Written evidence submitted by Fran Bennett
SUMMARY
- This evidence focuses on areas of concern. Broad
acceptance of complexity and work incentives as key issues should
not preempt critical examination of the proposals, or consideration
of alternative ways of achieving desired goals.
- UC merges three different forms of payment, with
differing implications for each.
- The Bill should not be rushed in while important
decisions remain to be taken.
- Some language used in the White Paper (eg "welfare
dependency") labels claimants and seems to contradict its
focus on financial disincentives to work.
- The UC encourages a combination of benefit and
work, however minimal, with continued conditionality; ensuring
progression in work will be critical.
- The focus is on getting one person in a household
into work, rather than recognising the importance of access to
independent income for all adults. It seems that some "second
earners" might face much higher withdrawal rates.
- "Real time information" may make the
"poverty trap" more visible. Previous in-work support
has been designed deliberately not to change immediately.
- Payment of UC elements for children to the "main
carer" would label them as being intended for children and
help ensure they were spent as intended.
- Fortnightly UC payments would match low-income
families' budgeting.
- The makeup of the UC should be itemised, to ensure
the various elements are clear; and if one element is in dispute,
the others should continue to be paid.
- Plans to "localise" various payments
will compromise certainty of entitlement.
- Carer's Allowance should be retained as a non-means-tested
benefit and improved. Child Benefit must not be absorbed into
UC in the longer term.
- The source of income, its recipient and its labelling
affect how it is used; this must be discussed in relation to UC,
especially insofar as it affects couples.
- Means testing is a source of much complexity
and disincentive effects. Other important sources of complexity
will remain (eg changes of circumstances).
- A "new contract" is proposed. But this
is rather one-sided for claimants. Conditionality is being tightened
first. And time-limiting Employment and Support Allowance breaks
the national insurance contract. Seeing the new contract as between
the haves and have-nots, and the aim as freedom from financial
support, betrays a narrow view of the functions of social security.
INTRODUCTION: NEED
FOR MORE
DETAILED SCRUTINY
1. This evidence focuses on areas of concern
about the White Paper (Cm 7957). There seems to be broad acceptance
of the significance of the two key concerns underlying itthe
complexity of benefits/tax credits and the need to ensure positive
work incentives. However, this should not preempt detailed critical
examination of the proposals, or consideration of alternative
ways of achieving the desired goals. (Alternative ways of achieving
simplification from claimants' perspective include such experiments
as the In and Out of Work pilot and the Tell Us Once project;
and work incentives can be improved by reducing the costs of working,
such as childcare and/or transport.)
2. The White Paper proposes merging three existing
forms of payment:
- out of work income replacement benefits for different
groups;
- in work tax credits and benefits; and
- some support for additional costs (not yet clearly
delineated).
Each of these three amalgamations has different implications,
which are not always clearly distinguished in commentary.
3. The Welfare Reform Bill is due in January.
But decisions on some policies central to the proposals have not
yet been taken. And the government has said it is keen to hear
from stakeholders. It would be better to delay the Bill until
these issues are decided. This would also give time for consultation
with claimants about relevant issues. Such a radical experiment
as this should not be proceeded with in its absence.
ASSUMPTIONS AND
LANGUAGE IN
THE WHITE
PAPER
4. It is unfortunate that the White Paper labels
as "universal" a payment which brings together various
means-tested benefits and tax credits, as "universal"
is usually used to mean non-means-tested. This may create confusion
in didscussions about different forms of social security payments
and their functions.
5. The recognition that uncertainty about being
better off, and anxiety about delays in in-work payments,[46]
may be a barrier to entering and/or increasing income from employment
is welcome (though its importance in relation to recent increases
in social security spending and dependence on out-of-work benefits
can easily be exaggerated;[47]
there are many other barriers to participation in work). But in
some sections of the White Paper, these financial factors seem
to be downplayed in favour of assumptions about "welfare
dependency", leading to a disproportionate emphasis on conditionality
and sanctions and a damaging labelling of claimants.
STIMULATING PROGRESSION
IN WORK
6. Some payments already cross the in/out of
work divide (including eg Child Benefit, Child Tax Credit). But
the UC abolishes the distinction entirely, encouraging claimants
towards a combination of benefit and paid work, however minimal.
Its impact on work incentives seems uneven. Proposed earnings
disregards vary depending on household type, and single people
will get none (whereas now even those on Jobseeker's Allowance
have £5 per week).
