Universally Discredited and yet still in need of a consultation?

GMWRAG is 100% (ish) confident that most of our members will by now be aware that the SSAC has launched a consultation on government proposals for managing the migration of claimants on legacy benefits to Universal Credit.

Testing of the full managed migration process will start in January 2019 with the intention to increase volumes by July 2019.

The draft Universal Credit (Transitional Provisions)(Managed Migration) Amendment Regulations 2018 – which were presented to the SSAC at its meeting on the 20th of June 2018 – set out the government’s proposals on –

  • requirements for claimants on existing benefits to make a claim for universal credit (including the deadlines for doing so) and arrangements for ending their existing benefit; and
  • the calculation, award and ongoing treatment of transitional protection.

In the explanatory memorandum to the draft regulations the government advises –

‘Between July 2019 and 2023, the final phase of universal credit roll out will take place. During this phase, the Department will manage the migration of all the remaining claimants with awards of existing benefits to universal credit.

From January 2019, we intend to start testing the full managed migration process on a small scale, with the intention to increase volumes by July 2019. This will enable us to evaluate the initial process to ensure that it supports claimants effectively. This ‘test and learn’ approach will allow us to change the process, where necessary, before larger volumes of claimants are managed migrated to universal credit.’

To help inform its examination of the draft legislation, the Committee has launched a consultation seeking views from a range of organisations and individuals and particularly welcoming case studies on the following aspects:

  • the overall migration timetable;
  • arrangements for contacting claimants and inviting claims from them;
  • issues associated with making a claim, and ending legacy benefit claims;
  • the calculation of transitional protection (including the treatment of earnings and capital);
  • the impact of proposed transitional protection (including how easily it will be delivered and the degree to which it will be understood by claimants);
  • the impact on workers, including the self-employed;
  • equality impact (whether there will be particular effects for different groups and how these can best be addressed), including whether there any groups that will not be covered by transitional protection; and
  • monitoring and evaluation.

Commenting on the proposals, Chair of the SSAC Paul Gray said –

‘SSAC is keen to ensure that the scrutiny report it submits to ministers and Parliament is as well informed as possible, and we therefore strongly encourage all organisations and individuals with relevant evidence to take part in this consultation process.’

NB – responses to the consultation should be submitted by 10am on Monday the 20th of August 2018.

For more information see Government proposal to move claimants on ‘legacy’ benefits to Universal Credit: consultation announced from gov.uk

Now, is it just GMWRAG or is there a bit of an issue here? We’re being asked to contribute to a consultation on what is in effect the final roll out of Universal Credit. What is the justification for that roll out? Anyone remember the UC pilots? The concept of “test and learn”?

In the first 6 months of this year alone a browse of Rightsnet shows we have learnt that

