Select Committee on Work and Pensions Written Evidence


Memorandum submitted by Professor Neville Harris, University of Manchester

SIMPLIFICATION OF SOCIAL SECURITY

INTRODUCTION

  The complexity of the social security system and the problems now widely and officially acknowledged to flow from it[72] have inevitably prompted a search for solutions based on simplification. The evidence in the UK shows that the complexity of the system as a whole and its legislative framework affect the quality of decision making by generating an increased risk of mistakes by officials; and it has been identified as one of the principal causes of citizen confusion and failure to apply for particular benefits (such as pension credit).[73] As the Pensions Commission reported, it is also a significant problem for those planning for retirement.[74]

  There is "intrinsic complexity" within individual schemes:[75] the complexity of housing benefit and the administrative difficulties and costs flowing from it has, for example, been highlighted by the National Audit Office (NAO),[76] while the complexity of the tax credits system has, according to the Parliamentary Commissioner (Ombudsman), been instrumental to the hardship and uncertainty experienced by many claimants.[77] According to the Social Security Advisory Committee (SSAC), the introduction of tax credits has contributed to the complexity, opacity and lack of cohesion of the entire system of state support.[78] Other factors giving rise to complexity include: the transitional arrangements that are needed when schemes are changed or replaced; the interaction between different schemes through often complicated interfaces; the highly prescriptive, rule-based framework governing entitlement to means-tested benefits; and the nature of social security reform, which generally occurs on a piecemeal basis.

  Complexity in social security systems and legislation is not a problem that is confined to the UK. The intricacy of social security law in other states, notably the US and Australia and many European states, is also well known,[79] while a report on social assistance in OECD countries has highlighted the complexity of such schemes.[80] Complexity seems to be a particular problem where the system is designed to allocate resources to citizens systematically but on an individualized basis—that is, with reference to the wide range of circumstances or contingencies facing claimants—and with the need for continual updating.

REFORM OF SOCIAL SECURITY SYSTEMS IN OTHER STATES

  While complexity in the field of social security is recognised as a problem in most states, few are making systematic attempts to ameliorate it. The position is well summed up by the comment by an officer of the Czech Republic's Social Security Administration to this commentator that "the desire to make the social system less complicated accompanies sometimes reforms of social security, but it has never been the main reason for reforms in last 15 years". Nevertheless, Schulte has observed that many states' awareness of the complexity of their social security systems has led them to take measures to rationalise their legislation.[81]

  Schulte cites as examples: the Royal Commission established two decades ago in Belgium with a responsibility for the codification, harmonisation and simplification of social security legislation; and the Sozialgesetzbuch (Social Code) introduced in Germany, which is aimed, among other things, at greater transparency and accessibility to benefits. The Code, published in a series of books (SGBI-XII), is partly founded on the establishment of common principles and rules relating to specific parts of the system (such as social insurance (SGB IV) and administrative proceedings (SGB X)), although many of the books have a specific focus (such as the one covering youth welfare (SGB VIII)). Despite the establishment of these codes, complexity remains a problem, because it is provided that the special rules governing specific schemes will take precedence over common rules.[82] Thus while the Rehabilitation and Participation book (SGB IX) aims to reduce complexity by establishing a basis for cooperation, coordination and convergence, the benefits for disabled persons are governed by as many as seven of the individual books, which as previously noted have priority over common rules. In Germany there is a problematic interface ("Schnittstellen") between different parts of the Code.

  In Australia, the complexity of the system as a whole and the law of social security in particular has been widely acknowledged.[83] The Social Security Act of 1991 represented an attempt to codify the legislation and simplify and modernise the language used. However, the Act has over 1,000 sections and as the Full Court of the Federal Court indiciated in Re Blunn v Cleaver (1993), while the 1991 reform intended to create "a more accessible piece of legislation that ordinary Australians can reasonably be expected to understand", the Act comprised "a maze of provisions made the more complex by prolix definitions, provisos and exceptions".[84] Similarly, in 2003 the Federal Court repeated its criticism of the 1991 Act as "notoriously complex and difficult to interpret".[85] Further, in 2004, in the Full Court, Weinberg J commented: "Regrettably, as each year goes by, the Social Security Act becomes still more complex, and less accessible to those who most need to understand it".[86] Although the introduction of the Social Security (Administration) Act 1999 had aimed to make the system simpler and more coherent, complexity remained.

