The benefit cap Contents

3Is the benefit cap fair?

50.The Government said that one of the main aims of introducing the benefit cap was to:

Introduce greater fairness between those on out-of-work benefits and taxpayers in employment.74

The Minister reiterated this argument in oral evidence:

We also wanted to put in place a reasonable limit … .We did not think it was right for hardworking families often seeing people able to get more in benefits than they were able to get through full time work themselves.75

Fairness in the existing benefit system

51.The cap limits a household working less than the required 16 hours per week to £23,000 in London or £20,000 for households in the rest of the UK. The Government has argued that this is “fair” because around 4 in 10 workers earn this amount or less. However, this does not include the additional benefits to which in-work families are entitled, such as Child Benefit, Child Tax credit and Housing Benefit. Organisations such as CIH and Child Poverty Action Group (CPAG) told us that this results in a “false comparison” between some of the income of working households and all of the income of those who aren’t working. CPAG argued that the Government’s claim is therefore misleading as it implies that in-work households are in a similar position to capped households and face similar choices on, for example, where they should live.76

52.Both analysis by the CIH and analysis we commissioned from the House of Commons Library showed that fairness, as defined by the Department, is already built into the system—as households are better off in-work than similar households on benefits even without the cap.77 For example, the Library’s analysis showed that a single parent with three children earning £20,000 (after tax and National Insurance) is around £8,000 (or £150 per week) better off than they would be on out-of-work benefits.78

53.When the cap is applied, the gap in income between those in work and those considered out of work by the Department can equate to tens of thousands of pounds. The Library’s analysis (see figure 6) showed that the greater the number of children in a family, the larger these gaps become. For example, a working single parent with three children would be around £12,000 better off than their out-of-work counterpart, while a working single parent with five children would be around £22,000 better off.

Figure 6: Single parent income scenarios

Interaction with the two-child limit

54.If a family is subject to the two-child limit these income gaps are reduced. The two-child limit means that a family can only claim child benefits for two children, unless their third or subsequent child was born before 6 April 2017 or special circumstances apply. As shown in the figure below, a family with three children would be around £8,000 better off in work if subject to the two-child limit, as opposed to £12,000 better off if the two-child limit was not in place. Josephine Tucker of CPAG explained “the two policies broadly work in a similar direction for larger families”. She also highlighted that, for some families, the two-child limit could effectively remove the work incentive the benefit cap intends to create, because those families would not see a significant increase in income if they moved into work.79

Figure 7: Income scenarios for a single parent with three children

Source: House of Commons Library analysis

55.For the moment, it is likely that the majority of capped claimants are not affected by the two-child limit because their children were born before April 2017. However, as time goes on, more and more families will be affected by the two-child limit. As this happens, the work incentive offered by the benefit cap will be further eroded. We have already raised concerns about the impact of the two-child limit, and plan to look at that policy in a wider inquiry.80

56.CPAG also pointed out that there is no provision in legislation to ensure that the cap rises in line with inflation.81 Its analysis found that a family with three children on benefits were already 40% short of affording what the public deems to be minimum acceptable standard of living—”a well researched process, costing a basic no-frills but acceptable standard of living in the UK”—before the implementation of the lower cap (a £200 a week shortfall). By 2021, due to the rising cost of living and the lower benefit cap, it said that this gap will have doubled and the same family will have barely a third (36%) of what they need. Without the cap they would still face a shortfall of almost half (47%) of what they need.82

57.We are not convinced by the Government’s argument that the cap restores fairness to the benefit system. Families in work were already better off than similar families who were out of work, even without the cap. Furthermore, the Government sets the cap by referring to earned income, without taking into account the additional benefits that in work families can receive. This means that, when the cap is in place, differences in income between capped claimants and similar families in-work earning the cap limit can amount to tens of thousands of pounds. The greater the number of children in a family, the more pronounced these differences become—from a difference of £12,000 for a single parent with 3 children (a third of capped households), rising to £22,000 for a single parent with five children (5% of capped households). Comparing only part of the income of an in-work household with all of the income of a capped household is not fair. The result of this is that the benefit cap is set far too low.

58.We recommend that the Government increases the current cap limits, by taking account of in-work benefits as well as earnings when calculating the limits. It should also ensure that cap levels are uprated in line with inflation.

