Disability Federation of Ireland
Submission to the
Department of Social Protection
Recommendations
for Budget 2014
June 2013
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
“..although the disability benefit system provides the basic levels of income
for survival, people with disabilities are still among the poorest in society.
Therefore, the combining of such benefits with earnings from employment
would contribute to people with disabilities living a life in dignity and not one
only just above the poverty line. Action is needed to highlight and target the
1 poverty of disabled people within the context of social protection and social
inclusion debates. “
Introduction
DFI welcomes the opportunity to make a submission to the Department of
Social Protection regarding the protection of the rights and dignity of people
with disabilities, via income supports and employment activation measures.
People with disabilities must be prioritised in this budget. The adverse impact
of cuts and withdrawals imposed on people with disabilities over the last five
years have pushed many individuals with disabilities and families with
disabled members to a point where they do not have adequate income and
can no longer live with dignity. Reductions in income supports and activation
measures represent part of a larger picture of cumulative reductions in both
disability-specific and mainstream services that have had devastating effects.
This trend is undermining the infrastructure required to underpin the UN
Convention of the Rights of People with Disabilities, which Ireland is
committed to ratify. It also undermines this Government’s commitment to the
National Disability Strategy.
Budget 2014 must recognise that people with disabilities lack choice and
opportunity and face a multitude of barriers to get into employment including
poor health, a lack of education, accessibility issues and inflexible work
arrangements, which keeps them far from active participation in the labour
force2. Budgetary measures must not add further to the distance people with
disabilities currently experience from the labour market. It must instead
1
Bloch, F (2008) Disability Benefit Reform and the Contract for Income Support, Foundation of Law,
Justice and Society, Oxford.
2
Social Portrait Report of People with Disabilities (2012), Office for Social Inclusion, Department of
Social Protection.
Disability Federation of Ireland, June 2013
Page 2
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
prioritise the activation of people with disabilities, in accordance with individual
capacity.
This submission makes recommendations under two broad headings, calling
for adequate income supports for people with disabilities and for the inclusion
of people with disabilities in all employment activation measures as well as a
considered approach to specialist measures at activating people with
disabilities.
1. Adequate Income for People with Disabilities
People who cannot work due to chronic illness or disability depend on the
State to insure them against a reasonable level of risk including poverty and
social inclusion. While labour market participation remains the best insurance
against poverty, the same opportunities do not apply to disabled people.
Twice the number of families whose head of household is not at work due to
their disability or illness were living in consistent poverty in 2010 compared to
2009.
Disability Allowance remains a contingency payment, on par with Jobseekers
Allowance. Yet those on the Jobseekers payments are expected to move
back into the labour force, whilst many people with disabilities are likely to
continue to live on the lowest of income protection supports, often for their
entire adult lives. The OECD report (2008) points out that “the probability of
Disability Federation of Ireland, June 2013
Page 3
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
returning to work after being granted a disability benefit is below 2% annually
across member countries”.
There have already been substantial cuts to income for people with
disabilities. Disabilities payments have been reduced by 8.1% since 2010
and the cumulative impact of cuts to secondary benefits, such as the heating
allowance have had a greater impact on people with disabilities because of
the nature of their conditions. DFI therefore, opposes any cuts to the rate of
basic social welfare payments.
DFI Recommendation 1: Protect basic payments for people
with disabilities.
Rationalisation of Disability Payments
DFI understands the complexity of providing income supports and the
potential that payments result in unintended consequences such as
dependency for people who might have the capacity to take a more active role
in the labour market. We also concur with the OECD assertion that hiding
unemployment in the “wrong” welfare system is a failed and costly strategy3.
We are concerned to ensure however, that the 86% rise in the number of
claimants between 2000 and 2009 is not used as a rationale that effectively
disqualifies people who are genuinely eligible for income supports, or to hold
up new applications in an unnecessary appeal process. Appeals are costly,
not only in terms of the Departments resources, but they are costly for the
health and wellbeing of people with disabilities who could reasonably expect
to qualify for income supports.