  Two specific initiatives concerned wholly or partly with simplification were taken in Australia between 2001-2003. First, in February 2001 the Government established a Rules Simplification Task Force comprising members of the Department of Families, Community Services and Indigenous Affairs (FaCSIA) and Centrelink, the agency which runs the benefits system on the Department's behalf. The Task Force's brief included simplification of the rules on (old) age pension and the Newstart Allowance (a benefit for persons aged between 21 years and pension age who are unemployed and who must satisfy an activity test involving seeking work or undertaking an activity to improve their employment prospects). For example, one reform involved the streamlining of the process by which an unemployed person reclaimed benefit after not being in receipt of it for less than a year. The government also said that the assessment of new claims for age pension was assisted by a rules simplification ordered by the Minister for Family and Community Services in 2002.[87] Further legislative simplification was announced in the 2003-04 budget, including measures to reduce unnecessary duplication and to alter the numbering format of the 1991 Act. However, these reforms were very modest in scale.

  The second initiative in Australia occurred in December 2002 with the publication by the government of an important policy document entitled Building a Simpler System to Help Jobless Families and Individuals.[88] This presented a case for modernisation of the system. One argument was that "[a]s the system has evolved over the years, more payment types have been added and rules and payments changed. This has created an unnecessarily complex system that people can find hard to navigate".[89] The system was also considered to incorporate distinctions in levels of support between diverse groups that were difficult to justify.[90] It was proposed that design principles for a reform system of working-age benefits should include "simplicity and fairness… People with similar capacity for work should face similar requirements. Administration is transparent, easy to navigate and cost-effective".[91] No conclusion was reached on whether reform should proceed incrementally, through simplification of parts of the existing system,[92] or should involve a complete redesign to bring about "a simpler and more responsive income support system".[93] However, it is clear from the report that simplification was one of a number of underlying objectives—others included incentivising working, increasing social participation and improving the benefits-tax interface—rather than the principal focus of the reform. There was a consultation period of around six months following publication of the proposals.

  A paper published by the Social Policy Research Centre paper at the University of New South Wales, Sydney, argues that, in practice, reforms to the system introduced since 2000 have tightened up on the obligations of jobseekers and improved services to some degree, but have "failed to grapple with the problems of complexity and disincentives".[94] The government's failure to adopt a simpler system based on a the idea of a single base rate of benefit for all, with adjustments to cover the costs of disability, job-search or children, has been criticized as an abandonment of the approach reflected in the Building a simpler system proposals.[95] But an incremental approach was one of the options presented by the government, which has arguably been preoccupied by its policy of welfare-to-work, and it is clearly the one that it has favoured.

Various other states are currently reforming their systems to achieve greater simplicity in the legislative framework or the structure of benefits. In some cases only partial simplification is sought, rather than a wholesale re-casting of the legislation or the benefits structure. For example:

    —  n Luxembourg, some rationalization is underway; the distinct arrangements for blue and white collar workers in relation to rates of contribution and provision of sickness benefit are to disappear and in all cases employers will pay salary for up to 13 weeks and then payments will be made via the Sickness Fund. Also, the four separate pension funds are being merged into one fund.

    —  In Iceland, the complexity of whose social security system has long been criticized by claimants, interest groups and politicians, the four separate schemes (basic pension, income supplement, housing supplement and home-keeping supplement) were collapsed into three in 2006 through the merging of the last two.

  In some other states there are ideas or plans for simplification, rationalisation or consolidation of schemes and legislation, but currently relatively little progress. For example:

    —  The Department of Social Security in Cyprus is currently working on a simpler and more comprehensible text for its social security legislation, which in its current form is considered to be complicated and difficult to understand not by potential claimants but also officials and lawyers. This work is still in progress.