Impact on claimants unable to escape the cap

Financial shortfalls

59.CPAG stressed that the benefit cap ‘breaks the link between need and entitlement’, which it argued was ‘fundamental to a means tested social security system’. We heard that households unable to escape the cap are left with significantly less money than they need.83 DWP’s most recent statistics show that, as of November 2018, 58% of households had their Housing Benefit capped by £50 or less a week, a further 29% of households were capped by £50–100 per week and 13% (6,390) of capped households had their Housing Benefit capped by more than £100, including 0.3% (180) capped by more than £300 a week.84 Weekly reductions to capped households’ Housing Benefit are shown in the figure 8 below.

Fig 8: Capped households by weekly amount capped, at November 2018 (Housing Benefit only)

Source: DWP Benefit Cap statistics to November 2018

60.Organisations including Policy in Practice and Shelter told us that these reductions simply do not leave most families with enough money to cover their basic needs.85 Shelter told the Committee that “housing costs are now so high, and the cap is so low, that it is not possible for thousands of families caught by the cap to both pay rent and avoid destitution”.86 Its analysis to determine whether families affected by the cap would have enough money to pay for “a set of very basic essential family costs” after paying their rent found that a one-parent family with three children would not be able to meet their living costs in a third of the country and a one-parent family with four children would not be able to meet these costs in 43% of the country. Giovanni Tonutti told us that Policy in Practice’s analysis of 11 local authorities had found that around 60% of claimants who are not able to escape the cap faced a shortfall between their monthly income and their estimated costs.87

Impact

61.The majority of evidence to our inquiry stressed that the “intolerable” financial position the cap places families in is causing poverty and hardship.88 We heard evidence that many households were falling into rent arrears, and in some cases losing their homes. Witnesses also told us that families who were unable to escape the cap were buying less food, resorting to foodbanks and turning off their heating.89 Rob Gowans, Policy Officer for Citizen’s Advice Scotland (CAS), told us that CAS had seen cases of people not moving in with their partner to avoid the cap and at least one case where the stress of the cap caused a relationship to break down.90

62.We also heard from four people who had been subject to the cap. They told us about the impossible choices they have had to make: between paying rent, heating their homes, providing for their children, and having enough to eat.91

Box 1: Coping with the cap, video testimonies.

“It was either feed the kids or pay the rent” - Sally, single mother of four children

“You can’t afford to eat, you can’t afford to put your heating on, it’s a case of heating or eating basically … .my eldest lad used to leave food because he knew I ate the leftovers… you don’t want to take food away from the children as you don’t know when you’ll next be able to [buy it], because you’re robbing Peter to pay Paul at this stage …..do you pay rent or do you pay your council tax? Do you buy food, or do you pay your electric?” - Paula, single mother of three children

“It was a case of do I feed the kids or pay the bills? I chose to feed my children and just got in more and more debt” - Jo, single mother in temporary accommodation

“When the children went to school, me and my partner used to sit there in the cold with jumpers and coats on, so we could afford to have the heating on when they came home. As soon as they went to bed at night, it went off, we sat in the cold again” - Emma, mother of four children caring for her sick partner

Source: Claimant videos

63.We heard how these “very desperate” situations can cause “enormous stress” and exacerbate existing mental health conditions.92 This theme also came through in witness testimonies.93

Box 2: Stress and anxiety, video testimonies.

“ I couldn’t cope very well. I didn’t cope very well at all, due to debt pushing me over the edge, I got sectioned once because of it, I’ve been on antidepressants for years because of it, and I was offered no support whatsoever, I didn’t know where to turn.” - Jo single parent in temporary accommodation

“Because he can’t work, he thinks that he’s failed me and the children so he’s got a lot of anxiety and depression problems and because he’s got the anxiety and depression problems, I’m now on antidepressants, I feel like a bad parent, I feel like I can’t contribute maybe and look after my family” - Emma, mother of four children caring for her partner

Source: Claimant videos

Impact on children

64.CPAG stressed that the “main losers” from the benefit cap will be children. It cited research from the Public Policy Institute that showed the benefit cap will lead to 200,000 more children living in severe poverty - below 50% of the median income.94 We also heard that parents are having to cut back on healthy food and essentials. In addition, witnesses told us that some parents are unable to pay for school trips and activities or are cutting off their internet—affecting children’s progress and their ability to do their work.95Sally told us her story.

