Supplementary memorandum submitted by
UnumProvident following the publication of the Welfare Reform
Green Paper
UnumProvident is the UKs leading provider of
group income protection insurance, with over 30 years of experience.
Our customers benefit from our expertise in the specialist areas
of disability, rehabilitation and return-to-work. We enable individuals
to protect their incomes, ensuring their financial security if
they are unable to work because of illness or injury. For employers,
we safeguard one of their most valuable resources by helping employees
return to work following long-term absence. At the end of 2004,
UnumProvident protected over 2.1 million lives through more than
19,800 schemes. During 2004 we paid total benefit claims of over
£249 million—of which more than £177 million related
to income protection claims.
We are active in several key areas of interest
to the Committee as follows:
THE ROUTE
ONTO BENEFITS—THE
ROLE OF
THE GP
In 2004 Professor Mansel Aylward was appointed
to be the first director of the UnumProvident Centre for Psychosocial
and Disability Research at Cardiff University. A current work
strand of the centre involves GP education as to the role of the
clinician as the gatekeeper to IB. This looks at piloting improvements
in the competency, training and engagement process of GPs with
incapacitated patients who want to return to work. When published,
this research will be made available to members of the Committee.
EMPLOYERS AND
THE HEALTHY
WORKPLACE
A key partner organisation for UnumProvident
is the Employers' Forum on Disability (EFD). We supported EFDs
Global Inclusion Benchmark which surveyed the inclusion of disability
in companies' social reporting and worked alongside other members
in the development and piloting of a UK Disability benchmark.
UnumProvident is a sponsor of the Healthy Workplaces category
at the BITC Annual awards for excellence and was supported in
this by the Department of Health and it was run in association
with the Health and Safety Executive. We are also founder members
of a new BITC Leadership Team on Healthy Workplaces which seek
to address this important aspect of the corporate responsibility
agenda. We would be happy to share with the committee the lessons
from these initiatives.
PARTNERSHIPS
Our commitment to the wider world of disability
and employment is shown by our prime mover support for "Beginnings".
Beginnings is a coalition of the private sector, employer and
employee organisations and groups of and for disabled people,
who believe that placing and then keeping disabled people in productive
employment will provide them with fulfilment and self-esteem,
as well as economic independence.
Each year Beginnings holds an annual event.
Our 2006 event will be chaired by Beginnings' patron Baroness
Sally Greengross and will be held on 16 March. Confirmed speakers
include: Rt Hon John Hutton MP, Secretary of State for Work and
Pensions Lord Kirkwood, former chair of the Commons Work and Pensions
Select Committee.
In concept with RNID we developed a second Workplace
of the Future stand which was successfully showcased at all
three party conferences. We continue to work with RNID to ensure
modern workplaces are made accessible for disabled people. These
are just some examples of areas where commercial regulations,
in concert with the voluntary sctor, can make a real difference.
WELFARE REFORM:
MEETING THE
CHALLENGE
1. UnumProvident is pleased that the Incapacity
Benefit (IB) system is being considered for reform, for indeed
it was at our 2005 Beginnings event that the Green Paper was proposed.
Like many other groups, we are pleased with the overall content
of the Paper and will work with the Government to ensure the stated
goals are achieved.
2. Together with our partners we have consistently
called for measures to be considered which would make a real difference
to peoples life and employment choices including:
— Early intervention is critical
for enduring Return to Work success.
— GPs require training in the
therapeutic benefits of work.
— Revision of the "sicknote"
process.
— Prevention is also important—creating
healthy workplaces and retaining sick and disabled people in the
jobs they already have.
— Encouraging employers and Government
to focus on ability not disability.
— Extending Pathways to Work and
providing better quality rehabilitation capacity.
— Making the system flexible for
those with mental illness and intermittent conditions.
And we were therefore very pleased to see that
the Green Paper, amongst other measures called for:
— Minimum wait for personal capacity
assessments.
— New training for healthcare
professionals at all stages in work and "all the health benefits
this brings".
— Consideration given to pilots
of new sick note pads and Statutory Sick Pay reform—payable
from day one.
— Investors in People Healthy
Organisation standard by 2007.
— Benefits not to be given on
the basis of a certain disability or illness but on capacity assessment.