The total number of individuals on Disability Allowance (DA) year on year has
slowed down, from 7.5% since 2008 to 1.7% in 20114.
3
4
Sickness, Disability and Work (2008) OCED
http://www.welfare.ie/en/downloads/statse2011.pdf.
Disability Federation of Ireland, June 2013
Page 4
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
Year5
Rate of Increase of
People on Disability
Allowance
2007 - 2008
7.5%
2008 – 2009 4%
2009 – 2010 1.5%
2010 – 2011 1.7%
It is also striking to note that the proportion
of awarded claims to new claims has
dropped from 58% awarded in 2007 to
38% awarded in 20116.
DFI is also concerned that disability rates
and health and wellbeing are being
confused in the rationale being used to understand how to go about
reconfiguring payments in order to meet budgetary requirements. Ireland is
not unique in reporting an increased level of health hand in hand with
increased numbers of people categorised as having a disability, in terms of
disability payments7. An individual can be in good health and have a disability,
or have a chronic illness that is not categorised as a disability. For example a
person with a progressive condition may have a long-term disability in terms
of being hindered from full participation in society even though they are
healthy. It is entirely possible that the population could have good health and
at the same time have a significant number of people with disabilities.
The numbers of people on Disability payments have increased for several
legitimate reasons as indicated in the Value For Money Review of Disability
Allowance (2010) including the following:

Demand versus budget led payment: the previous disability payment
(DPMA) may have artificially supressed the numbers eligible for
payments.

Change in eligibility criteria and diagnosis: In 2002 people with
autism and ADHD became eligible for Domiciliary Care Allowance, and
as they became adults they became eligible for DA. In 2007 people in
institutional care became eligible for Disability Allowance (rising to an
immediate increase of 2,700 claimants in 2002 alone). There are now
20,000 people with mental health problems on Disability payments,
5
http://www.welfare.ie/en/downloads/statse2011.pdf.
http://www.welfare.ie/en/downloads/statse2011.pdf.
7
http://www.who.int/mediacentre/factsheets/fs352/en.
6
Disability Federation of Ireland, June 2013
Page 5
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
living in the community, which corresponds roughly with the numbers in
mental health institutions in the 1950s.

Migration between payments: changes in eligibility criteria has
resulted in many people with severe substance misuse issues
migrating to Disability Allowance.

Population changes: An OECD analysis estimates that half of the
growth in disability payments is attributable to changes in the age
structure of Ireland’s population. In addition to this, population growth
would have added 16,500 claimants between 1998 and 2008.
Migration also accounted for almost 4% of claims from foreign
nationals.
DFI Recommendation 2: Improve the effective
administration of the schemes to include transparent
application and appeals processes, including the medical
assessment process and guidelines to ensure that those
who are eligible receive payments in a timely manner.
Cost of Disability:
People with disabilities face additional costs, estimated to be a third of
average weekly disposable income.8 To-date no specific payment exists to
compensate people for these costs where relevant. A direct payment (or tax
credit for those at work) is one aspect of a wider ‘cost of disability package’ to
help put people on a level playing field. Other aspects of such a package
have already evolved in the form of secondary benefits and income
disregards associated with disability payments such as Disability Allowance.
These measures were also introduced to counteract the poverty and
unemployment traps particular to disability. DFI is therefore very firmly against
any decision to reduce associated secondary benefits, in the absence of
consultation around specific reform proposals to provide a cost of disability
package.
Cullinan, J, Gannon ,B and Lyons, S (2010) “Estimating the Extra Cost of Living for People with
Disabilities”,Health Economics
8
Disability Federation of Ireland, June 2013
Page 6
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
We have concerns about some measures taken in Budget 2013 such as the
effective reduction in the Household Benefits Package of the electricity
allowance and the rationale used for this. The change from units to a cash
payment presumed that people in receipt of these benefits have the capacity
and internet capability to shop around almost halved the effective buying
power of the allowance from €70 to €38.88 for those most socially excluded.
