HC 576 Progress towards the implementation of Universal Credit

Written evidence submitted by Institute of Revenues, Rating and Valuation (IRRV)

The Institute of Revenues, Rating and Valuation (IRRV) is pleased to provide the following submission to the  Inquiry into the implementation of Universal Credit.

The IRRV is the professional body concerned with all aspects of local benefits administration and local taxation in the United Kingdom and has members within both the private and public sectors. Institute members are engaged in local authority benefits administration, local tax administration, valuation of property for taxation, the appeals process and financial management in local government. The Institute represents the professional interests of its members who work within this broad church.

The Institute is the only professional body in the United Kingdom that specialises in the law and practice of local authority revenues and local taxation collection together with the income related benefits that support these processes.

Summary

We are concerned about the level of support that will be available to the more vulnerable customers, who may not have the access or skills to claim electronically in the ‘digital by default’ process.

Little is known of the government’s intention regarding local government’s role in providing support and advice in UC delivery. Late LA involvement in the process will hamper local authorities in both resourcing and delivery terms; and it may impact on customer service.

Current reductions in local authority staffing numbers may lead to reduced capacity to deal face-to-face with customers under UC.

Bringing the majority of claimants round to the use of electronically managed claims may be more resource intensive than originally estimated.

The UC IT solution in general and the interface with RTI systems for PAYE in particular need to be extremely well designed, planned and executed in order for UC to work. Timescales may prevent adequate full system testing and evaluation.

Localised council tax support is being introduced over too short a timescale and its financial impact on various client groups and local authorities themselves, particularly when considered in conjunction with the raft of other forthcoming benefits changes, cannot be adequately assessed at this stage.

There is a genuine concern that the loss of high calibre staff will affect performance targets and service delivery of legacy benefits and/or any UC role.

Body of Response

The proposed arrangements for claims and payments and the provision of support and advice for claimants

1. We are concerned about the level of support that will be available to more vulnerable customers who may not have access or skills to claim electronically in the ‘digital by default’ process. Local authorities (LAs) would be ideally suited to provide client-facing support for UC. However, little is known of the government’s intention regarding local government’s role in support and advice. Late LA involvement in the process will hamper them in both resourcing and delivery terms – and it may ultimately impact on service delivery to those who are least able to cope with the system changes. We are concerned that current reductions in LA staffing numbers may lead to reduced capacity to deal face-to-face with customers under UC.

2. More generally, the take-up of electronic claiming has not had an impressive track record. In our view bringing the majority of claimants round to the use of electronically managed claims may be more resource intensive than originally estimated.

3. Commissioning the face-to-face role via an application process will add complexity to the process. Adequate data sharing arrangements will be key to ensuring partnership arrangements work efficiently.

4. Monthly budgeting is a key theme under UC, but it will throw up difficulties for many who have long coped with more frequent payments. There is little give in the system for those who may have difficulties dealing with this change of approach – and the impact of erratic finances could be felt family-wide, not just by the claimant themselves.

Progress with developing the necessary IT systems to administer Universal Credit, including the real-time information (RTI) system for PAYE taxation being developed by HM Revenue & Customs.

5. Our observation here is that the UC IT solution in general and the interface with RTI systems for PAYE in particular need to be extremely well designed, planned and executed in order for UC to work. Our concern is that the timescales will prevent the necessary full system testing and evaluation being conducted prior to and during the pathfinder phase, from April 2013.

The impact of the changes on local authorities, including budgets, staff and support for claimants. The changes include those to Housing Benefit; the introduction of the benefit cap; and localisation of council tax support.

6. A shared sentiment amongst practitioners is frustration regarding the uncertainty about both UC implementation delivery and the role that LAs may or may not play in the delivery process. There is a marked lack of definition of the LA role. This is played against a background of having to operate a range of changes to legacy benefits from April 2013 in the run up to UC, in respect of the benefit cap, the new Council Tax Support Scheme and the size criteria in the social rented sector.

7. Localised council tax support is of major concern. In our view this major change is being introduced over too short a timescale and its financial impact on various client groups and local authorities themselves, particularly when considered in conjunction with the raft of other forthcoming benefits changes, cannot be adequately assessed at this stage. The uncertainties may impact on budget setting.

8. We already are seeing what impact these cumulative changes are having on staffing, in terms of significant staff concerns about employment prospects, staff leaving LA employment and the pressures of working in an information vacuum regarding the LA delivery role. It is difficult to estimate what the overall workload will be as a result of these cumulative changes, but there is a genuine concern that the loss of high calibre staff will affect performance targets and service delivery of legacy benefits and/or any UC role.

17 August 2012

Prepared 7th September 2012