Citizens Advice submission to the Work and Pensions Select Committee urgent inquiry into the Pathways to Work Green Paper
A summary of our submission is published below. You can access a pdf version of the full submission here 290 KB , or an editable Google doc version here.
We focus in this submission on the green paper proposals that the government intends to implement without consultation. We oppose the government’s decision not to consult on the main disability and incapacity benefit cuts, which is based largely on the need to meet the Office for Budget Responsibility’s timetable for assessing the fiscal rules. This is not a credible approach to making changes to benefits that will leave millions of disabled people worse off.
We are concerned that the impact assessment does not provide a full analysis of the impact of the green paper. An inappropriate baseline risks obscuring the number of people that will fall into poverty (it could be as high as 400,000 people – including 100,000 children), and it provides no analysis of the combined impact of Personal Independence Payment (PIP) eligibility changes and the abolition of the Work Capability Assessment (WCA).
The current disability and incapacity benefits system is flawed. It causes anxiety and stress for claimants. Delays are common, and reassessments are frequent. Above all, it does not provide a sufficient income for disabled people to live on. There are few concrete proposals in the green paper focused on addressing these problems – and the cuts to benefit eligibility and rates will exacerbate its most significant flaw.
Preliminary analysis based on our debt client data suggests that people losing the PIP daily living standard rate would end up with a monthly deficit of £297, and those losing the daily living enhanced rate would have a deficit of £423. For disabled people on UC and out-of-work (a proxy for receiving the UC health element), monthly deficits would grow to £229. In short, disabled people’s income will fall a long way short of what is needed to cover their basic living costs.
The changes to PIP eligibility criteria are based on fallacious logic that only those scoring 4 or more points in a single daily living category have significant financial needs arising from their condition, and indeed that only this group should be deemed incapable of work after the WCA is abolished.
Our advisers, who work closely with the people who will be directly affected by the green paper’s proposals, are concerned that many of the people who will lose PIP have serious medical conditions, with limited opportunities to challenge their scores when reassessed. The changes will see people’s health, access to care, and ability to work worsen. And there will be a significant increase in or deepening of poverty, especially as a result of the Universal Credit cuts.
We are not convinced that the people who will be financially worse off as a result of the cuts will be able to increase their income from employment. The government has not yet published analysis of the likely impact of new investment in employment services, or the impact of losing PIP on claimants already in work. And there are wider barriers to work around health, the cost of living, and discrimination that the green paper does not meaningfully address.