DISABILITY BENEFITS CONSORTIUM - The DBC have written to the DWP minister Rt. Hon. Thérèse Coffey MP.

Below is a copy of the letter. The ABC are members of the Disability Benefits Consortium.

Rt. Hon. Thérèse Coffey MP

Secretary of State for Work and Pensions

Caxton House

Tothill Street

London

SW1H 9NA

27 March 2020

Dear Secretary of State,

Covid-19 – the Disability Benefits Consortium’s proposals for additional short-term measures to protect disabled people’s incomes

The Disability Benefits Consortium (DBC) is a network of over 100 organisations with an interest in disability and social security. For our full list of members, see https://disabilitybenefitsconsortium.wordpress.com/dbc-members/

Using our combined knowledge, experience and direct contact with millions of disabled individuals, people with long-term health conditions and carers, we seek to ensure that Government policy reflects and meets the needs of all disabled people.

The DBC welcomes the recently announced measures designed to protect the incomes of large numbers of people whose livelihoods have been adversely impacted by the Covid-19 crisis. But we believe that these support measures need to go further.

People living with a disability and those with long-term health conditions tend to have lower real incomes and higher costs than the general population and we are calling on the Government to produce a more comprehensive package of support, to better protect these individuals and their families, at this difficult time.

1. 1. One of the most pressing issues is the current level of demand on the system due to the unprecedented number of new claims. This is causing extremely long waiting times and problems with the digital claims process. We welcome the commitment to expand the Department’s capacity, but the challenge remains considerable. We believe that the Government should give high priority to resolving urgently the technical and capacity issues involved.

Also, clear guidance must be made available (to the public and to staff) regarding the correct process to make both a digital claim for Universal Credit (UC) and a non-digital claim, including how the verification call is to be made – that is, if outbound from the DWP rather than inbound from the claimant.

 2. The increase in the UC standard allowance is very welcome, helping to cushion the financial shock, which many will experience. However, other claimants likewise face financial challenges, especially after several years of a benefit freeze. We recommend that the Government should give a corresponding uplift of “legacy” and similar benefits – including, for Employment and Support Allowance (ESA), the restoration of the Work-Related Activity Group (and UC equivalent Limited Capability for Work) addition.

3. 3. We believe that artificial limits that keep many households (mainly with children) below basic benefit levels are particularly inappropriate at this time. We recommend that the Government should suspend the benefit cap and the “two-child policy”.

4. 4. Any Working Tax Credit (WTC) claimant who loses their job over the coming few months will not be able to continue claiming WTC and will have to claim UC instead. This means they will lose Transitional Protection (TP). As you know, this is a temporary top-up payment that would have been added to their UC to offset any losses, when the DWP eventually transferred them from WTC – but it is not payable when you move to UC because of a change of circumstances, such as job loss.

Disabled people in work and parents of disabled children stand to lose far more than most people if they lose TP – sometimes amounting to thousands of pounds a year. This will make it even more difficult for them to recover from the economic shock of the next few months.

The recommendation above to restore the Limited Capability for Work Addition to UC will help, as long as these claimants can retain it in their UC calculation up to and after they return to work.

Also, we recommend that the lower rate of the disabled child element of UC should be restored to its level in the legacy system.

5. 5. New claimants for UC will have to wait at least five weeks until they receive their first payment. We know that this can mean people face a significant reduction in income, leading to worry about how to pay bills and buy food. The DWP offers an “advance payment”, in effect a loan deducted from future payments, which can leave people struggling to make ends meet. We recommend that the Government should make all UC advances for disabled people non-repayable grants.

6. 6. There has been no formal indication that work-related conditionality has been suspended, although it is difficult to see how it could be meaningfully applied in present circumstances. We recommend that the Government should explicitly suspend work-related conditionality and associated sanctions. 

7. 7. Currently, 1.3 million claimants have deductions made from their UC payments to pay debts – over half of them losing 20% or more of their basic allowance. We recommend that the Government should suspend all debt repayment deductions from UC, to ease financial hardship for the duration of the current crisis.

8. 8. It is very important that, during this epidemic, people living with a terminal illness have swift access to benefits via the Special Rules for Terminal Illness. It is our understanding that under UC, people with a terminal illness will temporarily be able to apply via the Special Rules without the DWP needing sight of a DS1500 form (a form signed by a medical professional to say that the person has a reasonable expectation of death within six months). If this is the case, then this is a very welcome step. We recommend that the Government should extend this provision to other benefits which can be applied for under the Special Rules: ESA, Personal Independence Payment and Attendance Allowance.

 There are further measures that the Government could take that are likely to have an impact on those living with a disability and in need of benefit support at this time, including:

9. 9. As medical professionals come under more pressure over the coming weeks it is unreasonable to expect they will be able to provide medical evidence to support a claimant’s benefit application. We recommend that the Government should extend the time requirements for claimants to return paperwork and to gather medical evidence where necessary.

10. 10. Similar pressures are likely to slow down the Mandatory Reconsideration (MR) process. This will mean people could be receiving less financial support than they are entitled to. We recommend that the Government should pay the basic/ standard rate to claimants whose benefit is suspended pending MR, until the process is completed – and also, fully reinstate a benefit that has been wholly or partly withdrawn and is awaiting MR or an appeal. 

11. 11. Help to pay council tax is also crucial at this time of acute financial pressure. We recommend that the Government should encourage Local Authorities to remove features such as the two-child policy and the self-employed claimants’ Minimum Income Floor from their local Council Tax Support/ Reduction schemes. Some have simply copied these rules automatically from DWP benefits, possibly without fully appreciating their adverse impact where claimants are struggling.

We hope that, when something like a normal life returns, the support package as outlined above, which suggests achievable and positive temporary improvements, to be introduced in response to a crisis, might prove a focus for longer-term policy discussion.

Meanwhile, we commend to the Government the above proposals to make immediate changes to complement the emergency measures already taken.

In view of the widespread public interest in the current emergency measures, we shall be releasing these proposals to the media.

Yours sincerely,

[Signed]

………………

cc Justin Tomlinson MP

     (Minister for Disabled People, Health and Work)

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