CPAG s response to the disability living allowance reform consultation

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1 CPAG s respnse t the disability living allwance refrm cnsultatin Executive summary February 2011 Child Pverty Actin Grup 94 White Lin Street Lndn N1 9PF

2 Summary CPAG welcmes the pprtunity t cmment n the cnsultatin n the replacement f disability living allwance (DLA) with the persnal independence payment (PIP). We recgnise the need fr a system f exemptins t be fair and transparent and als welcme the cmmitment t ensuring that the Gvernment will mnitr the intrductin f the persnal independence payment t see if it reslves r exacerbates the srt f administrative prblems that currently impede the effective delivery f DLA t sme grups. We believe the intrductin f PIP needs t be seen in the cntext f extensive cuts in benefits, tax credits and services, which cumulatively are likely t have the greatest impact n disabled peple. We are nt cnvinced that intrducing a new system at a time f significant cutbacks t the DWP will reslve prblems in the delivery f DLA. The refrm fails t engage with issues in and arund the intrductin f the universal credit. It seems t ignre evidence f prblems in and arund the intrductin f emplyment and supprt allwance and the Wrk Capability Assessment. There are a number f cntradictins in the verarching principles utlined in the cnsultatin and the prpsals. Fr example: Far frm generating barriers t emplyment access t DLA particularly the mbility cmpnent prvides vital supprt t thse mving int, and remaining in, wrk. The cnsultatin fails t distinguish between the existence f legislative changes and effective implementatin. It suggests that access t aids and adaptatins may be used t reduce supprt via the PIP. We think it is prfundly inequitable that accessing rightful entitlement t the supprt needed t facilitate scial inclusin shuld be used t reduce entitlement t financial supprt. Restrictins n the availability and delivery f supprt services and aids and adaptatins t disabled peple suggest that they will need mre, nt less, supprt via the PIP. It ignres the csts t the ecnmy f failing t supprt disabled peple: research shws that spending n scial prtectin narrws cstly and wasteful health inequalities, which the Marmt Reprt argues csts between 51 and 65 billin a year in lst prductivity and taxes. The cnsultatin fails t cnsider the vital rle that disability benefits in general and DLA in particular play in reducing pverty in husehlds affected by disability. Restricting entitlement is likely t increase child pverty.

3 1. 2. CPAG respnse t disability living allwance refrm 1 - Intrductin and cntext 1. The prpsal t refrm DLA need t be reviewed in the cntext f wider cuts that analyst and cmmentatrs calculate will have a disprprtinate impact n the mst vulnerable grups. i Questin 1 - What are the prblems r barriers that prevent disabled peple participating in sciety and leading independent, full and active lives? Disabled peple are mre likely t live in pverty than nn-disabled peple because they are less likely t be in paid emplyment, are mre likely t be reliant upn benefits, and they incur additinal disability-related csts. Disability and pverty Causes f pverty Disabled peple are at particular risk f pverty because high living expenses (due t extra heating, laundry csts and the need t finance special equipment, persnal supprt r gds and services) are cmpunded by a greatly reduced earning capacity. Extra csts: Lss f incme due t the nset f sickness r disability is usually accmpanied by an increase in disability-related csts, which vary accrding t the severity f the disability. Emplyment Mving ut f paid emplyment: is likely t trigger a significant drp in incme at a time when csts are likely t increase. Wrklessness and In-wrk pverty: HBAI shws that pverty in wrking families has risen fr the fifth year in a rw, leaving well ver half f children in pverty living in a family with a wrking adult. Disabled parents are particularly susceptible t in-wrk pverty. Pr wrking cnditins: An increase in cnditins such as stress, depressin and anxiety indicates a link between being in lw-paid, lw status ccupatins and the nset f sickness r disability. Barriers t emplyment: Despite legislative changes, emplyment cntinues t prvide an unreliable and ften unrealistic rute ut f pverty fr many disabled peple. Benefits Adequacy: The adequacy f disability benefits is a prblem. Disability benefits fail t meet additinal csts.

