Supplementary memorandum submitted by
A4e after the publication of the Welfare Reform Green Paper
A4e welcomes this opportunity to further contribute
to the evolving policy for Incapacity Benefit Reform following
the publication of the Welfare Reform Green Paper.
The response takes the form of comments relating
to key points in the green paper and is limited to issues that
relate to IB Reform and A4e's areas of expertise.
Over the last year we have provided training
and employment services to over 6,000 disabled clients and helped
almost 3,200 clients back into work. A4e has built considerable
expertise in delivering client-centred provision through our delivery
of over 260 welfare to work related contracts on behalf of DWP
and Jobcentre Plus, across 90 delivery centres from Edinburgh
to Exeter. Our philosophy is that work provides opportunities
for personal and professional development, and that it is a partnership
between individual, employer and Government that leads to success.
Over the last three years we have been specifically
researching and piloting approaches through our existing programmes
to develop an effective delivery methodology for working with
this particular client group. This has been a deliberate strategic
approach, pre-empting the trend in unemployment decline and in
anticipation of the emerging requirements of the economically
inactive. This includes developing expert provision through our
Jobcentre Plus LOT, BET and SIBS contracts to specifically target
this client cohort. In addition we are also working closely with
other Government departments and local authorities to ensure that
we link provision to associated reforms in the marketplace, Local
Enterprise Grant Initiatives and Direct Payment for Social Care,
that impact on our client's lives.
On the basis of our experience and principles,
A4e would welcome the opportunity to meet with you to share more
in depth views and dialogue on the IB reform agenda, and to continue
to actively contribue to this consultation agenda, building from
our established experience in this arena. We strongly believe
that the IB programme must not be viewed in isolation but must
be part of a coherent programme that links welfare to work, enterprise
creation and workforce development. As such, we pride ourselves
in effectively working across all these areas.
There is undoubtedly a need to dispel the myth
that people in receipt of incapacity-related benefits are incapable
of working. The proposed new benefit structure will go a long
way to signal that whilst a person's usual employment may no longer
be an option, this does not mean that work is no longer an option.
Additionally, the proposed benefit system will introduce a process
of regular contact between the maority of claimants and Jobcentre
Plus and supporting organisationssomething that is only
currently available on a limited basis in PtW pilot areas through
mandatory work-focused interviews.
However, statistics show that the flow of new
claimants onto IB is significantly slowing downit is the
cohort of stock claimants that is the problem, particularly those
who have been on IB for two years plus. Maybe it is for legal
reasons that stock claimants will remain on their current benefit
until a benefit break arises, but it is disappointing to see that
this radical and much needed reform will not directly impact on
the main problem area.
Paragraphs 109 and 110 of the green paper state
that the proposal is to work more proactively with existing customers
and claims that since February 2005 PtW pilots have been extended
to require "some" existing claimants to take part in
three work-focused interviews. However, these statements are very
vague and the implication is that no clear and consistent method
of establishing regular contact with existing claimants has been
Communication is probably the most important
method by which IB claimant numbers will be reduced. There is
still a significant lack of information getting through to existing
IB claimants about the positive psychological, social and financial
benefits to be gained through economic activity and the advice
and support mechanisms that are there to help them. People must
be given the positive message directly, rather than receiving
fragmented and emotion sound bites from the media or by work of
mouth. It is vital that JCP and the private and voluntary sectors
work closely together to get a clear message to existing claimants.
One of A4es specialised programmes that was
suffering poor IB claimant take-up, despite this cohort representing
60% of the total people claiming benefit in the area. JCP locally
claimed that they rarely had contact with IB claimants and that
we needed to contact people direct. We agreed and asked for contact
details of IB claimants in the areathe list was withheld
for procedural reasons.
It is excellent to see that the proposed PCA
will focus on assessing people's capability for work rather than
a numerical points system that triggers benefit entitlement.
Additionally, A4e supports the proposal that
the exempt group will not be based on the specific condition,
but rather on how that condition impacts on individual functionality.
In paragraph 22 of the green paper, blind people are used as an
example. Our concern would be aimed at how rigid the system of
determining individual capability for work will beie is
it reasonable to follow the same process and assessment criteria
as for those with less severe conditions? People with severe health
conditions and disabilities have extra factors that must be taken
into consideration. For example, time is a crucial factora
person with a recently acquired condition will have a vastly different
level of capability for work to that of a person who has had the
same condition for a long period of time.
This needs to be carefully thought through if
we are to avoid seriously disadvantaging individuals and creating
significant opportunity for negative publicity.
The green paper states that PCAs will be more
regular to ensure that people with improving work-related capability
will be more easily identified. This regularity must be standardised
if the current irregular and subjective re-assessment process
is to be avoided. Steps must be taken to promote PCA review as
a positive step towards independent economic activity and to avoid
the perception that is a punitive measure, as it is widely regarded
at the moment.
A4e welcomes the proposal that future PtW provision
will be delivered primarily by the private and voluntary sector
and supports the notion of payment by results. This recognises
the expertise of the sector and the wider scope of support and
time commitment that can be offered to clients.
