Sense Public Policy Team
101 Pentonville Road
London N1 9LG
Email: parliamentary@sense.org.uk
Voice and text: 020 7014 9386
Personal Independence Payment (PIP)
About Sense and deafblindness
Sense is a national charity that supports and campaigns for children and adults who
are deafblind. We provide tailored support, advice and information as well as specialist
services to all deafblind people, their families, carers and the professionals who work
with them. In addition, we support people who have a single sensory impairment with
additional needs. Deafblindness is a combination of both sight and hearing difficulties.
Most of what we learn about the world comes through our ears and eyes, so deafblind
people can often face problems with communication, access to information and
mobility. People can be born deafblind, or become deafblind through illness, accident
or in older age. There are an estimated 356,000 deafblind people in the UK.
Introduction
The Welfare Reform Act 2012 legislated for Personal Independence Payment (PIP) to
replace Disability Living Allowance (DLA). This will first apply to people aged 16-64 from
2013. The benefit will have two components – Daily Living and Mobility. The assessment
will use a set of points-based criteria; individuals currently will need 8 points to qualify for
the ‘standard rate’ and 12 points for the ‘enhanced rate’ of each component.
We still remain very concerned by the overall aim of reducing the future DLA spend by over
£1 billion. We believe this will negatively impact on designing a benefit that can address the
wide range of barriers faced by disabled people and their additional costs. DLA currently
plays a vital role in supporting disabled people to lead independent lives and plays a
specific preventative role in offering support to disabled people with lower level needs,
including some people with a more moderate sight and hearing impairment. This group are
unlikely to have access to ongoing social care support, due to the high threshold of local
authority eligibility criteria. For this reason the Dilnot Commission recognised the
importance of DLA in supporting disabled people; there appears to be a mismatch between
the Dilnot vision of DLA/PIP as a simple way to provide support for people with low level
need and the current government plan to focus PIP on those with the highest need.
A first draft of the assessment criteria for PIP was published in May 2011 with a second
version published in November 2011. Sense welcomed some improvements in the second
draft of the criteria, including an improved understanding of communication support needs.
However we still have significant concerns about the criteria, specifically whether they will
allow for a fair assessment of deafblind people and award an appropriate level of points
and benefit award. Sense’s response to the consultation with detailed amendments to the
criteria is available on request or accessible on the Sense website.
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Parliamentary debate on the third draft of the assessment criteria
Officials are currently considering the points raised by the consultation on the second draft
of the assessment criteria for Personal Independence Payment. Section 94 of the Welfare
Reform Act 2012 requires that a draft instrument for the Regulations for the assessment
criteria be laid in both Houses of Parliament and be subject to affirmative procedure. It is
currently unclear if there will be any further meaningful informal or formal consultation on
the third draft of the criteria before the instrument is laid before Parliament.
‘Activity 7 – Communicating’ should recognise the double disadvantage linked
to difficulties accessing both written and verbal information.
“The communication activity needs to take into account the different ways we
communicate and the very high costs.” (Deafblind man)
The current descriptors fail to take account of the combined impact for someone who
cannot access both written and verbal information. As only one of the descriptors can
be selected under each activity, individuals can only be awarded points for barriers
they face to accessing either written information or verbal information, not both. This
fails to acknowledge the extra barriers and costs faced by individuals who require both
assistance from another person or aids to access written information and
communication support from another person to understand or convey verbal
information. Given that communication and access to information has such an impact
across individuals’ lives, we believe individuals who face multiple barriers to accessing
both written and verbal information should receive at least 10 points under this activity.
‘Activity 10 - Planning and following a journey’ should identify individuals who
require assistance or use orientation aids or taxis
We believe that the criteria do not currently fairly consider the full range of aids people
use to support their mobility. It is unclear if use of either assistance or orientation aids,
other than support dogs, such as long canes, hearing aids and GPS locators, will be
considered under this descriptor. People with sensory impairments who rely on
assistance, orientation aids or taxis to get around should be considered to be in the
same position as those who use support dogs.
“My mobility cane is really useful and vital. Travelling is very hard work where
destinations and unfamiliar places are concerned, especially if I am to commute to
work every day from home in terms of health and safety.” (Deafblind woman)
Conclusion
 We believe that Parliamentarians should be able to access and comment on the third
draft of the PIP assessment criteria before they are formally laid in Parliament.
 Sense would welcome support to ensure that the ‘communicating’, ‘engaging socially’
and ‘planning and following a journey’ activities recognise the needs of those who face
barriers to communicating and getting about, including deafblind people.
 The Government should consider the impact of reduced access to DLA/PIP on
diminished preventative support for disabled people and the likely higher costs to social
care and health services in the longer term.
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