This puts into question the Department’s assertion that the main welfare and
direct tax measures of Budget 2013 led to no significant changes in the atrisk-poverty-rate. It has been established that the cost of living with a disability
is higher for many in terms of heating and fuel requirements. Reductions in
these allowances pushes people with disabilities further into untenable living
conditions, even more so than others who are also socially excluded. Further
reductions to Domiciliary Care Allowance or Respite Care Grants cannot be
sustained by people with disabilities and their families. DFI opposes any cuts
to secondary benefits or changes in the way in which they are delivered, in
the absence of a considered dialogue with stakeholders in the disability sector
concerning how else these extra necessary costs are to be supported.
DFI Recommendation 3: Protect ALL secondary payments
for people with disabilities that recognise the extra costs
involved in living with a disability.
DFI Recommendation 4: Engage all stakeholders in a
consultation to review how Cost of Disability payments can
best be tailored for those who need them.
Poverty and people with disabilities
We welcome the monitoring mechanisms that the Department has put in
place, namely the Social Inclusion Monitor and the Social Impact Assessment
of the Main Welfare and Direct Tax Measures. For the Social Impact
Assessment to be effective in its aim of strengthening the implementation of
national social targets and sub targets on child poverty and jobless
households, all adjustments considered for any of the disability payments
Disability Federation of Ireland, June 2013
Page 7
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
must be considered in terms of the cost of disability and include all payments
across government departments, including medical card eligibility.
We also hope both measures will develop in their capacity to run
comprehensive risk assessments on the cost of leaving many people with
disabilities socially excluded and living in poverty and their accompanying ill
health over time. That will account for the true cost of disability in Irish society,
not only to the state but to people’s lives. In the immediate term however,
more must be done to ensure that budgetary measures are disability proofed
across all departments.
DFI Recommendation 5: Widen the scope of the Social
Inclusion Monitor and the Social Impact Assessment of the
Main Welfare and Direct Tax Measures to include analysis
of the impact on people with disabilities using a whole of
government approach.
2. Activation and Employment
It is important to point out that people with disabilities were already
disadvantaged coming into the recession. Even at the height of the boom,
when long-term unemployment was at an all-time low, the percentage of
people with disabilities in employment was only half that for those without
disabilities.9 By 2011, 30% of adults with disabilities were active in the labour
market compared to 61.9% of other adults. The low educational attainment
9
http://www.nda.ie/cntmgmtnew.nsf/employmenttraininghomepage?OpenPage
Disability Federation of Ireland, June 2013
Page 8
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
and poor health of people with disabilities has made it even more challenging
to find and keep work. For instance, among people with disabilities, 43%
have not progressed beyond primary education.10 This structural
unemployment of people with disabilities who are more and more distanced
from the labour market means that equality of access to activation measures
are vital to encourage active participation and promote social inclusion.
Evidence from the Social Portrait of People with Disabilities shows that where
possible people with disabilities are willing to work if the conditions are right.
Data from the National Disability Survey (2006) demonstrated that 37 per cent
of people with disabilities who are not at work would be interested in a job,
which corresponds to over 40,000 people who wish to be more active in the
labour market.
Enablers, such as flexible working arrangements, accessible transport and
building, financial supports and health services, need to work seamlessly11.
We still await the Comprehensive Employment Strategy for People with
Disabilities. In the meanwhile, employment and activation programmes need
to be made accessible to people with disabilities. Eligibility for the Tús
Scheme remains closed to recipients of disability related payments. DFI
acknowledges that those on Disability Allowance can now access the
JobsBridge Scheme, but we are disappointed that this has not been extended
to people on Blind Pension. Even more worrying is the effective exclusion of
people with disabilities from the public face of the purpose of Intreo services.
DFI is concerned that marketing Intreo and concentrating employment
activation measures almost exclusively on those on the live register means
that many disabled people will be further distanced form the labour force,
making it more likely that they will live in poverty and experience social
exclusion12.