7. Stimulating progression once in work has hitherto
been achieved by such means as giving extra income at 16 hours'
and 30 hours' work per week,[48]
and more recently through the In Work Credit, as well as the Retention
and Advancement Demonstration scheme. In the White Paper this
is achieved instead by continuing conditionality for those gaining
some employment. It will be important to ask what plans there
are to improve the position of those who move into "mini-jobs".
8. It is important to support second earners
in couples, because two earners are much more likely to lift the
family out of poverty, but also because both partners then have
an independent income. The government's interest seems to be in
helping at least one person in a household into employment, rather
than in the work opportunities of both partners as individuals.[49]
But our qualitative research with members of low/moderate-income
couples in the Within Household Inequalities and Public Policy
(WHIPP) project showed that independent access to income was clearly
important for some women in particular.[50]
Family Action calculates that some 1.35 million households on
tax credits only could see their marginal deduction rate (MDR)
increase from 70 to 76%.[51]
It also appears that, for couples already above their earnings
disregard, the change could increase the MDRs of potential/actual
second earners under the tax and NI threshold from the current
39 (soon 41)% to 65% under UC. If this is correct, it would be
a detrimental change for a group ("second earners")
who are known to be more sensitive to work (dis)incentives, and
would encourage a more uneven division of gender roles.
9. Previous in work support has had fixed-term
awards, or a high annual disregard, in effect operating almost
like a non-means-tested benefit for people to build on with additional
income. But the faster adjustment of UC in response to earnings
increases achieved by the "real time information" which
will be available under planned PAYE reforms may make the "poverty
trap" much more visible, with an impact on work incentives.
MONEY FOR
CHILDREN
10. It is proposed that (jointly owned) UC should
be paid in one payment to one person in the household. It is unclear
how this will be decided for couples; and the White Paper leaves
open the possibility that payments for children could be made
to the mother/"main carer". The previous government
decided that Child Tax Credit (CTC) should be paid to the "main
carer" for families in or out of work.
11. It is crucial to pursue this option. Research
has shown that money paid via the "purse" rather than
the "wallet" is more likely to be spent on the children.[52]
In low/moderate-income families it is still the mother who tends
to take the main responsibility for meeting children's day-to-day
needs.[53]
Yvette Cooper MP recently cited evidence that 86% of CTC payments
for families in work go to mothers.
12. Moreover, paying the means-tested element
for children to the "main carer" means it is more likely
to be labelled explicitlyas Child Tax Credit isas
intended for children. This reinforces the message that it should
be spent on children, and makes this more likely. Research by
Goode et al. (1998, chapter 2) showed that how money was
labelled influenced the way it was perceived and used.
13. The prevalence of joint bank accounts may
be thought to make this less necessary. But our research with
low/moderate income couples for the WHIPP project found that,
whilst joint accounts were a powerful symbol of trust for couples,
their presence was not necessarily an accurate indicator of their
togetherness in terms of finances. In several cases, women felt
uncomfortable accessing the joint account, in particular when
children from a previous relationship were living with them. The
existence of a joint account is no guarantee of equal access to
money by both partners.
14. Leaving aside Child Benefit, the other payment
for children paid to the "main carer" is the childcare
element of the Working Tax Creditdone because research
(eg by Jan Pahl) showed that childcare costs were more likely
to be paid by mothers. The White Paper leaves undecided future
support for childcare costsvia a voucher system, an earnings
disregard or (as now) partial reimbursement of costs. Relevant
recent developments include the reduction of help from 80% to
70% of childcare costs; the White Paper proposes that those working
under 16 hours per week should also receive help with their childcare
costs, but from the current totalso others would receive
less. As Family Action has pointed out,[54]
withdrawal of childcare support may add to the marginal deduction
rates (MDRs) under the UC, in some cases resulting in over 100%
MDRs. But if childcare support is subsumed within UC, many mothers/"main
carers" in couple families could lose out. Payment should
continue to be made to the "main carer".
MONTHLY PAYMENT
15. The White Paper suggests that UC may be paid
in one monthly lump sum.[55]
The government recognises this may cause difficulties and suggests
people could be given help with budgeting. But there is no indication
of where resources for this might come from, especially given
current spending pressures; and it does not seem sufficient to
deal with the problem. Currently, many benefits can be paid fortnightly
rather than monthly; and research suggests that low-income families
value payments made more frequently than once a month for budgeting
reasons.[56]
16. Among the low/moderate-income couples in
our WHIPP research,[57]
spending often took gendered forms; the commonest pattern was
for the man to be responsible for bills which were more likely
to be monthly, whereas the woman tended to do the weekly shopping
(food etc.) and to be responsible for spending on everyday needs.
