Select Committee on Work and Pensions Written Evidence

Memorandum submitted by Housing 21


  Housing 21, as a specialist housing, care and support provider for older people across England has an interest in promoting the financial wellbeing of our customers.

  This report starts by outlining Housing 21's response to promoting uptake and awareness of benefits as evidence of good practice with a group that is often "hard to reach" for a number of reasons.

  The report then goes on to cover key points of the Inquiry that concern older people's issues specifically and highlights the following points, using practice based case studies to illustrate examples and recommendations for solutions where appropriate:

    —  The Benefit Simplification Unit, the Freud review and the DWP Simplification Plan—This section looks at the various published reviews on simplifying the benefits system and points out that there has been little focus on older people's issues in any of this work.

    —  Accessing the benefits system: This section explores the complexity of the system, the number of different benefits, grants and loans available and secondly the range of executive agencies administering different benefits.

    —  Information and communications: Sources of information, links between different benefits administered by different agencies and communication between executive agencies and claimants.

    —  The disincentives for older people to take up work: The demands of the UK labour market are increasingly for a flexible workforce. Many older people provide vital (paid and unpaid) work. However, for older people to contribute effectively to the workforce then the benefits system needs to work more flexibly and swiftly. We offer a case study example of how the existing process acts as a barrier to older people contributing to the labour market.

    —  Conclusion: Fundamentally the Select Committee will need to decide whether the existing complexity of the UK benefits can be streamlined or clarified. If it is fundamental that benefits are of necessity complex and primarily means-tested, then the Committee need to explore ways of resourcing better and more accessible information, and resourcing specialist outreach, advocacy and advice agencies and services to help people navigate through the complexities of the system and claim their full entitlement.


  Housing 21 employs two welfare benefits managers who work across England. Uniquely in the specialist housing sector, Housing 21 recognises the key role that financial wellbeing has in sustaining an older person's quality of life and maintaining as independent a lifestyle as possible. The specialist welfare benefit manager posts were created to ensure that Housing 21 tenants had the advice, information and assistance needed to help them to access the benefit system, to navigate a route through all the complexities, to promote uptake and to ensure they were receiving their correct benefit entitlement.

  I work with staff and tenants across the country to increase uptake of benefits via a number of mechanisms:

    —  Targeted benefits advocacy work with tenants via a rolling programme of "court" (housing complex or scheme) based campaigns.

    —  Development and delivery of front-line staff training.

    —  Dissemination of information through a range of communications media including an annual benefits newsletter to tenants and "benefit information centres" on courts.

    —  Advice and information to staff via a range of methods—workshops at regional offices, briefings in Housing 21 internal communications.

    —  Policy development work ensuring the "financial inclusion of older people"—eg our role in individual budgets, Sure Start and LinkAge Plus.

  The benefits team has been in post for nearly six years. Reported performance statistics to date show that the direct uptake work alone has raised over £3.5 million in additional annual income for Housing 21's tenants over the past five years. Benefit gain as a result of the secondary work, provision of training and information, cannot be quantified in this way.


3.1.1  Benefits Simplification Unit

  Thus far, none of the work done by the Benefit Simplification Unit has been specifically focussed on older people. Furthermore, older people are absent from the discussion and recommendations in both the DWP Simplification Plan and the Freud review.

  The Benefit Simplification Unit was set up in 2005 and employs five members of staff. In 2006, the Benefit Simplification Unit published a document entitled "Simplification—Guide to Best Practice". This is a useful document with helpful and practical suggestions but the suggestions, in the main, do not appear to have been taken on-board.

  An example of a simplification proposal on a particular benefits eligibility anomaly which has not been put into effect is shown on page 7 of this document: "...customers having to establish that they are entitled to Carers Allowance in order to receive a Carers Premium even though the overlapping benefit rules mean they will not get the Allowance." This at least recognises the problem but people still have to go through this procedure so it would appear that nothing has changed, despite the publication of this document. The recommendations in this report are often useful, informative and achievable, yet the findings do not appear to have been widely disseminated. The Benefits Simplification Unit should have more resources for dissemination and promotion of good practice.