4 Take up: disadvantaged grups particularly frm ethnic minrity grups wh als experience high levels f unemplyment are least likely t apply. Administratin: Administrative prblems and pr decisin making generate prblems, and these are likely t wrsen at a time f departmental cuts. Child pverty Althugh prgress has been made reducing child pverty verall, the link between pverty and disability has remained stubbrnly in place, and fr sme grups, is increasing. Nearly ne millin children in pverty live in a husehld affected by disability (adult r child). Under 3 year lds in families with incmes f 10,400 r less are 2.5 times mre likely t suffer life-limiting chrnic illness, and tw times mre likely t suffer frm asthma than under 3 years lds in families with incmes ver 52,000 and ver. Childhd sci-ecnmic disadvantage has been shwn t heighten the risk f disability and mental health prblems - in adulthd. Tackling pverty in husehlds affected by disability Tackling benefit adequacy Althugh disability benefits d nt meet all additinal csts, statistics shw that access t disability benefits significantly reduce the risk f child pverty in husehlds affected by disability. Access t disability benefits can make the difference between a family getting by and ging under financially. Families use DLA t cushin fluctuatins in incme that generate cstly debt, and spend it in ways that maximise scial and educatinal pprtunities fr their children. DLA therefre It supprts plicies that fcus n early interventin and aim t reduce cstly health and educatinal inequalities. The aspiratin t eradicate child pverty utlined in the Child Pverty Act will nt be achieved until the link between pverty and disability is well and truly brken: access t disability benefits play a vital rle in tackling that link. Tackling take-up Despite imprvements in take-up, cmplexity, lack f infrmatin and pr administratin keeps take up lw - particularly fr mre disadvantaged grups wh need it mst. Wrk a rute ut f pverty? Research shws that a heavy reliance n wrk as the primary rute ut f pverty has prved t be a prblem fr families affected by disability. High levels f in-wrk pverty and barriers t emplyment remain a prblem. The patchy implementatin f equality legislatin and the failure f duties n emplyers and service prviders t be rbustly enfrced remains a prblem.

5 Fr any given level f qualificatin, a disabled persn is between tw and three times as likely as a nn-disabled persn t be lacking but wanting wrk. In 2006, the numbers f disabled adults wh lack but want wrk was five times the number included in the fficial unemplyment figures. 2 - The new benefit: ur prpsals Questin 2 is there anything abut DLA that shuld remain the same? The cnsultatin identifies a number f element t DLA which it believes wrk well and may retain. Including: ability t spend mney in ways t reflect persnal circumstances (s need cash supprt); nn-means tested, and nt taxable, and nt dependent n paying NI; available t thse in and ut f wrk; It als identifies a number f prblems with DLA which it claims the new benefit will reslve. But intrducing a cmpletely new system when intrducing the universal credit, in a time f cut-backs t the DWP, the advice sectr and legal aid, renders this unlikely. CPAG therefre suggests that: DLA is disregarded in all means tests fr ther benefits. Maximising take-up is essential. DLA is paid t peple bth in wrk and ut f wrk, and t thse in educatin r training. The intrductin, assessment and administratin f PIP shuld reflect cncerns arund the wrk capability assessment (WCA). Adequacy shuld be addressed and shuld mre accurately reflect the real csts f disability including particular nes incurred in husehlds with children. N changes shuld be intrduced until the impact n disabled peple is fully understd. This means undertaking thrugh research befre legislating fr change. Questin 3 What are the main extra csts that disabled peple face? The cnsultatin questins the use f care and mbility as prxies fr csts, and is keen t review the adequacy f DLA as part f wider range f supprt and services available t disabled peple. Althugh additinal csts f disability are wide ranging and difficult t quantify, it is well knwn that disabled peple are at particular risk f pverty because high living expenses (due t extra heating, laundry csts and the need t finance special equipment, persnal supprt r gds and services)

