Select Committee on Work and Pensions Written Evidence

Supplementary memorandum submitted by UnumProvident following the publication of the Welfare Reform Green Paper

  UnumProvident is the UKs leading provider of group income protection insurance, with over 30 years of experience. Our customers benefit from our expertise in the specialist areas of disability, rehabilitation and return-to-work. We enable individuals to protect their incomes, ensuring their financial security if they are unable to work because of illness or injury. For employers, we safeguard one of their most valuable resources by helping employees return to work following long-term absence. At the end of 2004, UnumProvident protected over 2.1 million lives through more than 19,800 schemes. During 2004 we paid total benefit claims of over £249 million—of which more than £177 million related to income protection claims.

  We are active in several key areas of interest to the Committee as follows:


  In 2004 Professor Mansel Aylward was appointed to be the first director of the UnumProvident Centre for Psychosocial and Disability Research at Cardiff University. A current work strand of the centre involves GP education as to the role of the clinician as the gatekeeper to IB. This looks at piloting improvements in the competency, training and engagement process of GPs with incapacitated patients who want to return to work. When published, this research will be made available to members of the Committee.


  A key partner organisation for UnumProvident is the Employers' Forum on Disability (EFD). We supported EFDs Global Inclusion Benchmark which surveyed the inclusion of disability in companies' social reporting and worked alongside other members in the development and piloting of a UK Disability benchmark. UnumProvident is a sponsor of the Healthy Workplaces category at the BITC Annual awards for excellence and was supported in this by the Department of Health and it was run in association with the Health and Safety Executive. We are also founder members of a new BITC Leadership Team on Healthy Workplaces which seek to address this important aspect of the corporate responsibility agenda. We would be happy to share with the committee the lessons from these initiatives.


  Our commitment to the wider world of disability and employment is shown by our prime mover support for "Beginnings". Beginnings is a coalition of the private sector, employer and employee organisations and groups of and for disabled people, who believe that placing and then keeping disabled people in productive employment will provide them with fulfilment and self-esteem, as well as economic independence.

  Each year Beginnings holds an annual event. Our 2006 event will be chaired by Beginnings' patron Baroness Sally Greengross and will be held on 16 March. Confirmed speakers include: Rt Hon John Hutton MP, Secretary of State for Work and Pensions Lord Kirkwood, former chair of the Commons Work and Pensions Select Committee.

  In concept with RNID we developed a second Workplace of the Future stand which was successfully showcased at all three party conferences. We continue to work with RNID to ensure modern workplaces are made accessible for disabled people. These are just some examples of areas where commercial regulations, in concert with the voluntary sctor, can make a real difference.


  1.  UnumProvident is pleased that the Incapacity Benefit (IB) system is being considered for reform, for indeed it was at our 2005 Beginnings event that the Green Paper was proposed. Like many other groups, we are pleased with the overall content of the Paper and will work with the Government to ensure the stated goals are achieved.

  2.  Together with our partners we have consistently called for measures to be considered which would make a real difference to peoples life and employment choices including:

    —    Early intervention is critical for enduring Return to Work success.

    —    GPs require training in the therapeutic benefits of work.

    —    Revision of the "sicknote" process.

    —    Prevention is also important—creating healthy workplaces and retaining sick and disabled people in the jobs they already have.

    —    Encouraging employers and Government to focus on ability not disability.

    —    Extending Pathways to Work and providing better quality rehabilitation capacity.

    —    Making the system flexible for those with mental illness and intermittent conditions.

    —    Change the name of IB.

  And we were therefore very pleased to see that the Green Paper, amongst other measures called for:

    —    Minimum wait for personal capacity assessments.

    —    New training for healthcare professionals at all stages in work and "all the health benefits this brings".

    —    Consideration given to pilots of new sick note pads and Statutory Sick Pay reform—payable from day one.

    —    Investors in People Healthy Organisation standard by 2007.

    —    Benefits not to be given on the basis of a certain disability or illness but on capacity assessment.