  In January 2007, a further document was produced entitled "Official Error Task Force and Benefit Simplification Unit: Progress Report". Even though this report was released on 24 January 2007 it has only been deposited in the House of Commons Library and this means it is not available online and as the Library is not open to the public it is difficult and frustrating for the general public and advisers to ascertain exactly what progress has been made.

3.1.2  Freud Report

  The Freud report (2007) entitled "Reducing dependency, increasing opportunity: options for the future of welfare to work" sets out a range of cost effective recommendations to improve the financial wellbeing of the most socially excluded groups. The first sentence of the foreword states this purpose clearly "This report makes a series of recommendations to reduce the number of the most socially disadvantaged people in the country." However, it would appear from this report that it does not class older and/or retired people as "socially disadvantaged", which in reality is often the case. 1.8 million pensioners, after housing costs are in poverty (Age Concern, Key facts & statistics 2006) and 68% of pensioner households depend on state benefits for at least half of their income (Age Concern, 2006)

3.1.3  Benefits Simplification Plan

  In December 2006, the DWP produced it's simplification plan for 2006-07. I would like to refer to two statements on page 23 of this document. The first reads, "The Department has a strong ambition to improve the efficiency and effectiveness of the system of working age benefits. The present benefits system for people of working age is complex." The second statement reads, "In December 2005, the Permanent Secretary set up a new Benefit Simplification Unit (BSU). It is designed to act as a catalyst for driving forward simplification across the system of working age benefits to challenge existing complexity and to ensure that the benefits system operates in ways that customers and staff can understand." Both these statements indicate that although the Department recognises that the benefit system is complex, it is only looking at reforming benefits for people of working age, it is not looking to reform benefits for older people.

    —  Key message: Because of the overarching emphasis of "welfare to work" not enough resources have been targeted into looking at issues specific to older people. Many older people continue to participate in the labour market, and many benefits such as Attendance Allowance and Pension Credit are specific to older people. The Benefits Simplification Unit needs to "age-proof" its work and address implicit age discrimination. It also should take account of key issues associated with older people and benefits such as the work started by the Link-Age Plus programme.


4.1.1  The sheer range of benefits

  The sheer range of benefits, loans and grants which older people may potentially qualify for is confusing. In total there are 33 different kinds of benefit available and a further 11 types of grants or loans that are also available to older people and other groups. This causes problems for people trying to access the benefit system as people often do not know what benefits are available, what the entitlement criteria are and how they can apply for them.

4.1.2  Misleading titles and name changes

  The names of different benefits are often misleading. For example, Pension Credit is available to people aged 60 and over, irrespective of whether or not the person has retired and is receiving a State Retirement Pension. This means that Pension Credit is available to people who are not pensioners. The confusing title of the benefit and lack of clarity about entitlement is a barrier to uptake.

  Another example of this lack of clarity is Attendance Allowance. Attendance Allowance is payable to people who have significant health difficulties that affect them in every day life, but to claim Attendance Allowance it is not necessary to have a carer or helper to "attending" to you. Again this is a barrier to uptake and many older people who would be entitled to this benefit are missing out. Housing 21's Welfare Benefits Managers statistics on take-up show Attendance Allowance accounts for the largest proportion of income gain amongst our tenant population. The Government estimates that there is currently a 40% underclaim rate for Attendance Allowance.

  The fact that benefits sometime change their name can be confusing for people. In recent years, for people aged 60 and over, Income Support first changed to become Minimum Income Guarantee (MIG) and in October 2003 this then became Pension Credit. Another benefit that has changed it's name in recent years is Carer's Allowance (formerly Invalid Care Allowance)

    —  Key message: Whilst it may be necessary to change the name of a benefit, it is important that the new name does not add to or compound confusion. Messages about benefits, what they are for and intended recipients need to be communicated clearly and in plain English. For example, a clearer name for Attendance Allowance which explicitly links the benefit to its purpose would help to improve take-up.