Box 3: Sally’s story

Sally, a single mother of four children was told she had thirty-nine weeks to find a job or she would have her benefits capped, after her husband left her. Three weeks before her rent was due she received a letter telling her that her Housing Benefit would be reduced to £150. She did not have the money to pay the £750 shortfall in her rent and quickly built up rent arrears. When her ex-husband did not pay her maintenance money she was forced to go to a foodbank and is living on £7 a day to cover the essentials for herself and her four children. She tried to keep the effect of the cap away from her children, but this was impossible: she has had to move house a number of times, which has meant her children have had to move schools several times within a very short time period.

Source: Claimant videos

Human rights

65.Organisations including Gingerbread and CPAG drew attention to the Supreme Court’s 2015 ruling, which found that the original cap’s application to single parents with children under two breached the UK’s international obligations in relation to children under the UN Convention on the Rights of the Child ([2015] UKSC 16). In her concluding statement Lady Hale, now President of the Supreme Court, said:

The prejudicial effect of the cap is obvious and stark. It breaks the link between benefit and need. Claimants affected by the cap will, by definition, not receive the sums of money which the State deems necessary for them adequately to house, feed, clothe and warm themselves and their children. It cannot possibly be in the best interests of children affected by the cap to deprive them of the means to provide them with adequate food, clothing, warmth and housing, the basic necessities of life.96

CPAG said it was “alarming” that in the light of this judgement, the decision was made to lower the cap further.97

66.The Government successfully appealed this judgement in March 2018. However, the case was considered again by the Supreme Court in July 2018, alongside a further judicial review which challenged the application of the benefit cap to all single parents and in particular to lone parents with children under 5. The ruling is awaited.98

Monitoring the impact of the cap

67.The Department’s evaluation of the original higher-level cap (£26,000) reported that most interviewees said that they were “getting by but struggling”.99 It found that people were buying less food, not paying other bills, turning down the heating and borrowing money from doorstep lenders. Over a third (35%) of those affected by the original cap reported spending less on “household essentials”.100 It is particularly concerning that despite evidence—from its own research—that the cap was causing considerable hardship for many claimants, the Government decided to lower the cap limits potentially fuelling more illegal lending and other crime.

68.Witnesses, including CPAG, expressed concerns that the Department has not published any evaluation of the impact of the lower cap. The Department told us that it has commissioned the National Centre for Social Research to carry out an evaluation of the lower cap which includes a survey of capped claimants and case studies of local authority areas with jobcentre staff, local authorities and local support agencies. It plans to publish this evaluation in Spring 2019.101

69.This is all the more concerning given that even without the cap, benefit claimants have seen reductions in the value of their income due to various caps and freezes to benefits and tax credits since 2010. This will have reduced the real incomes of out-of-work households by at least 5.7% by 2019–20 compared to a 19.6% increase in average earnings for working households.102 The Committee heard that the freeze to working-age benefits has reduced household resilience to income and expenditure shocks, and left households at greater risk of destitution.103

Reassessing the cap limits

70.The Minister told us the benefit cap limits must be reviewed by the Secretary of State at least once every Parliament. In correspondence he set out that the Department plans to publish its evaluation of the lower cap in Spring 2019, and said, “the level of the cap will be reviewed in due course following the publication and in the fullness of this Parliament”.104

71.The Department decides whether people are entitled to benefits, and how much it thinks they need to live on. It is therefore inevitable that the benefit cap, which takes some of that money away, leaves many families without enough money to meet even their basic needs. Parents are left making impossible choices: whether to pay their rent, feed their children or heat their homes. Many experience stress and anxiety because of mounting debt and insecurity; we even heard cases of relationships breaking down and in some cases families losing their homes. Bluntly, the Government’s policy is plunging families into hardship—but it is only just beginning to consider the impact. It last looked at this in 2014 when the cap was set at £26,000. Its next evaluation of the impact of the cap will be published in spring 2019—more than two years after the lower cap was introduced. Given the backdrop of various caps and freezes to benefits and tax credits since 2010, which mean that even without the cap, benefit claimants have been significantly left behind—real incomes of out-of-work households will have reduced by at least 5.7% by 2020 compared to a 19.6% increase in average earnings—a competent Department must surely recognise that assessing the impact of the cap every 5 years is unacceptable.

