Supplementary memorandum submitted by
Alan Tyler after the publication of the Welfare Reform Green Paper
The proposals in the green paper
provide a sound way forward for the reform of Incapacity Benefit
and the services that accompany it.
Faith in the reformed PCA procedure
will be important if claimants are to be engaged effectively by
the new benefit proposals.
There will be concerns over
whether sufficient resources will be available to roll out Pathways
to Work nationally by 2008.
More attention needs to be paid
to how other parties such as employers and insurers can be engaged.
Long term proposals for integrating
Disability Living Allowance are unclear.
How a satisfactory evidence
base and a standards and accreditation system for service providers
will be delivered is unclear.
1. Much of the green paper's content is
praiseworthy and will gain support across the wide spectrum of
organisations involved in the reform programme:
Proposals for the new Employment
and Support Allowance are a sensible balance of rights and responsibilities,
benefit payments and services, conditional on the participation
of the claimant. Extended linking rules and greater scope for
voluntary and part-time work will provide further encouragement
for claimants to engage in work related activity and reductions
in benefit for non-compliance with action plans is a sensible
The decision to "encourage"
participation from existing IB claimants, thereby enabling them
to gain access to a higher level of benefit, is a sensible one
and can be reviewed at a later date as the effectiveness of the
new proposals and the accompanying change in culture that this
hopes to generate can be measured.
Confirmation that Pathways to
Work will be nationwide by 2008 with the full involvement of the
private and voluntary sectors is welcome.
Simplification of Statutory
Sick Pay rules will be welcomed by employers.
Rule changes for JobSeeker's
Allowance to address the flow onto Incapacity Benefit are also
Changes to Housing Benefit and
city initiatives targeting disadvantaged groups are consistent
with the IB proposals and the long term aim of a simplified benefit
system accessed via a single gateway is praiseworthy.
2. The success of these new proposals will
rely heavily on:
The effectiveness of the new
PCA test in accurately assessing claimants' work capabilities.
Whether the PCA can be delivered
within the 12 week period envisaged.
Whether the necessary resources
are in place to provide return to work services nationwide by
To what extent other interested
parties can be engaged (see point 5 below).
3. In my earlier submission I made the point
that much momentum with these reforms had been lost since early
2005 due to wholesale changes to the ministerial and departmental
teams at the Department for Work and Pensions and there appears
nothing substantial in these proposals that were not in place
a year ago.
4. Bearing in mind the long term aim for
a simple benefit system accessed via a single gateway, it is perhaps
disappointing that the other major sickness related benefit assessing
people's support needs, Disability Living Allowance, has not been
tackled at the same time. I can understand that to do so might
have resulted in further delay and that progress on IB and other
benefits could be viewed as a reasonable first stage but some
indication of the government's intentions to bring DLA into a
more co-ordinated benefit structure would be beneficial.
5. The successful implementation of these
proposals will depend heavily on the co-operation of other parties
and require both the "top down" support of representative
bodies and "bottom up" initiatives at grass roots level
in order to effect change and identify "champions" who
can lead and exemplify that change:
The October 2004 publication
"A UK Framework for Vocational Rehabilitation" set out
proposals for a Steering Group to enable stakeholders to contribute
but it is not clear whether this is still proposed and how this
level of engagement will be achieved.
Whilst proposals for both "top
down" and "bottom up" approaches are evident for
health professionals, this is less obvious for other groups with
an important role to play, such as employers and insurers.
Employers will welcome better
information on absence management and some of the benefit changes
proposed but may need more than that to become fully engaged.
The insurance focus remains
stubbornly on Employers' Liability Insurance but this covers only
injuries and diseases sustained as a result of a person's work.
These relate to only a small percentage of workplace sickness
absence as opposed to the common health conditions that result
in the great majority of IB and other insurance claims. A wider
range of insurance providers needs to be engaged (including Group
Income Protection and Group Medical Insurance writers) and indeed,
it may be a good opportunity to re-think private insurance propositions
against the background of public sector reform.
6. The publication "A UK Framework
for Vocational Rehabilitation" also proposed Working Groups
responsible for Research (in order to establish a firm evidence
base for the services being offered) and Standards and Accreditation
(so that successful service providers could readily be recognised
by employers, insurers and patient groups). Both these factors
are important and it is not clear where these proposals now lie.
Health and Welfare Business Consultant