IMPROVING ADVICE JOURNEYS

Transcription

1 IMPROVING ADVICE JOURNEYS Reform Advice in Westminster June 2015

2 Contents Executive Summary 3 Key findings 3 Key recommendations 5 Glossary 6 Introduction 7 Context 7 The purpose of this report 7 About AdviceUK and the author 7 Methodology and acknowledgements 8 Findings 9 Social welfare in Westminster 9 Overall picture of demand for advice 10 Advice channels 11 Demand for welfare benefits advice 12 Demand for debt advice 13 Demand for housing advice 14 Social policy issues 14 Complaints 16 Client journeys 18 Interviews with stakeholders 23 Emerging themes 24 Conclusions and recommendations 29 2

3 Executive Summary The ongoing changes initiated by the Welfare Reform Act 2012, 1 cuts to civil legal aid for most social welfare cases from April and increased demand for advice services in a context of shrinking public sector budgets 3 have all combined to produce a very challenging set of circumstances for people seeking advice and the agencies that provide such services. The Reform Advice in Westminster (RAW) project 4 was set up to support Westminster advice agencies to deliver more sustainable advice services, to improve access to advice and address causes of preventable demand for advice. RAW partners believe that advice agencies and stakeholders such as Westminster City Council (WCC) and the Department for Work and Pensions (DWP) need to work in collaboration to effect change: both to support Westminster residents to navigate changes arising from welfare reform; and to reduce preventable demand for advice and support from advice agencies. The RAW project has gathered data about demand for social welfare advice services in Westminster, identifying sources of preventable demand for advice in order to improve the lives of residents seeking advice, particularly those who are disadvantaged. Key findings Overstretched advice services and vulnerable clients In total, 17,250 unique clients accessed advice services provided by RAW partners over the first six quarters of the project, between 7% and 8% of Westminster s population. Demand for advice met by RAW partners is focused very clearly on welfare benefits, debt and housing issues, which together account for over three quarters of issues on which people sought help. Demand for face-to-face advice is high. A large proportion of welfare benefits advice (the biggest volume of advice given by a large margin) was related to just two issues: Housing Benefit (HB) and Employment and Support Allowance (ESA). For debt advice, the single most common issue (almost a quarter of all issues related to debt) was rent arrears. For housing advice, access to and provision of accommodation was the most common issue on which people sought help. Clients seeking advice are vulnerable due to a combination of low income, unemployment and poor mental and physical health. They are struggling to navigate complex and time-consuming benefits administration processes and cope with the impacts of ongoing welfare changes, particularly those involving ESA, Personal Independence Payment (PIP) and HB shortfalls. 1 See (accessed 5 June 2015) 2 See (accessed 5 June 2015) 3 See (accessed 5 June 2015) 4 See (accessed 26 February 2015) 3

4 Existing advice services are overstretched, with very limited capacity to provide ongoing support to clients, particularly clients who lack the skills, knowledge and resources to manage their situation independently. There is a particular gap in the provision of advice with casework and representation, exacerbated by cuts to legal aid funding from April 2013 onwards. Fragmented customer and client journeys The report presents three journeys that describe the typical experiences of vulnerable people seeking advice and support to navigate complex benefits administration systems. Poorly-designed systems for benefits administration fragment and complicate the journeys that clients need to go on to get a decision on their entitlement to benefit. Multiple interventions are required to resolve problems that are both predictable and preventable These cause distress to the client, put unnecessary pressure on advice agency resources and result in additional transaction costs for the DWP an WCC. Multiple interventions are required to resolve problems that are both predictable and preventable. The volume of complaints about maladministration by the DWP and WCC recorded by the RAW project reflect levels of preventable demand for advice in these areas, particularly in the administration of ESA and HB respectively. In the same way, social policy issues identified by RAW partners correlate both with well-publicised problems associated with the administration of ESA and PIP and the impact of welfare changes such as the benefits cap and Bedroom Tax / Spare Room Subsidy (BT / SRS). Opportunities to work collaboratively to improve journeys and reduce preventable demand As part of this report, we sought the input of seven stakeholder organisations. Three main channels for current engagement between key stakeholders have been identified: the Westminster Advice Agency Liaison Meeting (WAALM); the Westminster Advice Forum (WAF); and the Westminster and Kensington and Chelsea DWP Customer Representatives Group (WAKAC DWP CRG). These meetings allow participants to exchange information, update each other on current initiatives and address problems faced by benefit claimants on a case-bycase basis, but coordinated work to address systemic problems is not being undertaken. As a result, opportunities are being missed to address the root causes of high volumes of demand. 17,250 unique clients accessed advice services provided by RAW partners 4