72.In order to ensure that families do not face hardship because of the cap, the Department should:

Temporary accommodation

73.Local authorities often use more expensive temporary accommodation to house homeless households. Research by Shelter Scotland showed that temporary accommodation can be 282% higher than the local housing allowance rate.105 In its 2014 report, Support for Housing Costs in a Reformed Welfare System, our predecessor Committee called on the Government to exempt households in temporary accommodation from the cap on the basis that “these claimants have no choice about where they are housed and few options for reducing their housing costs.”106 Evidence to our inquiry reiterated this argument. We also heard that households who attempt to move elsewhere to escape the cap risk homelessness as they may be deemed to be intentionally homeless and they would lose priority for housing.107

Box 4: Jo’s story

Jo was in temporary accommodation when she was affected by the benefit cap. The cap meant that Jo needed to find £117 a week to cover the shortfall in her rent, which was £330 a week in total. She went from being in credit with her rent to being in £400 of rent arrears within 3 weeks of the cap setting in. Jo lost her home and was transferred to different temporary accommodation, which she has been in for 8 years, resulting in thousands of pounds of debt. The stress of being in debt led to mental health problems that meant she struggled to leave the house and was sectioned at one point. Jo told us that her decision to return to work, for her own mental health, has actually left her worse off and in even more debt.

Source: Benefit cap; claimant videos

Department’s rationale for capping households in temporary accommodation

74.When asked why the Government would not exclude households in temporary accommodation from the cap, the Minister said:

Because it is only meant to be temporary by nature. It keeps all the organisations, plus that household, focused on looking for the long-term solution.108

He argued that households in temporary accommodation should be supported by Discretionary Housing Payments (DHPs)—funding provided to local authorities to help claimants who struggle to adjust to the cap.109 The Minister confirmed in correspondence that the Department has not conducted any analysis on the impact of temporary accommodation on a claimant’s ability to move into work.110

75.We stand by our predecessor Committee’s conclusion in 2014 that capped claimants in temporary accommodation are immediately put at a disadvantage: they are placed in expensive accommodation over which they have no choice. We do not agree with the Government’s argument that the cap should continue to apply to these households simply because it maintains pressure on local authorities to find a long-term solution. It is clearly not the claimant’s fault that their accommodation is significantly more expensive, so it seems ludicrous to apply the cap in these circumstances.

76.We recommend that the Government immediately exempts all claimants in temporary accommodation from the benefit cap.

UC claimants

77.Organisations including CPAG and London Councils explained that the way the benefit cap is applied in UC—to the overall award, not solely to a household’s housing costs—can leave households in “even more severe hardship” as it can go “deeper into your benefits including benefits that were expected for children”.111 If the amount a household is to be capped exceeds their housing costs, the cap can then eat into other parts of a claimant’s award such as their standard allowance, as well as child and disability elements. Josephine Tucker of CPAG noted that if claimants had other deductions—such as repayments of Advances—in place, their income could be even further reduced as deductions are applied after the cap has been calculated.112 The Department explained that the original approach of only capping a household’s Housing Benefit under the legacy system was “a bit of a stopgap”, and that the way the cap is operating under UC is “delivering the policy intent”.113

78.Claire Horton, Service Improvement Lead for Newcastle City Council, said that “because [UC] is eating into the personal allowance as well, not just the housing costs it can really go wrong”. She noted that a family in Newcastle on UC was losing £885 per month because of the cap. She explained that the family were in ‘difficult and desperate’ circumstances and that the children were about to be removed because of neglect.114

79.The Minister was not able to provide data on how many households had been capped by an amount greater than their housing costs in Universal Credit.115 However, in correspondence, he explained that in August 2018 around 10% (5,500 of the 58,000 households capped) had the full amount of their Housing Benefit capped. He said that this “may indicate that further reductions should have been applied”.116

