Work and Pensions Committee - Universal Credit implementation: meeting the needs of vulnerable claimantsWritten evidence submitted by Community Links

Introduction

Community Links’ client group varies; we serve the needs of a community rather than people with specific issues/circumstances, for example homeless people or people with a disability. We also deliver the Work Programme as a Tier 1 subcontractor in East London and we deliver an advice service for local people; offering them help with applications for a benefit award or helping them to appeal a decision made regarding their award etc. We do not advertise our advice service yet we are consistently vastly over-subscribed with daily queues in reception leading outside of our front doors.

We see a large volume of people on our Work Programme, many of whom have multiple needs that require intensive, tailored support to gain employment and with general benefit claims. We deliver the ESF Families programme and the DWP’s Innovation Fund as well as a range of voluntary employment support programmes that support the varied needs of unemployed people. With the majority of our employment support we are required to deliver the conditionality regime on behalf of the Secretary of State. We have years of experience with sanctions and believer we have firmly grasped how to balance the duel role of conditionality and support to the maximum benefit of the customer.

Therefore, in this submission we have focused on two areas, firstly the delivery of Universal Credit as digital by default. We highlight what problems may arise based on our experience of providing welfare advice services such as form filling support, guidance on claims and appeals due to error. Secondly we have submitted evidence on the use of conditionality and sanctions based on our delivery of employment support services.

1. The proposed arrangements for claims and payments and the provision of support and advice for claimants, including the presumption of a predominantly online, self-service claims process; monthly payment to one person in the household; and arrangements for providing telephone and face-to-face support and independent advice for claimants who need it.

1.1 Advice

From April 2013, with the effective end of legal aid for welfare benefit issues, there will be a substantial (and in some areas complete) gap in availability of independent advice for claimants. For example, in Newham, there will be no funding for independent advice on welfare benefit issues, and as the sole provider of advice in this field we will be attempting to continue a service via cross-subsidy from other funding streams. It is unclear whether we will be able to deliver this. Local authorities are not sufficiently independent to replace this provision, given their administration of housing and other support (and from 2013, the social fund and council tax support).

An absence of independent advice has serious consequences for claimants and for the rollout of Universal Credit. For our clients, many of whom face multiple and serious barriers to using online or telephone services (including language and disability) and who will be dealing with significant change to their benefit entitlements, the absence of face-to-face independent advice will mean many missing out on support they need and are entitled to, undermining the principles of the reforms and with serious long-term consequences for their welfare.

Independent advice providers should be considered a resource by the Department for Work and Pensions (DWP), contributing to the smooth rollout of the reforms, informing where implementation or policy needs tweaking, and challenging where appropriate. We urge DWP to make funding available for independent advice agencies during the rollout of Universal Credit, with the funding designed in such a way as to promote constructive feedback on the reforms alongside independent advice for clients.

1.2 An online service

IT system

These are the main barriers our clients will face in using a digital by default system to claim and manage their Universal Credit award:

The majority of the people we see do not have access to a computer; many people do not have a computer at home and rely on public libraries etc.

Many of them are IT illiterate, or have poor IT literacy skills.

Language barriers; English is not the first language of many of our local residents, there are over 100 different dialects spoken in Newham. It is unclear if the IT system will be designed to provide different language formats to meet the needs of all claimants.

A high number of our service users have mental health problems which often go undiagnosed and will be hard to pick up via an online service.

Our form filling service has a high percentage of people with learning disabilities who may often struggle to articulate their needs and circumstances. They require face to face support but it is unclear how this will be detected with a digital by default system.

Claimants may be housebound due to physical disabilities and without internet access a digital by default system of claiming will be inaccessible.

A lot of our service users have, quite often severe reading and writing barriers. Again this often goes undetected and with a digital by default system may lead to increased error.

There are cultural barriers that already exist; people have spent years on the old system with potential negative experiences which means they no longer trust the system. It will be difficult to overcome this preconception and will require a period of learning for trust in a new system to develop.

Age will be an issue as many of our older clients are less capable of adapting to an online service.

Poverty will have an impact on accessibility, for example the cost to renew passports etc mean some people do not have any form of identification or national insurance numbers etc. Another example would be the cost to make a telephone call from a mobile phone will restrict people with very low incomes from using this service.

Debt and money management issues.

People that are in the process of determining their immigration status will be unable to provide all the information required and so the on line system will need to be able to support people in this situation in this way.

Universal Credit delivery

Delivery of welfare benefits, whether face to face, via telephone or online, comprises of both financial payments and detecting the level of support and conditionality appropriate for each customer. The Universal Credit IT system needs to serve at least three obvious functions

the initial application for UC award;

registering a change of circumstances; and

communicating the responsibilities of the claimant and the responsibilities of the state.