5 Key recommendations More effective engagement between stakeholders to improve client journeys Meetings involving advice agencies, WCC and the DWP should focus on developing joint work to improve benefits administration systems for current, high-volume benefit caseloads such as ESA, PIP and HB. There should be a focus on developing and agreeing shared measures that can be used to understand end-to-end performance from the perspective of people claiming benefits, particularly claimants who are experiencing poor mental or physical health, or who are vulnerable in some other way. Future drivers of need and demand for advice WCC should seek to involve advice providers in work to prepare for the rollout of Universal Credit (UC) locally, and recognise the role of social welfare advice in fulfilling its responsibilities under the Care Act. Given the focus on digital delivery of public services, future work by both the DWP and WCC to address digital exclusion should explicitly address the needs of people making claims for working-age disability benefits, those with problem debt and people in housing need. This is particularly important given the focus on ongoing welfare cuts for working-age benefits. Improved access to advice with casework support and representation Concerted efforts should be made by all stakeholders, particularly WCC and advice agencies, to review the provision of social welfare advice with casework and representation in the borough. WCC should consider what practical steps it can take to resource and support such services. Such casework and representation services should explicitly measure and seek to reduce preventable demand for advice. Invest in frontline expertise and information provision Training for frontline staff involved in both benefits administration and social welfare advice provision should be focused on systemic improvement to journeys taken by benefit claimants. The DWP and WCC should seek input from local advice agencies to inform and improve its provision of training for frontline staff and decision makers involved in benefits administration. Local training opportunities should continue to be made available to advisers that give them regular opportunities to update and deepen their knowledge of DWP benefits administration policy and processes, with a focus on current operational practice in areas with high-volume caseloads such as ESA and PIP. 5

6 Glossary AA BT / SRS CA CT CTC CTS DLA DHP DWP ESA HB IB IS JSA KCAF KPIs MR PIP RAW RBKC UC WAALM WAF WAKAC DWP CRG WCA WCC WTC Attendance Allowance Bedroom Tax / Spare Room Subsidy Carers Allowance Council Tax Child Tax Credit Council Tax Support (localised) Disability Living Allowance Discretionary Housing Payment Department for Work and Pensions Employment and Support Allowance Housing Benefit Incapacity Benefit Income Support Jobseekers Allowance Kensington and Chelsea Advice Forum Key Performance Indicators Mandatory Reconsideration Personal Independence Payment Reform Advice in Westminster project Royal Borough of Kensington and Chelsea Universal Credit Westminster Advice Agency Liaison Meetings Westminster Advice Forum Westminster and Kensington and Chelsea DWP Customer Representatives Group Work Capability Assessment Westminster City Council Working Tax Credit 6

7 Introduction Context The Reform Advice in Westminster (RAW) project 5 was set up to support Westminster advice organisations to deliver more sustainable advice services, to improve access to advice and address causes of preventable demand for advice. One strand of the project has given partners the opportunity to jointly monitor and evaluate data about demand for their advice services in the borough, and this has included work to identify maladministration 6 and social policy issues. 7 RAW has been funded by the Big Lottery Fund and Cabinet Office through the Advice Services Transition Fund programme. The project has been led by the Migrants Resource Centre, in partnership with Westminster Citizens Advice Bureau, Zacchaeus 2000 Trust and Fitzrovia Neighbourhood Association. 8 The purpose of this report This report aims to share the learning of the RAW project, making information available to stakeholders across the borough and elsewhere. It also makes recommendations aimed at improving the lives of Westminster residents, focusing particularly on the typical journeys people take that involve or result in a need for social welfare advice. RAW partners believe that positive change can best be achieved by promoting constructive dialogue between advice services and stakeholders such as WCC and the DWP. The report is not intended to comprehensively map social welfare advice 9 needs or current demand for social welfare advice services in Westminster, although we have sought input from other advice services not directly involved in the RAW project. About AdviceUK and the author AdviceUK is a diverse network of some 800 independent providers of legal advice and information. Its membership includes grassroots community advice organisations, large national charities, housing associations, student unions, and a small but growing number of community interest companies. The core of AdviceUK s membership is made up of multipurpose charitable organisations who provide advice alongside a range of other activities including training, housing-related support, employment support or community development. AdviceUK supports both individual members and wider advice partnerships to be more effective and sustainable. They also provide insurance products tailored to advice services, access to management support, consultancy support, access to specialist second-tier services for advisers, and the AdvicePro range of case management software. Dal Warburton has over 7 years experience of providing development and consultancy support to social welfare advice services and partnerships. He works with organisations to build their capacity in areas such as strategic planning, fundraising, service design, use of information technology in service delivery, performance monitoring, impact evaluation, and competitive tendering. 5 See (accessed 26 February 2015) 6 See (accessed 26 February 2015) 7 See (accessed 26 February 2015) 8 Fitzrovia Neighbourhood Association were involved in the first year of the RAW project only 9 See Definitions to Help You Understand the Advice Sector, Definitions-to-help-you-understand-the-advice-sector.pdf (accessed 17 April 2015) 7