    —  In Sweden, the report of the "Inquiry on Coordination of Social Insurance Legislation" (SamSol) was published in 2005. The remit of the inquiry was to undertake a technical review of social insurance statutes and to submit proposals for new legislation "to give improved clarity and better assurance against lack of consistency as regards rules and concepts common to social insurance" and to ensure that social security legislation "is easier to take in and apply".[96] The Inquiry recommended that all legislation on social insurance should be set out in a code, which would replace around 30 separate Acts. The codified legislation of France, Germany and elsewhere is cited as an influence.

        It was argued that the code would improve citizen understanding and would be easier to administer. It would provide for greater coherence, particularly as cross-referencing would be possible, so that "the connections between and consequences of various regulations and measures" could more easily be identified.[97] It was also claimed that such a code would facilitate updating of the legislation, since it would be easier to amend it than to amend simultaneously numerous separate statutes. Mirroring the German approach, discussed above, the Swedish proposals also adopt the idea of common provisions where possible. However, some specific areas, including unemployment insurance, would not be integrated into the code. The code would have eight separate sections ("Titles"):

        A.  General provisions

        B.  Family benefits

        C.  Benefits in the event of sickness or work injury

        D.  Special benefits in the event of disability

        E.  Benefits in old age

        F.  Benefits to surviving dependants

        G.  Housing allowances

        H.  Certain common provisions

        The Inquiry report contemplates that decision-making with reference to the code would be "facilitated both by the structure of the code itself and by the fact that the language of individual provisions will be more accessible".[98] The hope is expressed that this may lead to "a more legally secure and consistent application of social insurance".[99] The report suggests that it would be feasible, if the government acts on its recommendations, for the new code to be in force by 1 January 2008. However, to date no clear governmental commitment to implement the Inquiry's recommendations has been evinced, although this may not be altogether surprising given the relatively recent change of government.

    —  The House of Commons Work and Pensions Committee has recently noted that New Zealand "is planning to introduce a simplified benefits system".[100] In fact, the key element in that simplification, the introduction of a "single core benefit", is not in prospect at the present time and doubts have been expressed about this reform ever occurring. The proposal emerged from the Labour-coalition government's ideas expressed in Pathways to Opportunity: From Social Welfare to Social Development, published in 2001. This reflected a clear welfare-to-work agenda, although also expressed a commitment to ensure that citizen needs were properly met. In addition, it acknowledged that the benefit system was "overly complex with many layers and types of benefit", making it difficult for claimants to know what to ask for and for the system to identify and address people's needs. The government undertook, over time, to remove unnecessary complexity from the structure of benefits and supplementary assistance. In this regard, it questioned the need for having five separate benefits for people of working age.[101] It suggested that one option could be "a move towards a "universal" benefit with standardized eligibility rules and conditions that would greatly simplify the system for both the beneficiary and administration".[102] There would be a need for "add-ons" to reflect particular family circumstances, such the caring of children and disability.

        The first phase of the reform programme, designed primarily to establish a framework to manage the transition to work in what amounts to a similar regime to that governing jobseeker's allowance in the UK, although also concerned with beginning the process of aligning some of the rules concerning income-related benefits, is being brought into effect via a Social Security Amendment Bill that is still before the New Zealand Parliament (see below). The second phase, which as noted above may not come to fruition, would involve the replacement of all the working age benefits with a "single core benefit", as also noted above. It was proposed that this benefit could have two streams: a "rapid return to full time work" stream, which would represent the standard position, and a "development" stream for those such as carers of children who could not be placed in the first stream. Although the creation of the new benefit would ostensibly represent a simplification of the structure of the benefit system in New Zealand, there are fears that due to the need to have separate rates to reflect family size and special arrangements in relation to people with disabilities (including cost-based rather than flat rate payments), the government may, in the words of New Zealand's Child Poverty Action Group, be merely "replacing one hopelessly complex system with another".[103]

        The New Zealand government in fact began in June 2005 to trial a model under which claimants of working age were assessed according to their work-status categorization, which is reflected in the categories now set out in the Bill and constitutes part of the first reform phase. These categories in turn broadly reflect the streams proposed for the single benefit.[104] Consequently the need for such a benefit to be introduced is perceived to have diminished. Certainly there would appear to be no potential gains in terms of simplification, other than perhaps the somewhat cosmetic effect of an overarching name.