We would add an additional three more valuable functions:

Assessing people’s barrier to successfully entering and sustaining employment.

Detecting vulnerability amongst clients and highlighting the need for face to face support.

Engagement with employers.

We recommend the following principles behind the design of online delivery of Universal Credit:

Transparency.

Knowledge and understanding of application.

Chapters outlining the philosophy behind the questions.

Personalised—clear option for face to face or phone support.

Designed to detect vulnerability.

Designed to be as digitally inclusive as possible; use of online videos etc to enable the less IT literate to participate in online systems in some way.

Specific Recommendations

Simplicity and clarity in communications

Universal Credit IT should be developed and presented in “chapters” to inform and guide customers clearly through the process. They should be aware of what each “chapter” or “section” is in regard to and why it is relevant to them.

(a) Ensuring customers are fully able to convey the difficulties they face.

Often, but not always clients understand their own circumstances. However, even if they do, they are not always able to express their personal circumstances accurately.

We recommend that it is made very clear that customers are entitled to face to face support for help with applications if they so wish.

We also recommend that the philosophy behind a question is made clear so that the customer understands what the questions are asking for and why to ensure they answer it properly.

Form complexities

DWP language is not accessible to many of our customers and forms are updated on a regular basis and so customer’s previous experience of an application may no longer be relevant. Forms are complicated and are more accurately filled in if customers are able to read the form in its entirety first to understand the thinking behind the questions.

Plain English should be used for more customers to understand the process and clear explanations given for decisions being made.

An IT system should consider the use of an online translator.

It should clearly notify customers of changes made for applications.

Customers should be able to read through forms before filling them in online.

The option to print a form and fill it in by hand should be made easily available. (Currently you cannot do this with a child benefit form for example.)

Have absolute transparency behind the question; information should be provided so customers are able to make an informed decision, clients need to know the criteria behind the assessment.

Detection of specific circumstances/vulnerable clients and support available

Many customers who are vulnerable or have special circumstances will not self identify or they often do not know they have special needs. Online services run the risk of losing subjectivity, without the face to face discretion to detect such circumstances, an online UC system will easily miss detecting such issues. For example those suffering domestic abuse, those who require direct payments to their landlord etc. From our experience, trust is fundamental to identifying vulnerable customers. Our frontline advisers call it the importance of “building the bridge” together.

The IT system should be designed to detect vulnerability; customers may know their own issues but the IT system should be responsible for identifying these.

Alternative options of delivery: face to face support, phone services should all be made available and an adviser should have access to the customer’s online account following a number of security questions so that the customer doesn’t have to repeat all the information they have entered. An interactive help box should also be available.

A warning trigger should be send to Jobcentre Plus (JCP) if an application is not completed, where by a follow up phone call to check for particular problems, need for further support.

Monitoring and evaluation of those who request advice support or a paper application should be carried out to further develop the IT system to meet these customers’ needs.

Security

It is crucial that claimants trust an online service that they are entering a vast amount of personal details into. The customer must be assured complete security if accessing an account on a public computer. Also data protection issues will arise if applications are to be made per household unit; many people on low incomes live in shared accommodation. Some members of a household unit may wish not to disclose personal information being requested from the online application. It is necessary to be clear who is making the online application and who has access to the account.

Online services need to guarantee security, for people with particular needs it will be necessary to develop security cards that are developed in a particular way that is secure and practical, for example a way to remember login details etc.

There needs to be secure zones clearly identified within the online application.

Access

The majority of the people we see are either IT illiterate or do not have access to a computer at home. This will mean they require alternative methods of delivery, IT training or use of public computers. If using public computers in a public place, for example in a library there is usually a time limit on access which is very likely to jeopardise the efforts made to apply successfully. Furthermore, usually quite thorough proof of identification, address etc is required to sign up to a library before free use of computers is granted. Librarians are not trained to provide any type of welfare advice and so cannot assist customers with their applications. This is just one example of using public computers to access a Universal Credit account, make an application etc. There will also be very limited access to independent advice by the time Universal Credit starts to be delivered.

An increase of computer terminals should be made in all Jobcentres, available to all customers. Trained staff should be on standby to assist with any queries.

Jobcentres should also run basic IT training sessions tailored for specific use of Universal Credit online.

As part of the transitional plan independent advice should be funded to ensure error is minimised.

Online “chat rooms” or webinars should be built into the system with an adviser from central office at the other end to advise online customers on a technical error.