  • Based on its current design, the new benefit system will save only £1bn by 2022/2023, says Office for Budget Responsibility
  • In ‘Rolling out universal credit’, the NAO found that the DWP’s expectation that UC will eventually deliver £8 billion of net benefits a year – through a combination of savings from encouraging 200,000 more people into work, reducing error and fraud, and reducing the costs of administering benefits – is based on unproven assumptions.
  • The Shadow Secretary of State for Work and Pensions has called for the government to listen to the NAO and halt the roll out of UC completely and urged the actual Secretary of State to “… wake up to the misery being caused by her policy.’
  • announcing that it intends to take evidence from the DWP about the programme’s value for money and the experience of claimants under the new scheme, the Public Accounts Committee has said “The Government’s introduction of UC has been one long catalogue of delay with huge impact on people’s lives. After eight years’ work and £1.3bn spent on the project, not even 10% of claimants have transferred. Many who have moved are suffering hardship but the Department for Work and Pensions does not accept it is at fault. DWP needs to wake up and understand what is going so wrong before future claimants share a similar fate.”
  • the Treasury Committee’s March 2018 report on Childcare called for childcare costs within the new benefit to be paid either up front or direct to the childcare provider. They called payment in arrears a “fundamental design flaw”.
  • In ‘Universal Credit and Financial Abuse: Exploring the links‘, three women’s groups point out that, under universal credit, payments are made into one bank account for everyone in the household, rather than individual accounts, which risks giving more power to abusers in homes where women live with domestic violence.
  • The chair of the Work and Pensions Committee Frank Field has written to UC Director General Neil Couling questioning him about the impact of universal credit on rent arrears.
  • Almost half of UC claimants say that they needed help in registering their claim online, according to new research published by the DWP.
  • More than a quarter of the 2 million UC claims made since April 2013 have failed to result in a ‘start’ on the benefit, according to DWP statistics.
  • Whilst the research found that 98 per cent of claimants had claimed online, and over half (54 per cent) were able to register their claim online unassisted, it also found that – ‘Three in ten (30 per cent) of those who registered a claim online found this difficult, and the process of verifying their identity online was seen as particularly difficult. Overall, more than four in ten (43 per cent) claimants said they needed more support registering their claim for universal credit. Three in ten (31 per cent) said they need more ongoing support with using their UC digital account.’ Indeed, the research found that it was quite common for the claim process to take more than one attempt and, even amongst those with experience of claiming other benefits, again nearly half found it more difficult to claim UC.
  • A report from the Joseph Rowntree Foundation finds that benefit delays, gaps, sanctions and harsh recovery practices are common factors that tip people into destitution.
  • Led by the University of York, the final report on the five year ‘Welfare Conditionality Project (2013/2018)’ – that is based on the results of repeat interviews with welfare service users drawn from nine policy areas including universal credit, jobseekers and disabled people – finds that benefit sanctions and mandatory claimant commitment requirements do not prompt ‘behaviour change’ or provide meaningful improvements to job prospects or work outcomes for most claimants.
  • The rate of overpayments in UC has increased to 7.2 per cent in 2017/2018, up from 5.5 per cent the previous year, according to DWP statistics.
  • UC work coaches often ignore the caring commitments of single parents, according to a new report from Gingerbread.
  • Changes to free school meal entitlement under UC will create a great number of winners, but also a substantial number of losers. 13 per cent of the 1.3 million children who would have qualified under the legacy system will find themselves ineligible under UC, says IFS
  • In ‘Universal Credit: supporting self-employment’, the Work and Pensions Committee warns that the MIF rules as they now stand – with a one-year exemption for self-employed start-ups and rigid reliance on monthly income reporting – fail to deliver parity of treatment between employees and the self-employed and pay little reference to the reality of self-employed start-ups that may take years to develop and often face irregular payment patterns.
  • In two reports about UC Citizens Advice looked at the impact of work allowance cuts on people’s budgets, and explored why the MIF can leave self-employed workers at a financial disadvantage. It highlighted that a self-employed worker who receives  could be worse off by £630 a year compared to an employee on the benefit, even if their year-end earnings are identical; and households affected by the cuts to work allowances will receive an average of roughly £100 less per month.
  • Appearing on a Channel 4 Dispatches programme – Britain’s Benefit Crisis – PCS General Secretary Mark Serwotka highlighted that, in a recent survey, 79 per cent of DWP staff felt that there was an insufficient amount of staff to cope with demand from claimants and 70 per cent of DWP staff want the roll-out of UC to be stopped.
  • Highlighting that the negative impacts are largely driven by changes to the benefit system, in particular the freeze in working-age benefit rates, changes to disability benefits, and reductions in universal credit rates, the EHRC reports that an extra 1.5 million will be in poverty; households with at least one disabled adult and a disabled child will lose over £6,500 a year, more than 13 per cent of their annual income; Bangladeshi households will lose around £4,400 a year, in comparison to white households, or households with adults of differing ethnicity, which will only lose between £500 and £600 on average;; lone parents will lose an average of £5,250 a year, almost one-fifth of their annual income; and women will lose about £400 per year on average, while men will only lose £30.
  • the Trussell Trust highlights that between 1 April 2017 and 31 March 2018 it distributed 1,332,952 three day emergency food supplies to people in crisis, of which 484,026 went to children – a 13 per cent increase on the previous year. The primary referral reasons were benefit delays (24 per cent), benefit changes (18 per cent) and debt (9 per cent);whilst referrals due to ‘benefit sanction’ have declined over the last year, those due to ‘reduction in benefit value’ have the fastest growth rate of all referrals made due to a benefit change, and those due to ‘moving to a different benefit’ have also grown significantly; and food banks that have been in full UC rollout areas for a year or more experienced an average increase in use of 52 per cent in the twelve months after the full roll-out date in their area, whereas foodbanks either not in full universal credit areas, or only in full rollout areas for up to three months, showed an average increase of 13 per cent.
  • Research from Policy in Practice shows that one in ten working-age households report earnings from self-employment., In London, 78 per cent of self-employed households on low incomes will be £344 per month worse off under UC.
  • The House of Lords voted in favour of motion to delay regulations that introduce an earnings threshold for free school meals under universal credit and stated that delaying the change would enable the government to ‘put their house in order’ and complete a full poverty impact assessment
  • Only 76 per cent of households on UC in December 2017 were actually receiving a payment, according to DWP statistics.
  • Four out of five UC sanction appeals are successful. DWP statistics also show that sanction decisions are not changed in 72 per cent of mandatory reconsiderations.
  • The universal credit Project Assessment Reviews ‘barely mention claimants’ and are ‘shot through with management gobbledegook’, according to the Chair of the Work and Pensions Committee Frank Field. Publishing its assessment of the reviews of UC carried out by the Infrastructure and Projects Authority (IPA) and its predecessor the Major Projects Authority – which included five Project Assessment Reviews carried out between March 2012 and October 2015 and five other related reports – the Work and Pensions Committee says that the reviews ‘… are written in dense project management speak, a combination of the cryptic and the clichéd … [and] … do not examine government policy or the consequences for claimants’.
  • In the minutes of its November 2017 meeting, the Privacy and Consumer Advisory Group – that advises the government on how to provide users with a simple, trusted and secure means of accessing public services – reports that research shows that while 35 per cent of universal credit claimants can use the Verify online service, 30 per cent are not yet able to, and 35 per cent could verify online but do not. Research at a jobcentre also showed that out of 91 users, 48 needed help with the process.
  • In relation to tax credits, the Public Accounts Committee highlights that many of the 110,000 tax credits claimants who have so far transferred to UC also have tax credits overpayments that have become the responsibility of DWP to collect and raised concerns that the DWP’s greater powers to recover debts risk subjecting vulnerable people to more aggressive tax credit debt recovery attempts.

