Organisation response to consultation on aids and appliances
and the daily living component of Personal Independence
Payment
Disability Equality NW [DENW]
DENW is a user-led, disabled people’s organisation working mainly in the central
Lancashire area. We have over 2000 members and provide a range of services to
disabled people and their carers that promote independent living, equality and
inclusion.
In the short time available to seek views from those relevant we have mainly drawn
on the feedback from our Trustees and our volunteers (all of whom are disabled or
have personal experience of disability) together with those gleaned from service
users either seeking or being reassessed for their support.
Our Response
We can see that the current arrangement does seem to generate anomalies where
those with much lower support needs attract the same level of support as those with
significantly higher ones.
However, it is clear to us that needing an aid or an appliance to complete basic living
tasks effectively – and experiencing difficulty if not available – needs to be reflected
somehow.
The discussion document emphasises the purpose of PIP (and DLA) – “to
compensate for the increased costs caused by their impairment or condition.”
Whilst we understand that this is the stated aim of the benefit (it is a cash payment)
its central purpose is to ensure that disabled people can continue to be independent
and maintain a civilised life. A more rigorous approach to this idea was abandoned in
the initial PIP development discussions because it was too complex and could make
the benefit too costly to deliver. Similarly, it seems retrograde to us that old DLA
Low Rate Care – should also be looked at again.
Options 1- are based on either reinventing low rate care, revisiting the issue of
personalising the benefit or establishing a method for the classification of qualifying
aids and appliances.
Taking the options in order:
1. Involves personalisation. This would introduce excessive delivery costs and
bureaucracy. Personalisation works when it is thorough. The approach would
become arbitrary and not succeed in reflecting actual “increased cost”.
2. Virtual low rate care (old DLA).
3. This option would ignore those for whom the aid or appliance was costly or crucial.
4. This option is caught up by boundary issues and would almost certainly result in
challenge(s) at appeal. Given the interpretation being given by current case at
Tribunal we do not see why the same complexity would not arise. The prospect of
developing a “list” approach via this process is daunting. In addition, the option
assumes that all people will receive the same level of assistance or be able to utilise
the aid or appliance with the same effectiveness.
5. For PIP scores to have meaning the present system can only respond to point
scores of 2. In some cases this would in effect mean that the need to use an aid or
appliance would be disregarded entirely as an indicator of need or difficulty
irrespective of its importance.
We also want to make the following more general points about the impact of this
change.
1. The loss of “passporting” to the severe disability premium (and carer’s
allowance?) which is more or less implicit in the options proposed will mean a
significant loss of weekly income (over£100). For those who have been budgeting
and organising their support for some time this is a massive reduction to
accommodate.
2. The discussion document makes no reference to how the change might impact on
the provision of social care locally. Most local authority social care arrangements
consider the daily living component as relevant income when financial assessment
takes place. Most of the options would result in its removal.
We have not been able to reach a conclusion about which option we would propose
but suggest that if change is to happen “choice” be considered, as clearly one option
isn’t going to work for all. Other than introducing further stratification of the
component as a whole, a model based on well-established personalisation principles
is probably the fairest way to go, but it will need to be supported by effective
assessment - and the financial consequences this would entail.
DENW
29th January 2016