    —    National roll-out of Pathways to Work (2008) and national helpline for SMEs.

    —    Tiered re-named benefit and more generous linking rules—and a recognition that more work needs to be done.

    —    Employment and Support Allowance.


  3.  We endorse the name of the benefit being changed to the Employment and Support Allowance. We have long argued for this change as it sets the tone for how the benefit is perceived.


  4.  The Pathways to Work pilots have shown very promising results on the basis of the first assessment. They have comprehensively shown that it is possible for many claimants of IB to get jobs with the right help and support, and that early intervention with rehabilitation support is highly effective. We therefore warmly welcome the £360 million investment in a national roll-out for this proven route back into work.

  5.  However, we are concerned about the ability for these new schemes to be delivered. While the Government has noted that it will be supporting greater private sector involvement, particularly in the extension of Pathways, we are nonetheless concerned that this will not generate sufficient further capacity in terms of support and intervention—which will take some time to build. This is a wider concern in the medium-term as the Government looks to offer more help to existing claimants, to achieve its one million in a decade target.

  6.  Our extended experience in this field has shown us that the correct model to apply when helping people to return to work is a bio-psychosocial one. This incorporates elements of helping the individual deal with any sickness/illness (bio), motivating them and providing them with the necessary support/advice/information to get back into employment (psycho), and fully understand the social setting of their disability/lack of capacity (social), which can incorporate wider pressures upon them (eg childcare) and employer perceptions of certain conditions.

  7.  Vocational Rehabilitation professionals are required to undertake this work and we are pleased that the Government has understood and applied this in their development of back to work services (notably through Pathways). We are, however, very concerned that the capacity for such staff will not be available for further initiatives/roll-outs mentioned in the Green Paper, and nor are the qualifications and infrastructure to deliver such further capacity. A highly respected research report has noted that:

    "The current picture, therefore, is one of a mosaic of standards, drawn from a variety of sources with no major cohesion or critical mass for one or more sets of standards covering the whole field (of Vocational Rehabilitation)."[39]

  8.  As a private provider, UnumProvident has been working on solutions to this capacity dilemma—which will affect both sectors. In 2005 when we acquired the UK licence for potential solution for this. A programme has been developed by a non-profit organisation in Canada, known as the National Institute of Disability Management and Research (NIDMAR), and consists of Disability Management (DM) Audit Training and DM certification programmes.

  9.  The former will provide valuable information to employers that will enable them to more capably manage their sickness absence policies and processes. The training programme consists of 26 stand-alone modules, which together provide comprehensive education in the DM field for clinical and other support staff eg Nursing, OT and Physio. We are in discussion with a number of accreditation bodies to introduce this process into the UK and thereby seek to improve the cadre of vocational rehab procedures. We will keep the Committee informed of this progress.


  10.  We noted in our first submission that UnumProvident's own rehabilitation model has been highly successful due to its focus on early intervention and employer engagement—before the employee's contact with them has been lost and social networks cut. Certainly we see the employer as crucial to our success, and any successful programme that helps employees back to work must also positively engage with the employer. The Government should consider this interaction as much as is possible; beyond the city-focused strategies.


  11.  We welcome the recognition in the Workplace Health Connect initiative that employers, particulary small employers, need support when hiring disabled staff and to be more involved in job retention so that people can remain or return to their work when recovering from illness or adapting to a disability. Employers also have a key role to play in reducing the impact of stress and other mental health conditions in the workplace; the biggest growing claim on both public and insured benefit systems.

  12.  However greater employer engagement may well see corresponding further pressure being placed upon Access to Work (AtW) funds. We welcome the additional investment made thus far by Government, but would note that this will need to be increased if employer involvement is to make a meaningful contribution. It is claimed that £1 million spent on AtW quite quickly brings £1.7 million back into the Treasury. If this case can be proven, we would ask that the Treasury hypothecates any money saved and re-invests this in the scheme—ie payment by results. We would also note that reform should be considered to allow disabled people to apply for AtW—gaining a guarantee of support—before they accept a job offer, as this can otherwise lead to weeks of inactivity for the employee and employer as equipment is ordered and installed.