2. The proposed arrangements for the “claimant commitment”, sanctions and hardship payments

2.1 Conditionality used effectively

Community Links has a particular interest in the design and delivery of the conditionality regime. People in our local community that use our services are often significantly affected by this policy area. Furthermore it has a direct impact on our service delivery, in the free independent welfare advice we provide and on the back to work support we provide, including the Work Programme.

As an organisation with many years of experience delivering high quality employment support and providing advice to people hoping to appeal a sanction, we see the need to reform of the current conditionality regime. There are many aspects of the regulations on conditionality, the claimant commitment and sanctions that we welcome. For instance we fully support the ambition of clarifying why a person could be sanctioned and if they are, for what duration. Many people who use our services do not understand why they are being sanctioned, and in some cases do not even realise they have been sanctioned. The aim of detailing this in the claimant commitment is welcomed and should prove effective. We also welcome the intension to personalise conditionality regimes so that they are relevant in each individual—taking into account individual needs and circumstances.

However, as so much of the policy design is reliant on front line Jobcentre Plus advisers skills in using discretion, we remain concerned with the capabilities of advisers. We have concern over the quality of customer service; how competent and confident all frontline advisers are in identifying people’s needs, their hidden needs, and their barriers to employment and just as importantly, their perceived barriers to employment.

As a Work Programme provider we place a huge amount of emphasis on the importance of the adviser/customer relationship in order to establish an effective and supportive service. In our own service delivery we support our front line advisers to uphold the guiding principles outlined in our Deep Value1 report; trust, understanding, collaboration, commitment, communication and empowerment. We envisage the claimant’s journey back to work as a “mutual endeavour” and other providers in the welfare to work industry accept and support our Deep Value approach.

Conditionality plays a central role in delivering support services and we strongly feel it should be designed as part of a support package. Conditionality, like support, must be tailored to the individual. We understand that this is one of Government’s objectives however we know that to deliver a truly personalised service, this requires investment in skilling up front line advisers and management. The success of these regulations is solely reliant on the skills of the advisers delivering the resulting service. We would welcome further details on the guidance being issued to all advisers for implementing new policy and more information on how the department intends to ensure a benchmark on quality is consistently adhered to.

In our response to the initial Green Paper, 21st Century Welfare, where we were asked to comment on several principles underpinning reform. On specifically related to conditionality and we responded with the following which remains applicable to current policy on this area:

In contrast, we are concerned about the principle to “promote responsibility and positive behaviour, doing more to reward saving, strengthening the family and, in tandem with improving incentives, reinforcing conditionality.” We feel that language like “reinforce conditionality” implies that all claimants are under suspicion for wrongdoing.

From our experience claimants are keen to take on more responsibility and the structural reforms being suggested will naturally enable this. We recommend a principle that indicates reforms “will enable responsibility and recognise constructive activity that is deemed appropriate for family wellbeing by the claimant.”

We stress that it is not necessary to include conditionality in a principle that promotes personal responsibility; in fact to do so is detrimental to increasing autonomy. Instead we suggest that a more positive form of “conditionality” be designed into the personalisation agenda at Jobcentre Plus—it should be agreed in advance between the client and adviser, since each case will present very different circumstances.

2.2 Claimant commitment and rights and responsibilities

We welcome the claimant commitment for the purpose of clarity and fairness. We also think this will make the use of sanctions more effective. However we are concerned about the method of acceptance and recommend that the claimant commitment should be agreed upon rather than it “must be accepted”. This is because the claimant commitment will also document the type of support the adviser will also commit to providing and unless this is adequate for the individual they should not be required to commit to fulfilling actions that could otherwise lead to a sanctionable offence.

The three options outlined in the regulations rely on claimants being equipped to fully comprehend what they are committing to. More vulnerable claimants will most likely require face to face methods to gain a full understanding of the requirements. Face to face is also necessary for detecting needs and certain circumstances that should be accounted for in designing the claimant commitment. We recommend that face to face is also a method of acceptance.

We welcome the word encouraged in the purpose of the work focused interview and would like to see a better evaluation of the impact of encouraging people to move into work, separate from the evaluation of the impact of sanctioning people. If there are reasons why a claimant may not be able and willing to immediately take up paid work, these should be identified in the claimant commitment and the support to over come these barriers should be recorded within the claimant commitment.

2.3 Sanctions

We are concerned about sanction and mandatory work placements. There should only be a sanctionable offence if the mandatory work activity is considered reasonable in relation to the claimant’s needs and circumstances. There is little evidence to guarantee this is always the case in current provision.

For the high, medium and low level sanctions they should all be monitored and evaluated to assess the impact on behavioural change and compliance with a set of actions. Equally support should be separately monitored and evaluated to provide a clear understanding of what was successful in getting a claimant to comply with a set of actions.