Direct rent payments

80.Several witnesses, including CPAG, also told us that when a household’s rent is paid directly to their landlord (known as a managed payment to landlords), families can be left with zero income to meet their living costs as their rent is paid in full to their landlord and it is the rest of their benefits which are reduced. London Councils noted that some councils had asked for managed payments to landlords to be stopped but stressed that this does not solve the problem as “you are still left with not enough to pay your rent and pay for basics like food”. They noted that, while the numbers of UC claimants affected by the cap are currently relatively low, this could become a “serious issue” as increasing numbers of capped claimants are migrated to UC.117

81.Where a UC claimant’s rent goes directly to their landlord, they can find that the benefit cap leaves them with nothing. This is because their rent is paid in full to their landlord and the cap deduction is taken from their living costs. Removing the direct payment merely puts claimants in the position of being able to make the difficult choice between paying their rent or buying essentials—like food for themselves and their children. However, it is imperative that claimants are made aware that if their direct payment remains in place they could be left with nothing.

82.Until the introduction of Universal Credit, because of practical limitations, only Housing Benefit could be capped. Under Universal Credit it is not only a household’s housing costs that can be reduced, but its whole UC award. That means that the cap can cut far deeper into the entirety of a household’s income—including even money intended for children. The little money that these households have left can then be further reduced by deductions to their UC awards, which can include the repayment of Advances necessary to tide people over during the five- week wait for their first UC payment. The Government says simply that this is how the cap is supposed to work, but the risk that it leaves even more families facing severe hardship is obvious. Due to the delayed roll out, the number of capped households on Universal Credit so far is small, but it is rising. Already we are hearing the appalling effects of families being left with so little, including—in extreme but real instances—children being taken into care because of neglect. Given the Minister’s indication that the proportion of households on Housing Benefit who should have been capped beyond their housing costs was around 10%, we estimate that any additional savings from applying the policy as intended under Universal Credit would not be substantial.

83.We recommend that the Department ring-fence elements of UC to ensure that claimants are not left without money for food. Specifically, the cap should not be applied to the following elements of a claimant’s UC award:

In response to this report the Government should also provide an estimate of how many people it expects to be capped via Universal Credit and how many people it expects to be capped via Housing Benefit, once UC is fully rolled out.

UC assessment periods

84.Problems arising from how frequently a claimant is paid and when their UC assessment period falls have already been widely reported. In January 2019, the High Court ruled that the way in which the Department has been assessing income from employment through its UC assessment periods is unlawful. The four claimants in the case received their monthly salaries on or around either the last working day of the month. This meant that there were times when they received two months’ worth of salary within one assessment period. In their judgment, judges in the case said that treating claimants as having earned twice as much as they do if they happen to receive two pay cheques in one monthly assessment period, and as having no earnings in the next assessment period is “odd in the extreme” and “ … . could be said to lead to nonsensical situations”.118

85.CPAG explained that in the context of the benefit cap, people on UC whose paydays do not align with their UC assessment periods can face serious financial losses and that there can be “arbitrary differences in awards between claimants purely because of when their paydays fall”. For example, if a claimant is paid four-weekly rather than monthly they will usually be paid their wages once in eleven of their UC assessment periods and twice in one assessment period, because they are paid thirteen times in one year. This means that if they earn just over the benefit cap threshold on a monthly basis, they will be paid slightly under the cap threshold in eleven months, but well above the threshold in the one month they are paid twice. This can result in them being capped in eleven months out of twelve, while someone with identical earnings would never be capped. An example of this is given below.

Box 5: Example of unfair capping due to UC payment scheduling

A single mother working 17 hours per week is paid £510 every four weeks. The monthly equivalent would be £552.50–enough to mean that she would not be benefit capped if she were paid monthly. However, as she receives less than this in almost all assessment periods, except the one in twelve where she is paid twice (receiving £1,020), she is benefit capped almost every month.

Source: Child Poverty Action Group (BEC0022)

86.Figure 9 shows the different ways that people working 16 hours per week on the National Living Wage—the level at which the benefit cap should not apply—nonetheless face being benefit capped up to 11 months each year, depending on when their pay frequency and assessment period dates.

Figure 9: Examples of how claimants earning the same wage can be unfairly capped depending on their pay frequency and UC assessment period dates.