8 Methodology and acknowledgements This report uses three main sources of evidence: statistical data gathered in the course of deskbased research, primarily data published by local and central government sources; monitoring data gathered in the course of the RAW project by its delivery partners; and notes of semistructured interviews carried out with stakeholders. Comments from interviews are not directly attributed, as we gave undertakings of confidentiality to enable those approached to speak freely and openly about the issues involved. Unless indicated otherwise, RAW monitoring data relates to the period covering the first six quarters of the 2-year project (9 September 2013 to 8 March 2015). Interviews were conducted in the second half of April and first half of May Our thanks go to all who contributed to this report. 8

9 Findings Social welfare in Westminster According to Greater London Authority figures, 10 the borough has an estimated population of 228,200 (2014). 73.9% of the population is of working age (2013), 9.3% of the population of working age claim out-of-work benefits (May 2014) and 21.8% of children live in out-of-work families (2013). This would indicate a population of around 15,000 residents claiming outof-work benefits. Between February 2013 and February 2015, 11 DWP figures for numbers of Housing Benefit (HB) claimants in Westminster showed a slight downwards trend from 26,949 to 25,396 people. The latter figure represents about 11% of the borough s population. Welfare benefits bring a significant amount of money into the borough: in , 12 central government spend was over 570 million. HB and pensioner benefits (State Pension and Pension Credit) were by far the biggest categories of expenditure, accounting for 232 million and 186 million respectively. After this, working-age disability benefits represented the largest category of expenditure, accounting for 73 million. According to research published by the Money Advice Service, % of the population in Westminster are over-indebted, which would correspond to a population of around 6,000 over-indebted people in the borough. Benefit Spend in Westminster Housing Benefit State Pension Employment And Support Allowance Pension Credit DLA (working age) Jobseeker's Allowance Attendance Allowance DLA (pensioners) Income Support (incapacity benefits) Carer's Allowance Income Support (lone parent) Winter Fuel Payments Discretionary Housing Payments Incapacity Benefit DLA (children) Severe Disablement Allowance Income Support (carer) Income Support (others) Bereavement/Widow's Benefit Spend ( million) See (accessed 25 February 2015) 11 See (accessed 10 June 2015) 12 See (accessed 26 February 2015) 13 See v3.pdf (accessed 26 February 2015) 9

10 Overall picture of demand for advice The experiences of people using advice services in the borough are directly relevant to effective social welfare provision and wider efforts to improve the health and wellbeing of residents. Given the large amounts of public money involved, advice services can play a unique and useful role to improve both the effectiveness and efficiency of social welfare systems. 14 This is quite apart from the direct benefits they bring in terms of income maximisation, financial resilience and overall wellbeing. Advice services can play a unique and useful role to improve both the effectiveness and efficiency of social welfare systems A total of 17,250 unique clients accessed advice services provided by RAW partners over the period, between 7% and 8% of Westminster s population, and this figure is broadly comparable with the numbers of people receiving out-of-work benefits or claiming HB in the borough. Similarly, the figure of 5,253 debt issues dealt with by RAW partners over the period is broadly comparable with the previously-referenced Money Advice Service research that suggests a population of around 6,000 over-indebted residents. This indicates that services provided by RAW partners have a good reach and are targeted on those in greatest need. It should be noted again here that although RAW partners are major players in the provision of social welfare advice, these figures do not cover work done by other advice services, particularly organisations working with particular client groups. 15 Demand for advice met by RAW partners is focused very clearly on 3 high-volume areas: welfare benefits (including advice on housing-related benefits such as HB and localised Council Tax Support [CTS]) debt housing (focused on rights to be housed and rights as a tenant) Together, they account for over three quarters of issues on which people sought advice from RAW partners. Advice on immigration and employment issues account for a further 9% of demand. Our analysis in this report is focused on these high-volume areas, as they offer the greatest potential both to improve the lives of people living in Westminster and to get better value for money spent from the public purse. 14 These ideas are explored in more depth in It s the System, Stupid! Radically Rethinking Advice, AdviceUK 2008, see (accessed 27 February 2015) 15 An indication (though not necessarily an exhaustive list) of organisations providing social welfare information and advice locally can be found at (accessed 2 June 2015) 10

11 Overall demand for advice 1% 2% 1% 2% 2% 2% 1% 1% 0% Welfare Benefits Debt Housing 3% Employment 4% Immigration Other 5% 45% Legal Utilities and Communications Relationships and Family Consumer Tax 14% Health Travel, Transport and Holidays Education Finance Products 17% Advice channels Looking at channels through which advice was given, 36% of client contacts recorded were made by phone and 64% through face-to-face contact. For self-service information resources (where advice was not given), over 230,000 visits to partner websites were recorded, with 3,386 downloads of self-help materials. We do not currently have data that associates website hits with particular types of demand for information or advice. Advice channels for client contact Hits and dowloads Face-to-face Telephone Website hits Self help materials downloaded 11

