Written evidence submitted by Access to
Benefits (A2B)
1.0 INTRODUCTION
1.1 A2B is a not-for-profit organisation with
a four year, fixed term life-span. Its vision is to empower and
enable the older people of Northern Ireland to maximise their
take-up of benefit entitlements.
1.2 A2B has developed online resources available
to older people, their carers and Voluntary Sector and Governmental
advisers to screen older people for benefit eligibility, prepare
their claims applications and submit their data for claims processing.
Additionally, it provides its all-age-group partners with the
online resources required to provide identical screening mechanisms
to other age groups.
1.3 A2B welcomes the opportunity to respond to
the White Paper. This response is in addition to our endorsement
of the Welfare Reform Group paper, submitted by the Law Centre
NI. In it we cover some general overarching points followed by
a more detailed analysis of key points within the White Paper.
2.0 GENERAL POINTS
2.1 A2B supports the Government's commitment
to "reforming the welfare system to make it fairer, more
affordable and to tackle poverty and welfare dependency, whilst
continuing to support the most vulnerable in society". There
are many problems with the current welfare system, not least its
vast complexity, and any moves to make it simpler and easier would
be welcome. We also welcome any moves to reduce fraud and error,
but this should be done with the interests of vulnerable claimants
in mind—fear of being accused of fraud and/or of making
a mistake in a benefit claim dissuades many older people from
claiming in the first place.
2.2 However, our biggest concern is that there
is very little detail within the White Paper as to how the reforms
will actually work in practice. Section 3 covers our main queries
and requests for clarification. It seems that, in particular,
the needs of older workers have not been considered in planning
Universal Credit, yet our population is ageing and both the State
Pension age and retirement age are rising.
2.3 The detailed comments below should be read
in the context of the gradual rise in State Pension age (SPA).
While the minimum age is rising for women, men cannot claim Retirement
Pension until 65, yet would be eligible for Pension Credit from
the time they reach the minimum SPA. This means that many people
aged over the minimum SPA will be in employment, or indeed seeking
employment. They may also have school-age children of their own
or be responsible for children such as grandchildren, or be carers
or have disabilities. The boundaries between working age and pension
age are becoming blurred and the Universal Credit needs to adapt
to this.
2.4 While we appreciate that the White Paper
does not specifically cover Northern Ireland and we will be responding
to the local consultation in due course, it is important that
devolved issues are taken into account in the overall framework
for Universal Credit as there is little scope to change the new
benefit at a local level once it has been established. Northern
Ireland has higher levels of disability, higher transport costs
and poorer childcare infrastructure, all of which make it more
difficult for those seeking employment.
2.5 It must be remembered that "welfare
dependency" comes in many forms. The most negative images,
perpetuated by the media, of benefit fraudsters and people who
do not want to work portray only the minority. Many older people
rely on the benefit system which they have paid into during their
working lives while many working people are supplementing their
low incomes with benefits such as Tax Credits or Housing Benefit.
Any changes must be fair to all these claimants.
3.0 DETAILED
COMMENTS
3.1 The remainder of this response consists of
detailed comments on the specific items within the White Paper.
Where appropriate, paragraphs are referenced.
3.2 Will the new single taper for Housing Benefit/
Council Tax Benefit also apply to the new housing element for
people claiming Pension Credit? (p15, para 8)
3.3 For how long will the additional amount be
paid to top up to previous benefit rates, if the claimant will
lose out under the move to Universal Credit? Will this be permanent
or time-limited? (16, 13)
3.4 We welcome any initiatives which might lead
to increase in take-up but on the other hand the prospect of sanctions
may well put off potential claimants. The White Paper states that
the simplicity of Universal Credit will lead to greater uptake.