4.1.3  Changing eligibility criteria and unequal treatment

  There are anomalies in terms of benefits which are withdrawn, replaced or eligibility criteria change. For example, Severe Disablement Allowance (previously Non-contributory Invalidity Pension) is a benefit that is no longer payable to new claimants. People who were already receiving this benefit continue to receive it, however new claimants are no longer eligible to claim this benefit and there is not a "like for like" replacement. It is however, accepted that provision was made in the Incapacity Benefit legislation for a level of non-contributory Incapacity Benefit to be paid to those people who, due to severe disablement, would be unlikely to build up a National Insurance Contribution Record in their own right. This potentially could mean that you have two people in identical circumstances where one person gets this benefit as they were receiving it prior to the cut-off date and the other person does not as they did not realise they could apply for this benefit until it was too late.

  There are two separate elements of Pension Credit. The Pension Credit Guarantee Credit is available to people aged 60 and over, the Pension Credit Savings Credit is available to people aged 65 and over. This age discrepancy often causes confusion amongst people.

    —  Key message. The question that needs to be addressed is what purpose does this discrepancy based on age serve? It would certainly be clearer to have one age as a baseline for eligibility. If this is not feasible then more resources need to be put into direct promotion and take-up advice. There need to be more specialist advisory posts to support people in navigating their way through the benefits maze.

4.1.4  Complexity of eligibility and shifting criteria

  Small changes in financial circumstances, can have a significant affect on differing benefit entitlements, and this impact on eligibility differs from benefit to benefit. It is unclear to many older people which changes are "significant" and need to be reported. For example, a small increase in savings or capital is not classed as a significant change of circumstances and will not affect entitlement to Pension Credit, but this same increase in savings will have an impact on entitlement to Housing Benefit and Council Tax Benefit if Pension Credit guarantee credit is in payment. (NB If it is only Pensions Credit (savings credit) then any and all changes will have to be reported for an adjustment to be made to Housing Benefit/Council Tax Benefit.)

  Entitlement rules for various benefits are so different they can be bewildering For example, the capital limit for Income Support is £8,000, for Housing Benefit and Council Tax Benefit the capital limit is £16,000 and for Pension Credit there is no capital limit. The discrepancy between the capital limit for Pension Credit and that for Housing Benefit/Council Tax Benefit is particularly confusing as someone with Pension Credit (Guarantee Credit) will be entitled to maximum Housing Benefit/Council Tax Benefit even if their capital exceeds the £16,000 limit that ordinarily applies to stand alone H/CTB claims. From our professional experience, we have had several examples where local authorities have interpreted this wrongly and much correnspondence has been necessary to rectify the situation. This causes confusion for many older people, particularly as all these benefits are means-tested.

  Many minor changes and shifts in entitlements are not cost effective for claimants or for the state. For example, when someone reaches the age of 80, their State Retirement Pension increases by 25 pence per week. If that person is in receipt of Pension Credit savings credit, Housing Benefit and Council Tax Benefit then all these benefits will need to reassessed to take into account this increase in State Retirement Pension. Once these benefits have been reassessed, Pension Credit savings credit, Housing Benefit and Council Tax Benefit will reduce by a total of 22 pence per week, meaning that the claimant is actually only 3 pence per week better off. (If someone is getting Pension Credit (Guarantee Credit) and continues to be entitled to this after the 25p addition to their retirement pension then their Housing/Council Tax Benefit will not be affected. This case scenario only applies if Penson Credit savings credit or no Pension Credit at all is in payment.) The time and cost involved in processing these changes and then sending out notification letters for all these benefits and a revised Council Tax bill far outweighs the actual cost to the state.

    —  Key message (1): If it is not possible to streamline entitlements then information needs to be clearer and the different agencies responsible for administering different benefits need to be upskilled in terms of recognising these anomalies and coordinating their work with each other and the claimants they serve.

    —  Key message (2): Benefit anomalies need to be reviewed so that the money spent is more effectively targeted to the people who need the support.

4.1.5  Complexity of calculations

  The Pension Credit Savings Credit is a complicated calculation and people are often not able to work out whether or not they are entitled to this benefit.