10
ESRI & Department of Social Protection (2011) A Social Profile of People with Disabilities.
The Developmental Welfare State, (2005) NESC.
12
Sickness, Disability and Work (2008) OCED
11
Disability Federation of Ireland, June 2013
Page 9
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
Whilst 14 activation pilot projects have been put in place for people with
disabilities across the BMW region, there is little if any connection with
mainstream activation programmes. We would have to question the
government’s continued commitment to mainstreaming and the National
Disability Strategy if this not included. This adds to a two tiered system,
structural inequality where there are no bridges between the two, and it is
difficult to map clear progression routes.
DFI Recommendation 6: Introduce the Comprehensive
Employment Strategy for people with disabilities, as
committed to in the National Disability Strategy.
DFI Recommendation 7: All mainstream activation
measures need to provide equality of access to people on
disability payments, where this is appropriate and desirable
for the individual.
Young people:
Among young adults aged 20-34, Ireland now has the third highest number of
people on disability benefit: 2.8% compared to an OECD average of 1.5%13.
Young people with disabilities continue to be left behind as there is no overt
policy to help people transition from school to the workforce, with projects
tending to reflect active inclusion as a by-product of their activities rather than
as an objective14. Young people with disabilities are less likely to emigrate or
stay in education longer as compared to their non-disabled cohorts, leading to
further structural inequalities. DFI welcomes this Minister’s Commitment to the
Youth Guarantee which will assure young people under the age of 25 a good
quality offer of employment, continued education, an apprenticeship or a
traineeship within four months of becoming unemployed. We hope that all
programmes developed under this guarantee make provision for the real and
13
14
http://www.oecd.org/ireland/46461490.pdf.
Active Inclusion of Young people with Disabilities or Health Problems, (2010) Eurofound
Disability Federation of Ireland, June 2013
Page 10
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
active participation of school leavers and young people with disabilities, and
we recognise the Minister’s commitment in this area.
DFI Recommendation 8: All actions taken under the youth
guarantee must have budgetary provision for any extra
supports that may be required to support people with
disabilities on par with their non disabled peers.
Partial Capacity Benefit Scheme
DFI recognises the Department’s attempt to address some of the structural
inequalities inherent in the welfare system, by introducing the Partial Capacity
Benefit Scheme as a substantive initiative to reform payments allowing people
on Invalidity Pension to take up work. The replacement of discretionary
exemption arrangements for individuals taking up employment with
standardised work capacity assessment represents a sizable shift in the
assessment of people with disabilities, away from a medicalised condition
focused assessment to an assessment based on capacity. Concerns remain
however, about the Scheme’s capacity to respond to and accommodate
people with disabilities changing needs. In order for people to be confident in
being able to move within the labour market, protection of secondary benefits
including the medical card must be guaranteed as part of a recognition of the
cost of disability.
DFI Recommendation 9: The Partial Capacity Scheme must
ensure that participants are not “locked out” of services
and income supports that recognise the cost of disability
when and if required.
CE Schemes:
Almost one in ten Disability Allowance claimants are engaged in employment,
and a quarter of these are on CE schemes. It seems clear that the earnings
disregard and tapered withdrawal rate introduced in 2006 has had a positive
impact on the improved take up of rehabilitative employment, with an
improved take up rate of 40% up to 2009. However entrants on disability
Disability Federation of Ireland, June 2013
Page 11
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
payments to CE schemes has fallen from 19% to 10% from 2008 to 201115.
We are concerned that people on disability payments are not being prioritised
for participation on CE schemes. We are also concerned that reductions in the
duration of the Schemes is resulting in an erosion of the maintenance of
service and social supports that many schemes provide to people with
disabilities, which is particularly important at a time of high unemployment16.
DFI Recommendation 10: People with disabilities are
prioritised for CE schemes, where appropriate, especially
given the difficulties in entering the labour market at this
time.