Now, hand up anyone who still thinks the legacy transfer is what the SSAC should be consulting about? GMWRAG is happy to hold our hands up and apologise for the length of this post but this is a moment to reflect on exactly how bad Universal Credit is and why it still exists, which appears to now amount to it being more expensive to get rid of it. Our trawl through the past six months of media coverage found but the one assertion by DWP as to the merits of UC. In most of the above cases they simply haven’t addressed the overwhelming evidence against the implantation of what is in effect structural poverty and destitution.

GMWRAG of course strongly encourages responses by members to all such consultations but this is one response where the terms of reference really need to be reframed by the respondents.

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New consultations for GMWRAG members to be aware of

Two new interesting consultations with very differing approaches to deadlines. We think GMWRAG members should be aware of, and consider responding to, both.

So, first of all, the SSAC have launched another consultation on decision making and mandatory reconsideration. There are 6 key questions to be answered and the answers need to be in by no later than 11:45pm on the 15th of March 2016. We’re not sure what’s wrong with midnight!

It’s hard to imagine any WRO having nothing to say on the subject but if you really don’t have the time to put something together as a service, and we can understand that given the ridiculously short deadline, then our friends at NAWRA are ahead of you and have created a nice simple survey for you to complete and add your contribution as an individual or organisation. However, note that the deadline for that is the 7th of March 2016 at midday.

Additional to the above is a consultation which may have escaped members but which will resonate with many of us. The judiciary is proposing a ban on fee charging “McKenzie Friends”. for reasons which become obvious when you read the article, The consultation paper can be found here and the deadline is a rather more generous 19th of May 2016. 

GMWRAG thinks we can probably predict the majority of responses to the former but that the former is equally interesting. GMWRAG minutes are littered over the years with references to concerns about individuals and organisations charging for services.

Reduced funding in the advice sector has led to not only a rise in the number of lone practitioners charging for services many provide for free but also organisations which charge and purport to be expert but actually provide the equivalent of a “McKenzie friend” in place of what we would recognise as representation.

When completing your responses here are some key definitions from Ambrose Bierce to assist 🙂

LAWYER, n. One skilled in circumvention of the law.

LIAR, n. A lawyer with a roving commission.

LITIGANT, n. A person about to give up his skin for the hope of retaining his bones.