12 Demand for welfare benefits advice It is immediately obvious that a large proportion of welfare benefits advice (itself the biggest overall category of advice given by a large margin) was linked to just two issues: HB (26% of issues) and ESA (22% of issues). Welfare benefits by issue Housing Benefit Employment Support Allowance Other benefits issues Disability Living Allowance Working & Child Tax Credits Personal independence payment Jobseekers Allowance Localised support for council tax Universal credit Income Support Benefit cap Pension Credit Child Benefit Attendance Allowance Welfare reform benefit loss Localised social welfare Carers Allowance State Retirement Pension Incapacity Benefit Social Fund Loans-Budgeting National Insurance Discrimination Number of issues Housing Benefit issues account for 26% of demand for welfare advice 12

13 Demand for debt advice Of debt-related issues, 23% involved rent arrears, by some margin the largest issue faced by people seeking debt advice. A further 12% related to council tax (CT) arrears, while another 12% related to fuel debt. Just over 10% of debt issues related to benefit overpayments (for HB, localised CTS, tax credits, Income Support [IS] and Jobseekers Allowance [JSA]). Debt issues by subject Rent arrears Council tax, community charge arrears Fuel debts Other Credit, store & charge card debts Water supply & sewerage debts Overpts. Housing & Council Tax Bens. Bank & building society overdrafts Overpayments of WTC & CTC Unsecured personal loan debts Overpayments of IS+/or JSA Catalogue & mail order debts Mortgage & secured loan arrears Mag. Cts. - fines & comp. ord. arrears Maintenance and child support arrears Telephone & broadband debts Unpaid parking penalty & congestion charges Debt Relief Order Social Fund debts Private Bailiffs Payday loan debts Bankruptcy Hire purchase arrears Number of issues

14 Demand for housing advice Access to and provision of accommodation was the single most common named issue (14% of issues). The volumes of housing issues related to tenants (whether private sector, local authority or housing association tenants) significantly outweigh those related to owner occupiers. It should be noted here that housing advice does not cover advice on HB or localised CTS, which come under the category of welfare benefits advice. Housing issues by subject Other housing issues Access to and provision of accommodation Private sector rented property Local Authority housing Housing association property Actual homelessness Threatened homelessness LA homelessness service Owner occupier property Environmental & neighbour issues Discrimination Number of issues Social policy issues One workstream of the RAW project was designed to gather information about wider social policy issues faced by people seeking advice. The focus was on collecting information on situations where clients had been impacted by policy decisions, 16 an obvious example being the benefit cap. Such decisions shape the overall purposes and operations of the systems in question. 80% of social policy issues 17 fell into the first 14 categories listed in the chart opposite. Of these all but three categories relate to welfare benefit administration and housing issues: foodbank vouchers (where there is controversy over whether welfare changes, particularly the localisation of welfare schemes and benefit sanctions, have driven the increase in demand for assistance from foodbanks 18 ); employment cases relating to terms and conditions; and employment cases involving discrimination. Social policy issues identified reflect anecdotal evidence from advisers and the well-publicised national issues with the introduction, implementation and administration of ESA (in particular the Work Capability Assessment [WCA]), 19 and the controversy surrounding the benefit cap 20 and BT / SRS. 21 These figures demonstrate the strong linkages between local and national systems for welfare benefit administration and demand for social welfare advice. In our view they highlight the need to eliminate or at least mitigate preventable demand caused by systems that predictably do not work well. 16 See (accessed 20 May 2015) 17 An asterisk notes that data for this topic was collected only by Westminster CAB 18 See (accessed 3 June 2015) 19 See (accessed 26 February 2015) 20 See (accessed 26 February 2015) 21 See (accessed 26 February 2015) 14

15 Number of social policy cases reported Benefits - poor administration/complaints * Foodbank Vouchers * Housing - benefit shortfalls / benefit cap * Benefits - Personal Independence Payments - poor Housing - poor administration/complaints * ESA sanctions Employment - Discrimination * Housing - Homelessness Council tax Benefits - delay in payments Mandatory reconsideration ESA, ineligible for JSA Discretionary Housing Payments Housing - Bedroom Tax Employment - Terms/Conditions * Utilities - complaints * Benefit CAP - Underoccupancy * Appeals - no support after 1st tier tribunal Discretionary Housing Payment refused Benefits - Social Fund (Funeral Debts) * Housing - repairs/maintenance * JSA sanctions Housing Benefit - Equalities issues Benefit CAP - LHA allowance not meeting local rent Employment - Migrant workers * Housing - Temporary accommodation/b&b Discretionary Housing Payment received Debt - bailiff action (Rent arrears) Housing - Suitability Consumer - fraud Debt - Payday Loans * Transport - Unfair enforcement of new Parking regulations Immigration - Subsistence support denied-asylum seeker Health - charges Consumer - other Benefits - Local Support Payment refusal - crisis Licensing - disturbance from licensed premises * Financial - Missold PPI & Harrassment Relationships - lack of services for domestic violence Legal Aid withdrawn Debt - Online Gambling * Housing - Landlord harassment (Rogue landlord - illegal EEA national affected by HB rule changes Number of cases

