Work and Pensions CommitteeWritten evidence submitted by Community Links

1. Introduction

In previous DWP select committee responses and DWP consultation responses (2010–13) Community Links has repeatedly highlighted concerns over the existing functions of Jobcentre Plus. We recommended the Department for Work and Pension (DWP) carry out a review of its aims and objectives should be under the new benefits system Universal Credit. Furthermore we recommended that operationally, there could me improvements made in terms of local partnership working and quality benchmarks for customer service introduced.

Community Links has a programme of research dedicated to the modification of Jobcentre Plus (JCP). This programme grew out of the Working Age Poverty project we did for the European Year against Poverty in 2010, where we spoke to over 1000 people on benefits across the UK. When we asked what the key barriers to moving into work are, surprisingly JCP was listed as the number one barrier, followed by a lack of local jobs and then the benefits systems itself. From our experience of delivering a range of employment support provision and welfare advice services to our local community in Newham, the operations of JCP continues to be high concern to our organisation.

2. Background InformationInsert CL Paragraph

Community Links has a long and successful track record of delivering government funded employment support programmes. Based in Newham, the east London borough with one of the highest rates of long-term unemployment in the country, we delivered the New Deal from 1999 and became the most successful prime contractor in London and the South East for over four years. Since July 2011 we have been delivering the Work Programme as a subcontractor to the Careers Development Group (CDG). The majority of our clients have complex needs and require intensive support to help them into employment and remain there. We are confident about delivering the Work Programme and strongly welcome both the payment by results model and the black box approach to service delivery.

3. Summary

3.1 If JCP is to provide employment support in the future, its role needs to be clear and synchronized with the other existing provision. There is a need to avoid duplication, ensure consistent quality across all provision, work towards a shared aim and be held to account appropriately. Overall JCP performance should be judged in the same way that other providers are, based on employment outcomes—not off flow. There needs to be a separation of roles that work in harmony for the best interests of its customers.

3.2 JCP provision is patchy and can vary dramatically across geographical variances. Recent reforms have localised provision and handed over more discretion to district mangers and even frontline workers. This is a positive move, provided personnel are skilled to manage this increased responsibility.

3.3 Conditionality has become harsher but less effective. This is due to a lack of understanding how to use it and why amongst JCP officials. Training and accountability checks need to be put in place with an in depth monitoring system in place.

4. Jobcentre Plus’ Employment Services

4.1 Needs Assessment

4.1.1 In February 2011 Community Links gave evidence to the committee on Work Programme design where we stated that support services must be based on a person’s needs and barriers to employment, not the type of benefit they claim. This recommendation was based on the lack of understanding around customer needs that currently exists, or more accurately that gets diagnosed with the existing model.

4.1.2 As an employment support provider our programme of research on customer needs has illustrated the lengthy process of needs assessment, starting with Jobcentre Plus through to a prime contractor’s assessment and then the subcontractor’s assessment of need. In addition there is also the Work Capability Assessment and soon there will be the PIP assessment. Overall it can take up to two years, and on occasions longer for an unemployed persons needs to be fully identified and the appropriate support package provided.

4.1.3 Each assessment has different aims and is delivered by different bodies. It is not common practice to share the data collected from these assessments which can lead to repetition and ultimately inefficiency within the assessment system. Furthermore the repetitive nature has a detrimental effect on the customer moving into work as they can become frustrated and therefore disengaged from the process.

4.1.4 In the early days minor barriers to employment and the resulting support needs can often be manageably met. However, if not addressed early they can escalate and be harder to overcome, usually requiring more investment in support.

4.1.5 We recommend DWP carries out a cost benefit analysis of investing in a one stop shop holistic diagnostic assessment, delivered at the start of a persons benefit claim. The review should assess the cost of administration, including training and management, the cost of additional upfront support and the potential benefit savings made through people moving into work and staying there (as hidden needs will have been picked up and addressed, stopping them from resurfacing at a later date and jeopardizing employment).

4.1.6 The DWP to introduce a differential payment model that is based a client’s needs rather than on benefit type. This personalisation would be based on an in-depth needs assessment delivered by Jobcentre Plus as the service with a holistic understanding of local customers’ needs. This needs assessment will give prime contractors the information they need to create a “sophisticated and effective supply chain” that responds to the specific needs of the clients in their CPA

4.2 Get Britain Working (GBW)

4.2.1 GBW gives Jobcentre Plus advisers more flexibility in assessing claimants’ individual needs so that they can offer the support they think most appropriate, including access to a number of get Britain working measures. However the department has not invested in adviser’s assessment skills and no new assessment tools have been introduced. Therefore the success of Get Britain Working is dependant on the judgment of advisers, who often fall back on the benefit type for eligibility criteria to decide which customer to offer more intensive support to.

