Advice NI Response To: Shaping Future Support: The Health and Disability Green Paper

12 October 2021 09:54
  • Consultation Responses

This consultation focuses on the main benefits paid to disabled people and people with long-term health conditions of working age. 

Advice NI Response To: Shaping Future Support: The Health and Disability Green Paper 


Advice NI is a membership organisation that exists to provide leadership, representation and support for independent advice organisations to facilitate the delivery of high quality, sustainable advice services.  Advice NI exists to provide its members with the capacity and tools to ensure effective advice services delivery.  This includes: advice and information management systems, funding and planning, quality assurance support, NVQs in advice and guidance, social policy coordination and ICT development. 

Membership of Advice NI is normally for organisations that provide significant advice and information services to the public. Advice NI has over 70 member organisations operating throughout Northern Ireland dealing with over 500,000 enquiries on an extensive range of matters including: social security, housing, debt, consumer and employment issues.  For further information, please visit


  1. It is disappointing that to our knowledge DWP made no apparent effort to engage or raise awareness about this Green Paper during the consultation window or engage regarding the contents of the Green Paper and the potentially wide-ranging impacts if some of the ideas were to be actioned. The timing of the consultation leaves much to be desired, launched on the 20th July with a deadline of 11th October.

The Scope of this Green Paper

This consultation focuses on the main benefits paid to disabled people and people with long-term health conditions of working age. These benefits fall into two groups: • Benefits for people who have a health condition or disability that affects their ability to work and who are unemployed or on a low income. These benefits are ESA and UC. • Benefits to help with some of the extra costs for disabled people and people with long-term health conditions. These are paid to people whether or not people have a job or income, and aim to support independent living. The main extra costs benefit is Personal Independence Payment (PIP), which is replacing Disability Living Allowance (DLA) for adults.

  1. The inclusion of Universal Credit will create deep unease, especially given that the consultation paper straddles the implementation of a cut to Universal Credit which has been described as:
    • “Tomorrow the Government will make the biggest overnight cut to the basic rate of social security support since the birth of the modern welfare state. The social security lifeline that millions of families rely on will be cut to completely inadequate levels. #KeepTheLifeline (Joseph Rowntree Foundation)
    • “The theme for #WorldMentalHealthDay is mental health in an unequal world. That’s why we’re using today as a reminder of the devastating consequences this week’s £20-a-week cut to Universal Credit will have for people’s mental health.” (British Psychological Society)
    • “Our modelling indicates that child poverty will increase by 300,000 unless the chancellor changes course.” (Child Poverty Action Group)
    • “Cut to universal credit uplift 'not the right way to save government money'” (Gordon Brown)
    • “The cut to Universal Credit will disproportionately affect women.” (Fawsett Society)
    • “The assertion by Government that it wants to focus on jobs as a route out of poverty does not deal with the issue and in fact demonstrates a fundamental misunderstanding of Universal Credit. Claimants are not a homogeneous group of people. For example, 40% of households in receipt of Universal Credit have ‘No Work’ requirements, for example they are severely ill or indeed terminally ill, and so unfortunately work is not an option for them and so is not a solution to the £20 cut.” (Advice NI)

Should the Government be thinking about using Universal Credit as the ‘common denominator’ and levelling down support for people with disabilities to this ‘common denominator’, then the Government will simply be launching people with disabilities into even greater poverty and hardship.

It is also worth noting that this Green Paper follows deep cuts to disability benefits in terms of the reassessment of DLA to PIP (Treasury document in 2010 forecast 20% cut in terms of caseload and expenditure which has been borne out) and the abolition of the Work Related Activity Component in ESA (was equivalent to £29.05 per week).

  1. There is little doubt that trust in Government in terms of it’s commitment to support people with disabilities is fatally eroded given the track record in what is known as the decade of austerity. Some would fear that the Green Paper is less an attempt to provide the right support: rather it is really a cynical attempt to remove even more financial support from people with disabilities. The following paragraph in the Green Paper is a case in point:

“59. We must ensure that disabled people and people with health conditions are effectively supported. This Green Paper will consider whether the money we spend on supporting disabled people and people with health conditions is spent well. This includes ensuring that we have the right checks in place to make sure we are paying people the right amount of money for their particular circumstances. This is because we want to ensure that the health and disability benefits system is effective and sustainable in the future.”