— National roll-out of Pathways
to Work (2008) and national helpline for SMEs.
— Tiered re-named benefit and
more generous linking rules—and a recognition that more
work needs to be done.
— Employment and Support Allowance.
BENEFIT NAME
3. We endorse the name of the benefit being
changed to the Employment and Support Allowance. We have
long argued for this change as it sets the tone for how the benefit
is perceived.
PATHWAYS TO
WORK—BUILDING
THE REQUIRED
CAPACITY
4. The Pathways to Work pilots have shown
very promising results on the basis of the first assessment. They
have comprehensively shown that it is possible for many claimants
of IB to get jobs with the right help and support, and that early
intervention with rehabilitation support is highly effective.
We therefore warmly welcome the £360 million investment in
a national roll-out for this proven route back into work.
5. However, we are concerned about the ability
for these new schemes to be delivered. While the Government has
noted that it will be supporting greater private sector involvement,
particularly in the extension of Pathways, we are nonetheless
concerned that this will not generate sufficient further capacity
in terms of support and intervention—which will take some
time to build. This is a wider concern in the medium-term as the
Government looks to offer more help to existing claimants, to
achieve its one million in a decade target.
6. Our extended experience in this field
has shown us that the correct model to apply when helping people
to return to work is a bio-psychosocial one. This incorporates
elements of helping the individual deal with any sickness/illness
(bio), motivating them and providing them with the necessary support/advice/information
to get back into employment (psycho), and fully understand the
social setting of their disability/lack of capacity (social),
which can incorporate wider pressures upon them (eg childcare)
and employer perceptions of certain conditions.
7. Vocational Rehabilitation professionals
are required to undertake this work and we are pleased that the
Government has understood and applied this in their development
of back to work services (notably through Pathways). We are, however,
very concerned that the capacity for such staff will not be available
for further initiatives/roll-outs mentioned in the Green Paper,
and nor are the qualifications and infrastructure to deliver such
further capacity. A highly respected research report has noted
that:
"The current picture, therefore, is one
of a mosaic of standards, drawn from a variety of sources with
no major cohesion or critical mass for one or more sets of standards
covering the whole field (of Vocational Rehabilitation)."[39]
8. As a private provider, UnumProvident
has been working on solutions to this capacity dilemma—which
will affect both sectors. In 2005 when we acquired the UK licence
for potential solution for this. A programme has been developed
by a non-profit organisation in Canada, known as the National
Institute of Disability Management and Research (NIDMAR), and
consists of Disability Management (DM) Audit Training and DM certification
programmes.
9. The former will provide valuable information
to employers that will enable them to more capably manage their
sickness absence policies and processes. The training programme
consists of 26 stand-alone modules, which together provide comprehensive
education in the DM field for clinical and other support staff
eg Nursing, OT and Physio. We are in discussion with a number
of accreditation bodies to introduce this process into the UK
and thereby seek to improve the cadre of vocational rehab procedures.
We will keep the Committee informed of this progress.
EARLY INTERVENTION
10. We noted in our first submission that
UnumProvident's own rehabilitation model has been highly successful
due to its focus on early intervention and employer engagement—before
the employee's contact with them has been lost and social networks
cut. Certainly we see the employer as crucial to our success,
and any successful programme that helps employees back to work
must also positively engage with the employer. The Government
should consider this interaction as much as is possible; beyond
the city-focused strategies.
SMES AND
ACCESS TO
WORK
11. We welcome the recognition in the Workplace
Health Connect initiative that employers, particulary small employers,
need support when hiring disabled staff and to be more involved
in job retention so that people can remain or return to their
work when recovering from illness or adapting to a disability.
Employers also have a key role to play in reducing the impact
of stress and other mental health conditions in the workplace;
the biggest growing claim on both public and insured benefit systems.
12. However greater employer engagement
may well see corresponding further pressure being placed upon
Access to Work (AtW) funds. We welcome the additional investment
made thus far by Government, but would note that this will need
to be increased if employer involvement is to make a meaningful
contribution. It is claimed that £1 million spent on AtW
quite quickly brings £1.7 million back into the Treasury.
