Consultation Responses: Social Security
Self-employment and the gig economy January 2017
We responded to a (Westminster) Work & Pensions Committee inquiry on self employment and the ‘gig’ economy. We acknowledge that the introduction of Universal Credit is going to cause particular difficulties for low earning self- employed workers who are currently in receipt of tax credits and so we make a number of recommendations to ease the impact.
We also highlight how self employment can be a method used by employers seeking to reduce their duties/liabilities to their workers i.e. to bypass employment rights. This is particularly worrying given the increase of ‘casual work’ (including zero hour contracts and agency workers) and the so called Gig Economy.
It is essential that recognised European victims of slavery have immediate access to social security benefits. We propose a number of Northern Ireland initiatives to the Westminster Committee that might assist. While these initiatives were developed in the context of refugees, we think that they could also be useful for victims of slavery.
Programme for Government 2016-2021 December 2016
We build on recommendations in our previous response. We urge Executive to prioritise improving childcare infrastructure, to commit to safeguarding access to independent advice, to tackle zero hour contracts and to seek to protect the rights of European nationals living in NI.
Civil Justice Review December 2016
We welcome the bold recommendations proposed by the Gillen Review of Civil Justice. Where possible, we would like the proposed innovations to be applied to the Tribunal system (not just to the courts).
Programme for government framework July 2016
We commend the department for what this draft Programme for Government is trying to achieve.
We make a number of suggestions for additional indicators and measures.
We look forward to the publication of the action plans, which are essential in order to make these ideas real and meaningful.
A joint response with Housing Rights to a Social Security Advisory Committee consultation.
DWP proposes to amend the Housing Benefit and State Pension Credit regulations to reduce the period of allowable absence from outside Great Britain, generally from 13 weeks to 4 weeks. It is a condition of entitlement to both benefits that claimants are in Great Britain, although the regulations provide that temporary absences are permitted in some instances. This is part of a series of measures to harmonise existing Regulations with the Universal Credit system.
We do not support the proposed changes. However, if the changes do proceed, we would recommend that the Social Security Advisory Committee seek a commitment from the Department to monitor the impact of these Regulations given their potential impact.
We would also recommend that the Social Security Advisory Committee scrutinises the equivalent Northern Ireland regulations when available.
DFP rate rebate replacement scheme February 2015
We agree with the Department’s proposal to link rate rebates to Universal Credit but highlight the need to make discretionary funds available for people experiencing difficulty paying their rates.
Removing the entitlement of jobseeker EEA migrants to Housing Benefit risks homelessness and may particularly affect vulnerable groups.
In this joint submission to the NI Committee for Finance and Personnel, Housing Rights Service and Law Centre consider the merits of the Department’s different models of ‘passporting’ different categories of claimants for Universal Credit purposes.
We explain that arrangements for WCA medical assessments are still inadequate for ESA claimants with limited mobility. We also make the case for audio recordings of medical assessments.
DSD: Provision of Discretionary Support April 2013
Law Centre NI welcomes the opportunity to provide comment on the provision of discretionary support. Law Centre NI recommends that the new scheme reflects the strengths of the current Social Fund and also calls for the necessary resources to be put in place to provide a meaningful alterative in terms of financial advice, to enable applicants to improve their financial capability.
Law Centre NI recognizes the opportunity this consultation presents to develop a progressive and tailored Northern Ireland rate support scheme. We see merit in the interim of taking the sub option 1.1 approach and offsetting savings from additional schemes being made towards the cost of maintaining the existing scheme in the short term.
DSD: Maximising Incomes and Outcomes April 2013
Given the current backdrop of austerity measures, increased living costs and rising unemployment, Law Centre NI welcomes the opportunity to comment on this plan. We support the Department’s continued investment in proactive approaches to encouraging benefit uptake given the outcomes achieved for people most at risk of poverty in previous years.
The NI Welfare Reform Group recommends that the Committee’s scrutiny extends to information provided in the secondary legislation as the Bill cannot be divorced from the details contained in the Regulations. The Groups also recommends that the Committee examines and calls for enhanced procedures to the monitor the impact of the Bill once implemented.
This is a detailed clause-by-clause assessment of the Welfare Reform Bill. We highlight lots of areas where we believe Northern Ireland could do things differently.
Law Centre (NI) recommends further training for assessors with specific expertise in mental health and fluctuating conditions and additional weighting be given to evidence from the applicants medical and support staff.
Law Centre (NI) encourages the Department to highlight the different circumstances in Northern Ireland particularly the significantly greater incidence of mental health problems and the objective ramifications of the proposals to replace DLA with PIP for claimants.
DSD: Bereavement Benefit in the 21st Century April 2012
Law Centre (NI) expresses concern that this reform represents further erosion of the national insurance contributory principle and recommends further debate around the role of insurance-based benefits and increased reliance on means-tested benefits.