        There are some examples of small scale simplification contained in the Social Security Amendment Bill. For example, the definition of child dependants has been standardized as have the residence requirements in respect of a range of different benefits. A further example relates to the sanction of suspended or cancelled benefit due to failure to comply with the work test imposed (under s 117 of the Social Security Act 1964) upon a member of a couple who are in receipt of benefit. The current legislation and the amended version in the Bill are set out in the box below.

        Note that the latter "simplified" version is in fact three words longer than the former. This example also illustrates that where there is an elaborate framework governing a particular area of provision, simplification means making things simpler but not necessarily making them simple.

EXAMPLE OF SIMPLIFICATION REFORM IN THE NEW ZEALAND SOCIAL SECURITY AMENDMENT BILL 2007

Social Security Act 1964, s 120

  "(1)  If the suspension or cancellation under section 117 of a benefit payable at a work-test married rate results from the failure of one of the spouses or partners in respect of whom the benefit is paid to comply with a work-test obligation—

    (a)  it only applies to one half the applicable rate of the benefit before any abatement or account of income; and

    (b)  the other spouse or partner is entitled to receive half of that rate (and the appropriate Income Test applies to that rate, but at half the abatement rate in that test)."

Social Security Act 1964, s 120 as it would be amended by Social Security Amendment Bill 2007

   "(1)  Where under section 117 the payment of a benefit is to be suspended or the benefit is to be cancelled, and the benefit is payable at a rate for a person who is married or in a civil union—

    (a)  the suspension or cancellation applies only to 50% of the applicable rate of the benefit before any abatement on account of income; and

    (b)  the person's spouse or partner is entitled to receive 50% of that rate of the benefit, and the appropriate Income Test applies to that rate, but at half the abatement rate in that Income Test."

SIMPLIFICATION OF THE UK'S SOCIAL SECURITY SYSTEM

  It would appear that if were replicated in the UK, the New Zealand "single core benefit" would represent an amalgamation of the jobseeker's allowance and the new employment and support allowance provided for by the Welfare Reform Act 2007. This might simplify the benefits structure as a whole but might not result in simpler law or a clearer basis of entitlement. Moreover, one of the questions arising from the proposed benefit in New Zealand concerns the process of transition. It seems highly likely the complexity of the transition arrangements would represent a major and insurmountable barrier to any similar reform in the UK.

  Benefit reform tends to occur on a piecemeal basis, so that one of the major causes of complexity is the over-layering of changes to the legislation, which is constantly being amended. Thus, as the National Audit Office has explained, "[n]o Government is in the position of being able to start again and design an entirely new system with the intricacies and difficulties removed… the current system is an accumulation of successive governments' actions".[105] Comprehensive re-design is something that has been discussed in other states, but no government to date has been willing to take on board such a difficult task.

  Simplification requires consideration of a range of difficult trade-offs. For example, a simpler non-intrusive application process may undermine the goal of reducing fraud, while the goal of simpler rules is difficult to realise if the system is also aiming to cater for diverse personal circumstances and to ensure the careful and precise targeting of resources on particular needs. Even the cost argument, namely that greater simplicity may aid administration of a benefit and in the process reduce costs, is more balanced than might be expected. For example, the "living together as husband and wife" rule which determines whether an unmarried couple should be assessed as having the same entitlement as if they were married (or civil partners), being less than the sum of the payments made to them as individuals, is a complex rule to administer because of the diverse personal circumstances that must be looked at. If it were abolished and all couples were simply paid double the single person's rate regardless of whether they were living separately it would cost £2.2 billion per annum in additional benefit payments in order to save £190 million in administrative costs.[106]

  The NAO has explained that complexity can be reduced by design changes, as has occurred with child support and housing benefit, or by piecemeal adjustment, as with the alignment of capital limits for income support and income-based jobseeker's allowance with those for housing benefit and council tax benefit.[107] These approaches to simplification are, as discussed earlier, the kind that other states have also been adopting and could be pursued more vigorously in the UK. Of course, other complementary strategies may also be needed including those recommended by the NAO: better staff training, better explanations for claimants and more effective use of information technology.