  1. The acknowledgement of the role of the independent advice network is to be welcomed in the Green Paper. In NI, Independent advice agencies provide services in every community in every locality in Northern Ireland. Access to advice supports people to receive the benefits they are entitled to or resolve problems before they escalate. Timely debt advice, for example, enables people to alleviate their money problems and take charge of their financial future. Newcomers to Northern Ireland face particular difficulties and the advice sector plays a critical role in enabling migrants to enjoy their legal rights and entitlements. Regional infra-structural support organisations provide infra-structural support to frontline providers through a range of services; for example, information, training, ICT support, help with addressing social policy issues, assistance with governance and finance/funding issues and a broad range of other support functions to allow the frontline services to function effectively.

This range of independent advice network access in NI must not be taken for granted; these channels must be sustained and the necessary funding must be in place to allow them to function effectively, in particular if Government see a more prominent role in the future.

In terms of the mobility needs of people with disabilities and the Motability Scheme in particular, there has been much comment on the effectiveness of the Motability Scheme. It is unclear whether the Motability Scheme forms part of the scope of the Green Paper, and whether ideas such as retaining a motability car while a social security benefit decision is being challenged could be explored.

“95. We have listened to what people have told us at Green Paper events, through surveys and research. Although most people find our services easy to access63, we know that some disabled people and people with health conditions can struggle to access benefits and use services. Because of this, we want to do more to help people find their way through the benefits system and access wider support. This includes improving signposting to other services, such as housing and health, and testing advocacy support. 96. We believe that together, improving signposting and offering advocacy could make it easier for people to use the benefits system and help meet their wider needs. Since being able to move around and travel freely is an important need for many disabled people, we also want to understand what more we can do to help people meet their mobility needs.”

  1. It is clear that the action of DWP in terms of support for people with disabilities has been at least a contributory factor in the deaths of some social security claimants. What could be described as harassment of claimants; the failure to engage with and adopt safeguarding processes and procedures; the removal of financial support; all form part of the perception and reality for many people with disabilities who rely on the social security system.

An essential starting point moving forward for the Green Party will be to do more to find out about the needs of and barriers facing people with disabilities. The Government and DWP should resist what appears to be an overwhelming temptation on cutting costs – such an approach will inevitably create fear and lead to resistance from claimants and representative organisations alike.

“158. Employment can have a positive impact on many people’s lives, so we want to do more to help disabled people and people with health conditions to start, stay and succeed in appropriate work, wherever possible. To be truly effective, we know a range of support is required, from early intervention to stop people falling out of work in the first place to effective back-to-work support when people do. In addition, employers have a critical role to play in creating inclusive workplaces where people can thrive. 159. Because we know health and employment are related, we want to do more to join up employment support with health services. Disabilities and health conditions affect people in different ways, so it is also clear that support needs to be personalised. We know that support has to be trusted and provided in settings where people feel comfortable taking it up. That is why we want to look at a range of options from continuing to make jobcentres more welcoming to asking what more can be done to encourage people in the ESA Support Group and with LCWRA to take up voluntary employment support. We want to hear how we can improve the support on offer for disabled people and people with health conditions.”

  1. There are aspects of the ideas within the Green Paper which could be implemented, perhaps as a matter of urgency, if Government and DWP were serious about improving the experience of the person with disabilities. For example, implementing safeguarding as the ‘business as usual’ approach of DWP (and DfC in NI) towards supporting vulnerable claimants and setting up regular ‘Voice of the Claimant / Claimant Experience’ fora across all social security benefit areas. The Health Transformation Programme is already underway, although it remains to be seen whether this will improve the claimant experience.

Again, there is at least ambiguity (and at worst an implied threat) in the reference to ‘bolder steps’ as highlighted below. The fear of people with disabilities and representative bodies is that Government will simply initiate ‘welfare reform round 3’ (to follow welfare reform + welfare reform & work) which focussed on cutting the social security budget.