Pension Credit is meant to be a simple benefit but it is still
widely underclaimed. Will people be made aware of how to claim
Universal Credit and how it applies to them? There are other barriers
which many people face, including language, literacy and mental
health issues, which will continue to prevent them from engaging
with the welfare system. Additionally, some people may not be
able to claim Universal Credit due to changes to eligibility for
other benefits eg Disability Living Allowance, Employment and
Support Allowance. (17, 17)
3.5 Will the existing criteria be used for additional
amounts for carers, disability etc? Will the concept of "no
worse off" also apply if the additional amount criteria are
changed and someone who was previously entitled to a premium no
longer meets the criteria? (18, 18)
3.6 We would direct the Committee's attention
to the work on disregards currently being carried out by OFMdFM
in Northern Ireland, looking at earnings disregards and child
poverty. (18, 18)
3.7 The White Paper states that "the model
introduced in 2008 for ESA has worked well". However, the
recently released Harrington report would show that there is much
room for improvement. We appreciate that the Department has taken
on board many of the recommendations but we would caution against
using the same approach for changes to other benefits in the meantime.
(18, 21)
3.8 We would welcome clarification on when decisions
will be made re carers. Recent research showed that carers in
Northern Ireland are missing out on millions of pounds of benefit.
It is vital that the future of benefits for carers is made clear.
(19, 27)
3.9 Who decides what is "fair but not excessive"
in terms of housing costs? There are many different circumstances
in many different areas and what is seen as fair for one person
might not be fair for another. For example, an older person receiving
State Pension and Housing Benefit should not be expected to have
to find new accommodation without help and support to do so. This
is particularly important if they have strong community support
structures which can be vital in preventing an older person from
needing hospital or care home accommodation. (19, 29)
3.10 Direct payment of Housing Benefit to the
individual is not always appropriate and there are many cases
in Northern Ireland where the payment is still made to the landlord.
What will be done to support the most vulnerable tenants if this
change is made? (20, 31)
3.11 We welcome plans to increase data sharing
but it needs to follow the most rigorous standards and procedures,
following too many cases of data losses which have made the news
in the past few years. It is important to keep claimants informed
of what you are doing with their data, in language they will understand.
(21, 37)
3.12 Much more detail is needed on changes to
Pension Credit and how they will work. Will the rates available
for housing costs and children be the same as for Universal Credit?
What about the tapers for housing costs? Will a claimant still
be able to claim for housing costs and help with children even
if they don't meet the means test for Pension Credit itself? (22,
48)
3.13 Much more detail is required on the differences
between working and claiming Universal Credit and not working
and claiming Pension Credit. For example, what will happen if
someone is claiming Pension Credit and then decides to take up
work, or vice versa? What will the process be for transitions
between the two benefits? Will a claimant be able to defer State
Pension and claim Universal Credit? No one should be worse off
in terms of the additional elements or passported benefits when
moving from one benefit to the other. The possible variations
in interaction between two different benefit systems could end
up making the system much more complicated for people over SPA.
(22, 49)
3.14 There may be future consequences of preventing
people from gaining National Insurance Credits. Care should be
taken that this is not causing new issues for the future when
these people may not have adequate pension provision. (23, 51)
3.15 Will recipients of Attendance Allowance
be exempt from the benefit cap if they are claiming Universal
Credit ie are over 65 with an illness or disability and are in
employment? (23, 52)
3.16 No mention is made of age throughout the
section on sanctions. What if the claimant is a single older parent
or guardian (eg grandparent) over SPA? What if someone over SPA
wants help with jobseeking? If someone over SPA is working and
claiming UC, will they be subject to sanctions? What about support
for people over 50 who find it harder to find work due to discrimination?
It seems that age has not been considered at all here.
3.17 The conditionality and sanctions outlined
do not take into account the need for there to be jobs available,
the need for training and support and the discrimination often
faced by older workers. (26, 4)
3.18 Lack of suitable childcare, particularly
in Northern Ireland, is a large barrier to participation. This
applies in equal measure to older parents and also to older people
who are responsible for a child, such as grandparents who have
stepped in when the parents are unable to do so. (26, 7)
3.19 The personalised approach to conditionality
is not balanced by any mention of personalised support. This is
of huge importance to older workers, people with disabilities
and the long-term unemployed, all of whom may need more specialised
help in finding employment. (27, 10)
3.20 Will "claimant commitments" be
required of jobseekers and claimants who are over SPA? (28, 12)
3.21 The wider costs and consequences of sanctions
have not been considered—sanctions are necessary in some
cases but may lead to other issues including marital breakdown,
drug or alcohol dependency or mental health problems. This will,
in time, put a strain on other services. (28, 14)
3.22 We would welcome clarification of whether
hardship payments will continue to be made at the existing level?