  The design of the system and its legislation are matters that have attracted attention in other states. In Sweden, as noted above, there have been proposals for codifying social security law (a process which the German experience suggests is by no means certain to reduce overall complexity), while in Australia there have been attempts to re-format the existing legislation to make it more coherent. In terms of improving the intelligibility of the legislation, a possible model here might be the Coroner Reform Draft Bill, published in 2006, with its simple interpretation of each clause running alongside its text. Unfortunately, however, it may be impracticable for such a format to be adopted in the case of much of social security legislation due to its scale, the cross-referencing between provisions and the overall complexity. Moreover, its utility would be diminished due to the fact that important rules on entitlement are often buried within detailed delegated legislation. Even so, it is an approach which at least warrants exploration.

  Another potentially valuable strategy would be to combine monitoring of complexity with a process whereby ministers are placed under pressure to remedy it. The PAC's suggestion that an annual report of the Benefit Simplification Unit's (BSU's) activities and "accomplishments" should be published[108] is a very valuable one. Certainly pressure of this kind appears to have been lacking in connection with the activities of the Rules Simplification Task Force in Australia. In the UK, SSAC can also contribute to this monitoring process. SSAC has highlighted complexity in social security regulations and schemes on a number of occasions in recent years.[109] It is significant that departmental advice is now to the effect that all memoranda and papers accompanying proposed regulations or processes referred to SSAC by the Department for Work and Pensions should explain "the consequences of the proposal for simplification",[110] while the NAO has recommended that SSAC provides analysis of complexity in its stewardship reports on a more systematic basis. Yet SSAC has limited resources and although it occasionally is able to review particular aspects of the legislation, such as the transitional protection provisions, it would not be able to carry out wide-ranging and detailed assessments of existing provisions on a systematic basis. The PAC has highlighted the absence of a "clear gateway at which questions of complexity can be considered and complicating measures stopped or reversed".[111]

  Obviously there could be pressure to reform social security legislation via the regulatory reform process, given that simplification has been identified by the government as an issue that should be brought within it.[112] In a report in March 2005 the Better Regulation Task Force recommended that by September 2006 all government departments should set in place arrangements for systematically identifying regulations that could be simplified, consolidated or repealed.[113] The government has proposed that implementation of such reforms, where needed to primary legislation, could occur via regulatory reform orders,[114] now governed by the Legislative and Regulatory Reform Act (LARRA) 2006. Simplification should occur through measures clarifying the meaning of legislation and "restating the law, with a view to improving transparency, coherence or accessibility".[115]

  LARRA does not, however, refer specifically to simplification: it is only an implicit and secondary objective linked to the reduction of a regulatory burden and administrative costs associated with it. In any event, the Act does not seem likely to result in wholesale reforms to social security legislation. LARRA seems aimed more at removing technical imperfections and ambiguities in the law rather than substantive changes to simplify public services schemes. Of course, it would be undesirable in constitutional terms for substantive policy reforms to occur via the back door of regulatory reform. Either way, LARRA will probably not make a significant contribution to simplification of the benefits system and to making the system more intelligible to the general public.