6 are cmpunded by a greatly reduced earning capacity and a heavy reliance n benefits. Lss f incme due t the nset f sickness r disability is usually accmpanied by an increase in disability-related csts, which vary accrding t the severity f the disability. It is nt clear hw an individual s additinal csts will be utilised t establish levels f supprt in the new benefit and wrrying that that the prvisin f supprt and services - which may be ntinal, and are likely t suffer significantly as a result f wider cuts - are being used t justify cuts in supprt via benefits. Restricting access t financial supprt will inevitably damage children in husehlds affected by disability. It is extremely imprtant that any refrm f DLA recgnises and meets the additinal csts incurred by families with disabled children, and by disabled parents (as a cnsequence f the cmbinatin f bth their disability and their parental respnsibilities). Questin 4 The benefit will have tw rates fr each cmpnent: Will having tw rates per cmpnent make the benefit easier t understanding and administer while ensuring apprpriate levels f supprt? What, if any, disadvantages r prblems culd having tw rates per cmpnent cause? The persnal independence payment will be intrduced in 2013/14 and will have tw cmpnents: Mbility awarded n ability t get arund Daily living cmpnent awarded n their ability t carry ut ther key activities necessary t participate in daily life While replacing the care cmpnent with a living cmpnent culd intrduce greater clarity int the system and ensure that the particular experiences f disabled parents are better reflected it may intrduce additinal cmplexity int the assessment prcess. Significant care is needed t ensure that its intrductin des nt have a negative impact n claimants fr example by: Intrducing it at time f significant cuts and radical refrm f the welfare state; Intrducing a living cmpnent which might ensure that the particular experiences f disabled parents are better reflected but may intrduce additinal cmplexity int the assessment prcess; Failing t ensure that the way in which ne cmpnent interacts with and affects access t the ther cmpnent; Refrming the system t reduce entitlement.

7 Using certain cnditins r treatments as a prxy fr a level f need where these are well understd has the ptential t imprve cnsistency f decisin making, simplify entitlement frm the claimant s perspective and reduce csts f administratin fr the DWP. Althugh the extensin f this t ther cmmn cnditins/treatments (while retaining cnsideratin f the needs f the individual if it is greater than the impairment /treatment) might be helpful, the specific fcus n scial rather than medical mdels f disability, and the desire fr the new benefit t reflect individual need and changes in sciety may render this difficult t achieve. Imprving the quality f decisin ntices and infrmatin and the prvisin f adequate independent advice t claimants is the best way t ensure that claimants and decisin-makers understand and fllw the criteria. Questin 5 Shuld sme health cnditins r impairments mean an autmatic entitlement t the benefit, r shuld all claims be based in the needs and circumstances f the individual applying? The cnsultatin dcument als utlines the Gvernment s intentin t mve away frm a system that awards autmatic entitlement fr certain cnditins. Retaining existing autmatic entitlements t higher rate DLA is an efficient and effective way t allcate resurces. Putting claimants repeatedly thrugh a stressful prcess may well exacerbate their cnditin. Cnstant assessments may result in peple lsing their benefit even thrugh they are entitled t receive. This can generate unmanageable fluctuatins in incme and administrative csts. The idea f using certain cnditins r treatments as a prxy fr a level f need where these are well understd has the ptential t imprve cnsistency f decisin making and reduce csts f administratin. Althugh the extensin t ther cmmn cnditins/treatments (s lng as the needs f the individual are recgnised if greater than the impairment /treatment) might be helpful, the fcus n scial rather than medical mdels f disability, and the desire fr the new benefit t reflect individual need and changes in sciety may render this difficult t achieve. Questin 6 Hw d we priritise supprt t thse peple least able t live full and active lives? Which activities are mst essential fr everyday life? Peple with different impairments and disabilities face different barriers t everyday life, and it is imprtant that the persnal independence payment recgnises these. It is imprtant that the new assessment supprts the gvernment s verarching aim t generate equality f utcme with that expected fr peple withut a disability. While it is imprtant t ensure t supprt thse in greatest need, the desire t target supprt n the mst vulnerable grups is ften subjective and