    —  Key message: Clearly there is a need to resource information advice and advocacy services to help older people navigate their way through the benefits system. For example, to help with clarity would be much better if, when Attendance Allowance is paid to one or both of a couple, the other (or both of them) should automatically be entitled to the extra "Carers" amount that increases the means-tested benefits of Pension Credit, Housing/Council Tax Benefit.

4.2  "Making the links"—Information and communications

4.2.1  Fragmented information provision

  Though the Sure Start for Older People initiative and Link-Age Plus schemes are working to address the provision of better information for older people, there are still many issues to resolve. Not knowing where to start is the first barrier to benefits uptake. People often encounter problems with the benefit system as even if they know what benefits are available they are not always aware as to which executive agency deals with the type of benefit that they are enquiring about. There are six executive agencies that currently deal with benefits, it is not always clear as to which agency deals with which type of benefit. Currently they are as follows: Disability and Carers Directorate for Attendance Allowance, Disability Living Allowance and Carers Allowance, the Pension Service for Retirement Pension and Pension Credit, Jobcentre + for Income Support, Incapacity Benefit and Job Seekers Allowance. The Veterans Agency, local authorities, HM Revenue and Customs and the Department of Trade and Industry also administer various loans and grants. In fact, a claimant or adviser has to deal with two agencies just to deal with Attendance Allowance and Pension Credit.

  Information relating to benefits is not always readily available to people, particularly the most excluded members of society. Information relating to benefits is now primarily available on-line, however the vast majority of older people and the most excluded members of society often do not have easy access to the Internet to enable them to obtain necessary information. Additionally, if people do have Internet access, it can still be intimidating trying to find the relevant information. The DWP currently produces 178 different leaflets and guides to benefits. Compounding the confusion, there are a number of different websites available giving information on different benefits. People will need to look at a range of different websites depending on what type of benefits they require information on.

  The application forms for some benefits can often put people off claiming their entitlements. For example, the Disability Living Allowance claim form is 40 pages long and can be very time consuming to complete correctly. The Attendance Allowance claim form was redesigned in December 2005 to try to simplify the claim process, but the new simplified claim form is still 20 pages long which is still daunting for many of older people.

4.2.2  Keeping claimants informed

  Information about benefit claims is often unnecessarily obtuse. Benefit notification letters are often too long and not easy to read and interpret for older people. For example, the Attendance Allowance decision letter normally consists of four or five pages, as does the Pension Credit decision letter. It would be better and clearer to have a standard one or two page letter which sets out clearly the terms of the claim and what happens next. Currently, people in advocacy, advice and support roles (such as Housing 21's Welfare Benefits Team) have to effectively translate published information into terms that older people who are often frail or have sensory impairments are able to understand. If it is not possible to make information clearer and more concise, then more resources need to go into advocacy and advice.

    —  Key message (1): How can we address the volume and fragmentation of benefits information? If the system is necessarily complex, then work needs to be done so that the infrastructure—agencies administering different benefits, information sources, and media are streamlined. The "single assessment process" on social care assessments, linking a range of different agencies may be a model which can be deployed or developed in terms of benefits assessments. For example, the range of different agencies need to establish and further develop "data sharing protocols" so that individuals can be assessed holistically and obtain a seamless service. Again, if this is not possible, then more resources need to be deployed in terms of specialist advice and brokerage services; advisers who work directly with older people and liaise with the range of stakeholders involved in the assessment and administration of benefits. Initially the Pension Service was supposed to be offering a streamlined service and we were told that local staff would be available on a regular basis to hold "benefit surgeries" and to visit people at home to complete all benefit claims that were appropriate to an individual. However, this was significantly downgraded for budgetary reasons after 2005 even though it is widely acknowledged that the Government target for uptake of Pension Credit is not being met.

    —  Key message (2): Secondly information provision should be reviewed. When producing leaflets and information, the Government must recognise that on-line resources are not appropriate for all, particularly hard to reach groups. Older people missing out on benefits are likely to be amongst the most socially excluded, and it is unlikely that they will have access to the Internet. Some resources should be used to produce hard copies of information that can be distributed to community centres, doctors surgeries and facilities which older people actually use. Currently, advice services, and various voluntary organisations have to print out the information. These bodies are often under severe resource pressures.

