Response to SSAC Consultation - Extension of benefit waiting days

No Safety Net

Along with many of our members, SCVO believes that this new policy, alongside other devastating welfare cuts, will continue to undermine the very fabric of our society. We believe the policy will create another huge whole in an already inadequate safety net. As in our response to the recent Oakley Review[iii], we would question the impact of this consultation given the determination of the Coalition to radically alter the welfare state and the benefits system. Already a tide of evidence shows the impact of what has been implemented to date. For example:

• A range of third sector organisations give examples of individuals and families left in extreme hardship because of sanctions applied with little or no consideration of personal circumstances and in some cases having wider impact on family and support networks (e.g. sanctions on those with caring responsibilities).^{[iv] [v]   [vi]}
• The clear link between food bank referrals and negative changes within the benefits system. This includes delays which currently exist within the system. ^[vii]

We do not believe this policy’s impact assessment is full or detailed enough, or acknowledges the likely, full effect on people’s lives. The planned increase in waiting days adds to whole range of already significant challenges within the current benefit system, which impact substantially on people across Scotland and the wider UK.

Cost Shunting

In our response to Oakley, we highlighted the impact of benefits sanctions on people’s lives. At a recent session with the Scottish Parliament Welfare Reform Committee, a panel of third sector and academic experts^[viii] provided detailed evidence of a flawed and damaging regime. This further delay and reduction in payments places individuals and families at real risk of destitution. What is more, along with other changes, we believe that this planned change will continue to shunt costs to the third sector in Scotland.  Carer and disability organisations, housing associations, Citizens’ Advice Bureaux, condition specific organisations, and mental health charities all report increased demand for support and help as a direct result of welfare reforms. This has diverted organisations from delivering preventative support services, as outlined by SCVO’s research into the impact of welfare reform on Scotland’s third sector.^[ix] This planned change could also place additional pressure on the Scottish Welfare Fund, which has recently been extended to include more people affected by benefit changes, including those affected by sanctions.

What are changes likely to mean?

On reviewing the Equality Impact Assessment and other documents related to the waiting time regulations, a number of concerns emerge: Cumulative impact of changes – A recent report from Citizens Advice Scotland has outlined the significant challenges arising from maladministration within the benefits system, particularly in relation to ESA: “Poor administration, a lack of flexibility and breakdowns in communication mean that clients’ medical conditions are not properly considered as they apply for benefits. The process of claiming disability benefits is stressful and these problems compound that stress. In some cases the difficulties of trying to sort out these problems can exacerbate clients’ health problems.”^[x] Not only will these regulations lead to people being left with less money, there is no guarantee of any bridging support from Short Term Benefit Advances (STBA). These advances have to be paid back – from a poorer starting point for claimants, whose first benefit payment will now be reduced. In addition, there is no way to review decisions not to award STBA^[xi]. Poverty risk increased – for new claimants of JSA who are caught up in irregular, low paid work, their claim leaves them at risk of further poverty as they can expect a lower first benefit payment after claiming.  This policy clearly does not recognise the reality of work and the cycling in and out of benefits which can be experienced by families.^{[xii]  [xiii]} What is more, this cut comes on top of other previous cuts such as the 1% cap, creating the very real risk of poverty for many. Reinforcing a “them” and “us” approach – The language used to describe what will result from the change contributes to the ongoing stigmatisation of people. By highlighting that cuts to the benefits of one group will be reinvested to support other groups, the notion that welfare is for all is once again quashed by a policy which penalises those who are already vulnerable, with new diagnoses or illnesses and those for whom loss of employment has turned their lives upside down. Moreover, the ending of ineffective programmes ^[xiv]such as Mandatory Work Activity and Help to Work could have helped to fund more impactful interventions. Our view is reinforced by the clear aim of the waiting days regulations to discourage people from claiming benefits in the first place. Universal Credit impact – will be much worse given that it covers a fuller amount of household income for families. The Government intends to push ahead with this change anyway, clearly acknowledging in the Explanatory Memorandum that there are greater risks of hardship for families. We already know that many benefit changes have affected those who are already vulnerable ^[xv] - this planned increase in waiting days will likely affect similar groups reducing any real protection they could hope for from the benefits system.

Conclusion

Yet again, those on benefits appear to be at the end of unfair and it would seem unjustified cuts to the very safety nets we should all be able to rely on in times of need. Lack of any external consultation is concerning (Explanatory Memorandum, 5.1) – those most affected and those supporting them have no say or voice in this context. Evidence of the devastating impact of a whole range of welfare cuts steadily builds across Scotland and UK wide. The third sector sees the reality of this on a day to day basis and stands alongside people and families affected. SCVO supports the contribution of third sector colleagues such as SAMH which will identify the specific impact of changes on key groups in society such as those with mental health issues. Along with our partners and members, we urge the SSAC to challenge the DWP on this planned policy change.

Contact

Lynn Williams, Policy Officer Scottish Council for Voluntary Organisations Mansfield Traquair Centre 15 Mansfield Place, Edinburgh EH3 6BB Tel:  0141 559 5036 E mail: lynn.williams@scvo.scot Web: www.scvo.scot

About us

The Scottish Council for Voluntary Organisations (SCVO) is the national body representing the third sector. There are over 45,000 voluntary organisations in Scotland involving around 137,000 paid staff and approximately 1.2 million volunteers. The sector manages an income of £4.4 billion. SCVO works in partnership with the third sector in Scotland to advance our shared values and interests. We have over 1300 members who range from individuals and grassroots groups, to Scotland-wide organisations and intermediary bodies.