  13.  From a medical persepctive we welcome the Government's reference to the fact that "fluctuating conditions", particularly these with a mental health element, need to be accommodated within the system—and their admission that more work is needed to achieve this.

  14.  Through Beginnings we have also recognised this and have set up a "Intermittent Capacity" Taskforce to further look into the issue.

  15.  Most conditions can be described in someway as intermittent. Equally each employee can be said to have intermittent capacity to work for a variety of reasons. This is an important step in thinking to make in this area. Is someone with an intermittent condition, say stress, which can inhibit work, any different from a parent with intermittent childcare issues ie when they fall ill and have to spend time off school?

  16.  The benefit system will never be flexible enough to accommodate every nature of intermittent conditions. This should not lead to inaction or reform, but should help us recognise that, in the same way many employers treat parents, our focus should be on helping employers understand what is reasonable and fair. To this end the Intermittent Capacity Taskforce within Beginnings is working on establishing the principles for advice to employers on this issue. This will be available soon and can be made available to the Committee.


  17.  We welcome the Government's commitment to pilot the provision of employment advisers in GP surgeries. One-off examples have been very positive, provided GP surgeries are given some incentive to provide this extra service.

  18.  We equally welcome the Government's recognition that sicknotes may need to be reformed. On PCAs we will be moving from a system of judging what someone cannot do to what they can. This should equally be applied to sicknotes.

  19.  Sicknotes are currently too black and white—for example someone may have a bad back, which would qualify them for a sicknote, but that does not inhibit them from many of the functions of their job as an office worker. Employees and employers treat sicknotes as being sacred—and therefore do not want to disobey them for fear of harming themselves or an employee. Equally, GPs may be concerned that they are liable if they do not provide a sicknote for someone who is sick, but can nonetheless work.

  20.  We would therefore suggest the trialling of a "Functional Restrictions Pad" instead. This could be modelled on the PCA, and would highlight the activities that the individual can do without harming themselves or others. The individual, the GP and the employer could then make an active decision about whether the person could return to their specific role or work generally in some capacity. It must be remembered that most people ending up on IB are off-work for what they expect to be a short period of time—where possible this should be avoided and GPs should highlight the therapeutic nature of work.


  21.  It is known paradox that despite the vast advances in medical treatments in the later half of the 20th century that there is a huge increase in people who are considered too ill to work. This rise in incapacity has taken place from the 1980s onwards and is seen in all developed countries. It cannot be easily explained in medical terms. Clearly the increase in illness is a complex social and psychological problem and definitely not imaginary. The biopsychosocial model of disability not only explains this part of this phenomenon, but also suggest how best to manage it.

  22.  Managers need to understand that very few illnesses actually cause complete incapacity and that waiting until a member of staff is fully recovered from an illness or injury can be the very worst thing they can do. Similarly, appearing to question the reasons behind an absence can be very counterproductive and unnecessarily confrontational. Adopting an enabling approach seeking to overcome barriers to work is very much more effective.

  23.  A common question asked by employers of occupational physicians is whether an illness is covered by the Disability Discrimination Act. In many cases at the early stages of an absence the answer is "no" because the anticipated duration of illness is short. However, doing nothing and leaving people sitting at home can lead to illnesses becoming worse and complicated by depression. Treating all sick employees as potentially disabled and making adjustments where possible not only protects against liability under the Act, but can actually prevent disability.

  24.  At UnumProvident we have a non-medical, enabling model of rehabilitation and we are working with our partners at the UnumProvident Centre for Psychosocial and Disability Research at Cardiff University to better understand what places people at risk of long-term or chronic illness. Further information about this model can be made available to the committee.

39   Bysshe, S et al 2002, "Employment and Disability Functions in the UK: An occupational and functional review", HOST policy research. Back

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