The proposed changes to SMI include introducing a property charge for long term claims and moving away from the Mortgage Interest Direct Scheme.
DWP: supported housing Oct 2011
DSD: equality scheme April 2011
The Law Centre outlines strong concerns about the enormity, timeframe and intention of proposed changes to DLA given the high number of people in receipt of the benefit in Northern Ireland.
The Welfare Reform Group also responded to the DSD Disability Living Allowance consultation . Of particular concern for the group was the proposal to introduce an assessment comparable to the Work Capability Assessment of the Employment and Support Allowance.
The Law Centre responded to the Department for Social Development’s Consultation on the Universal Credit: Welfare that Works. The Law Centre welcomed the move to make work pay and simplify the benefit system. It was keen, however, to highlight that Northern Ireland presents particular circumstances regarding social security and, therefore, recommended that Northern Ireland examine scope for variation to takes these differences into consideration while maintaining the overall direction followed by Britain.
The Welfare Reform Group convened by the Law Centre also responded to Department for Social Development’s Consultation on Universal Credit : Welfare that Works. A key concern of the Group is the potential impact of the increased occurrence of conditionality and sanctions, given the current bleak economic climate and the lack of childcare infrastructure in Northern Ireland.
The Welfare Reform Group convened by the Law Centre responded to the House of Commons Work and Pensions Select Committee inquiry into the White Paper - Universal Credit: Welfare that Works.
The Law Centre submitted its response to the Social Security and Advisory Committee consultation regarding proposals to introduce ‘mandatory work activity’ from April 2011. We understand the potential benefit that can be derived from work activity; however, we are concerned about the introduction of these proposals and increased conditionality given the current economic climate, the capacity of the unemployment market and local divergences of regional resources such as childcare provision.
Law Centre (NI) and Gingerbread (NI) comment on a consultation on the restriction of the Sure Start Maternity Grant from April 2011 to families with no other children under 16 years of age.
DSD Consultation: National Insurance Credits Changes November 2010
The Law Centre responded briefly to the Department for Social Development’s consultation for National Insurance credit changes. We welcome the proposal to extend National Insurance credits for grandparents and other family members as an important step in recognising the valuable contribution they offer to the provision of childcare in Northern Ireland. We are concerned, however, that the withdrawal of starting credits may have an adverse impact on migrant workers.
21st Century Welfare: Law Centre (NI) Submission September 2010
21st Century Welfare is the coalition Government’s blue print for welfare reform.
The June 2010 Emergency Budget announced a number of changes to Housing Benefit, in particular, Local Housing Allowance, with conversion scheduled to begin from April 2011. Both the Work and Pensions Committee and the Social Security Advisory Committee launched inquiries into the impact of these amendments on the Housing Benefit (Amendment) Regulations 2010 and associated Rent Officers (Housing Benefit Functions Order) 2010. LCNI’s response to both Committees highlights our concern that the combined effect of these proposals will lead to sharp rises in rent arrears, evictions and cases of homelessness.
This consultation sets out proposals for the amendment of the work capability assessment (WCA). The Government expects an additional 5% of claimants to be found fit for work under the revised test which places greater emphasis on physical functioning to adaption. Our response emphasizes the need for strong safeguards to be in place for those found capable of work that have a disability or illness.
The consultation outlines the previous Government’s plans for reform of the Social Fund to make the scheme more active, easier for customers to get one-off or occasional support and to provide more support to frequent users of the Fund to tackle the underlying problems they may face. It also details how the scheme should provide better value for money for the tax payer by reducing the number of frequent users.
The proposed Regulations bring into force some of the more concerning parts of the Welfare Reform Act 2009 which impact significantly upon Lone Parents. LCNI’s response outlines our concerns regarding the potential impact of the proposals on lone parent families generally, lone parent families coping with certain health conditions and/or disabilities and the potential impact on child poverty.
In a joint response LCNI’s and Housing Rights Service highlight concerns with DWP proposals to reform Housing Benefit. As part of this reform agenda we believe it will be important for the Department for Social Development to consider the following local strategic issues: The absence of a review into the implementation and impact of LHA locally; The differences between Housing Benefit in Great Britain and Northern Ireland; Northern Ireland presents particular circumstances with regards to welfare and arrangements to move people into employment; and the capacity of the employment market.
The proposed regulations provide for the movement of benefit claims from Incapacity Benefit and Severe Disablement Allowance to Employment Support Allowance.
DSD: Welfare Reform Bill EQIA September 2009
DWP Consultation: The Social Fund: A New Approach December 2008
DWP Consultation: Joint Birth Registration September 2007
The Affordable Credit Deductions Scheme September 2006
Redesign of Child Support September 2006
New Deal for welfare consultation April 2006