Memorandum submitted by the Revolving
Doors Agency after the publication of the Welfare Reform Green
1. Revolving Doors Agency is an independent,
award-winning charity with over 10 years' experience of developing,
testing and promoting innovative ways of working with people caught
up in the damaging cycle of crisis, crime and mental illness.
All of our clients have mental health problems and have been arrested
or imprisoned, but most also present with a wide range of problems,
such as homelessness, substance misuse and histories of abuse
and institutionalisation. We are the United Kingdom's only national
charity exclusively devoted to working with this client group.
99% of our clients are unemployed.1
2. One area of our work is the development
of practical `Link Worker schemes' based in police stations, courts
and prisons, which offer a needs-led service combining assertive
outreach with the provision of emotional support and practical
help. We assist our clients to gain access to services such as
housing, primary health care, welfare benefits, and drug and alcohol
3. This written submission is based on learning
from our existing research and practice. Enclosed is a copy of
"Snakes and Ladders",
which details the findings from our Link Worker Schemes in 2003.
The relevant pages sections are referred to in brackets throughout.
4. The Welfare Reform green paper
notes that "the scale of the challenge is typically more
concentrated in some of the poorest and most disadvantaged areas,
and among people who often face other disadvantages, such as low
skills". Revolving Doors Agency offers a particular expertise
in relation to this challenge since all of the individuals with
whom we work not only fall into this bracket but are also isolated
from their communities and from services.
5. Our submission is intended only as a
précis of a far more comprehensive response to the green
paper, which will be based on extensive consultation with service
users and practitioners.
6. We draw attention to the following:
we agree that it is too readily assumed
that claimants of incapacity benefit are simply unable or unwilling
to work: this does not reflect our experience and with the right
support many benefits claimants could conceivably work (pp 39-40);
a benefit which supports individuals
who are unable to support themselves due to illness or disability
can play an important function in stabilising the lives of individuals
with mental health problems; the current incapacity benefit system
could be reformed with a view to performing this function more
effectively and in doing so better support people into work in
the green paper refers to the reforms
to the tax and benefit policies since 1997 which "have ensured
that work pays": this does not accurately reflect the position
as we have found it and more needs to be done (pp. 39-40);
the availability of part-time and
intermittent work deserves particular attention since for some
individuals with mental health problems this is often the most
effective referral routes for individuals
coming out of residential settings, such as psychiatric facilities
or prison, and the avoidance of delay should be priority areas
for any reform of the current system.
A DUAL BENEFIT
7. Any demarcation between those who are
able to work and those who are not will always lead to a grey
area at the boundary. The necessary implication, therefore, is
that any dual benefit system must rest on the principles of flexibility
and expert discretion. This cannot be overemphasised.
8. Our submission focuses on the following:
the viability of a dual benefit system
for individuals with mental health problems in light of the DWP's
aim to help more people into work and support those who can't
work as part of building a fair and inclusive society;
the wider implications on reducing
what balancing rights with responsibilities
means for our client group.
9. The relevance of mental health. The
green paper notes that nearly 40% of claimants of incapacity benefit
have a mental health condition, many of which will be variable
and manageable. Success in addressing the support needs of sufferers
is therefore crucial in meeting the target to reduce the number
of claimants of incapacity benefit by one million.
10. Supporting individuals with mental
health needs. Mental health service provision is currently
patchy and generally ill-equipped to deal with, what the green
paper rightly refers to as, "conditions [which] can vary
widely and be complex and challenging". This is frequently
exacerbated by cases of multiple needs and in practice what is
effective referral pathways into
local mental health services where these are available;
thorough training for personal advisers
in mental health issues;
joined-up working and seamless transitions
between services ranging from criminal justice, and drugs and
alcohol, to housing and health.
11. Functional capacity and personality
disorder. Whilst we agree that the Personal Capability Assessment
(PCA) should focus on functional capacity, this throws new emphasis
on many mental health conditions. Of very special concern, not
least due to its prevalence, is personality disorder, which affects
thinking, feelings, interpersonal relationships and impulse controlall
of which are highly relevant to the question of suitability for
employment, as recognised by the National Institute for Mental
Health in England.
Amongst our client group, one third has a formal diagnosis and
a further third is assessed by Link Workers as having personality
issues (pp 53-54). This lack of formal diagnoses does not reflect
a lack of severity; rather, it underlines the poverty of mental
health service provision
and that personality disorder is not easily susceptible to management
by medication, since it is not attributed to a specific biological
cause. This example demonstrates the crucial importance of a good
understanding of mental health conditions amongst personal advisers.
12. Expert review. We welcome the
proposal to review the mental health component of the medical
assessment. However, we strongly recommend that the views of frontline
mental health practitioners and, where possible, service users,
are solicited as part of this review given the negative experiences
that our clients have had of psychiatric services.
13. There is a danger that individuals who
can only work part-time or intermittently will fall into a gap
in a dual benefit system. They are not unable to work but nor
may they be able to undertake the proposed employment programme.
In relation to the theme "balancing rights with responsibilities",
while individuals have a responsibility to work if able, they
also have a corollary right to support in accessing work
which is appropriate to the level of responsibility they are assessed
14. Any reform of incapacity benefit must
ensure that individuals are not penalised financially by return
to work, which requires a holistic assessment of their financial
position eg if a recipient of a Freedom Pass giving free access
to London transport between Zones 16 started work full-time
and was required to fund his own transport, this would cost him
an additional £41.00 per week. For some people, the continuation
of certain concessions for a limited period at the beginning of
employment may reduce the danger of a cliff-edge in income that
would deter their move into employment. Also, any complexity or
delay leading to a temporary reduction in income (even if it can
later be claimed back) means that individuals may not move into
15. For many individuals the regular benefit
payment is one of their few sources of stability. They are therefore
asked to gamble this stability with a chance at work with odds
unknown. The financial incentives of work must be worth it. Many
of our clients are not even capable of engaging in the balancing
exercise that this requires which shows that for many individuals,
ongoing support means one-to-one guidance about what is in their
own interest. Trust in personal advisers is therefore paramount
but given the aim is one million cut, it is not unreasonable for
claimants to be wary that their current stability is under threat.