8 restrictive, may reduce take-up and cause decisin-makers t fcus n the medical rather than scial mdel f disability. Peple with mental health issues experience significantly different barriers frm thse with physical r sensry impairments, and this needs t be apprpriately reflected in the assessment prcess. Questin 7 Hw can we best ensure that the new assessment apprpriately takes accunt f variable and fluctuating cnditins? We welcme the fact that the gvernment is keeping an pen mind n hw best t ensure that the new assessment takes accunt f variable and fluctuating cnditins. The change frm a care cmpnent t a daily living cmpnent may better capture variable and fluctuating cnditins and indeed the variable impact that parenting respnsibilities have n a disabled parent s needs. Hwever, clear criteria will be needed t clarify what is a subjective assessment f such impacts n a persn s ability t carry ut ther key activities necessary t participate in daily life. 8. Shuld the assessment f a disabled persn s ability take int accunt any aids and adaptatins they use? What aids and adaptatins shuld be included? Shuld the assessment nly take int accunt aids and adaptatins where the persn already has them r shuld we cnsider thse that the persn might be eligible fr and can easily btain? We fear that this prpsal may penalise families fr accessing the adaptatins and aids they need t vercme sme (by n means all) f the barriers they face. Keeping track f the availability and reliability f aids and adaptatins will becme increasingly cmplex at a time at a time f significant and gegraphically variable cutbacks in supprt. The use f aids and adaptatins can in itself result in extra expenses. DLA prvides a vital financial resurce if aids r adaptatins need t be repaired. Remving entitlement based n their existence is perverse as it risks undermining the effectiveness f these vital surces f supprt. T carry ut the prpsed remval f the higher rate mbility cmpnent fr wheelchair users wuld undermine the intentin f a cash benefit t cmpensate fr extra csts. The ability t mbilise in a wheelchair des nt imply that a disabled persn is able t affrd an adapted car such as thse available thrugh the Mtability scheme. Questin 9 Hw culd we imprve the prcess f applying fr the benefit fr individuals and make it a mre psitive experience? The stigmatisatin f claimants has a prfundly negative impact n claimants and service-prviders alike including thse administering the

9 system. Challenging discriminatry language and attitudes is vital t make applying fr the benefit a mre psitive experience. Hw culd we make the claim frm easier t fill in? Current prblems include: difficulties getting hld f the frms in the first place and a frm that is lengthy, cmplicated and ften upsetting t fill in. The cnstant stigmatisatin f disability claimants puts many ff applying fr benefits t which they are entitled and need. Prviding the same infrmatin endlessly t a variety f departments and service prviders ver and ver again is time-cnsuming and frustrating. Hwever, even when a plethra f infrmatin is prvided, disagreements and anmalies in the decisin-making prcess result in sme families missing ut n their entitlement r receiving the wrng award. Streamlining and simplifying the frm requires adequately funded advice services with trained staff wh can ensure that relevant infrmatin is nt missed ut by claimants. A system f extending autmatic entitlement based n cnditin wuld reduce prcessing times in these cases and allw relevant infrmatin t be gathered quickly and efficiently frm medical prfessinals if necessary. The frm must ensure that claimants understand the srt f key activities that will be f interest t decisin-makers t keep take-up high and appeals lw. Attempts t make applicatins mre psitive are nt then used as an excuse t deny peple additinal supprt. A high level f training will be needed t ensure they understand the changes in emphasis when supprting r assessing - applicatins. Hw can we imprve infrmatin abut the new benefit s that peple are clear abut what it is fr and wh is likely t qualify? The evidence suggests that the supprt f independent welfare rights wrkers, wh prvide cntinuity f supprt thrughut the applicatin prcess, re-applicatins and appeals, is vital. The prvisin f advice n benefit entitlement in health centres increases bth take-up and imprves the health f claimants. The prvisin f printed infrmatin and leaflets is als vital, nt just in Jbcentre Plus and advice centres, but in places that peple are likely t visit such as hspitals, health centres, nurseries and schls, and the wrkplace. Prviding infrmatin, advice and supprt in cntracted ut services within the Wrk Prgramme prvides a valuable pprtunity t flag up entitlement and ensure peple have the additinal supprt they need t cver the csts f engaging in wrk-related activities and/r access emplyment. Maximising incme is a vital way f imprving health and enhancing an individual s capacity t access emplyment.