16 Complaints The second monitoring mechanism recorded complaints about maladministration, made by the Case Review Manager on behalf of clients of RAW partners. 22 It should be noted that to be valid for the purposes of the project, complaints needed to be about the way service providers had carried out their work. Specifically, complaints were not recorded if they related to implementation of policy. 23 The biggest single driver of complaints was maladministration associated with HB (83 complaints). This was followed by ESA (48 Complaints most commonly involved ineffective procedures, delays and failure to communicate information accurately to claimants complaints), followed by a range of housing-related issues, including: homelessness; suitability of housing; Council Tax (CT) and localised CTS; temporary accommodation; discretionary housing payments (DHPs); and rent arrears (taken together, this range of housing-related issues totalled 121 complaints). Again, unsurprisingly given the overall breakdown of demand for advice, most complaints related to maladministration either on the part of the DWP or WCC. Complaints most commonly involved ineffective procedures or failure to follow procedures, delays in processing information and responding to requests, and failure to record information or communicate information accurately to claimants. This data gives clear priorities for interagency work to address preventable demand for advice. 22 See (accessed 27 February 2015) 23 See (accessed 27 February 2015) 16

17 Complaints by issue Housing Benefit Employment and Support Allowance (ESA) Housing - Other Housing - Suitability Council Tax Benefit Housing - Homelessness Housing - Temporary accomodation/b&b Discretionary Housing payments (DHP) Council Tax Housing - Rent Arrears Disability Living Allowance (DLA) Housing - Bedroom Tax Personal Independence Payment (PIP) Child Tax Credit Job Seekers Allowance (JSA) Handling of a Complaint Other Attendance Allowance (AA) Working Tax Credit Pension Credit Child Benefit Number of issues Complaints by organisation Westminster City Council 12 Department for Work and Pensions - Jobcentre Plus 14 Housing Association HM Courts and Tribunals Service Department for Work and Pensions - Disability and Carers Service Other organisation HM Revenue and Customs Department for Work and Pensions - Pension Service 17

18 Client journeys Monitoring data for quarters four, five and six of the RAW project profiled clients seeking advice on ESA from RAW partners: they were typically UK citizens aged 35-64, single, unemployed and in poor mental health; they were a little more likely to be female than male. Profiling data for the same period is also available for clients who sought advice on HB issues. Clients were typically UK citizens aged 35-64, single, unemployed, and were significantly more likely to be female than male. Compared to clients seeking advice on ESA, they were less likely to be in poor mental health, although poor mental health was still a significant feature. For both sets of data clients describing their ethnic origin as Other Arab accounted for just over 20% of people seeking advice, but we have not been able to compare this category with a directly comparable category used to describe the ethnicity of the borough as a whole. 24 Clients describing their ethnic origin as Black African, Black Caribbean, Black Other and Clients were typically UK citizens aged 35-64, single, unemployed and in poor mental health Bangladeshi were more likely to be seeking advice from RAW partners when compared with the ethnicity of the borough as a whole. Clients describing their ethnic origin as White British, White Irish and White Other were less likely to be seeking advice when compared with the ethnicity of the borough as a whole. Given the significant levels of demand for advice on disability and housing-related benefits administered by the DWP and WCC, we selected 3 journeys that involved people seeking advice on HB, ESA and localised CTS. These journeys are examples of preventable demand for advice, and are intended to stimulate discussion and exploration of how stakeholders can improve the systems used both to administer benefits and advise and support residents, particularly vulnerable and disadvantaged people. It is important to note that these journeys are not meant to highlight unpredictable or isolated cases: rather, they aim to communicate the typical experiences of vulnerable people trying to navigate complex systems and get help doing this. As far as possible, the journeys are presented to tell the story of the person s whole journey, from end to end, as known by the advice service concerned, and are based on the experiences of real people. We believe it is vital to understand services and systems from the perspective of people who have to use them. For this reason, they include the time people need to get an appointment for advice or a response from a service, missed appointments, communications not acted on, lack of capacity in services supporting them, and in some cases, mistakes made by the client or organisation providing the service. 24 See (accessed 2 June 2015) 18

19 Client Journey 1 Housing Benefit start Client is a pensioner living in a 2-bed flat, reapplied for HB. Receives response resulting in smaller payment than before. Cannot afford to pay the shortfall. Looks for a free advice centre, asks friends and goes to nearest library. Barriers to accessing advice: did not know where to start, language barrier, client was illiterate and not in good health, felt weak and dizzy. Client attends 45 min appointment with interpreter. Letter explained: deduction of 14% made from HB underoccupancy penalty. After two weeks found advice centre through friend, but centre needed to arrange appointment with interpreter, leading to further delay of one week. Client should be exempt, adviser phoned WCC benefits service and explained the mistake. No immediate solution as helpline staff could not see the mistake in the claim suggested writing a letter. Appointment made for client to bring state pension letter. Client attended second appointment bringing evidence of age later that week. Adviser wrote letter to WCC requesting review and including evidence of client age, also wrote to housing association to explain accrual of rent arrears. Client receives response from WCC requesting further evidence, client requests appointment with the advice centre. Attends appointment a week later. Client receives rent arrears letter from housing association, visits WCC, given DHP form. Advised to take passport to WCC. After 11 weeks, client receives revised decision letter. Full HB awarded and backdated benefit entitlement paid. Journey time to resolve issue = 16 weeks end 19

