Supplementary memorandum submitted by
the Disability Employment Coalition after the publication of the
Welfare Reform Green Paper
DEC is chiefly concerned with the opportunities
for disabled people in the world of work and whilst we monitor
developments in the benefits system to ensure that this does not
work against the civil rights of disabled people or more specifically
the opportunities to access the world of work, we will mostly
leave specialist commentary about proposed benefit changes to
other organisations such as the Disability Benefits Consortium.
Our comments therefore primarily focus on the
opportunities for people with disabilities and people with significant
illness to access and retain work and employment.
We have been very disappointed that the "easy
read" version of the Green Paper still has not been produced
at the date of writing (15 February 2006) some three weeks or
so after the publication of the Green Paper in regular format.
Braille format has been produced but considerably after the initial
True inclusivity can only be achieved if all
accessible formats are seen as having equal priority and not an
afterthought and we would hope Government truly embraces this
concept for all future developments.
DEC welcomes the Government's declared commitment
to achieve greater equality for disabled people in the world of
work as this is entirely in line with our own Statement of Intent
published in 2005.
Some of our members have set their own objectives
for achieving equality for disabled people in the world of work
and these include international objectives as detailed in as RI's
"Included@Work" global campaign.
In this respect the Government's declared intentions
to achieve equality of treatment for people with disabilities
and significant illness is not only welcome in the green paper
but must be maintained in the eventual White Paper and any ensuing
legislation to ensure that this is the overriding objective of
all actions taken
DEC does have concerns on practical level about
the quality and spread of service provision that support disabled
people access the world of work.
The green paper is short on detail on the ways
in which greater access to the world of work will be developed
and there is considerable concern that there is sufficient competence
and ability amongst people providing services to those individuals
who want to work.
We would expect the Government to set out quality
standards for Service Providers which include direct feed back
from those individuals who have been provided with services. Quality
systems such as the European Quality in Rehabilitation Mark
(EQRM) are already in existence and are inclusively orientated
to ensure those in receipt of services have a direct say on how
they feel the system has worked or is working for them.
DEC also has concerns that the Green Paper places
some emphasis on the future provision of services by commercial
and presumably profit making organisations rather than "not
for profit" organisations. Any move to promote "for
profit" providers into service provision may, we believe,
place the emphasis on quantity and not on quality.
We do not believe that the ability to be innovative
belongs only to "for profit" organisations and we would
emphasise that most "not for profit" organisations with
specialist knowledge areas will provide a greater understanding
of the client centred approach needed to achieve sustained success
in this area.
Government should not extend or introduce services
in this area without also establishing regular feed back sessions
from stakeholder groups and we propose specifically a six monthly
review with nominated stakeholders in the field of employment
provision and an Annual conference involving Government departments/agencies;
service providers and organisations representing service users
to review how systems and processes are working and establish
a philosophy of continuous improvement.
It is important that any legislation and/or
reform to service provision are inclusive; client centred and
includes a requirement for quality standards which reflect an
individual's human rights.
DEC is worried that the Green Paper starts from
a precept that accepts that some people can work and others cannot
We believe that to be a very dangerous assumption
and likely to lead to discrimination and exclusion based on traditional
preconceptions and in built prejudices.
All future systems and processes should assume
that any person who wants to work can work and that no line is
used which creates a "them and us" situation which by
its very nature will create barriers to opportunity.
We are also concerned that there may be still
view that the only way to measure whether someone can or cannot
work is to apply a model of medical assessments and appraisals.
We know from the perspectives of both service users and service
providers that the person best placed to know whether or not they
can work is the individual themselves.
The system for accessing the world of work should
not seek to tell disabled people they can or cannot experience
the independence of the world of work; instead it needs to be
designed to accommodate all aspirations toward greater independence.
This reform process provides a unique opportunity
for Government to remove any arbitrary lines and start assuming
that every person is capable of becoming involved in the world
of work with appropriate support and personal development.
Many DEC members will have already expressed
their concerns that some people have very complex needs which
require additional support but never the less want to be included
in the world of work just like everyone else.
We believe that everyone is capable of individual
development and that if an individual wants to work society should
do all it can to support that individual in achieving their personal
We are not convinced currently that the provision
of services or the structure of processes such as Pathways to
Work are sufficiently robust or flexible enough to support individuals
for example with learning disabilities who want to work. Areas
such as this need to be addressed otherwise individuals with more
complex needs will be pushed to the back of any system and only
the easier to place and deal with will receive priority attention.
These comments apply to all groups where society
and employers currently have greater difficulty in understanding
and accommodating disability at work.
It is important that in any long term changes
to enable more disabled people to access work Government build
in processes that ensure that all groups of people with disabilities
have equal opportunities to work and employment and that the system
is not slanted or geared only to those who are easier to accommodate.
DEC has previously written jointly with the
TUC to the Chancellor of the Exchequer calling for any new approach
to be properly funded.
We see the current reform process as a tremendous
and perhaps one off opportunity for Government to demonstrate
that they are truly investing in the welfare to work philosophy
with the aim of achieving social and economic equality for disabled
We strongly believe that this is a win: win
opportunity for Government where more people with disabilities
and significant illnesses access work and employment with all
the social and economic inclusion implications that has whilst
at the same time reducing Government long term benefit costs as
equality is achieved.