16. Multiple financial insecurities created
by multiple benefits are a considerable exacerbating factor for
the depression, anxiety and paranoia suffered by many of our clients.
This may not only directly affect their assessed capacity to undertake
work, but may encourage a deep-seated reluctance to do so.
17. The green paper refers to a system that
is "relevantit must reflect the needs of the local
labour market". This requires joined-up assessments which
take into account the individual's needs and skills and the needs
and requirements of local employers. This is particularly important
if a system of penalties is introduced for those engaging in an
employment programme, since the key to success is matching individuals
to employers who need them.
18. Employers also need support. In economic
terms, it may appear riskier to employ an individual with chronic
mental health problems than one without and this will also act
as a disincentive. To counteract this, employers and fellow employees
need a reliable network of support and education about mental
health in the workplace.
19. Our experience suggests that incapacity
is one of a number of barriers to someone's return to work. Particularly,
statistics relating to the prison population
suggest a high overlap of people with mental and physical health
problems and with a criminal record, which is a significant barrier
to work. The Rehabilitation of Offenders Act 1974 should be reformed
in accordance with Home Office recommendations
to achieve the right balance between managing the risks posed
by ex-offenders and providing opportunities for them to reform
and return to employment.
We recommend undertaking research to establish
the full effect of multiple barriers to work.
20. A note of caution should be lodged in
relation to the reserved circumstances category of claimants.
The individuals who fall into this category are likely to have
problems as varying and diverse as those who are able to work
in some capacity. One sub-group is likely to be made up of individuals
who have led very traumatic lives and are subsequently damaged.
Transfer into the reserved circumstances group should be a key
point at which to identify such individuals and, in the spirit
of joined-up working, refer them to mental health services and
other agencies that are able to work with them.
21. As the green paper points out, GPs play
a pivotal role. However, around 50% of prisoners are not registered
with a GP
and similarly nor are 34% of our referrals (pp 41-45). Furthermore,
GPs have acknowledged that they do not have enough time to explore
complex mental health and multiple needs issues. The risk is that
our clients will be further excluded from support if lack of access
to primary care is not taken into full account.
22. The green paper proposes incentives
for those who engage in work-related activities and penalties
for those who do not if they are assessed as able. This approach
fails to recognise that incentives and penalties do not work as
mirror-images. It does not follow from the fact that a financial
incentive may encourage an individual to pursue a course of action,
that a financial penalty will have the same effect, particularly
when gambling on stability. Furthermore, penalties should not
be used to punish an individual for what are really manifestations
of their mental health problem.
23. Failing the vulnerable. There
is a risk that if the reformed system is defined by the target
that it is designed to meet, the most vulnerable and needy individuals
who are denied support in so many other areas, will also fall
short of the barrier into the new Employment and Support Allowance.
We welcome the positive proposals to support individuals into
work but guard against a target-driven approach which will inevitably
lead to the exclusion of the vulnerable. We particularly commend
the approach of the Office of the Deputy Prime Minister in this
regard and their commitment to "focus on the most disadvantaged
and champion them as services are transformed across Government"
by "using the experiences of the "bottom 10%" as
a litmus-test of reform across Government".
24. Increasing re-offending. The
effect of setting an individual up to fail by implementing a system
that does not take full account of the far-reaching effects of
mental health conditions directs vulnerable individuals with psychiatric
conditions into the criminal justice system and will drive up
re-offending: when income is reduced the incentive is not always
to work, but to commit crime. This is particularly acute in relation
to individuals coming out of residential settings such as prisons
and some psychiatric facilities.
25. Fraud and error. Incorporating
the principles of flexibility and discretion inevitably incur
greater risk of fraud and error. However, this can be minimised
with appropriate safeguards and the necessity for flexibility
and discretion as cornerstones of a dual benefit system far outweigh
this increased risk.
26. The human face of the benefits system.
A problem long-encountered by our clients is the inability
to interact socially, which causes particular problems when it
comes to communicating with frontline staff in charge of the benefits
system (pp. 23-24). Therefore, this issue of reform must be looked
at from both a systematic and an operational perspective.
231 N O'Shea, I Moran and S Bergin (2003) `Snakes
and Ladders' London: Revolving Doors Agency. Back
Department for Work and Pensions (2006) `A new deal for welfare:
Empowering people to work' London: DWP. Back
National Institute for Mental Health in England (2003) `Personality
Disorder: No longer a diagnosis of exclusion' London: NIHM(E) Back
Revolving Doors Agency is shortly to publish a collection of
case studies, at the request of the Home Office, which reflect
our clients' experiences of mental health services. A copy will
be available after publication on request. Back
Social Exclusion Unit (2002) `Reducing re-offending by ex-prisoners'
London: ODPM; and Simon, F. and Corbett, C. `An evaluation of
prison work and training' London: Home Office. Back
Home Office (2002) `Breaking the Circle: a report of the Review
of the Rehabilitation of Offenders Act 1974' London: Home Office. Back
Social Exclusion Unit (2002) `Reducing re-offending by ex-prisoners'
London: ODPM. Back
Office of the Deputy Prime Minister (2005) `Sustainable Communities:
People, Places and Prosperity' London: ODPM. Back