4.2.2 The concept behind GBW is commendable; however there is inadequate investment in the set of initiatives that fall under it. There also lacks an overarching strategy to bring the initiatives together with other existing programmes. For example, for a person who wishes to become self employed there is light touch enterprise club (which are mainly undersubscribed and run on a voluntary basis so the quality varies) there is the New Enterprise Allowance (which is time limited and only really suitable for the very capable and almost ready to go self employed) and then there is the possibility of a self employment support option on some (not all) Work programmes.

4.2.3 All three of these programmes are not joined up and lack overarching management. A claimant has to come off one programme before they can go on to another—and often start over again. Furthermore there is no dedicated enterprise manager within every Jobcentre and even within the department there remains no individual or team responsible for enterprise support.

4.2.4 We recommend the department establish an enterprise team to coordinate current provision for the self employment. They should be responsible for both enterprise policy and delivery.

4.2.5 We recommend that the initiatives under GBW are better designed around the needs of customers, not their benefit type and that they are incorporated into mainstream services to complement existing provision rather than be an additional option of support.

4.3 Jobcentre Plus’ role as a gateway to contracted-out services

4.3.1 Historically Community Links has had a strong and positive relationship with our local Jobcentre managers and advisers in terms of referrals and handovers. When we were a prime contractor under the New Deal we had a longstanding and personal relationship with staff which meant that we regularly shared information on clients the most up to date services on offer. We were able to coordinate the customer’s journey and identify who was responsible for managing it. We had a much better understanding of expected volumes so were able to plan in advance and we worked in a constructive way to engage and build relations with local employers.

4.3.2 We strongly feel this relationship has deteriorated as a result of the prime/sub contractor model. We no longer have the same dialogue with the local jobcentre and it is increasingly apparent that the services are becoming more fragmented. There only place for these vital relations to develop lies in forums like the Partnership Forums which is limited to prime contractors and DWP officials.

4.3.3 We recommend that Local partnership forums are introduced to allow for better communications between local providers, primes, and JCP and DWP officials to discuss necessary tweaks to policy and delivery issues.

4.4 Jobcentre Plus’ use of the Flexible Support Fund

4.4.1 Community Links has applied for a Flexible Support Fund (FSF). We believe the concept of the fund is a good on as it gives JCP the ability to commission services based on local need.

4.4.2 However we have raised concerns to the Department about the lack of national evaluation criteria for the FSF programme. We recognise that these programmes are about innovation, but in order to capture best practice there needs to be an overarching evaluation framework to disseminate what works well.

4.4.3 At the start of 2013, there were two Flexible Support Fund (FSF) projects in east London with a total spend of £33,108 whilst in the other regions of London there were a total of 76 projects with a total spend of £3,144,592. This presents an uneven spread of expenditure across London. As the funds are issued at the discretion of the JCP manager, the success of the FSF is largely dependant one person’s view of the programme, and on the relationship local organisations have with their district manager. As JCP has undergone a restructure these relationships may no longer be in existence.

4.5 The effectiveness of Jobcentre Plus’ relationships with other key stakeholders

4.5.1 In recent years there seems to be an increasing lack of collaboration between JCP and local partners including the local authority. We work well with our local authority but relationships with our local Jobcentre seem less productive.

4.5.2 This is likely to because we are no longer a prime contractor so communication is limited and dialogue is more difficult to establish.

4.5.3 It seems there is a compatibility problem between JCP and Work Programme providers specifically. Ultimately this is having a negative impact on the customer’s experience as it is unclear how both providers work together and who is responsible for what aspects of service delivery.

5. Jobcentre Plus’ Role in Relation to the Rights and Responsibilities of Benefit Claimants

5.1 The effectiveness of benefit conditionality

5.1.1 We are regularly seeing people being, what we consider to be, wrongly sanctioned. As a result our employment team is referring them to our advice team to appeal the decision.

5.1.2 The sanction, if applied wrongly, adds an additional barrier to the person’s journey back to work. This can have cost implications to the provider who may end up supporting the customer financially to over the loss of income.

5.1.3 Previously the discretion to issue a sanction lay with personal advisers on the Work Programme. This has been reformed and handed to Jobcentre Plus. We feel this was completely the wrong decision and is not productive for the customer or the support worker. As a consequence we are subject to refer people for a sanction, even if it is thought not to be a sanctionable offence—it has become a process driven approach which independent decision maker rule on.

