The Impact of Welfare Reform in Scotland - Tracking Study Sweep 4 Report - Appendices

Annex 4: Policy Recommendations and Implications from the Previous Study Reports

This appendix presents the policy recommendations and implications from all four sweeps of the study.

Sweep 1 (Lister et al., 2014)

• These findings suggest a need for much improved official communication about benefits and benefit changes, as well as continued support for third sector organisations providing impartial, specialist support.
• These findings suggest a need to improve the administration of benefits, including more sensitive service provision by departments, better administration of benefits changes and seeking to reduce the feelings of stress related to applying for them. They also highlight the crucial importance of recourse to emergency funds to mitigate the impact of these situations when they occur.
• These findings highlight the problem of the cost of living for those on a low income, and the need for quicker intervention for those who are struggling to cope.
• Stigmatising messages from the media need to be countered by education about those on benefits and of the true (limited) nature of benefit fraud. Jobcentre staff should receive more training in dealing with groups with specific needs and have specialist officials to deal with all those key groups (such as lone parents or those with different types of disability).
• There needs to continue to be policies to help ameliorate specific polices such as the social housing occupancy rules and specific circumstances, such as those who cannot rely on maintenance payments from their former partners. There appears to be a need for specialist employment services and staff who more fully understand the employment barriers facing specific groups, such as lone parent advisors in Jobcentres.
• In addition to the recommendations for welfare benefits, the research also highlighted a number of issues affecting those on benefits, and which policy could seek to address. One of these is the need for affordable childcare in order to enable parents, particularly lone parents, to compete for jobs that do not fit around school opening and closing times. Another is the development of a network of formal and informal support - this is especially important for groups such as lone fathers, who report a lack of support.

Sweep 2 (Graham et al., 2014)

• The findings of this study show that, according to the views of participants, stronger conditionality is unlikely to get more people into work, but there are a number of interventions that can help, by addressing barriers to work, in the areas of education, skills, employability services, childcare, and health.
• Current plans to extend free childcare provision are a welcome development, but do not address the gap identified by participants in provision outside of standard hours. To meet these needs, childcare provision needs to evolve to reflect the widespread expectation of non-standard hours in both the public and private sectors.
• Some of the reforms have changed the way in which recipients interact with the system, requiring them to give different information, or go through new procedures, in order to access support. However, this kind of change does not necessarily cause intractable problems - the findings show that in many cases, it can be navigated with appropriate support, whether this is helping those affected to understand confusing correspondence, fill in forms, locate specialist services or provide support for a benefit tribunal. Those who are affected by welfare reform can be supported in understanding and responding to changes. This feeds into the Scottish Government mitigation work in the area of providing advice and support, through advice services, third sector organisations, social landlords and Health Boards.
• The findings suggested that frontline services (such as health, social care and social work) could play a role in supporting those affected by welfare reform to access the support available to them, but that in places their involvement could be stronger and more joined up. For example, health services could advise patients who might be entitled to ESA or DLA that these benefits exist, and how to apply for them. This practice already exists for Child Benefit; new mothers are given an application pack in hospital, and take-up of this benefit is over 95 per cent among those eligible for it.
• The impact of welfare reform appears to vary depending on service provision at the local level. This feeds into current mitigation work with COSLA and the Improvement Service about how local authorities can best support people. Best practice should be shared and adopted, and local authorities should be made aware of instances where their activities are creating problems for benefit recipients (such as high care costs).
• The impact on benefit recipients who fall foul of new rules - or who are affected by a mistake on the part of a benefits agency that is not their fault - can be severe. When things go wrong, it is important that there is recourse to a well-funded crisis support service that can respond quickly to financial emergencies. The Scottish Welfare Fund will be crucial in mitigating the impacts of welfare reform.
• The experiences of participants in this study raise some questions regarding whether the WCA is effective at determining who is fit for work. The assignment of several cases here to the WRAG or fit for work categories - and their subsequent successful appeal - suggested that the assessment process has a high risk of 'false positives' with respect to assessing people's capability for work. In particular, the assessment should be revised to take better account of the impact of conditions that fluctuate over time and/or are less visible.

Sweep 3 (Graham et al., 2015)

• Forms should be reviewed by a panel of applicants, in order to test the accessibility of the language, the clarity of the requirements, and the appropriateness of the questions. When determining what information should be sought during the application, the benefit of additional information should be set against the increased strain on the applicant, and in the context of the overall burden of the form. Supporting information should be provided alongside forms, or at least clearly signposted, rather than left to the applicant to obtain for themselves.
• Reflexivity and responsiveness to feedback from claimants regarding the appropriateness of the assessment criteria and process should be built into the disability benefit system. Although the current system ostensibly does so, via its regime of regular independent reviews, policymakers should demonstrate clearly how they have responded to this feedback.
  
  Consideration also needs to be given to the suitability of polar questions in capturing the effects of fluctuating conditions. Entitlement to a disability benefit should not be predicated on the applicant being able to quantify a fluctuating condition, or attempt to predict its future course; this is simply not possible in some cases. Rather, the impact of the disruption and uncertainty created by a fluctuating condition should itself be taken into account as a limiting factor.

• Repeat assessments should be limited only to those whose condition is expected to improve. Even for those in this category, frequency of assessment should be balanced against the cognitive and emotional toll of assessment on respondents.
• Mistakes should be minimised, but are inevitable to some extent; so how the relevant agencies respond to these situations is important. Their response needs to be efficient, and should give claimants a reasonable benefit of the doubt. In the event of a dispute, assumption of liability should be with the state until the matter is resolved, and there should be an interim payment in place. All systems should be regularly reviewed to ensure that they are performing as efficiently and accurately as possible and continuous improvement in efficiency and accuracy sought.
  