The pressures created by the need to manage resources on a monthly
timescale are therefore likely to fall in particular on women
(lone parents, largely women, and women in couples). Payment of
UC should be fortnightly.
SINGLE PAYMENT
17. The White Paper perceives advantages in paying
UC in one payment, bringing together different benefits and tax
credits. There is evidence that claimants can currently find the
interaction of benefits and tax credits problematic[58]though
there will still be interaction between help with housing costs
and the UC (eg see Annex 3, White Paper). Amalgamation of benefits
is not the only answer, however. In the Netherlands, for example,
claimants agree that changes in ceratin circumstances reported
to one authority can be conveyed to others too.
18. Lessons should also be learned from the lack
of specification of tax credits awards, which has caused many
problems. The makeup of the UC should be itemised (ie how much
each element, such as housing, extra help for disability costs
etc, is), so that claimants can understand its composition. If
an MDR is applied, there should also be a specified order in which
elements are withdrawn (as there is currently).
19. In addition, if payment is from only one
source"all the eggs in one basket"the
consequences of disruption are far more serious, especially for
those on low incomes. Whilst the White Paper recognises that there
must be some fall-back provision, this will inevitably take time
and effort to be activated. It is crucial that if one element
of UC is in dispute, the others continue to be paid.
20. These points about the design of UC all have
implications for children living in low-income families, ie for
child poverty in practice.
CERTAINTY OF
ENTITLEMENT
21. The UC is intended to bring about greater
certainty about entitlementt. But the government is considering
"localising" Council Tax Benefit. In addition, those
affected by Housing Benefit cuts may be able to access a discretionary
fund administered by local authorities. The Educational Maintenance
Allowance is being abolished, with some cases to be helped by
existing local learner support funds. The government is also seeking
to delegate Social Fund crisis loans and community care grants
to local authorities. This is all likely to make entitlement less
rather than more certain (or to replace entitlement with discretion
with similar effects).
22. If these localised benefits are withdrawn
using a taper, they will add to the marginal deduction rate proposed
for the UC.[59]
And how passported benefits, such as free prescriptions and free
school meals, are to be awarded and withdrawn is still unclear.
NON-MEANS-TESTED
BENEFITS
23. The White Paper raises questions about Carer's
Allowance. Carers UK[60]
has said: "we are pleased the White Paper does not currently
subsume Carer's Allowance within the UC, as this would have introduced
means-testing after 34 years of carers having an independent income.
Carers UK has made it very clear that we would not accept moving
carers' benefits away from this universal principle" (2010,
p 3). In our interviews with individuals in couples for the WHIPP
project, Carer's Allowance was crucial for several women in giving
them an independent income or helping to give more of a "say"
in decisions about the household income. Carer's Allowance should
be retained and improved.
24. The White Paper states that Child Benefit
will not be part of UC. Yet the Secretary of State was reported
as having hinted that it might be absorbed into UC in future.
It is crucial that Child Benefitwhich is simple to claim
and pay and does not cause work disincentivesis also retained
as a separate universal benefit for children's needs.
25. Contributory benefits will rightly continue
to be paid to the claimant themselves. But in a couple, this should
not automatically mean that UC is paid to the same person.
CONCLUSIONS
26. Many issues above are often not visible in
economic modelling but are critical to the ways households work
(or do not work) as financial units. They relate to the "social
meaning of money" within families, demonstrating:
"... the significance of the source of income,
its recipient, and the way it is 'labelled', for shaping both
perceptions and allocation of financial resources". (Goode,
J, Callender, C and Lister, R (1999), "What's in a name?
Gendered perceptions of benefit income amongst couples receiving
IS/JSA and Family Credit", Benefits, p 11).
More consideration needs to be given to these important
issues.
27. The two key concerns of the White Paper (see
above) are complexity and work disincentives. Means testing is
implicated in both. The most complex benefits rely on assessing
income (and often assets), especially as this may involve joint
assessment and therefore someone else's income and assets. The
more the system can be based on non-means-tested and individual
benefits, the simpler it will be; and the more easily it can provide
a floor for people to build on by their own efforts, whereas means-tested
benefits are usually reduced when income increases, inevitably
creating some disincentive. For these and other reasons, the remaining
non-means-tested benefits should be preserved and improved.
