Memorandum submitted by the National Autistic
Society (EP 10)
The National Autistic Society welcomes the opportunity
to submit evidence to the Work and Pensions Select Committee inquiry
into the management and administration of contracted employment
programmes. The NAS believes that the Department for Work and
Pensions needs to:
— Develop a customer charter that ensures
that individuals are aware of their rights to employment support.
— Work to ensure that prime providers are
supporting all of their clients not just those closest to work.
— Ensure that the use of large prime contracts
does not undermine customer choice.
— Do more to monitor the relationship between
prime and sub contractors.
— Carry out a more thorough Disability
Equality Impact Assessment for the new Work Choice programme.
ABOUT US
1. The National Autistic Society (NAS) is
the UK's leading charity for people affected by autism. We were
founded in 1962, by a group of parents who were passionate about
ensuring a better future for their children. Today we have over
18,000 members, 80 branches and provide a wide range
of advice, information, support and specialist services to 100,000 people
each year, including a welfare rights helpline and Prospects,
the NAS' specialist employment service for people with autism.
A local charity with a national presence, we campaign and lobby
for lasting positive change for people affected by autism.
ABOUT AUTISM[45]
2. Autism is a lifelong developmental disability
that affects how a person communicates with, and relates to, other
people. It also affects how they make sense of the world around
them. It is a spectrum condition, which means that, while all
people with autism share certain difficulties, their condition
will affect them in different ways. It affects around one in every
100 people. Some people with autism are able to live relatively
independent lives but others may need a lifetime of specialist
support.
3. Asperger syndrome is a form of autism.
People with Asperger syndrome are often of average or above average
intelligence. They have fewer problems with speech but may still
have difficulties with understanding and processing language.
AUTISM AND
EMPLOYMENT
4. Currently, only 15% of adults with autism
are in full time employment[46]
but many want to work and have a lot to offer employers. However,
people with autism face many challenges in applying for work and
in the workplace itself. People with autism often need long term,
specialist support to overcome the communication barriers associated
with autism and find work.
5. With the right support, people with autism
can thrive in the workplace. The NAS' employment service, Prospects,
is a specialist service supporting people who have autism into
mainstream jobs. They have a very successful record of helping
people find and retain work. Between 1995 and 2003, 67% of
the clients they supported found work. Furthermore, 70% of the
pilot scheme's beneficiaries from 1995-97 were still in employment
in 2003.[47]
CONTEXT
6. We do not believe that the only way to
deliver employment support is through the prime provider model
and we would prefer the DWP to continue to contract directly with
all providers. By retaining direct control of all contracts the
DWP could ensure that prices reflect the real costs of supporting
those facing the greatest barriers into work, that provision is
fairly distributed across both rural and urban areas and that
support is delivered to all client groups.
7. Furthermore, in the case of Work Choice,
the rationale for moving to provision based around prime providers
is that people have multiple and complex needs and that services
focused on just one of these needs fail to provide all the support
necessary for the individual to move into work. However, the reality
of the intended prime-sub relationship is that people will continue
to receive support according to their impairment and there will
just be an extra layer of administration put into place before
this happens.
RESPONSE
Will the customer charter proposed by DWP ensure
that customers, Jobcentre Plus and contractors know what they
can expect of employment programmes?
8. The DWP customer charter should clearly
identify the rights of those accessing employment services and
the value of such a charter has been recognised by the (then)
Secretary of State for Work and Pensions (James Purnell) and we
also welcome the recognition of the importance of a customer charter
by the Work and Pensions Select Committee.[48]
9. The customer charter recently developed
by the DWP does set out some of the rights and responsibilities
of individuals accessing Jobcentre Plus services. However, we
feel more needs to be done to make people aware of the support
available and also to ensure that people understand the full implications
of the sanctions regime.
Will contract management in the prime contractor
model be transparent and effective in monitoring quality throughout
the supply chain, and in maintaining a role for sub-contractors?
10. Many people with autism have high support
needs and it can therefore cost more to support them into work
relative to other clients. With private providers delivering the
majority of contracts we are concerned that the focus on profit
will result in the neglect of those who may cost more to support.
11. Again, we welcome the Work and Pensions
Select Committee's recognition that under the current payment
structure "parking" and "creaming" are a real
risk.[49]
To address this it is crucial that there is rigorous monitoring
of prime contractors and this must include different impairment
groups in order to ensure that DWP employment programmes are working
for and being accessed by all disabled people and that individuals
are not being "parked".