DFI Recommendation 11: Recognition of the service and
support function of CE schemes needs to be recognised in
planning for budget 2014.
Interdepartmental Co-operation:
Disability is a societal issue and every aspect of living cannot be provided for
under the auspices of one government department. This becomes very
evident when we look more closely at disability proofing government policies,
and examine the cumulative effects of cuts in recent budgets that have
undermined the autonomy of people with disabilities. “Silo-thinking must be
replaced by strong coordination and integration of policies and services”
according to the OECD report Sickness, Disability and Work (2008).
This is most evident in relation to the retention of the medical card.
People must be able to retain their medical card and move fluidly with the
confidence that services and supports are there when required, as
recommended by the OECD. Access to health care needs to be improved by
making the entitlement to a Medical Card independent of benefit status and
linked to need.
15
High level Issues Paper Emanating from a Review of Department of Social Protection Employment
Support Schemes (2012) Department of Social Protection.
16
Sickness, Disability and Work (2008) OECD.
Disability Federation of Ireland, June 2013
Page 12
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
In the current system people with disabilities can keep their medical card for
three years on moving from DA into employment. However this is not
sufficient for those with significant medical costs. The medical expenses do
not go away after 3 years, particularly for those with progressive disabilities. It
may simply be too costly for them to remain in employment once the card is
removed. Overall the policy of linking medical cards to benefit as opposed to
need is a deterrent to work for those with costly or progressive disabilities.
DFI Recommendation 12: Government departments need to
work more closely to ensure that budgetary measures add
up to having positive outcomes for people with disabilities.
DFI Recommendation 13: Medical cards need to be linked
to need rather than to the benefits system.
Conclusion:
DFI strongly urges the Department of Social Protection to protect people
with disabilities in this budget. Protecting basic payments will not go far
enough to achieve this. Secondary benefits must be preserved to stop the
slide of people with disabilities further into poverty and long term
unemployment. Otherwise when the austerity programme hopefully ends in
2016, the State will face the frustration and extra costs of sustained social
stress and blockages that drag down growth, as well as increasing
inequality, caused by the depletion of Ireland’s social and health
infrastructure.
Since 2008, successive years of cutbacks have undermined the
independence of people with disabilities and diminished the supports they
need to live ordinary lives, to enjoy individual autonomy and to participate in
society as equals. That is not in keeping with the UN Convention on the
Rights of Persons with Disabilities. People, along with experiencing
deterioration in disability specific services and supports, are also living under
the weight of cutbacks and restrictions in general public services. This is a
Disability Federation of Ireland, June 2013
Page 13
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
double recession hit for them and their families, as we know that cuts in
general services impact more negatively on people with disabilities.
Please do not hesitate to contact DFI to discuss any aspect of this
submission.
Disability Federation of Ireland, June 2013
Page 14
Disability Federation of Ireland Submission to Department of Social Protection Budget 2014
The Disability Federation of Ireland (DFI) represents the interests and the
expectations of people with disabilities to be fully included in Irish society. It
comprises organisations that represent and support people with disabilities
and disabling conditions.
The vision of DFI is that Irish society is fully inclusive of people with disabilities
and disabling conditions so that they can exercise their full civil, economic,
social and human rights and that they are enabled to reach their full potential
in life. DFI’s mission is to act as an advocate for the full and equal inclusion of
people with disabilities and disabling conditions in all aspects of their lives.
DFI works on the basis that disability is a societal issue and so works with
Government, and across the social and economic strands and interests of
society.
For further information go to www.disability-federation.ie
Disability Federation of Ireland, Fumbally Court, Fumbally Lane, Dublin 8
Tel: 01-4547978, Fax: 01-4547981
Email: info@disability-federation.ie Web: www.disability-federation.ie
Union of Voluntary Organisations of People with Disabilities trading as The Disability
Federation of Ireland is a company limited by guarantee not having share capital,
registered in Dublin.
Registered No. 140948, CHY No 6177
Disability Federation of Ireland, June 2013
Page 15