10 Targeting infrmatin in different languages in cultural and religius centres will als help maximise take-up in sme black and minrity cmmunities wh are currently less likely t apply fr DLA. Cntracted ut welfare t wrk prviders shuld als be required t alert peple t their ptential entitlement, and have the expertise t help peple fill in frms. Questin 10 What supprting evidence will help prvide a clear assessment f ability and wh is best placed t prvide this? The cllectin f evidence fr DLA is ntriusly difficult. Applicants are ften unclear abut the need fr supprting evidence, and what this shuld invlve. The quality f the evidence prvided is als extremely variable, depending n the time, expertise and cmmitment f the persn prviding the evidence. It is imprtant that service-prviders and individuals wh are mst likely t be prevailed upn t prvide the evidence are well infrmed abut entitlement and purpse, and are given the time and resurces necessary t prvide the right kind f supprting evidence. Questin 11 An imprtant part f the new prcess is likely t be a facet-face discussin with a healthcare prfessinal. What benefits r difficulties might this bring? Are their any circumstances in which it may be inapprpriate t require a face-t-face meeting with a healthcare prfessinal either in an individual s wn hme r anther lcatin? Given the desire t fcus n the scial rather than the medical mdel f disability, it is imprtant t ensure that healthcare prfessinals include practitiners wh deal with the full range f scial rather than medical prblems. The invlvement f a face-t-face meeting with an independent healthcare prfessinal appears t be very similar t the Wrk Capability Assessment (WCA). Given the current prblems with the assessment and surrunding prcesses, this is causing increased anxiety t many disabled peple. Questin 12 hw shuld the review be carried ut? Fr example What evidence and/r criteria shuld be used t set the frequency f the reviews? Shuld there be different types f review depending n the needs f the individual and their impairment/cnditin? Fr peple with fluctuating cnditins, there are real challenges fr the review prcess and, in particular, the increased bligatins n the individual t reprt changes in circumstance. Our research shws that frequent assessments and reviews are stressful and take a cnsiderable tll n the health and wellbeing f bth parents and their children and we are reluctant t see these increased.

11 Frequency shuld cntinue t be set by decisin makers, and be apprpriate fr the individual. Regular reassessments which are likely t be cnducted by different decisin-makers with different (subjective) criteria, als generate mistakes, which lead t fluctuating awards and incmes. This means that a benefit designed t meet the extra csts f disability actually cntributes t thse individual as well as administrative csts. Questin 13 The system fr PIP will be easier fr the individual t understand, s we expect peple t be able t identify and reprt changes t their needs. Hwever, we knw that sme peple d nt currently keep the Department infrmed. Hw can we encurage peple t reprt changes in circumstances? CPAG is particularly cncerned abut the assumptin that because the persnal independence payment will be easier t understand this justifies the intrductin f penalties fr thse wh fail t reprt changes in circumstance. Regular reviews may generate cnfusin abut the need t reprt changes in circumstances, and this is particularly wrrisme given the intrductin f greater cnditinality and sanctins int the system. Extensive research n sanctins bth internatinally and in the UK suggests that they are likely t be ineffective and have a disprprtinate impact n the must vulnerable claimants. Research suggests that the impsitin f sanctins n families with children can have a prfundly negative impact n the health and wellbeing f children. Increasing the number f assessment is als likely t increase the number f administrative and custmer errrs and this t is extremely cstly, and may result in significant prblems fr claimants in an increasingly punitive system. Cnfusin abut the need t identify and reprt changes in needs are generated by a necessarily burdensme and cmplex bureaucratic system. Peple with mental health prblems and learning difficulties are likely t find it particularly difficult t keep track f this requirement. Questin 14 What types f advice and infrmatin are peple applying fr PIP likely t need and wuld it be helpful t prvide this as part f the benefit claiming prcess? There is a distinct lack f infrmatin abut DLA in places families are likely t see it (such as schls and GPs surgeries, Children s Centres etc). Families are heavily reliant n the advice and supprt f independent welfare rights wrkers. Successful take-up campaigns such as distributing leaflets in schls and health centres need t be supprted by access t advice and supprt. Ensuring that ther service prviders wh wrk clsely with families (fr example health visitrs, teachers and thse wrking in early year settings are