    —  Key message (3): The Internet is of course a valuable resource, but must be seen as one of a range of information sources. However, on-line benefits information resources can be improved considerably. A "one stop shop" web portal ("Benefits Direct") could be developed, using a model similar to the NHS Direct website which has improved information provision and enabled the NHS to prioritise and resource responses to enquiries and prioritise interventions more effectively.

    —  Key message (4): The links between certain types of benefits are not always clear and straightforward for people. For example, people are often not aware that a successful claim for Attendance Allowance impacts favourably upon eligibility for other benefits, such as "passporting" for new or increased Pension Credit, Housing Benefit and Council Tax Benefit. Communication and information sharing between executive agencies isn't always as good as it could be. Claimants find it very frustrating and time consuming having to repeat and duplicate information between different agencies. Data sharing protocols to improve joint working and speed up assessments should be developed.


5.1.1  Older people and employment

  The modern UK economy demands a flexible workforce. Many people over state retirement age are paid or unpaid (voluntary/informal) workers. As the population ages, more and more people who are active and over 60 will wish to continue to work. The benefit system currently does not help or encourage older people who wish to return to work. For example, if someone is in receipt of benefits such as Pension Credit, Housing Benefit and Council Tax Benefit and they return to paid employment this can cause several problems in terms of their overall income. Firstly, the fact that they are now in paid employment means that means-tested benefits are reassessed to take this into account. As a result of this reassessment entitlement to these other benefits will reduce. The case study below gives a full breakdown of this example.

    —  Key message (1): Reassessment of benefits is of course an indelible feature of the current targeted and means-tested system. The main concern is about how long it often takes for these reassessments to happen, particularly with regard to Housing Benefit and Council Tax Benefit. The time delay could mean that someone could potentially find themselves in financial hardship whilst they await the decisions on the reassessments of benefits following a return to paid work. To address this, the benefits system needs to be flexible to mirror the labour market, and the assessment process for claims needs to be speeded up.

    —  Key message (2): The allowances to people who are in paid work should be reviewed so the disincentives to work can be assessed more effectively.


  This submission has given an overview of issues about simplifying the benefits system for older people. The main recommendations from this are clear. If the system is necessarily complex and will continue to involve means-testing across a baffling range of eligibility criteria then the following solutions will help to ensure that the maximum number of older people are claiming their full entitlement

6.1  Accessible information

    —  There needs to be a "one stop shop" web based portal for benefits information across the range of agencies and different benefits. A model for this could be the NHS Direct portal which has enabled information and advice provision to be targeted and interventions more cost effective.

    —  Though technology is moving fast, many of the most socially disadvantaged groups and the voluntary sector do not have the resources to access computer technology or to print out leaflets. Some key benefits information should be made available in hard copies and in places within the community that older people use—eg GP surgeries, community centres, housing schemes.

    —  The myriad of different agencies who deal with benefits administration should improve joint working criteria. Data sharing protocols should be developed so that older people do not have to liaise with a range of different agencies. Again a "one stop shop" advice brokerage is useful in this respect.

    —  The good work of the Benefits Simplification Unit needs to expand to include older people, and to be disseminated more effectively

6.2  Advice, advocacy and outreach

    —  If the benefits system retains its current level of complexity, then it is vital that specialist advice posts are resourced so that "hard to reach" older people are enabled to claim their maximum entitlement.

    —  More resources need to be deployed on outreach work so that the most socially disadvantaged groups are reached.

    —  Benefits advisers have a key role in enabling people to navigate through the complexities of the system, the range of benefits which often have competing eligibility criteria. Every stage of the current process needs to be supported by a brokerage/advocacy/interpreting service so that claims forms, the claims process and outcome notifications are clear and understandable.

  That concludes Housing 21's submission, though I would welcome the opportunity to give oral evidence should you require further information on the issues raised here.

5 April 2007

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