12. Furthermore, whilst many prime providers
rely on specialist sub contractors to deliver support to those
with more complex needs we are concerned that the price offered
will lead to specialist providers being forced to either deliver
support at a loss or leave the market. These concerns are based
on the fact that those prime providers motivated by profit will
bid for the contract using costings based on the profit margin
that would occur through supporting the minimum number of clients
into work. Again, the profit motive implies that these would be
those clients easiest to support as they have less expensive support
needs and are more likely to produce quick returns for the prime.
Therefore, by the time the prime provider approaches the sub contractor
to deliver more specialist support there is not enough money in
their budget to enable them to offer specialist providers, who
do not have the benefits of economies of scale, a realistic price
for this support.
13. The reality of the threat posed by the
prime contractor model to smaller, non-profit providers is demonstrated
by the experience of New York City where the introduction of the
prime contracting model saw the loss of many of these smaller
organisations.[50]
Many of these smaller, specialist providers are charities who
cannot afford to make a loss.
14. Altogether, this will have a negative
impact on those clients who need more intensive support and also
risks a loss of specialist knowledge and support from the employment
programme market.
ADDITIONAL CONCERNS
Customer choice
15. We are concerned that the use of large,
regional contracts to provide DWP employment programmes will severely
limit customer choice. Although the DWP is committed to rating
providers, this information will be of little use unless customers
are able to choose alternative provision.
Code of Conduct
16. Without tighter monitoring of the relationship
between prime contractors and subcontractors, those with the most
complex needs are likely to miss out on specialist support. If
prime providers are to successfully engage with sub contractors
it is important that there is a strong Code of Conduct governing
this relationship. It is also vital that there is independent
adjudication available for when disputes between prime providers
and subcontractors arise. The Merlin Standard has the potential
to address this and it is vital that it introduces tighter regulation
of the prime-sub relationship.
Disability Equality Impact Assessment for Work
Choice
17. The DWP are currently issuing contracts
for Work Choice, the employment programme to replace Workstep
and Work Preparation. We are worried that the current disability
equality impact assessment, contained within the impact assessment
of "Raising expectations and increasing support—reforming
welfare for the future", does not adequately address the
impact of Work Choice on different groups of disabled people.
18. The current disability equality impact
assessment is as follows:
Re-shaping and providing additional funding
for the successor to WORKSTEP and other specialist disability
employment programmes
692. There is a risk that a better resourced
and reformed programme does not target the support it provides
at groups of disabled people with the greatest need for the support
it provides. Around 8 per cent and 36 per cent of customers
on WORKSTEP are people whose disability is, respectively, poor
mental health or a learning disability. Both groups are disadvantaged
by particularly poor work opportunities.
693. The new programme, which was consulted
on earlier this year, will be less prescriptive and more flexible
than current arrangements, with a greater focus on those who need
specialist support. Our proposals help to promote equality through
incorporating improved progression to unsupported employment and
a greater focus on job entries for customers who reach the stage
at which they could work without support.
694. The Department has recently commissioned
A Baseline Survey of WORKSTEP customers which will encompass a
quantitative and qualitative survey. The fieldwork is due to take
place in the first half of 2009 and is due to report in late
summer 2009. The results of this survey will form a baseline for
a future evaluation of our reformed programme. We are committed
to producing a full evaluation strategy for the new programme
by early 2010, in time for implementation when the new programme
is introduced.
19. Given the extent of these reforms and
their potential impact on people with autism we feel that the
existing disability equality impact assessment is inadequate and
a more comprehensive assessment needs to be carried out.
October 2009
45 The term autism is used throughout this document
to refer to all people on the autism spectrum including Kanner
autism, Asperger Syndrome and high functioning autism. Back
46
Rosenblatt, M. (2008) I Exist. National Autistic Society Back
47
Howlin P, Alcock J, Burkin C, "An 8 year follow-up of
a specialist support employment service for high-ability adults
with autism or Asperger syndrome" in Autism 9(5) (2005). Back
48
DWP's Commissioning Strategy and the Flexible New Deal, Work
and Pensions Committee Report, 5 March 2009, para 169. Back
49
DWP's Commissioning Strategy and the Flexible New Deal, Work
and Pensions Committee Report, 5 March 2009, para 118. Back
50
Finn, D. (2009) The welfare market and the flexible New Deal:
lessons from other countries. Local Economy, 24 (1). Back
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