12 an effective way f disseminating infrmatin and supprt. (See CPAG;s Sure Start prject). In a cntext f significant cutbacks it is hard t see wh will prvide this. There is evidence that even in the current situatin, the infrmatin prvided by the DWP is nt always available r indeed accurate. An increased reliance n the prvisin f infrmatin n-line pses prblems fr peple wh may nt have access t a cmputer, and/r face additinal barriers t accessing such infrmatin. Questin 15 Culd sme frm f requirement t access advice and supprt, where apprpriate, help encurage the minrity f claimants wh might therwise nt take actin? If s what wuld be the key features f such a system and what wuld need t be avided? It is nt entirely clear what the underlying purpse f this suggestin might be, but we are cncerned that it pens the way t cmpel claimants fr example drug addicts t access services and supprt r lse their entitlement t benefit. This in an unacceptable infringement f peple s rights, and risks preventing sme f the mst the mst vulnerable and hard-t-reach claimants frm accessing vital financial supprt which has the ptential t significantly imprve quality f life. Questin 16 Hw d disabled peple currently fund their aids and adaptatins? Shuld there be an ptin t use PIP t meet a ne-ff cst? Financing aids and adaptatins n inadequate incmes is a struggle, with families struggling t negtiate cmplex rules, brrwing mney r accessing the Scial Fund. Althugh research n the Scial Fund suggests that ne-ff payments prvide valuable additinal supprt t purchase aids and adaptatins that are essential t enable peple t access educatinal, scial and emplyment pprtunities, this des nt bviate fr additinal incme t cver many ther additinal csts. The cnstant need t finance the cnstant need t maintain, replace r update the equipment prvided is als an issue, and it is imprtant t ensure that disabled peple are nt cnstantly having t re-apply fr supprt t cver such csts. Questin 17 What are the key differences that we shuld take int accunt when assessing children? Prblems in the administratin f DLA particularly frequent reassessments f entitlement as children grw lder generate significant stress and csts fr families. The prcess must reflect the realities f families day-t-day lives, at a time when many parents will als be required t engage in nerus wrkrelated activities. DLA is a vital cmpnent f Gvernment supprt t enable families f disabled children live rdinary lives. It is likely t play a greater rle as cuts in services and supprt t families with children many f which will have a disprprtinate impact n children with disabilities begin t bite.

13 Access t DLA prvides a vital way t target supprt n families during the early years (fr sme families, frm birth) and supprts the gvernment s fcus n early interventins. Research als shws that increasing incme fr example via DLA has a psitive impact n the health and wellbeing f bth parent and children. Maximising family incme via disability benefits supprts the gvernment s desire t implement a preventative strategy by fcusing supprt n children during the early years. Other differences that shuld be int accunt when assessing children include: Assessing adequacy - Althugh DLA prvides vital additinal financial supprt, and triggers awareness f and entitlement t a range f services, it des nt fully meet families additinal financial needs. Extra csts - Parents with disabled children experience significant, and very particular additinal csts which have been well dcumented. Scial csts (financial csts exclude families frm participating in sciety, and this takes its tll n parents and children, and leads t: Family breakdwn Ill-health and disability amng parent-carers) Additinal caring respnsibilities Increase t qualifying perid We share Every Disabled Child Matters cncerns that while the Gvernment is cmmitted t retaining special rules fr peple wh are terminally ill, increasing the qualifying perid frm three mnths t six mnths befre entitlement t DLA will mean that that children brn with a disability will have t wait until they are six mnths ld befre being entitled t DLA. Assessment and Reassessment Disabled children already have their DLA eligibility reassessed at regular intervals aged 2, 5, 11, 14, 16 and 18 and we d nt believe that children shuld be reassessed any mre regularly than they currently are. Sharing infrmatin between assessments culd help, but it is imprtant that an incrrect assessment des nt deny a child supprt thrughut the system. Entitlement t PIP shuld be used t trigger access t the supprt t which children are entitled, nt be used an excuse t reduce financial supprt intended t meet sme f the extra csts incurred by families. Mbility Cmpnent f DLA CPAG is cncerned that the remval f the mbility cmpnent frm children and adults in residential care hmes is unfair, and will have a significant impact n the ability f claimants and their relatives t access the srt f scial activities the Minister describes (which are themselves under threat).