20 Client Journey 2 Employment and Support Allowance start Client attended appointment, ESA had stopped 17 days earlier. Very distressed. Had been helped by advice centre on previous occasions, came with relative as interpreter. DWP letter confirmed client was found not to have limited capability for work at WCA. Adviser explained Mandatory Reconsideration (MR) and helped with letter to DWP requesting MR, also that as ESA not payable, client would need to claim JSA and submit supporting medical evidence. No time to complete appeal form at the appointment; agreed to complete SSCS1 form and asked client to return in two days time to sign and submit the form. Client returned, the form was sent to the Tribunals Service with a copy of the MR notice and further medical evidence Client came back two days later with son, advised on: appeals process and direct lodgement; assessment rate ESA pending outcome of the appeal, and that she needs to contact the DWP to request this and close down her JSA claim once the appeal has been lodged. Also advised to submit medical certificates including a backdated medical certificate. Told that agency cannot offer tribunal representation but agreed to signpost client to another local partner agency which offers tribunal representation. Advised client to return once schedule of evidence received so that she could be referred to a partner agency for help with appeal preparation and representation. Three weeks later: letter from local authority regarding rent arrears, client came for appointment with advisor. Assessment rate ESA pending appeal still not being paid by DWP. Housing benefit suspended no income. Client very stressed, being supported financially by son. Journey time for unresolved issue = 6 months Referred client to local partner agency which offers tribunal representation, closed case. end 20

21 Agency tried to help client with online JSA application, but was not able to complete due to a conflicting ESA claim which client had submitted in the last month. Advised client to go to JCP and make application for JSA in person. Adviser informed local authority of change in circumstances to enable continued entitlement to housing benefit Booked appointment clashed with hospital appointment. Further appointment booked, client advised to speak to her consultant regarding supporting medical evidence, given template letter and a copy of the descriptors to take to the appointment with her consultant. Six weeks later, client received MR notice: the decision had not been changed in her favour. She went to agency, the decision letter was explained to her and she was briefly advised on the appeals process and the relevant deadlines. Could not be seen same day, appointment made for following week. Client was advised to complain to DWP and submit a copy of the appeal acknowledgement letter. Adviser assisted with writing complaint letter to DWP. Also advised her to contact local authority and ask for a nil income assessment of her housing benefit until ESA in payment. One month later: letter from Tribunals Service. Appeal hearing scheduled, client visited advice centre. Scheduled date conflicted with recuperation from heart surgery. Client advised on possible postponement of hearing, need for medical evidence, and possibility that postponement may not be granted. A letter was written the same day for client requesting an adjournment of the hearing due to her scheduled heart surgery. Three weeks later: client received notification of rescheduled date for ESA appeal hearing, attended agency without appointment. Client was referred to a partner agency dealing with appeals. Advised client to take her appeal bundle and any other medical evidence she may have. Ten days later: client s son came to agency without an appointment, informed adviser that his mother was now out of hospital. Tribunal had agreed to postponement of ESA appeal. Assessment rate ESA still not in payment, advised to chase DWP and return if issue unresolved. 21

22 Client Journey 3 Council Tax Support start Client received bill to pay council tax in instalments of 68 a month. Already knew about advice centre, made appointment to see adviser. Two weeks wait for appointment. Client pleased that adviser speaks her first language, attended appointment. HB award letter showed client s entitlement to full HB, client is also in receipt of income-related ESA, she should get full CTS. Adviser called local authority, informed that there was a problem with their system: had not been able to update client s details in order to process CTS. Three weeks later: client received council tax reminder, rang benefits services office of local authority and told again that she was entitled to CTS and that no payment was needed. Local authority confirmed that client entitled to CTS and that she doesn t need to pay. Adviser encouraged client to call the local authority next week to see if the record had been updated. Three days later: client sent a new council tax bill. Rang benefit services office again and was given the same answer. A further council tax reminder was sent after five months. One month later: client returned to the advice centre for help on another issue. Adviser discovered that CTS problem had not been resolved. Made appointment for the client, asked the client to bring council tax bills and other paperwork. Client stressed, suffering from depression. Adviser called the local authority, informed that CTS not in payment. Called benefit services office, told that they could not see from system whether or not CTS in payment. Helpline staff advised writing a letter with copy of council tax bill. Two weeks later: client attended appointment, but did not bring necessary paperwork. Appointment rescheduled for following week, missed due to illness, rearranged again. Letter written, taken by client by hand to local authority. Two and a half months later: CTS entitlement letter issued, with slip to request a refund for payments already made by client. Client received backdated CTS and CTS for current year. Journey time to issue entitlement letter = 21 weeks end 22

