HC 576 Progress towards the implementation of Universal Credit

Written evidence submitted by RNIB

Summary

· The Universal Credit regulations risk artificially separating out the support offered to different households with disabled children. One possible solution would be to amend the regulations so families with a child on at least middle rate DLA care receive the severely disabled child addition.

· The Government is redirecting support away from children with disabilities and working age adults living on their own to adults in the ESA support group. We would prefer to see the regulations amended to protect groups, like families with disabled children, who need additional support now.

· We support the idea of a self-care premium to reflect the additional costs borne by adults, like those with sight loss, who live on their own (this includes lone parents with dependent children). The self-care element would still be linked to DLA/PIP as SDP is today and would address the additional support needs disabled people living on their own experience above and beyond living with a health condition or impairment.

· RNIB has serious concerns about the claims process and would like to see the Government do more to assist claimants, like those with a visual impairment, who cannot readily or easily make a claim online.

· Blind and partially sighted individuals' access needs need to be at the heart of any claimant commitment and the regulations need to reflect there are a variety of good reasons why disabled adults might fail to comply with the claimant commitment, not least the provision of inaccessible information or the failure on the part of Jobcentre Plus or other relevant agencies to make reasonable adjustments.

1. Changes in the income entitlement of disabled people under Universal Credit

Reduced disability child additions

1.1 The maximum amount of Universal Credit is to include a specific addition to the Child Element called a Disabled Child Addition for each relevant child dependent. The disabled child addition will be awarded for a child who receives any rate of either component of DLA (mobility or care) apart from the highest rate of the care component. The severely disabled child addition will be awarded for a child who receives the highest rate of the care component of DLA or for a child who is registered blind.

1.2 Analysis by the Children's Society, Disability Rights UK and Citizens Advice [1] shows the support provided through disabled child additions will effectively be cut in half given families with a disabled child entitled to receive support through the disability element of child tax credit, currently receive £57 a week. In future many families with a disabled child will receive only £28 a week. This is equivalent to the loss of around £1,500 per year for most families with a disabled child. The change could cost families with a child born with a disability up to £24,000 by the time the child reaches 16 years old.

1.3 RNIB welcomes the recognition that families with children who are registered blind experience significant, ongoing extra costs. However RNIB questions the rationale of splitting the support families with a disabled child receive in the way the regulations currently propose. The regulations would mean families with children who are registered partially sighted experience a big drop in income compared with the current situation they find themselves in under child tax credit. The Government states it wants to support people with the greatest needs but registration status alone is not the most consistent or reliable predictor of a household's extra costs so to categorise and determine the support a household receives on the basis that a child is registered blind (as opposed to being registered partially sighted) is questionable in our view.

1.4 Children and young people with a visual impairment are more likely than children with no SEN to be socially and economically disadvantaged. Analysis of the Department for Education's own data highlights that 26 per cent of children with "Visual Impairments as their only SEN" and 29 per cent of children with "Visual Impairments plus another SEN" live in the fifth most deprived area of the country [2] . This tends to be the case of course, with other disability groups but what also needs noting is the very high proportion of children and young people with a visual impairment who have at least one other SEN or disability.

1.5 Children and young people with a visual impairment are rarely registered blind. The NHS Information Centre for Health and Social Care published figures [3] revealing two hundred children aged 0 - 4 years were registered blind the year ending March 2011 with only 710 children aged 0 - 4 years registered blind in total. With health studies showing far higher numbers of children and young people with partial sight than are reflected in registration data, RNIB is concerned that families with children who are not registered blind and do not receive higher rate DLA care and yet experience profound, complex problems will experience a disproportionate loss of income. This includes families with children with multiple disabilities including dual sensory loss.

1.6 The Universal Credit regulations risk artificially separating out the support offered to different households with disabled children. This could lead to the perverse situation where family 'Smith', to take a random example, would see their daughter with an unregistered sight impairment and severe hearing loss, experiencing a cut of £28 a week whilst family 'Jones' whose son is registered blind or receiving higher rate care (and experience the same needs) getting additional support under Universal Credit.

1.7 In summary what we are advocating is a level playing field. We warmly welcome the Government's recognition that families with a child who is registered blind experience additional, ongoing support needs but so too do families with children who are partially sighted or have sight loss and additional SEN. One possible solution would be to amend the regulations so families with a child on at least middle rate DLA care receive the severely disabled child addition, although this still has negative aspects. As we go on to explain in section (4) below, the Government is redirecting support away from children with disabilities and working age adults living on their own to adults in the support group. Whilst providing more generous support to individuals in the support group is a laudable aim - and one we would like to see the Government consider as finances allow - given the overall package of reforms for disabled people under Universal Credit is cost neutral, we would prefer to see the regulations amended to protect groups, like families with disabled children, who need additional support now.

Abolition of the severe disability premium

1.8 The severe disability premium (SDP) currently gives additional support to disabled adults who receive the middle rate or higher rate of the care component of DLA and live on their own (or just with children) and no one is paid carer's allowance for assisting them. This additional support helps to cover the additional costs of both living alone with a disability and having no carer, a situation that affects many blind and partially sighted people of working age.