If this case can be proven, we would ask that the Treasury hypothecates
any money saved and re-invests this in the scheme—ie payment
by results. We would also note that reform should be considered
to allow disabled people to apply for AtW—gaining a guarantee
of support—before they accept a job offer, as this can otherwise
lead to weeks of inactivity for the employee and employer as equipment
is ordered and installed.
"FLUCTUATING
CONDITIONS"
13. From a medical persepctive we welcome
the Government's reference to the fact that "fluctuating
conditions", particularly these with a mental health element,
need to be accommodated within the system—and their admission
that more work is needed to achieve this.
14. Through Beginnings we have also recognised
this and have set up a "Intermittent Capacity" Taskforce
to further look into the issue.
15. Most conditions can be described in
someway as intermittent. Equally each employee can be said to
have intermittent capacity to work for a variety of reasons. This
is an important step in thinking to make in this area. Is someone
with an intermittent condition, say stress, which can inhibit
work, any different from a parent with intermittent childcare
issues ie when they fall ill and have to spend time off school?
16. The benefit system will never be flexible
enough to accommodate every nature of intermittent conditions.
This should not lead to inaction or reform, but should help us
recognise that, in the same way many employers treat parents,
our focus should be on helping employers understand what is reasonable
and fair. To this end the Intermittent Capacity Taskforce within
Beginnings is working on establishing the principles for advice
to employers on this issue. This will be available soon and can
be made available to the Committee.
THE ROLE
OF GPS
AND "SICKNOTES"
17. We welcome the Government's commitment
to pilot the provision of employment advisers in GP surgeries.
One-off examples have been very positive, provided GP surgeries
are given some incentive to provide this extra service.
18. We equally welcome the Government's
recognition that sicknotes may need to be reformed. On PCAs we
will be moving from a system of judging what someone cannot do
to what they can. This should equally be applied to sicknotes.
19. Sicknotes are currently too black and
white—for example someone may have a bad back, which would
qualify them for a sicknote, but that does not inhibit them from
many of the functions of their job as an office worker. Employees
and employers treat sicknotes as being sacred—and therefore
do not want to disobey them for fear of harming themselves or
an employee. Equally, GPs may be concerned that they are liable
if they do not provide a sicknote for someone who is sick, but
can nonetheless work.
20. We would therefore suggest the trialling
of a "Functional Restrictions Pad" instead. This could
be modelled on the PCA, and would highlight the activities that
the individual can do without harming themselves or others. The
individual, the GP and the employer could then make an active
decision about whether the person could return to their specific
role or work generally in some capacity. It must be remembered
that most people ending up on IB are off-work for what they expect
to be a short period of time—where possible this should
be avoided and GPs should highlight the therapeutic nature of
work.
THE ROLE
OF EMPLOYERS
21. It is known paradox that despite the
vast advances in medical treatments in the later half of the 20th
century that there is a huge increase in people who are considered
too ill to work. This rise in incapacity has taken place from
the 1980s onwards and is seen in all developed countries. It cannot
be easily explained in medical terms. Clearly the increase in
illness is a complex social and psychological problem and definitely
not imaginary. The biopsychosocial model of disability not only
explains this part of this phenomenon, but also suggest how best
to manage it.
22. Managers need to understand that very
few illnesses actually cause complete incapacity and that waiting
until a member of staff is fully recovered from an illness or
injury can be the very worst thing they can do. Similarly, appearing
to question the reasons behind an absence can be very counterproductive
and unnecessarily confrontational. Adopting an enabling approach
seeking to overcome barriers to work is very much more effective.
23. A common question asked by employers
of occupational physicians is whether an illness is covered by
the Disability Discrimination Act. In many cases at the early
stages of an absence the answer is "no" because the
anticipated duration of illness is short. However, doing nothing
and leaving people sitting at home can lead to illnesses becoming
worse and complicated by depression. Treating all sick employees
as potentially disabled and making adjustments where possible
not only protects against liability under the Act, but can actually
prevent disability.
24. At UnumProvident we have a non-medical,
enabling model of rehabilitation and we are working with our partners
at the UnumProvident Centre for Psychosocial and Disability Research
at Cardiff University to better understand what places people
at risk of long-term or chronic illness. Further information about
this model can be made available to the committee.
39 Bysshe, S et al 2002, "Employment and
Disability Functions in the UK: An occupational and functional
review", HOST policy research. Back
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