Source: Child Poverty Action Group (BEC0022)

87.CPAG told us it had suggested a solution to address this issue to the Department. It recommended using existing arrangements for averaging earnings, which are currently used to determine whether claimants are earning enough to exceed the threshold for in-work conditionality—if they are in work but below the threshold they may be required to look for more work in order to receive UC and face sanctions if they do not continue to seek additional work. The averaging, which is done to make sure the system does not unfairly penalise people, currently has to be done manually. CPAG recommended the system be applied immediately due to the “serious financial losses for affected claimants”.119

88.In oral evidence the Minister told us the Department is aware of the issue and is looking into it.120 In correspondence, he confirmed that the Department does not know how many people have been affected by the issue but estimated this would be around 1% of those capped via UC (around 98 households).121

89.Courts have already found that the interaction between how frequently people are paid and when they receive their UC award can lead to unfair financial losses for claimants. In the context of the benefit cap, the alignment of a claimant’s payday and UC assessment period can mean that people who are earning enough to escape the cap are capped anyway. It is wholly unacceptable that going to work, as the Department wants and encourages people to do, can leave people suffering significant financial losses simply because of a fundamentally flawed administrative process. Worse still, the Department does not even know who has been affected. This is clearly not how the cap was intended to work and requires an urgent solution.

90.We recommend that the Department urgently finds a solution to ensure claimants are not unfairly capped because of the alignment of their payday and UC assessment period. It should identify all cases where the cap has been applied incorrectly and ensure claimants are fully compensated before September 2019. The Department should write to the Committee with an update of progress each month.

Discretionary Housing Payments as a safety net

91.The Department argues that Discretionary Housing Payments (DHPs)—paid to households by local authorities to households judged to be struggling with their rent—exist as a safety net for capped households. It said:

DHPs provide a necessary safeguard to help people adjust during the transitional period from when they are first capped or for longer term complex cases.122

92.Evidence to our inquiry generally agreed that DHPs have helped some families “avoid the worst impact of the cap” and can be “a vital lifeline for mitigating the impact of the cap”.123 However, organisations including Gingerbread and CPAG questioned whether DHPs were really an adequate means of preventing hardship for vulnerable claimants, given their uncertain and temporary nature.124 Organisations including the Residential Landlord’s Association also raised concerns that the discretion available to local authorities in how they use DHPs can result in a ‘postcode lottery’ depending on the funding local authorities have available and how they choose to exercise their discretion.125 Our predecessor Committee raised similar concerns in our 2014 report, Support for housing costs in the reformed welfare system.126

93.Claimants must apply to their local authority to receive a DHP. However, we heard that many claimants aren’t aware that they can access the support, or struggle with the application process.127 Furthermore, many local authorities—who face significant funding pressures—place time limits on the awards. Analysis by Shelter found that local authorities often limit awards to 12 weeks or less for capped claimants.128 Some local authorities apply conditions such as requiring claimants to seek work, and some do not provide claimants with the full amount to cover their rent.129 Paula, a single parent affected by the cap, told us that her local authority said she could only receive a DHP if she stopped paying for activities for her children, cut off her internet and gave up the car she needed to get her three children to school.130

94.In addition, we heard about cases where capped households’ initial applications for DHPs were turned down or where a household’s request for an extension of a previous award was refused. CPAG told us it was aware of cases which suggested some local authorities were rejecting applications because of funding constraints; it described this development as “very alarming”.131

95.The Department was not able to identify any analysis it had done of the different policies local authorities have on DHPs or whether DHPs are working as an effective safety net for claimants affected by the cap.132 However, a letter from the Minister explained that the Department is currently conducting new research to better understand uses of DHPs by local authorities and future demand through the Local Authority Insight Survey “to investigate local authorities’ DHP policies including questions on demand, effectiveness and conditionality”. The findings will be published this year.133

96.The Department has relied on Discretionary Housing Payments (DHPs) as the panacea for claimants who struggle to adapt to the cap. But the fact that this support is discretionary means that households can be subject to a ‘postcode lottery’, finding themselves at the mercy of their local council’s policies and decisions which in turn depend on the size of their budgets and competing pressures for funding. Since the Department has little understanding of how different local authorities use DHPs, it cannot know whether its key safeguard is working effectively for capped claimants and their families. The reality is that while DHPs work as a necessary sticking plaster for some families, many families are not getting the consistent support they need. This can be a particular problem in areas with high housing costs, where DHP allocations are more likely to be rationed.