“215. Most people have a positive experience of claiming benefits. For people who do not have that experience, we are listening to and acting on feedback so that everyone feels supported and able to rely on this Department. 216. We hope the changes that we have already made will mean disabled people and people with health conditions have a better experience of health assessments and feel more able to trust our decisions. We have also sought views on further changes. 217. These improvements are just the beginning. We know that we need to take bolder steps to help people live fully independent lives and to start, stay and succeed in work.”

  1. The ‘Re-thinking Future Assessments to Support Better Outcomes’ section of the Green Paper is in some ways a re-hash of what has been attempted in the past. For example, when ESA was introduced in 2008 there was a ‘work-focused health-related assessment’ which very quickly fell by the wayside as the Work Capability Assessment became the sole focus.

Advice NI has long advocated for social security benefit medical assessments being brought back in-house to address the serious delivery issues associated with profit-making private sector providers – the most recent being the finding of ‘systemic maladministration’ on the part of Capita in their role as Personal Independence Payment (PIP) assessment provider by the NI Public Service Ombudsman (NIPSO). It is unclear from the Green Paper whether this idea is on the table.

The idea of making changes to the assessment criteria requires careful scrutiny – in particular the purpose of these changes. Changes with the purpose of reducing expenditure with little to no reference to the needs of people with disabilities are unacceptable and will generate opposition.

It is welcome to see the issue of ‘Access to the right evidence at the right time is key to each stage of the assessment process’. This issue has plagued the disability benefit system since the introduction of Disability Living Allowance (DLA) in 1992. As with various aspects of the disability benefits within the social security system, ‘everything is connected’. Often the issue of establishing the full picture in relation to a person’s health and disability will need to be fully investigated and settled before engaging on a person’s readiness or otherwise to engage with the world of work. To resolve this issue requires an effective interface to be opened up between DWP and the Department for Health. At the moment too often supporting medical evidence is not sought, where it is sought too often it is not secured, where it is secured too often it is not acted upon.

Reading between the lines there are potentially other ideas under consideration including joint assessments for ESA & PIP; replacing ESA & PIP with a single benefit – which inevitably means levelling down in terms of financial support ultimately provided via Universal Credit. The best we can suggest is that Government, DWP and all stakeholders establish clearly why it was deemed necessary that non-means tested financial support be provided to people with disabilities to help towards the extra costs of physical or mental disability. It would be no less than an act of vandalism and an attack on the rights of people with disabilities for this Government to seek to undo and unpick the social security system in so far as it provides support to help people with disabilities take part in everyday life.

  1. The spectre of cuts to financial help for people with disabilities raises it’s head again under the Green Paper guise of ‘Exploring Ways to Improve the Design of the Benefits system’. It is difficult to see the direct link between increased spending and enabling independent living / employment other than a policy intention to ‘shrink the state’ and reduce the extent to which the state, via the social security system, supports people with disabilities. As referenced above, a policy goal of cutting spending will provoke opposition.

Advice NI believes in a ‘cash first’ approach to promote independence (a stated goal of the Green Paper), however there could be a situation where choice is provided to the individual in terms of whether they prefer to access cash or in-kind goods, services or support.

“We are committed to improving the lives of disabled people and people with health conditions. Rising spending on health and disability benefits suggests there is more we can do to enable independent living and employment. We want to explore making bigger changes to the benefits system that will improve outcomes for disabled people and people with health conditions and that will also mean the system will be more affordable in the future.”

  1. In conclusion, given the decade of austerity, and in particular the cuts to the social security budget, and further, the cuts to the disability benefits within the social security budget as highlighted above, Advice NI believes that any further cuts under the guise of further ‘reform’ is unacceptable.

A more genuine starting point to any ‘Health & Disability’ debate would be to initiate genuine engagement with people with disabilities on the increased costs that they incur; what an adequate income for people with disabilities looks like; the barriers presented in terms of seeking care and treatment; and barriers to staying in / entering the workplace.

Until such an approach is taken, any Green Paper and subsequent developments will be treated with deep suspicion.

Last updated:
12 October, 2021