  If simplification of social security law and administration is being taken seriously, there should arguably be specific statutory requirements to ensure that action is taken. The minister could, for example, be placed under a specific statutory duty to ensure that when regulations are drafted complexity is, so far as possible, kept to a minimum and simplicity is sought. Alternatively, a general statutory duty could be placed on ministers, when making social security (and tax credit) regulations, to have regard to the need to "maximise clarity, encourage simplicity and increase public understanding" of the benefit system. Promoting such policy objectives would be comparable, in terms of its approach, with those covered by the duty on education ministers in respect of their powers to regulate the provision made in schools and further education institutions, which powers must be exercised "with a view to (among other things) improving standards, encouraging diversity and increasing opportunities for choice".[116] Although only wholesale reform of the benefits system is likely to afford a sufficient opportunity for significant simplification,[117] the establishment of such general promotional duties could reinforce the cultural shift that the establishment of the BSU seems aimed at precipitating.

CONCLUSION

  Internationally there is a growing commitment towards simplification of social security benefits, whether as a means to improving social participation and thus the advancement of the "citizenship" ideal or to facilitate better administration and consequential reductions in costs. However, while there have been broad statements of intent by administrations in various jurisdictions, little has been achieved. Governments have tended to favour incremental change—smoothing out some inconsistencies, anomalies or duplication or streamlining some substantive or procedural areas—rather than undertaking wholesale reform.

  The framework for simplification established in the UK seems likely to systematise to some extent the process of simplifying aspects of the system, an avowed policy goal, but it has clear limitations. Ultimately the question for government is whether it is prepared to incur the huge development costs and potential political costs (when some lose entitlement due to the restructuring of benefits) that are likely to be involved in a wholesale reform of the benefit system, particularly when it has other policy priorities, not least the continuing pursuit of its dominant policy goal of welfare-to-work, reflected most recently in the Welfare Reform Act 2007. The experience in other countries with similar policy preoccupations does not offer much encouragement that the laudable aim of simplifying social security will be realized to the extent necessary. Nonetheless, the ideas emerging from these countries do suggest potential ways forward.

1 June 2007








72   Evidence from a range of sources including the House of Commons Committee of Public Accounts, including its 36th Report, Session 2005-06, Tackling the complexity of the benefits system (HC 765) (The Stationery Office, 2006) and Comptroller and Auditor General, Department for Work and Pensions: Dealing with the complexity of the benefits system, HC 592 (The Stationery Office, 2005), is discussed in N. Harris, "Complexity, Law and Social Security in the United Kingdom", European Journal of Social Security, 8(2) (2006), 145-178. Back

73   House of Commons Work and Pensions Committee, 3rd Report, Session 2004-05, Pension Credit Vol 1, HC 43-I (The Stationery Office, 2005), paras 117 and 121. Back

74   Pensions Commission, 2nd Report, A New Pension Settlement for the Twenty-First Century (Pensions Commission, 2005). Back

75   P. Spicker, "Five types of complexity", Benefits 13(1) (2005), 5-7. Back

76   Comptroller and Auditor General op cit. Back

77   Parliamentary and Health Service Ombudsman, Tax Credits: Putting Things Right, HC 124 (The Stationery Office, 2005). Back

78   Social Security Advisory Committee, 17th Report 2004 (Corporate Document Services, 2004), foreword. Back

79   Regarding Europe, see, for example, P.A. Kemp, "The role and design of income-related housing allowances," International Social Security Review, 53(3) (2000), 43-57; D. Pieters, Systems of the Member States of the European Union (Intersentia, 2002); Idem, The Social Security Systems of the States applying for Membership of the European Union, Intersentia, 2003); B. Schulte, Social Rights under International and National Law: Access to Social Security-A Discussion Paper for the ISSA (ISSA, 2002-www.issa.int/pdf/initiative/reports/2Schulte.pdf); RA White, EC Social Security Law (Longman, 1999). Regarding Australia and the USA, see A. O'Neill, "Plain English and the 1991 Social Security Act", in J. Disney (ed), Current Issues in Social Security Law (Centre for International and Public Law, Autralian National University, 1994), 151-164; F. Bates, "Social Security Law and Children with Disabilities: Change and Decay in Australian Statute Law" (1997) Statute Law Review, 18(3), 215-234.  Back

