out face-to-face work to promote an awareness
of Pension Credit, and to facilitate take-up.
Carrying out home visits to take claims from people
who cannot claim by telephone.
6.2 Most local service staff appear to have been energised
and motivated by the positive focus of their work. They find it
fulfilling to help older people to obtain all the benefits and
services to which they are entitled. This is a very positive development.
6.3 We have received reports that some local pension
service staff are not fully conversant with all the issues on
which they are expected to advise. For example, that an older
disabled person must have care needs in order to qualify for attendance
allowance. We suggest that the Pension Service should review the
training that these staff receive.
6.4 Local service was in the vanguard in establishing
relationships with local partner organisations such as Citizens
Advice Bureaux. As far as we are aware, these staff received no
training in what partnership involves, or how to work constructively
and sensitively with other agencies with important values and
agendas of their own. Consequently they got off to a mixed start
as far as their relationships with Citizens Advice Bureaux were
concerned. Some initiated a constructive relationship from the
start, but others came across as rigid and overbearingtaking
the line"you are now partners of the pension service
and this is what you must do". Local relations now appear
to be mostly good, and the CAB service is pleased to have signed
a Partnership Accord with the Pension Service. This is underpinned
by a "Code of practice for Citizens Advice Bureaux and The
Pension Service" (October 2004).
6.5 As part of the staff reduction programme in DWP,
the local pension service is being reorganised into a smaller
number of clusters. There have been rumours that this will involve
staff reductions of 10-15% in the local service. In view of the
huge job that remains to be done to increase take-up of Pension
Credit, especially amongst harder to reach pensioners, we consider
that any cutbacks in the local service would be a breach of faith.
6.6 DWP has recently informed the Partners Against Poverty
England and Wales group about the way in which it is reviewing
local pension service activity. This will include a critical look
at surgery sessions. It is disappointing that these plans were
not discussed with national partner organisations at an earlier
stage. We have been assured that decisions to close particular
local surgery sessions will not be taken before there has been
consultation with local partners.
7. DWP STAFF CUTS
7.1 Citizens Advice is very concerned that the planned
staff cuts at the Pension Service will have an adverse effect
on take-up of Pension Credit and on the standard of service provided
to pensioners on all their benefits. [89]At
the end of June, the then Secretary of State announced that 10
pension centres would be transferred to non-pension work or closed,
as part of DWP's programme to cut 30,000 jobs by 2008. He suggested
that this reduction could be achieved because the bulk of the
work of introducing Pension Credit had been completed.
7.2 This is not, in our view, a correct analysis of the
position. At the time of the announcement, 1.2 million pensioner
households who are eligible for Pension Credit were not receiving
it. This shows that there is still a great deal more for the Pension
Service to do in promoting take-up of Pension Credit. Also, we
believe that there are significant numbers of incorrect awards
that need to be corrected, and delays in the systemfor
both State Retirement Pension and Pension Credit also need to
be addressed. We are concerned that the further reorganisation
to which the Pension Service will be subjected is likely to lead
to a repeat of the problems when pension centres were first set
upinexperienced and poorly trained staff, confusion about
where a particular client's work is being done, and a loss of
papers as they are sent around the country. We consider that the
Pension Service should consult stakeholders on its reorganisation
plans and then publicise those plans when they have been agreed.
7.3 The local pension service has a vital role to play
in encouraging take up of Pension Credit and other benefits to
which older people are entitled. The service can do this both
through face to face work with pensioners at surgeries and at
home visits, and through developing local partnerships with local
authorities and voluntary agencies such as Citizens Advice Bureaux.
It is clear that, as take-up work moves to harder to reach pensioners,
targeted local work based on local knowledge and face-to-face
activities will become increasingly important.
7.4 In our view it is essential that the capacity of
the local pension service to contribute to this work is maintained
and enhanced. Any move to reduce the number of staff working in
the local service will call into question the government's undertaking
that the civil service cuts will not affect front-line services.
We consider that DWP needs to give an undertaking not to cut the
local pension service.
84
"A Firm Foundation for Retirement", Citizens Advice,
March 2003. Back
85
State Pension Reform: Managing the Transition, Pensions Policy
Institute, September 2004. Back
86
Reply to Parliamentary Question, 14 June 2004. Back
87
DWP Touchbase Magazine, March 2004. Back
88
Hanging on the Telephone, Citizens Advice, September 2004. Back
89
Citizens Advice Press Release 29 June 2004. Back
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