The Disability Federation of Ireland Position Paper on Report on the Desirability and Feasibility of Introducing a Singe Social Assistance Payment for People of Working Age (Department of Social Protection) What is proposed? The existing Jobseeker’s Allowance payment is put forward as the overarching payment for people of working age structured in such a way that conditions can be tailored across the spectrum in accordance with individual circumstances and support needs. It is envisaged that the payment would consist of three levels allowing for tailoring of conditionality at each level and related to the level of supports required by the individual. It states that the tailoring of services and supports, not all of which come within the remit of the Department of Social Protection (DSP), would have to be guaranteed (p.94). The report draws on the model envisaged in the Developmental Welfare State report published by NESC (p.19). Services Education Health Childcare Eldercare Housing Transport Training Employment Services Services Income supports Income Supports Progressive child income Supports Working age transfers for participation Minimum pension guarantee Capped tax expenditure Activist measures Activist measures Novel approaches Particular community groups Emerging new needs Outcome focused Evaluation and mainstreaming 1 Disability Federation of Ireland 7th February 2012 The payment would apply to new claimants only. The extension to existing claimants would happen over time. What are the three Levels envisaged in the Single Payment Structure? It is proposed that the single payment consist of three tiers: Level 1 Three Tiers of Single Social Assistant Payment Level 2 Level 3 Light support needs Moderate support needs Significant Support Needs People who are ‘work ready’ e.g. existing recipients of jobseekers allowances, lone parents/ qualified adult dependents with children over a certain age People who need support or plan to prepare to return to work e.g. lone parents/ qualified adult dependents with children between certain ages, some recipients of DA People with significant barriers to taking up employment e.g. because of long-term illness, disability/caring responsibilities or lone parents/qualified adult dependents with young children It is noteworthy that the three tier model mirrors the categories put forward in the Value for Money Review of Disability Allowance published in 2011. Three Categories proposed in the VFM Review of Disability Allowance Level 1 Level 2 Level 3 DA claimants who are job ready with a bit of training DA claimants who have some capacity but need interventions on ‘soft skills’ to get them to level one standard DA claimants who, by virtue of their medical conditions, who will get more from the labour market in terms of personal development and participation. Both the ‘Value for Money Review of Disability Allowance’ (2011) and the ‘Report on the Desirability and Feasibility of Introducing a Single Social Assistance Payment for Adults of Working Age’ recommended that an assessment would have to be carried out to establish the person’s capacity for work and ultimately to decide at which level the person should enter the payment and consequently what conditions apply (p.86). In each tier, the role of the case manager is seen as critical to identify and try to overcome the barriers to return to work. Access to healthcare professionals to manage illness/disability also recognised in the single payment three tier structures. 2 Disability Federation of Ireland 7th February 2012 What are the opportunities? Currently people on disability payments are not included on the live register as they are not considered ‘available to work’. However, in reality there are people who would like to work if correct and flexible supports were put in place to help them access the labour market. A Single Social Assistance Payment might shift our perception of disability to focus on what people are ‘able’ to do rather than what they cannot do. What are the challenges and concerns in relation to the Single Payment and people with disabilities? There is an assumption that Jobseekers Allowance be used as a template to build a single payment however this may not result in the best possible outcome for people with disabilities. Disability payments, and the secondary benefits associated with them, have evolved over time to respond to the specific needs of people with disabilities. These form a wide package of measures that address the costs of disability, as well as poverty and unemployment traps particular to disability and it is unclear how they will be incorporated into the new scheme. Some of these are demonstrated below: The first €50,000 of capital is assessed as nil means in the case of DA compared to €20,000 for other payments. This was introduced in recognition that a person on DA is limited in their ability to accumulate savings or work. It also provides greater protection to someone who receives compensation for an accident or injury and may have been in danger of losing their DA and secondary benefits. Disability allowance and blind pension are also the only two payments where an exemption of €190,500 off the proceeds from the sale of a principal residence applies. This protects parents who want to make future provision for their children. The provision of additional allowances and secondary benefits differ across schemes. For people with disabilities, allowances such as the free travel pass, the household benefits package and the fuel allowance go some way to recognising additional costs of disability. The loss of such benefits would severely impact on a disabled persons’ decision to take up employment, education or training. The income disregard has been a successful policy in supporting disabled people to take up paid employment. It is another measure that responds to the extra costs for someone with a disability going to work. Aligning disability payments with Jobseekers Allowance where employment is involved would result in a loss of earnings at all levels of income. For instance, at the time of publishing the report it was calculated that a single person on DA earning €100 would lose €24 per week or €1248 a year with the move to the proposed single payment structure. The move to cut disability allowance for young people aged 18-24 years would appear to have been a strategy to begin to align DA with Jobseekers allowance for the purpose of introducing the single payment. However this 3 Disability Federation of Ireland 7th February 2012 presumed that they have equal access to jobs, have the necessary supports in place and have no additional costs to do so. Any changes to align age limitations could only be done if the necessary income and personal supports are put in place beforehand and this is not currently the case. Disabled people are substantially disadvantaged in terms of access to work, education and training. Therefore, different age and time limitations have evolved to support their activation. For instance, a person on DA or Blind pension can apply for Back to Education Allowance at age 18 compared to 21 years for those on other payments. It is not clear how this would be incorporated into the new scheme. CE Schemes have been an important stepping stone for disabled people to access paid employment. The scheme had evolved to maximise their participation and to address the extra costs associated with returning to work for people with disabilities. The decision to phase out the payment of a second social welfare payment to CE recipients, as well as the proposal to cut the training and materials grant, is a step back from a proactive policy of activation that recognised the added barriers and costs disabled people face when accessing the labour market. The single social assistance payment is put forward as an element of the NESC developmental welfare state. The Report recognises that the single payment will only work in improving outcomes for people provided the necessary supports and services across Government departments are available. However this in not currently the case in relation to disabled people and it is therefore unacceptable to roll it out for existing or new applicants of disability payments until such a time that this can be guaranteed. The review argued that the ‘lower level of payment by moving from disability to Jobseeker template is compensated for by the availability of increased services and supports. However, there is a still a huge amount of work to be done across government departments and agencies to make services fully accessible to people with disabilities. In addition, the following issues would have to be addressed: The proposed National Employment and Entitlement Service (NEES) would have to be made available to people with disabilities as a matter of priority Case managers would require disability awareness training It is not clear how easy it would be for people to negotiate down the requirements that apply to them. This would apply to people whose health fluctuates and may need greater fluidity to move between levels 1 to level 3 depending on their health. A good example is those with conditions such as multiple sclerosis, arthritis or mental ill-health and who have periods of good and bad health. The loss of secondary benefits by moving up a level would act as a disincentive to work for people with disabilities and is to be avoided Current arrangements in terms of income disregard, secondary benefits and rules applied to payments make up a package of measures that go some way in addressing extra costs of disability. The review does not address how this would be impacted if the single payment is implemented as proposed. 4 Disability Federation of Ireland 7th February 2012 A full review of capacity would have to be well planned to deal with the complexity of the needs of people with disabilities and the supports they would require DFI are clear that the proposals outlined in the ‘Report on the Desirability and Feasibility of Introducing a Singe Social Assistance Payment for People of Working Age’ would remove important activation and income support measures that have developed in response to the specific needs of disabled people. The necessary supports and services to ensure that people with disabilities could avail of opportunities within a single payment structure are not currently in place. As such, DFI are of the view that the proposed scheme should not go ahead until such a time that adequate provision can be made for people with disabilities. 5 Disability Federation of Ireland 7th February 2012