14 Gvernments prpsals t remve the mbility cmpnent f DLA frm disabled children in residential schls r care fr mre than 84 days a year is particularly wrrying. It may prevent children visiting their families, and reduce additinal funding fr utings and excursins that might therwise nt take place. Changing the rates f DLA Families ften misunderstand the purpse f DLA (they may nt view their child as disabled) and many are cnfused abut the care cmpnent. (Many assume that as parents they are nt entitled, r that this is cvered by carer s allwance). Althugh we welcme the idea f a daily living cmpnent t replace the existing care cmpnent f DLA, we are cncerned that the reductin frm three t just tw cmpnents will be used t restrict entitlement and generate savings. 3 - Delivering the new benefit Questin 18 - Hw imprtant r useful has DLA been at getting peple t access ther services r entitlements? Are these things we can d t imprve these passprting arrangements? Accessing DLA is an extremely effective way f flagging up the availability and entitlement t ther services. Hwever, if access t thse services reduces entitlement t the benefit, this is likely t becme a duble-edged swrd. DLA is a vital passprt t many ther services, althugh the Gvernment must ensure that it is nt the nly rute t access services such as in the Blue Badge scheme r the Independent Living Fund. DLA als passprts claimants t higher level f bth means-tested benefits and tax credits (fr bth children and adults) and t carer s allwance. Questin 19 What wuld be the implicatins fr disabled peple and service prviders if it was nt pssible fr PIP t be used as a passprt t ther benefits and services? The failure t use PIP as a passprt t the benefits and services wuld therefre have a significant impact n families disabled peple and their families. Disabled peple wuld find it mre difficult t knw what is available and what they might be entitled t, and service prviders wuld face extra csts in assessments, reducing funds available fr services. It wuld intrduce the need fr additinal assessments t trigger entitlement elsewhere in the system, and this wuld generate additinal csts fr bth individuals and administratrs.

15 Questin 20 What different assessments fr disability benefits r services culd be cmbined and what infrmatin abut the disabled persn culd be shared t minimise bureaucracy and duplicatin? While sharing the infrmatin prvided in different assessments makes sense, it is imprtant t ensure that this des nt result in incrrect infrmatin becming entrenched in system and denying peple supprt acrss the bard. The failure t appeal an incrrect assessment in ne area shuld nt have an impact n access t supprt elsewhere in the system. The infrmatin required and prvided may differ accrding t the demands f the assessment, and it is imprtant t ensure that criteria are streamlined and cherent. The availability and quality f assessments may well fall prey t wide-ranging cuts, and it is imprtant that this des nt undermine a fair and swift assessment prcess. 4 - Impact Assessment and Equality Impact Assessment Questin 21 What Impact culd ur prpsals have n the different equality grups and what else shuld be cnsidered in develping the plicy? CPAG is cncerned that the cuts being impsed are likely t have a disprprtinate impact n sme f the mst vulnerable grups, including wmen, thse affected by disability, and sme BME grups. It is imprtant that the intrductin f PIP amelirates and des nt cmpund this wrrying develpment. The situatin needs t be clsely mnitred. 22. Is there anything else yu wuld like t tell us abut the prpsals in this public cnsultatin? Althugh sme elements f the cnsultatin appear t cnstitute a genuine attempt t reslve sme f the difficulties in the design and delivery f DLA, the verall prpsals read as a disingenuus attempt t discredit the existing supprt in rder t justify reducing rather than imprving - it. Gabrielle Prestn Plicy and Research Officer Child Pverty Actin Grup i James Brwne, Peter Levell, The distributinal effect f tax and benefit refrms t be intrduced between June 2010 and April 2014: a revised assessment, IFS Briefing Nte BN108, August 2010