Government should be realistic in the amount
it invests in service provision to ensure that they provide good
quality services for all groups of clients. Investment at too
low a level or spread too thinly will drive a quantative and not
a qualitative service which will in turn lead to the exclusion
of many who want to work but who will need more support and advice.
We also believe that the government is in danger
of writing off all other programmes in favour of the Pathways
to Work approach. We believe this to be wrong and would urge that
existing programmes such as Workstep and Welfare to Work should
be retained in a properly co-ordinated approach to accessing the
labour market in all its forms. In this respect performance data
for Welfare to Work achievements should be published and openly
debated before any final conclusions are reached.
Where Pathways to Work is extended and sits
alongside other programmes it is absolutely essential that it
is properly invested and resourced.
DEC particularly believes that the significant
expansion of Access to Work is vital in any future developments
and we would refer the Committee to the document "Access
to Work for disabled people", developed and published by
the Coalition in September 2004 which shows that for every £1.00
invested in Access to Work £1.48 is recouped in tax and NI
contributions by the Treasury.
The more investment there is in all the above
the quicker the return there will be for Government and the sooner
Government will hit its labour Market inclusion targets. In this
respect we wonder why it is that Government will wait until 2008
before triggering many of the changes required to achieve full
It is important that Government start from this
philosophy of investment in disabled people and achieving equality
of opportunities rather than seeing benefits and systems for accessing
work merely as "cost" areas.
Achieving equality of opportunities for disabled
people will require even more changes in society than has so far
DEC acknowledges and welcomes the statistics
in the Green paper which show that the number of people with disabilities
in work has been increasing in recent years.
However there is much more to do and a key feature
of continued change required to enable full equality of opportunity
to be achieved is to achieve changes in the labour market and
particularly amongst employers.
DEC has made it clear that we believe that there
should be changes in two specific legislative areas which would
assist disabled people and people with significant illnesses to
We believe that Government should act to introduce
legislation that requires employers to provide disability or rehabilitation
leave when an individual faces significant changes in their life
brought about by developing disabilities or significant illness
whilst in employment. In doing this Government should emphasise
to employers that this is not an additional burden on employers
but a sensible mechanism to enable employers to retain employees
through proper support processes.
We also believe that the Employment Tribunals
should have the ability to increase penalties on employers who
discriminate against employees who become disabled whilst in work.
Tribunals should be given stronger powers for reinstatement in
these circumstances to counter employers taking easy decisions
to avoid making sensible decisions to ensure people who have a
disability stay in work.
Additionally more work needs to be done to educate
employers about employing and retaining people with disabilities
in work and Government needs to actively and consistently promote
the abilities of disabled people in public campaigns through developing
provider/employer partnerships but also through the support systems
they sponsor or provide.
More work also needs to be undertaken to highlight
to employers how much more they can do particularly in conjunction
with the health sector to ensure that individuals who become disabled
at work can return to work as quickly as possible. This is a multiple
win: win which would positively affect government spending; employer's
costs; national productivity and individual satisfaction.
All of this needs to be considered in the context
of changes occurring in the labour market where because of pressures
on Pension Schemes and Government Pension provisions people are
being expected to work until they are older. This change will
introduce disability much more into Companies and organisations
as an aging workforce will also mean more people with age related
In pressing forward with the reform process
Government needs to actively support processes and legislation
which change attitudes in the employer sector particularly highlighting
the economic benefit of employing disabled people.
As mentioned earlier DEC does not see itself
as the main commentator of benefit reform but we feel we cannot
provide comments without being critical of the comments about
benefit fraud in the Green Paper. We have been entirely consistent
in pointing out that the level of benefit fraud by Disabled People
on Incapacity Benefit is miniscule and in making a bigger issue
of this Government are creating a negative picture amongst employers
and the general public who we all wish to educate about the abilities
of disabled people. This is neither helpful nor accurate.
We also have a view that individuals should
not be forced in to seeking work. The Pathways to Work pilots
haves shown that many disabled people want to get back to, or
enter, the world of work without the threat of compulsion hanging
Government also needs to consider the position
of employers in this process as they will not be keen to employ
people who are looking for work because they are forced to rather
than those who seriously want to work. Compulsion may lead to
individuals returning to work grudgingly and in the process staying
in work for a limited period and not entering a sustained period
DEC welcomes all processes,
systems and philosophies that will enable more people with disabilities
and significant illness to access the world of work or who want
to stay in work.
We are worried about the quality
and prevalence of services which will be provided and we are worried
that the involvement of "for profit" organisations may
lead to services that are not centred on individuals.
We are keen that Government
uses this reform process as an opportunity to seriously invest
in all aspects of ensuring disabled people access the world of
work or retain employment.
We would want Government to
avoid any dogmatic positioning over the type of services provided
and instead ensure that all services are geared to each individual's
disabilities, circumstances and aspirations.
We are keen that Government
establishes ways to work with employers to change attitudes in
the Labour market and to support legislative changes which remove
barriers to employment for disabled people.
We would not support compulsion
in the benefit reform process.
We would expect the process
of reform to be primarily based on achieving full equality of
opportunity for all disabled people in the world of work.
Ray Fletcher OBE
ChairDisability Employment Coalition
16 February 2006