28. Other key sources of complexity will remain
under UCincluding changes in circumstances (eg a partner
moving in, or a couple separating), which are not much discussesd
in the White Paper but can trigger complicated adjustments. The
frequency of changes in low-income families' lives seened to surprise
some policy makers when tax credits were introduced. This must
not be allowed to happen again.
29. The White Paper says it is proposing a new
contractgiving greater certainty and improved work incentives,
and so expecting more from claimants (in increased conditionality).
However, conditionality is being tightened up before UC is introduced.
The contract has in any case always been rather one-sided in terms
of power relations between the individual and the state;[61]
and with UC, control over most of a household's income will rest
with only one department rather than several.
30. The clearest example of a contract in the
social security system is the national insurance scheme, in which
risk is pooled through paying contributions in return for protection
in adverse circumstances. However, the wider context of the White
Paper includes time-limiting contributory Employment and Support
Allowance for the work-related activity group to one year, representing
a disruption of the existing national insurance contract.
31. The White Paper also describes its proposed
contract as being between taxpayers and claimantsbetween
the haves and the have-nots; and it endorses an ambition for individuals
to be free of financial support from the state. But this is a
narrow view of the multiple functions of social security, which
does not just relieve poverty or help people back to work, but
also prevents poverty, enables risk sharing, provides compensation,
distributes the cost of bringing up the next generation between
parents and the community, facilitates saving etc. In addition,
benefit claimants are also taxpayers, via indirect taxes but sometimes
also paying income tax. And all of us are in practice dependent
to some extent on financial support from the state, through tax
allowances and reliefs or in other ways.
December 2010
46 Throughout this evidence "work" refers
to paid work unless otherwise specified. Back
47
See, for example, HM Treasury (2010), Overview of the Impact
of Spending Review 2010 on Equalities, London: HMT, para.
2.3. Back
48
See, eg, Millar, J, Ridge, T and Bennett, F (2006), Part-time
Work and Social Security: Increasing the Options Department
for Work and Pensions Research Report No. 351, Leeds: Corporate
Document Services. Back
49
See Bennett, F (2010), "Gender analysis of transfer policies:
unpicking the household", in V Uberoi, A Coutts, D Halpern
and I.McLean (eds.), Options for Britain II: Cross-cutting
policy issues-changes and challenges, Oxford: Wiley-Blackwell,
pp. 100-116. Back
50
This was part of the Gender Equality Network funded by the Economic
and Social Research Council (www.genet.ac.uk):
RES-225-25-2001. Back
51
The Universal Credit: Marginal returns? Assessing the impact
of the Universal Credit on marginal deduction rates, London:
Family Action. Back
52
Lundberg, S J, Pollak, R A and Wales, T J (1997), "Do husbands
and wives pool their resources? Evidence from the United Kingdom
child benefit", The Journal of Human Resources 32(3):
463-480. Back
53
See, eg, Goode, J, Callender, C and Lister, R (1998), Purse
to Wallet? Gender inequalities and income distribution within
families on benefits, London: Policy Studies Institute; and
other evidence, eg from the Within Household Inequalities and
Public Policy research project. Back
54
The Universal Credit: Marginal returns? Assessing the impact
of the Universal Credit on marginal deduction rates, London:
Family Action. Back
55
Note that monthly is different from four-weekly, and that many
direct debits are made from bank accounts on a fixed day of each
calendar month, regardless of when payments are paid into the
account. Back
56
Thanks to Jackie Goode, University of Loughborough (J.E.Goode@lboro.ac.uk)
(Goode et al., 1998, p 94). She has also been involved
in a recent longitudinal study of credit and debt for the Joseph
Rowntree Foundation, which she reports demonstrated that frequency
of payment was significant in influencing food purchase and consumption. Back
57
See, eg, Sung, S and Bennett, F (2007), "Dealing with money
in low- to moderate-income couples: insights from interviews",
Social Policy Review 19, Bristol: The Policy Press. Back
58
See, for example, Bennett, F, Brewer, M and Shaw, J (2009), Understanding
the Compliance Costs of Benefits and Tax Credits, London:
Institute for Fiscal Studies, pp. 44-45. Back
59
The withdrawal rate in the White Paper already includes Council
Tax Benefit, however. Back
60
Carers UK (2010), "Universal credit: welfare that works:
White Paper on welfare reform", Policy Briefing,
London: Carers UK. Back
61
Griggs, J and Bennett, F (2009), Rights and Responsibilities
in the Social Security System, Occasional Paper 6, London:
Social Security Advisory Committee. Back
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