  There is a need for much improved official communication about benefits and benefit changes, not only by DWP, but also by Local Authorities around issues such as council tax. Those who will be affected by changes should receive clearer information about what will happen, and when, during the transition to a new benefit. Communication of decisions should be clear and unambiguous.

• The primary purpose of Jobcentre Plus should be to provide meaningful support rather than enforcing conditionality. At present this support role is in conflict with its enforcement role. The Work Programme also needs to be reassessed, especially for disabled people.
• The application and appeals process should be founded on the assumption that the applicant is genuinely in need, and potentially experiencing a range of life stressors that might constrain their ability to tackle the application process. It should be acknowledged that applicants might have few resources to fall back on, and that even temporary loss of benefit could have a substantial negative impact.
• This demonstrates the importance of recourse to crisis funds, and access to support and advice to help manage change and adjust to new situations.
• Upheaval in the form of changes to the system should be minimised. Language and policy rhetoric should be carefully considered, as it may affect the degree of fear with which change is viewed by those affected.
• The amount payable to carers does not value the work that they do, nor acknowledge their constraints on taking paid employment, and should therefore be increased.
• The findings of this study demonstrate a range of situations in which people might seek advice. It also shows that there is no ideal or 'one stop shop' solution; advice needs to come from a range of services. It should be considered how services that are currently perceived as not operating effectively can be improved. This is particularly important for CABs which form a large part of the support infrastructure.
• It is difficult - perhaps impossible - for services to be both an enforcement agency and a source of advice, from the point of view of approachability and gaining the trust of service users.
• There should be more joined up practice between health, social care and welfare services. Health and social care professionals do not have to be experts, but should at least be aware of the kind of support that people might be entitled to and referral mechanisms between health and social care, and advice services, should be established. Lessons could be learned from the 'Healthier Wealthier Children' project - a partnership approach between health, local government and the voluntary sector to addressing child poverty across NHS Greater Glasgow and Clyde. ^[57]
  
  It is also necessary to recognise and support the role of GPs in providing necessary information to support an application for disability benefits.

• All those experiencing issues with benefits should have access to appropriate advocacy services if they need them. For some people, the ability to raise or escalate issues may not be fully met by local political representatives. Fair and supportive independent appeal and advocacy processes are important.
• As well as providing a reactive service, a comprehensive advice service should have a proactive element - including efforts to raise awareness both of entitlements and sources of help.
• Different ways of advertising services and entitlements should be considered; different media, different types of places and services, public and private venues, etc. Robust referral arrangements with advice services should in place across the public service landscape. Signposting should also be part of the responsibility of those imposing the changes.
• These findings can help to identify best practice for those providing advice, and what is very important to get right. Advice should be timely and accurate, provided by well-trained and approachable staff, with whom users can have some continuity, where this is helpful and appropriate to the situation. This quality element is key to the service being helpful. Not all providers are sufficiently competent and well-resourced to provide this high quality service.
• Best practice is to provide support in multiple formats - in person, by telephone, on paper and online - in order to reach those who may not be able to access one or more of these formats. Online information can provide a useful source of support, but it cannot replace other delivery modes completely.

Sweep 4

• Family circumstances should be reviewed holistically before entitlements are removed. The criteria for receiving these should be reviewed, particularly in relation to whether they have a perverse impact on work incentives.
• It could be beneficial to low income families for policy makers to consider more broadly the costs incurred by families with children - such as school uniform, and other costs associated with attending school - and ways to offset these, in order to leave more room in the family budget.

• Increase the amount of childcare that parents can access cheaply or free of charge, including pre- and after- school and holiday care.
• The devolution of Carers Allowance to the Scottish Government provides an opportunity to ease the financial strain on carers, by considering increasing the level at which it is paid.
• The Scottish Government should consider the needs of those caring for more than one person. This does not necessarily imply awarding multiple allowances, but perhaps offering help with their transport costs.
• The gap between being 'fit to work' and the opportunities available in the labour market could be bridged with better, more targeted training and employability support for those with health conditions and disabilities.
• The devolution of this benefit provides an opportunity for the Scottish Government to implement a scheme that could better meet claimants' needs, and impose less of a burden on them.
• User experience could be embedded in the targets that providers are expected to meet. The system could be evaluated (among other things) on whether claimants feel they are being treated fairly, and with dignity.
• In designing the assessment process, the impact on claimants should be a key consideration. Life or long-term awards could be considered for those whose conditions are permanent, and some may not need to go through an assessment at all if their needs are clear cut. The burden of assessment should lie with the assessors; the requirement upon ill or disabled people to make long journeys to assessment centres should be minimised.
• It might be helpful if those potentially affected by changes were able to quickly find out how proposed changes might affect them, and also to know about what support is available to them if they were to lose entitlements.
• Language and tone matters. 'Talking tough' on welfare reform instils fear and distrust. The Scottish Government should seek to foster good relations between the system and claimants.
• Consider opportunities for some form of co-production in the development and implementation of the devolved version of DLA/ PIP.
• Offer a centralised opportunity to check all entitlements, so that anyone can make sure they are correctly receiving what they are entitled to.
• Ensure support and advice at all stages of the application process.