23 Interviews with stakeholders Cardinal Hume Centre Cardinal Hume Centre 25 is a multi-purpose support organisation focused on four main areas of need: people living on low incomes, homelessness and insecure housing, education and skills, and disadvantage associated with immigration status. We spoke to Mark Foster, Director of Advice and Assessment. Department for Work and Pensions The DWP 26 is responsible for welfare, pensions and child maintenance policy. As the UK s biggest public service department it administers the State Pension and a range of working age, disability and ill health benefits to over 22 million claimants and customers across the country. Jobcentre Plus helps people move from benefits into work and helps employers advertise jobs. It also deals with benefits for people who are unemployed or unable to work because of a health condition or disability. We spoke to Jonathan Chater, Borough Relationship Manager, Westminster and Kensington and Chelsea. Migrants Resource Centre Migrants Resource Centre 27 offers a range of free services with a focus on supporting migrants, refugees and asylum seekers. It provides specialist immigration advice for cases involving domestic violence, generalist advice as part of the Westminster Advice Services Partnership, and a range of support services in the areas of health, wellbeing, education, employment and digital inclusion. We spoke to Ros Lucas, Chief Executive, and Sylvia Velasquez, Volunteer Coordinator / Advice Service Supervisor. Paddington Law Centre Paddington Law Centre is part of the Law Centres Network. 28 Law Centres offer legal advice, casework and representation to individuals and groups, building capacity within local communities by training and supporting groups and by educating people about the law and their rights. Paddington Law Centre provides advice with casework and representation on welfare benefits, housing and employment issues. We spoke to Leroy Pitter, Solicitor. Westminster Citizens Advice Bureau Westminster Citizens Advice Bureau 29 provides generalist social welfare advice to Westminster residents, and is the lead agency in the Westminster Advice Services Partnership (WASP), 30 a consortium set up to deliver WCC-funded generalist advice. It also has separate funding to provide casework support on welfare benefits, debt and housing issues. We spoke to Shirley Springer, Chief Executive Officer, and Brenda Smith, Social Policy Coordinator. 25 See (accessed 17 April 2015) 26 See (accessed 22 May 2015) 27 See (accessed 8 May 2015) 28 See (accessed 20 May 2015) 29 See (accessed 8 May 2015) 30 See (accessed 8 May 2015) 23

24 Westminster City Council Westminster City Council 31 provides a range of services to local residents, including the Housing Benefit and Council Tax Support Service. 32 Its biggest areas of spend are on: adult social care; children s services; and growth, planning and housing. It funds the Westminster Advice Services Partnership (WASP). We spoke to Richard Cressey, Principal Policy Officer in the Policy, Performance and Communications Department. Zacchaeus 2000 Trust (Z2K) The Zacchaeus 2000 Trust, 33 also known as Z2K, helps vulnerable debtors and people on low incomes. It supports individuals through advice and casework, and lobbies for improvements to the legal and benefits system in the UK. We spoke to Emma Lough, Case Review Manager. Emerging themes Overstretched services and vulnerable clients All interviewees commented on the financial pressures faced by both advice providers and those involved in benefits administration, with advice services reporting demand for advice and support that was significantly greater than their ability to supply. Current arrangements for WASP have provided welcome stability to contracted and sub-contracted organisations providing generalist social welfare advice in the borough. However, when the commissioning process for the current WASP contract was initiated, legal aid was still available. Several advice providers interviewed commented that cuts to legal aid (which culminated in the withdrawal of civil legal aid for most social welfare cases from April 2013) had left a very large gap in support available to clients with more complex problems, particularly where ongoing casework or representation at tribunal is required. These cuts have resulted in significant reductions to advice service capacity. Advice services commented on the fundamental mismatch between the low incomes of the majority of their clients and basic costs of daily living Advice services commented on the fundamental mismatch between the low incomes of the majority of their clients and basic costs of daily living. Clients were not able to deal with unexpected bills or make essential one-off purchases without delaying or missing payments of priority debts such as council tax or rent, often leading to additional debt in the form of financial penalties and charges from debt collection agencies. Many clients did not understand how to demonstrate and evidence their entitlement to a particular benefit, and struggled to pick out and act on important information in letters sent to them by WCC and the DWP. One interviewee commented that clients do not feel confident in their own ability to complete and send off forms, particularly when forms are lengthy, use jargon or technical language, or form part of a wider adversarial process (for example, when clients are challenging a decision on entitlement to ESA). 31 See (accessed 22 May 2015) 32 See (accessed 20 May 2015) 33 See (accessed 20 May 2015) 24