(29, 16)
3.23 Will Mandatory Work Activity be required
of jobseekers over SPA or will they be able to get help with finding
work without having to meet other conditions? (29, 17)
3.24 It may be difficult to nominate a lead carer
in some more complicated relationships or where the child(ren)
is in the care of a guardian eg grandparent. This needs to be
planned for. (31, 20)
3.25 We have some concerns regarding the idea
that people will not only have to find work but then increase
their hours or face sanctions—for many people, particularly
those with a disability, it is difficult enough to move into work.
Further pressure to then increase working hours may do more harm
than good. (31, 22)
3.26 If both members of a couple are over SPA
but one is working, will they have the option between Pension
Credit and Universal Credit or will they have to claim Universal
Credit? Or will one claim Universal Credit and one Pension Credit?
Again, much more detail is needed and thought should be given
to couples in this situation. (33, 5)
3.27 The White Paper states that claims will
"normally be made over the internet"—how else
can they be made? We welcome the idea of a single application
but more information is needed about how the system will work
for people who don't have internet access. (33, 5)
3.28 How will claimants be able to access their
claim information if they don't have the internet? How can claimants
notify the authorities of changes of circumstances without internet
access? (34, 8)
3.29 We believe that the three month continuation
of records is a good idea—will this also happen if the Universal
Credit claimant moves on to Pension Credit, in case they decide
to return to work? (34, 11)
3.30 While the White Paper does mention some
efforts for those without the internet, more detail is needed.
What will happen with ongoing communications eg award notifications—will
these continue to be sent out to claimants in writing? (38, 27)
3.31 Will people over SPA have access to the
support of the Work Programme, if they so wish? Many jobseekers
over SPA would benefit from tailored support. (39, 29)
3.32 As associate members of the Institute of
Revenues, Rating and Valuation, we are aware of many examples
of Local Authorities working towards better social inclusion and
benefit uptake. The years of good practice developed by Local
Authorities in the administration of benefits must not simply
be lost (39, 31)
3.33 The world of work is much more unstable
these days and many people work in more complicated patterns.
How will the real time earnings system cope with fluctuations
eg shift patterns, overtime, seasonal or term-time employment?
(43, 9)
3.34 We are very concerned about the possible
impact of £50 fines on older people in difficult circumstances
eg bereavement, serious illness. It is too easy for them to make
mistakes or forget to report a change in such circumstances and
there must be some level of flexibility to protect vulnerable
claimants. (43, 14)
3.35 There also needs to be protection from debt
recovery due to official error for the most vulnerable claimants.
(44, 19)
3.36 Stopping Contributions-Based Employment
and Support Allowance after one year is unfair to those with many
years of National Insurance contributions, particularly older
workers. (46, 1)
3.37 The White Paper states that after ESA (CB)
stops, people "may be able to" get UC. What if they
can't? There will surely be some gaps and this needs to be anticipated
now. The transition process needs to be clear and simple. (46,
8)
3.38 We welcome continued automatic payment of
Cold Weather Payments which are of great value to older people,
particularly in recent cold winters. (47, 10)
3.39 We are concerned that existing recipients
of passported benefits could lose out and would welcome further
detail on whether passported benefits will also be covered by
the principle of no one being any worse off after the change?
Passported benefits are very important to recipients—how
will they be administered outside the Universal Credit system,
for example with Pension Credit? (48, 14-16)
3.40 Will the idea that people will "automatically
receive everything they are entitled to" apply to people
receiving benefits outside the scope of Universal Credit? (52,
8)
3.41 We would like to see more information on
the potential impact on poverty for people who are working but
over SPA. (52, 9)
December 2010
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