97.We recommend that the Department complete a full review of Discretionary Housing Payments to understand how different local authorities approach the provision of DHPs for capped claimants. It should also evaluate how effective DHPs have been as a support for claimants who struggle to adjust to the cap, by looking at individual claimants’ experiences. The Department should use the information from this review to produce clearer and more directive guidance to local authorities about the provision of DHPs so that they act more effectively as a safeguard. If the Department refuses to carry out this review, we will invite the National Audit Office to carry out a value for money study of DHPs and their use by different local authorities in mitigating the impact of welfare reforms.


74 Department for Work and Pensions (BEC0023)

75 Q142

76 Child Poverty Action Group (BEC0022)

77 Child Poverty Action Group (BEC0022), Chartered Institute for Housing (BEC0025)

78 House of Commons Library analysis

79 Oral evidence taken on 12 December 2018, HC 1540, Q 28

80 Work and Pensions Committee, Twenty-Third Report of Session 2017–19, Two-child limit, HC 1540

81 Child Poverty Action Group (BEC0022)

82 Child Poverty Action Group (BEC0039)

83 See for example Child Poverty Action Group (BEC0022), Zacchaeus 2000 Trust (BEC0027)

84 Department for Work and Pensions, “Benefit cap quarterly statistics: GB households capped to November 2018”, February 2019

85 See for example Child Poverty Action Group (BEC0022), Shelter (BEC0024), Policy in Practice (BEC0029)

86 Shelter (BEC0024)

87 Q14

88 Gingerbread

89 Q14,Q19,Q72,Q73

90 Q72

91 Benefit Cap; claimant videos

92 Q105,Q72

93 Benefit cap; claimant videos

94 Child Poverty Action Group (BEC0022)

95 See for example Q73, Benefit cap; claimant videos

96 Supreme Court, Judgment, “R vs Secretary of State for Work and Pensions, March 2015

97 Child Poverty Action Group (BEC0022)

99 Department for Work and Pensions, “In-depth interviews with people affected by the Benefit Cap”, December 2014

100 Department for Work and Pensions, “The benefit cap: a review of the first year”, December 2014

102 House of Commons Library briefing provided to the Chair

103 Oral evidence taken on 16 January 2019, HC 1539, Q56

105 Shelter Scotland (BEC0013)

106 Work and Pensions Committee, Fourth Report of the Session 2013–14, Support for housing costs in the reformed welfare system, HC 720, p4

107 Zacchaeus 2000 Trust (BEC0027)

108 Q199

109 Ibid.

111 Child Poverty Action Group (BEC0022), London Councils (BEC0018)

112 Q87

113 Q193

114 Q136

115 Q193

117 London Councils (BEC0018)

118 England and Wales High Court Decisions, “Between R and Secretary of State”, 11 January 2019

119 Child Poverty Action Group (BEC0022)

120 Q195

122 Department for Work and Pensions (BEC0023)

123 Child Poverty Action Group (BEC0022), Gingerbread (BEC0012)

124 Child Poverty Action Group (BEC0022), Gingerbread (BEC0012)

125 Residential Landlords Association (BEC0028)

126 Work and Pensions Committee, Fourth Report of the Session 2013–14, Support for housing costs in the reformed welfare system, HC 720

127 Zacchaeus 2000 Trust (BEC0027), Carmarthenshire County Council (BEC0041), Kingston upon Thames(BEC0043), Women’s Aid Federation of England (BEC0017)

128 Shelter (BEC0024)

129 Liverpool City Council (BEC0044), Kingston upon Thames (BEC0043), Oxford City Council (BEC0040), Spelthorne Borough Council (BEC0045), Brighton and Hove City Council (BEC0021), Newcastle City Council and Your Homes Newcastle (BEC0020)

130 Benefit Cap; claimant videos

131 Child Poverty Action Group (BEC0022)

132 Q202–203




Published: 12 March 2019