DWP consultation on DLA reform

DWP have published a discussion paper on the proposed changes to benefits affecting the disabled.


Readers of my recent blogs and tweets will know that I have argued against making the economic cuts hit those most in need.  I would rather see corporate tax laws enforced and loopholes closed.  This would raise far more revenue than the disability living allowance cuts.


The comments below have been submitted to DWP, my MP, rethink and those who follow me on social networks.  Please reuse anything you like and do add your own comments


Response to public comment document Disability Living Allowance Reform  

Question 1 What are the problems or barriers that prevent disabled people participating in society and leading independent, full and active lives?  
Mental and or physical incapacity such that no paid work is possible   
Mental or physical symptoms that render it dangerous to the individual or others for them to be in a normal working environment or indeed unaccompanied anywhere.
 
Question 2 Is there anything else about DLA that should stay the same? Recipients of higher rate DLA and MobA need assisted living so their combined allowance would have to cover the median private sector rate for that provision since few state run communities still exist.  In my area (DA1) the cost of private care is between £500 and £1000 per person per week so if care is to be outsourced that is the accommodation and food component of need; transport remains as is now.
 
Question 3  What are the main extra costs that disabled people face?
Inability to earn money for food and accommodation
The cost of a shared able bodied carer
Cost of a car with driver or taxis to get to voluntary work, therapy and discussion groups
 
Question 4  The new benefit will have two rates for each component:
Will having two rates per component make the benefit easier to understand and  administer, while ensuring appropriate levels of support?
What, if any, disadvantages or problems could having two rates per component cause?
Flexibility is reduced for cases at the margins.
Existing payment matrix is only 12 cells each with a rate – hardly complex
 
Question 5  Should some health conditions or impairments mean an automatic entitlement to the benefit, or should all claims be based on the needs and circumstances of the individual applying?
Some mental and physical disabilities can neither be treated nor cured.  In such cases this could be established at initial assessment.
I would also point out that mental incapacity must be decided by at least one qualified psychiatrist and not a specialist assessor with little medical knowledge and, at best, a degree in some occupational related subject  
Right to appeal to a panel of qualified mental or physical specialists must be built in.
The named social worker of the individual being assessed must sign off the final assessment and ensure that the result is the ability of the individual to live safely and comfortably in suitable accommodation.
If the individual is in a private care facility because there is no state facility then financial liability will continue even if the individual is hospitalised – the state must cover this cost as the price paid for outsourcing care to the private sector
 

Question 6  How do we prioritise support to those people least able to live full and active lives? Which activities are most essential for everyday life? 

Assessment should start with need – how much does appropriate accommodation, care, travel and food cost and then take into account the ability of the individual to earn anything

Question 7 How can we best ensure that the new assessment appropriately takes account of variable and fluctuating conditions?
Monitor RPI, get GP to sign notes indicating change or no change, liaise job centre to find out if individual is in work or could be in work if work was availabke.  In the latter case benefit will obviously have to be continued.
 
Question 8 Should the assessment of a disabled person’s ability take into account any aids and adaptations they use?
• What aids and adaptations should be included?
• Should the assessment only take into account aids and adaptations where the person already has them or should we consider those that the person might be eligible for and can easily obtain?
Stage one is for health and welfare to provide adaptations that will benefit the individual
Stage two is assessment of the ability of individual with aids that have been provided
 

Questions 9, 10 and 11 have essentially the same answer

Question 9:  How could we improve the process of applying for the benefit for individuals and make it a more positive experience? 

For example:
• How could we make the claim form easier to fill in?
• How can we improve information about the new benefit so that people are clear about what it is for and who is likely to qualify?
 
Question 10  What supporting evidence will help provide a clear assessment of ability and who is best placed to provide this?
 
Question 11 An important part of the new process is likely to be a face-to-face discussion with a healthcare professional.
• What benefits or difficulties might this bring?
• Are there any circumstances in which it may be inappropriate to require a face-to-face meeting with a healthcare professional – either in an individual’s own home or another location?
Claimant need fill out nothing if he/she has a carer.  Carer or claimant to submit evidence of living expenses.  Medical assessment from GP and appropriate specialist.  Any occupational
therapy reports to be reviewed by an appropriate qualified consultant physician.
 
Question 12  How should the reviews be carried out? For example:
• What evidence and/or criteria should be used to set the frequency of reviews?
• Should there be different types of review depending on the needs of the individual and their impairment/condition?
Unless GP notes indicate a change there is little point repeating
 
Question 13 The system for Personal Independence Payment will be easier for individuals to understand, so we expect people to be able to identify and report changes in their needs. However, we know that some people do not currently keep the Department informed. How can we encourage people to report changes in circumstances?
Department asks for regular GP “sick” notes and possibly a rough breakdown of living costs. 
If the individual is in a care home run by private sector then that could be paid directly.
 
Question 14  What types of advice and information are people applying for Personal Independence Payment likely to need and would it be helpful to provide this as part of the benefit claiming process? 

Clear definitions of each criterion that will have an effect on the outcome
 
Question 15 Could some form of requirement to access advice and support, where appropriate, help encourage the minority of claimants who might otherwise not take action? If so, what would be the key features of such a system, and what would need to be avoided?
Those eligible to claim should have a carer and the carer should act as advocate.
 
Question 16  How do disabled people currently fund their aids and adaptations? Should there be an option to use Personal Independence Payment to meet a one-off cost?
Cost of approved aids and adaptations should be met in addition to PIP by the state;  at present the wealthy buy the best available whilst others rely on appeals and third sector assistance. As I understand it PIP is to be set at minimum to cover living costs so aids would have to be funded in aaddition to regular PIP
 
Question 17 What are the key differences that we should take into account when assessing children?
Children unlikely to be working or eligible to work.
Children will often have a parent as main carer
Children currently expected to live in parents’ home forever as no provision for assisted living.  When older than 18 young people should be found assisted living accommodation in a community where the disabled person can interact with peers ( http://tinyurl.com/38wg6jn ) .