Future provision needs to be mapped in terms
of revised JCP Districts to avoid post-code lottery eligibility
for advice, support and incentives. There is currently some confusion
over the geographical parameters of some earlier announced pilot
areas and the re-shaped JCP Districts, both of which may clash
at the next pilot phase due to commence in April 2006clarity
is required for all concerned.
4. LINKING RULES
Extension of the 52-Week Linking Rule will go
a long way to help people take the leap of faith necessary to
go from benefit into work. However, this will only be advantageous
if it is effectively communicated to claimants.
The main problem with the current system is
that it is only known to a minority of clamants and eligibility
is based on a relatively onerous but essential registration requirement.
The proposal to make registration automatic will resolve the eligibility
issue, but to gain client confidence, it will still need to be
confirmed in writing that the client is covered under the rule,
providing that there has been no material change in their condition
and that this is confirmed by an appropriate medical certificate.
In the same way that future PtW programmes are
expected to be delivered by the private and voluntary sector,
the proposed pilot initiative to have an Employment Advisor (EA)
presence in GP surgeries would also benefit from the expertise
and network capability of the sector.
Pilots should be geographically diverse and
appropriately fundedie provision should not be restricted
to areas where ESF funding can be secured. Additionally, as this
will initially be a pilot initiative, it is important to try out
different delivery models, rather than a "one size fits all"
It is essential that EAs are seen as "honest
brokers" and that they provide impartial information, advice
and guidance in-line with the matrix standard. Additionally, the
facility should not exclude people who are already in employment
but need access to advice and support to help them stay in work.
This is a very important proposal as it has
the potential to impact on employees, people on JSA and other
benefits, SSP volumes, workplace occupational health, IB claimants,
in fact anyone and anything that can benefit from a synergy of
medical and employment expertise.
6. IMPROVED IN-WORK
It is increasingly coming to A4es attention
that in-work support for people with emerging or developing health
conditions and disabilitis is significantly lacking under current
arrangements. It is our experience that most employers are initially
supportive when such conditions emerge, but many quickly become
less supportive as the condition develops to the extent they would
need to make alterations or adjustments, temporary or otherwise,
to keep the person in employment.
As office-based employee of a local ambulance
service was diagnosed as having MShe is fortunate to be
living in an area where ground-breaking drugs are made readily
available to patients, so his symptoms are mostly controlled,
although he has relapses when he is quickly fatigued to the extent
of being incapacitated, but after 30 minutes rest he is re-charged.
His employer was initially very supportive but more recently,
as they became more "uncomfortable" with his condition
and how it appeared to other employees, become less supportive
and, in fact, pressured him into virtual retirement due to ill
health. A few minor adjustments could have made it possible for
the employee to continue to work for the foreseeable future, but
the easier opition was for the employee to move onto benefit and
the employer to recruit a new member of staff.
The employee received no support and is now
on IBhis psychological and physical condition is rapidly
A4e would fully support initiatives that provide
in-work and back-to-work support for employees. Again, private
and voluntary sector expertise would come into its own in this
area of advice and support.
7. TEST TRADING
Proposals to make Test Trading an option for
people in receipt of ESA in order to help business start-up will
be a significant step forward. All existing NDDP clients will
be in receipt of IB or equivalent benefits up to the expected
end date of the programme in March 2007. This means that should
a successor programme be agreed, claimants will continue on the
same benefit up to and potentially after 2008. It is, therefore,
essential that legislation preventing current claimants from working
(self-employed or otherwise) beyond 16 hours a week, without having
to leave their benefit, is amended to allow Test Trading to be
8. HOUSING BENEFIT
A simplified, uniform approach to calculation
of Housing and Council Tax benefits is essential. People in receipt
of such benefit need an accurate calculation regarding how moving
into work, part-time or full-time, will affect (if at all) their
benefits. Because the calculations and waivers etc differ according
to various local authority areas, it is very difficult for JCP
or NDDP Job Brokers to give an accurate indication of how these
benefits will be affected. Fear of losing Housing and Council
Tax benefit is ome of the key reasons quoted for not accepting
full-time and part-time jobsand this is from people who
have already taken the proactive and voluntary step of registering
with a NDDP Job Broker.
As social housing rent rates tend to be more
stable and less diverse than the private rented sector, a more
simplified system should be considered.
A4e supports the proposal to generally make
benefit payments to the claimant rather than to the landlord or
local authority. This will have a clean impact on accommodation
choice and will promote financial responsibility. However, provision
must be made to ensure that people who are less able to be financially
responsible are given support or, as a last resort, payments are
again made direct to the landlordaspirations of financial
responsibility and inclusion must not be allowed to lead to homelessness.
Although childcare is mentioned under the section
of the green paper that deals with single parents, it must be
noted that child and other care responsibilities are currently
rating highly in reasons not to work. Because many people on IB
have been considered as "always available to provide care",
"pick the kids up from school", etc, they have often
become a usual suspect to the extent that a new, strong barrier
to work has emerged.
Stable, appropriately-financed, professional
and readily available care facilities must be available for those
cases with genuine need. Additionally, people may need to be educated
away from the "you can always rely on Uncle Fred" syndromemaybe
another area where private and voluntary expertise could come
to the fore.