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Consultation Responses: Social Security


Migration from legacy benefits to Universal Credit - SSAC call for evidence August 2018

From 2019 the Department for Work and Pensions (DWP) will start to move claimants on one or more of the following benefits to Universal Credit:

Working Tax Credit; Child Tax Credit; income-based Jobseeker’s Allowance; income-related Employment and Support Allowance; Income Support; Housing Benefit

The proposals are set out in the draft Universal Credit (Transitional Provisions) (Managed Migration) Amendment Regulations 2018. The Social Security Advisory Committee (SSAC) is examining views on the potential implications of the proposed process for claimants.

ESA Arrears - call for evidence May 2018

Approximately 8,000 claimants in N. Ireland have lost out on an average of £3,000 due administrative errors during the transfer from Incapacity Benefit. In this response to the (Westminster) Public Accounts Committee’s Inquiry on Employment & Support Allowance, we argue that all of these claimants should be awarded arrears.

PIP - call for evidence  March 2018

We made 29 recommendations to improve the PIP Assessment process. Key recommendations are: Improved communications with claimants and healthcare professionals; access to audio recording (free of charge) for claimants during face-to-face assessments; greater emphasis on identifying vulnerable claimants; an agreed process for accessing medical evidence; an agreed process for carers to input into the assessment; improved accountability and transparency through the regular publishing of PIP data; an independent complaints process that looks at all aspects of the PIP journey.

Social housing allocations  January 2018

In this partial response, we support a number of the Department’s proposals about the housing selection scheme including the proposals to introduce an independent housing service, align the selection scheme with the social size criteria ('bedroom tax'), etc. We also support Housing Right’s suggestion of replacing the intimidation points scheme with a trauma model. Finally, we suggest that the Department ensures that legislation and practices meet the needs of victims of trafficking and family reunion refugees.



Funeral Payments September 2017

The scope of this consultation is disappointingly narrow; specifically, it fails to address the fact that Funeral Payments do not cover the cost of a basic funeral.


Universal Credit and help with costs September 2017

We make a number of recommendations to the Department of Health including: to align the Help with Health Costs scheme with Transitional Protection to help mitigate against the loss of entitlement for Universal Credit and to commit to reviewing the scheme in 12 months time.


Changes to eligibility criteria for free school meals and uniform grants re: Universal Credit  June 2017

The introduction of Universal Credit affects eligibility to Free School Meals. We recommend that Department for Communities adopt an interim position until at least July 2019 to ensure that children do not lose their entitlement.


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.



Modern Slavery Inquiry and access to social security benefits December 2016

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 and 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.


Housing Benefit and State Pension Credit (Temporary Absence) (Amendment) Regulations 2016 February 2016

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.



SSAC - Housing Benefit Habitual Residence Amendment Regs June 2014

Removing the entitlement of jobseeker  EEA migrants to Housing Benefit risks homelessness and may particularly affect vulnerable groups.


Joint submission to the NI Assembly on Rate Rebate Reform and Universal Credit April 2014

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.


Work and Pensions Committee inquiry into ESA and ECA Feb 2014

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.


DFP: Welfare Reform - Rate Rebate Replacement Arrangements – Preliminary Consultation Paper April 2013

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. 



Ad Hoc Committee on Conformity with equality requirements and observance of human rights: NI Welfare Reform response to call for evidence on Welfare reform Bill October 2012

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.


Submissionto the Committee for Social Development on Welfare Reform October 2012

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.


DSD: Work Capablity Assessment 3 year Review September 2012

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.


LCNI: Work and Pensions Select Committee Implementation of Universal Credit  August 2012

Welfare Reform Group: Work and Pensions Select Committee Implentation of Universal Credit August 2012

SSAC Consultation- Draft Universal Credit Regulations July 2012

DSD: DLA Reform and Personal Independence Payment - Completing the Detailed Design June 2012

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.

Response to Social Security Advisory Committee re Assessment of The Housing Benefit Executive Determinations Amendment Regulations NI 2012 May 2012

DWP: Mandatory Consideration of Revision before Appeal May 2012

DSD: PIP - Assessment Threshold and Consultation April 2012

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. 

DSD: Work Capablity Assessment - Cancer Consultation  March 2012

DSD: call for evidence on Support for Mortgage Interest Feb 2012

The proposed changes to SMI include introducing a property charge for long term claims and moving away from the Mortgage Interest Direct Scheme.



WRG response to Welfare Reform Bill EQIA Nov 2011

DWP: supported housing Oct 2011

DSD: Work Capability Assessment review Oct 2011

WPSC: Replacing DLA with Personal Independence Payment Sept 2011

SSAC: Passported Benefits under Universal Credit July 2011

SSAC: Housing Benefit Regulations: Shared Room Rate  June 2011

DSD Consultation: NI Independent Review of the Work Capability Assessment May 2011

DSD: equality scheme April 2011

WPSC: Migration from Incapacity Benefit to ESA April 2011

DSD Consultation: Reform of Disability Living Allowance to Personal Independence Payment February 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.

DSD Consultation: Reform of Disability Living Allowance: A Welfare Reform Group Response February 2011

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.

Universal Credit DSD Consultation - Law Centre (NI) response January 2011

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.

Universal Credit DSD Consultation - Welfare Reform Group response January 2011

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.



Universal Credit - Welfare Reform Group response to House of Commons inquiry December 2010

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.

SSAC Consultation: Jobseeker’s Allowance (Mandatory Work Activity) Regulations 2011 December 2010

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.

SSAC Consultation: Social Fund Maternity Grant Amendment Regulations 2011 December 2010

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.

Work & Pensions Committee: Inquiry: Impact of the Changes to Housing Benefit Announced in the June 2010 Budget  September 2010

SSAC Consultation: Housing Benefit (Amendment) Regulation 2010 and Rent Officers (Housing Benefit Functions Order) 2010  September 2010

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.

SSAC Consultation: The Employment & Support Allowance (Limited Capability for Work and Limited Capability for Work Related Activity) Amendment Regulations 2011 September 2010

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.

DWP Consultation: Social Fund Reform: debt, credit and low-income households  June 2010

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.

SSAC Consultation: The Income Support & Employment and Support Allowance Regulations 2010 March 2010

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.

DWP Consultation: Supporting people into work: The next stage of Housing Benefit reform  February 2010

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.



DFP:  Draft Spending Priorities for the Dormant Bank and Building Society Account Scheme in NI October 2009

DSD:  Welfare Reform Bill EQIA September 2009

Child Poverty Unit of Dept. for Children Schools & Families: Ending child poverty: making it happen March 2009



DWP Consultation: The Social Fund: A New Approach  December 2008

DWP Consultation: Reforming Welfare to Reward Responsibility  October 2008

SSAC Consultation: Social Security (Miscellaneous Amendment) Regulations  June 2008

SSAC Consultation: Proposals to Limit Pension Credit and Housing Benefit  May 2008



DWP Consultation: Joint Birth Registration September 2007

HM Treasury:  Unclaimed assets distribution mechanism: a consultation August 2007 

DWP Consultation:  Industrial Injuries Disablement Benefit Scheme April 2007

A New System of Child Maintenance  March 2007

OFMDFM Consultation: Guidance on the Definition of Disability  January 2007



The Affordable Credit Deductions Scheme  September 2006

Redesign of Child Support  September 2006

New Deal for welfare consultation  April 2006



Social Security (Work Focussed Interviews Amendment) Regulations  July 2005



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