Finally we are concerned about the introduction of a tougher conditionality regime prior to the introduction of Universal Credit. When Government have openly acknowledged the barriers claimants face with the current system to moving into work, its seems only logical and fair that tougher conditionality should only be introduced when government has removed the barriers that have been created by the structural design of the system itself.

Additional Relevant Policy

Community Links Minimum Service Standards—a new approach

1. Background

As part of the “Personalisation of Welfare” programme at Community Links, we have looked at the role of minimum service standards as a viable benchmark for measuring quality support against. This is particularly important in developing guidance to advisers that are responsible for issuing sanctions as well as adequately supporting claimants. We believe that current approaches need improving, particularly so as to:

Ensure a high quality, personalised service for all customers using the Work Programme and/or Jobcentre Plus.

Provide a framework to identify staff training needs and to design more effective approaches for monitoring and evaluating employment support services.

We advocate a new approach focusing on the effectiveness of the one-to-one relationships between front-line staff and customers.

While some parts of government are embracing ideas around the value of one-to-one in public service delivery, there are also powerful trends taking service delivery ever further from the human relationships that should be at its heart. These trends reflect a legitimate interest in saving costs and securing value for money and, in this context, it can appear that the benefit of investing in one-to-one relationships is difficult to measure and that working in this way is a luxury that we cannot currently afford.

However, our own experience over 30 years of providing services to people, backed up by research from a wide range of fields including employment, health, education and legal services shows that an effective relationship is instrumental to achieving desired outcomes. This is especially important when people have complex and chronic needs and lower levels of skills and confidence. Increasing the effectiveness of relationships is, therefore, a lever for improving quality, performance and value for money.

Many public services are not currently designed in ways that focus on enabling staff and customers to work together effectively to generate the best outcomes. Instead pressure is placed on these relationships through inappropriate targets, heavy administration, lack of time and tight budgets. This puts the relationship under such strain that the results are often frustration, resentment, bad service and poor outcomes. Some of this can be explained by the attitudes and behaviour of some staff and customers, but it runs deeper, to the wider systems for planning, administering, funding and reviewing services that contribute to poor working practices.

We need to turn the design of services on their head so that they start by focusing on the quality of the one-to-one relationship at the front-line.

2. New Service Standards

We have looked at how Minimum Service Standards can provide the basis for a service based on effective relationships. Behind this statement are accompanying materials both to help Advisors to develop these relationships and to monitor their success at doing this.

Design principles for Service Standards

The work uses a set of design principles:

The starting point should be dropping the word “minimum” from “minimum service standards.” From the outset it sends out an unhelpful message about services being the least, the smallest or the lowest. They can really just be called “Service Standards.”

The standards should be short, clearly addressed to the customer and written in Plain English.

The standards should support people’s capabilities at the same time as understanding their particular circumstances.

In addition to setting out the role of the service provider they should also set out what is expected of the customer, emphasising that achieving the desired outcome will be a shared effort.

The standards should not just be a statement of warm words but shape the practical delivery of the service.

Whilst seeking to shape the service, they should be also be consistent with the “black box” approach which gives providers flexibility in how outcomes are achieved.

The standards should reflect a customer’s whole journey, from initial referral to staying in sustainable work.

The following is a statement that would be given to customers with Jobcentre Plus or on being referred to the Work Programme.

Service Standard

These Service Standards set out how we will work together to help you move successfully into work.

Understanding where you are coming from

Our starting point is to build on your skills, experience and interests. In doing this, we will work with you to understand your needs and circumstances and work with you to find ways to take care of these.

Committing to a shared effort

For our work together to be successful, it needs us both to commit to doing all we can to achieve the end result.

Before your first appointment, we will have received all your details from the JobCentre and spoken to your previous advisor. We will give you a Personal Advisor who will meet you face-to-face within five days of your referral.

At your first meeting, you and your Advisor will discuss what you are hoping to achieve and your circumstances. Your Advisor will explain all the resources and options available to you and together you will draw up an initial action plan. You and your Advisor will keep this action plan under review and change it when necessary.

Working together to get you where you want to be

The aim from the start should be for both you and your Advisor to be honest with each other and to demonstrate a real willingness to work together. Your Advisor will help you to build on your strengths. At times, this may involve challenging you, where your Advisor feels this will help you to move forward.

You will be supported by the same Advisor throughout your time on the Work Programme so that you have the time to develop a good working relationship. Your Advisor will also stay in touch once you move into work.

Making sure we are making progress

At regular intervals in your time on the Work Programme you and your Advisor will sit down together to review progress, including looking at whether the standards set out in this statement are being met.

16 August 2012