5.1.4 This defeats the purpose of having conditionality as part of an employment programme. The threat of conditionality is as, if not more powerful than issuing them. Conditionality can be a very sophisticated tool, combined with a comprehensive package of support to moving people into employment. However it required a high skills level and a personal approach to utilise it effectively.

5.1.5 We strongly recommend that discretion is handed back to personal advisers and instead more thorough monitoring of the use of conditionality is implemented so that providers do not abuse it. Monitoring systems should check that all support needs have been mat, and a sanction is a last resort. They should also check that sanctioned are not being issued for a reoccurring offence, as evidence shows this is not effective.

5.2 The level and appropriateness of Jobcentre Plus’ use of benefit sanctions

5.2.1 The reformed conditionality regime has been made tougher, with a three year penalty introduced for the most serious offence. Through our advice services and employment programmes we are seeing a very negative impact of the new regime.

5.2.2 We feel that the severity of the sanction outweighs the offence. Sanctions are creating vulnerability and destitution. We see this on a daily basis.

5.2.3 The threat of a sanction is just as concerning for people as an actual sanction, because they are so severe and hastily issued.

5.2.4 There is variation on who gets sanctioned (The Guardian Scorecard).

5.2.5 In our advice services we have seen a large increase in sanctions related inquiries, most people do not know why they had been sanctioned.

5.2.6 Under UC, tougher sanctions are likely to have a negative impact on rent payments and result in more arrears.

5.2.7 There are very serious problems with the administration of sanctions at JCP:

They are being issued without a justified reason.

The act does not match the length of the sanction.

Advisers are placing unreasonable expectations on people eg daily sign on.

There is a strong sense that decision making for sanctions clearly isn’t working.

Personal circumstances are not being taken into account; single parents are being treated the same as other claimants.

People aren’t being told they can apply for a hardship loan. We have cases where people have been sanctioned for one year and are reliant on our food bank, friends and family support and on occasions shoplifting to survive.

5.2.8 The Secretary of State has assured us that sanctions will only be applied if a person unreasonably refuses to take up an offer of employment. Recent research1 by Joseph Rowntree Foundation states that the long-term effects of a sanctions regime has not yet been considered and evidence shows that sanctions lead to poorly paid, short term and insecure employment; creating the unemployment “loop” for many—and exactly what this Government is trying to reverse with a focus on sustainable and progressive employment. Particularly concerning, is the finding that “there is little evidence this will achieve the changes in behaviour sought”.

5.2.9 We recommend the department carry out a review of the functions of the conditionality regime, before further the implementation of the new sanctions regime. This review should look at the following:

Will sanctions apply to claimants that have been identified as having multiple needs?

Will sanctions be applied as part of a wider strategy to overcome the barriers claimants have which prevented them form taking up employment in the first place?

What assurances are there that JCP advisers will be adequately trained to use their discretion when applying sanctions?

What guidance will the DWP give to what is considered “reasonable” for an individual?

6. Supporting a Flexible Labour Market

6.1 Universal Jobmatch (UJM)

6.1.1 UJM has not proven that effective as it is not very accessible and has a lengthy and complicated registration process. It was felt by our Personal Advisers to be not very intuitive and require staff resource to support customers to use it.

6.1.2 There is a function to allow for an easy application of jobs; however this runs the risk of clients over applying for every jobs and therefore overwhelming employers. In turn employers may be deterred from recruiting for this reason.

6.1.3 From experience job brokerage with both local and national employers is much more effective and allows for applications to be tailored to employers needs and result in a higher recruitment rate.

6.1.4 We are finding JCP is burdening clients to use UJM, as a provider we occasionally have to distance ourselves from JCP in order to form a productive relationship with clients, but also with employers.

6.2 JCP and sustained job outcomes vs. off-benefit flows

6.2.1 For as long as Jobcentre Plus delivers employment support, it should be employment outcomes focused, and not benefit off flow driven. By focusing JCP objectives, there will be a change in performance and we believe the customer’s interests will be better supported and therefore employment levels increased.

6.2.2 A large proportion of JCP customers move into work fairly quickly, however they often end up back on the benefits system within three months. This is because work has been unsuitable for that individual or because underlying needs have not been met. If JCP was judged on sustained employment this issue would be addressed.

7 June 2013

1 Sanctions within Conditional Benefit Systems; A Review of Evidence. Joseph Rowntree Foundation, December 2010

Prepared 27th January 2014