1.9 The Government is abolishing the SDP with the introduction of Universal Credit. This will cost disabled adults with no one to care for them, or with only a young carer, about £58 per week (over £3,000 a year). The Government's stated objective is to simplify the benefits system and remove the complex web of additions and premiums. However, in RNIB's view this is a case of over-simplification. It involves simplifying the system without recognising the obvious damage it will do to disabled people experiencing the triple whammy of living on their own, losing additional support and in many cases receiving little, or no state-funded care from cash-strapped local authorities.

1.10 We support the idea of a self-care premium to reflect the additional costs borne by adults, like those with sight loss, who live on their own (this includes lone parents with dependent children). The self-care element would still be linked to DLA/PIP as SDP is today and would address the additional support needs disabled people living on their own experience above and beyond living with a health condition or impairment. This would better fulfil the Government's stated aims of supporting households with the greatest needs. In addition it would do very little damage to the cause of simplification given other additions, for example for carers, are being carried over from the current system.

Additional support for disabled adults in the support group for employment and support allowance

1.11 The Government is redirecting support away from children with disabilities and working age adults living on their own to adults in the support group. Whilst providing more generous support to individuals in the support group is a laudable aim - and one we would like to see the Government consider as finances allow - given the overall package of reforms for disabled people under Universal Credit is cost neutral, we would prefer to see the regulations amended to protect groups, like families with disabled children, who need additional support now.

Cuts to support for working age disabled people

1.12 Tax credits currently provide in-work support for people on low incomes. The disability element of working tax credit (WTC) is worth £54 a week and recognises that many disabled people have a reduced earning potential and are unable to work full-time as a result of their health condition or impairment. They also frequently face extra costs which can't be met by schemes such as Access to Work. The support will not, however, be replicated in Universal Credit except for those who would qualify as not fit for work. There will be no extra financial help within Universal Credit for anyone found 'fit for work' under the ESA work capability assessment. This represents a dramatic and unfortunate shift in the level of support provided to disabled adults hoping to remain in work or who have an ambition of increasing their hours or wages. It is in our view contrary to the wider aims of Universal Credit, which are to improve work incentives and support people in low income jobs.

2. The proposed arrangements for claims and payments

2.1 RNIB has serious concerns about the claims process and would like to see the Government do more to assist claimants, like those with a visual impairment, who cannot readily or easily make a claim online. A default and preferred option of encouraging online claims should not in any way compromise blind and partially sighted people's access to Universal Credit.

3. Arrangements for the "claimant commitment", sanctions and hardship payments.

3.1 RNIB has concerns about the Claimant Commitment, conditionality, sanctions and the hardship regime. Many blind and partially sighted people are found 'fit for work' following an assessment of their work capability. RNIB knows of a number of cases where individuals who are registered blind have been placed straight on to Jobseeker's Allowance, which of course entails a totally different - non-specialist - level of support compared with ESA WRAG. DWP figures reveal that around 55 per cent of new ESA claims are being found 'Fit for Work'. Bearing in mind these claimants will have health conditions and disabilities, the regulations governing conditionality and sanctions must be sensitively and fairly applied to individuals in the Work Related Requirements group.

3.2 Blind and partially sighted people often tell RNIB they receive information from Jobcentre Plus and other public bodies in formats they cannot read. Research shows that inaccessible job adverts represent one of blind and partially sighted people's main barriers to searching for and obtaining employment. Blind and partially sighted individuals' access needs need to be at the heart of any claimant commitment and the regulations need to reflect there are a variety of good reasons why disabled adults might fail to comply with the claimant commitment, not least the provision of inaccessible information or the failure on the part of Jobcentre Plus or other relevant agencies to make reasonable adjustments.

4. Eligibility for and operation of passported benefits

4.1 The Social Security Advisory Committee noted in its Annexe to its review on passported benefits ('passporting to the future') that the following groups of people (and their partner if they have one) are eligible for support with the costs of sight tests and optical treatment:

Individuals in receipt of:

· Income Support

· Income-based Jobseeker's Allowance

· Income-related Employment and Support Allowance

· the Guarantee element of State Pension Credit for partners under 60

People (and their partner if they have one) receiving the following Tax Credits are eligible if their income is below a threshold amount - currently £15,276 gross taxable per year:

· Working Tax Credit with a disability or severe disability element

· Child Tax Credit with Working Tax Credit

· Child Tax Credit on its own

4.2 In common with optical groups we would be extremely concerned were rules on eligibility for passported benefits to restrict access to support with the costs of sight tests and optical treatment. The administration of Universal Credit needs to be simple enough to enable the Department of Health - and indeed optical practices - to continue assessing entitlement to individual support under the General Optical Services contract (GOS).

About us

RNIB is a membership organisation with over 10,000 members who are blind, partially sighted or the friends and family of people with sight loss. 80 per cent of our Trustees and Assembly Members are blind or partially sighted. We encourage members to be involved in our work and regularly consult with them on government policy and their ideas for change.

Our priorities are to:

· Stop people losing their sight unnecessarily

· Support independent living for blind and partially sighted people

· Create a society that is inclusive of blind and partially sighted people's interests and needs.

17 August 2012


[1] 'Disability and Universal Credit', Royston, Sue & Royston, Sam (July 2012).

[2] http://www.rnib.org.uk/aboutus/Research/reports/education/Pages/educational_attainment.aspx

[3] NHS Information Centre for Health and Social Care Registration Figures year ending March 31st 2011.

Prepared 7th September 2012