25 Vulnerable people can access initial face-to-face advice, but there is very limited capacity to provide help and support outside relatively short, stand-alone client interviews. Clients often need to contact advice and benefits services more than once to fully resolve a problem, and in advice services, once the time allocated for the individual client is over, there is pressure to move on to the next client waiting in the queue. This causes problems, particularly in situations where clients need coordinated, ongoing support to navigate transactions with benefits administration services on multiple occasions over periods lasting several months, and when people are struggling with ill health, disability or language barriers that impact other areas of their lives simultaneously. Fragmented customer and client journeys No one organisation has an overview of the journeys that people living in Westminster take as citizens, customers and clients when navigating the benefits system. Advice organisations commented on the interrelation and interdependence of problems involving welfare benefits, housing and debt issues. Delays in determining entitlement to benefit are predictably resulting in rent arrears and hardship arising from reduced income available to claimants. Interviewees commented that neither advisers nor clients acting on their own behalf could easily speak directly to decision makers, and were instead put through to a customer services representative. Such frontline staff are by virtue of their role unable to give useful information about the progress of a case, timescales for what will happen next, or what specifically is needed to move a case forward. Delays in determining entitlement to benefit are predictably resulting in rent arrears and hardship arising from reduced income available to claimants All advice services felt that DWP administrative and decision-making processes for ESA and PIP were ineffective and inefficient, resulting in long delays to establish entitlement. One interviewee noted that current demand for advice now relates to PIP decisions explaining these decisions to clients and advising them on MR and appeal rights. Advisers also commented that figures for current demand inevitably hide unmet need, perhaps need that is judged to be less of a priority by advice funders and providers. Organisations are much less likely to collect data on need that they are unable to meet. Advisers noted that issues in one area of a person s life (for example, rent arrears) are often directly affected by issues in another area (for example, housing benefit payments). The right to appeal DWP decisions to an independent body was viewed as vital, but advice services felt that current success rates in challenging DWP decisions on benefits like ESA clearly indicate the need to improve the quality of first-instance decision making. 34 It is noticeable that high levels of spend on state pension and Pension Credit in the borough are not reflected in correspondingly high levels of demand for advice on these benefits, or demand for support in challenging decisions on entitlement. Some commented that the outsourcing of work such as WCAs to private sector providers had made it more difficult to improve the process end to end. One interviewee noted that post MR of decisions, appeals were being listed very quickly after being lodged and registered, making it difficult for representatives to 34 See Mar15_final.pdf (accessed 21/05/2015) 25

26 gather information on behalf of clients in preparation for hearings, despite long periods of waiting earlier in the process. 35 Several advice services commented on the difficulties they face in obtaining medical evidence needed to establish entitlement to working-age disability benefits. There are no sources of funding to cover the costs of obtaining or providing medical reports, and advisers reported having to negotiate with GPs and other healthcare professionals to waive or reduce fees, with charging practice and quality of evidence provided varying depending on the GP or health service involved. Some progress has been made in this area, with Westminster Advice Forum (WAF) writing to the Central London Clinical Commissioning Group 36 (covering Westminster), and receiving a response indicating that providing medical evidence was part of the remit of GPs and should not incur a charge. Generalist advice services and specialist advice services are in some cases provided by different organisations, with clients receiving an initial advice and support with first steps service on the day at one organisation and then referral (depending on client availability and very limited service capacity) to an advice with ongoing casework service at another organisation. Each referral has the potential to build in delay or, in a worst-case scenario, to prevent the resolution of a client s case, for example when clients fail to navigate the intake processes of a new organisation. There is little or no evidence on the success rate of referral or signposting activities and the eventual outcomes for the client. Engagement between key stakeholders Three main channels for current engagement between key stakeholders have been identified: the Westminster Advice Agency Liaison Meeting (WAALM); the Westminster Advice Forum (WAF); and the Westminster and Kensington and Chelsea DWP Customer Representatives Group (WAKAC DWP CRG). More consistent engagement and commitment from a wider range of organisations is needed Firstly, a number of interviewees made reference to the quarterly WAALM meeting convened by WCC. Most commented favourably on the commitment of WCC to organising this meeting, noting the improved access to managers overseeing the delivery of the Westminster Benefits Service and the escalation routes available to resolve individual cases involving HB claims. Some interviewees commented that the meeting was underused by advice service providers, and that more consistent engagement and commitment from a wider range of organisations was needed. Others indicated that there were very limited opportunities to undertake systemic improvements that could be made to benefits administration processes and advice journeys, particularly given outsourcing arrangements (to Capita in the case of the Westminster Benefits Service, and to WCA providers or internal benefits processing centres in the case of the DWP). A number of frustrations were reported by interviewees, including: a perceived lack of willingness on the part of WCC to identify and implement systemic improvements to the service; unnecessary duplication of effort required by WCC staff to address formal complaints made by advice services on behalf of their clients when from the perspective of WCC, the original grounds for the complaint had already been addressed and practical 35 As part of a localised pilot for tribunal cases heard at Fox Court 36 See (accessed 15 May 2015) 26