80   T. Eardley et al (1996) Social Assistance in OECD Countries: Synthesis Report Department of Social Security Research Report No 46 (HMSO, 1996).  Back

81   Above n 8. Back

82   SGB I, para 37. Back

83   For example, O'Neill and Bates, n 8 above. Back

84   (1993) 111 ALR 65 at 82. Back

85   Secretary, Department of Family & Community Services v Draper [2003] FCA 1409, per Jones J at para 24. Back

86   Secretary, Department of Family and Community Services v Geeves [2004] FCAFC 166, at paras 37 and 38. Back

87   Hansard, House of Representatives, 26 June 2002, 4467. Back

88   Commonwealth Department of Family and Community Services, 2002. Back

89   ibid, para 15. Back

90   ibid, paras 36 and 37. Back

91   ibid, para 47. Back

92   ibid, Paras 51-53. Back

93   ibid, paras 54-58. "Income support" is used here to refer to benefit support in general.  Back

94   P Saunders, Disability, Living Standards and Welfare Dependency in Australia, SPRC Discussion Paper No 145 (University of New South Wales, Sydney, 2005), p 2. Back

95   See Hansard, Senate, Community Affairs Legislation Committee, 21 November 2005, CA 37. Back

96   Statens Offentliga Utredningar, Socialfrsäkingsbalk Del 1 (Statens Offentliga Utredningar, Stockholm, 2005), p 35. Back

97   ibid, p 36. Back

98   ibid, p 38. Back

99   ibid. Back

100   House of Commons Work and Pensions Committee, Third Report of Session 2006-07, The Government's Employment Strategy, Report, HC 63-I (The Stationery Office, 2007), para 347. Back

101   Namely, unemployment, sickness, invalids', widows' and "domestic purposes" benefits. Back

102   Ministry of Social Development, Pathways to Opportunity: From Social Welfare to Social Development (Ministry of Social Development, Wellington (NZ), 2001), p 6. Back

103   Child Poverty Action Group (New Zealand), Submission on the Single Core Benefit Proposal (CPAG (NZ), Auckland, 2005), para 5. Back

104   Under the Bill there are in fact three streams: (1) Work Support concerns primarily persons in receipt of unemployment benefit, who will be provided with assistance to find and retain work; (2) Work Support Development will concern for most other beneficiaries (subject ot exempt groups), who will be assisted to plan for work in the future, with services designed to assist with this and with developing work-related skills; and (3) Community Support, for people receiving benefit for the care of the sick or infirm and some invalidity benefit recipients. I am indebted to Dr Louise Humpage of the University of Auckland for guidance on these developments. Back

105   Comptroller and Auditor General, above n 1, para 2.7. Back

106   ibid, para 4.5. Back

107   ibid, Executive Summary, paras 34-36. Back

108   House of Commons Committee of Public Accounts, Thirty-sixth Report of Session 2005-06, Tackling the complexity of the benefits system, HC 765 (2006, London, The Stationery Office), p 5. Back

109   Including, most recently in SSAC, Eighteenth Report 2005 (2006, Leeds, Corporate Document Services).  Back

110   Benefit Simplification Unit, Simplification: Guide to Best Practice (2006, London, DWP), p 12. Back

111   Above n 37, para 20. Back

112   Cabinet Office, Better Regulation Executive, A Bill for Better Regulation: Consultation Document (Cabinet Office, 2005), p 10. Back

113   Better Regulation Task Force, Regulation-Less is More: Reducing Burdens, Improving Outcomes (Better Regulation Task Force, 2005). Back

114   Above n 41. Back

115   ibid, p 11. That burdens that fall exclusively on government departments are excluded from this framework is considered inconsistent with the Government's avowed commitment to increase the efficiency and effectiveness of public services: ibid, p 10. Back

116   Education Act 1996, s 11(2). Back

117   As claimed for the "Citizen's Income" proposed in B Jordan et al, Stumbling Towards Basic Income (Citizen's Income Study Centre, London, 2000). Back


 
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