The coalition government today published its consultation on the reform of Disability Living Allowance (DLA). The headline is that DLA is going to be replaced by a "Personal Independence Payment" (PIP) from 2013/14.
DLA has been in the news a considerable amount since the emergency budget in June this year, primarily because it has been the main disability-focused benefit the government has looked to cut. I've blogged quite a lot on the topic: see here, here and all posts here.
As such, today's consultation on the reform of DLA is of huge significance and interest because it provides far more detail and intent of what is planned for DLA. Below, I summarise what I think are the key issues. (Via delicious you can keep track of other reactions via my tag DLAreform.)
1. The foreword states that:
We are committed to a sustainable and fair system that allows people to work when they can and provides unconditional support to those who are unable to work (emphasis added).
The idea that the reformed DLA system provides "unconditional" support is palpably nonsense. Moving from the system (where people can self-assess) to one where the explicit aim of the reform is to reduce the number of recipients and spend by 20% is quite the opposite.
2. These proposed reforms suggests introducing "conditionality" into the system (paragraph 2.35). The idea is that as part of the PIP, recipients will be required to discuss their circumstances with a professional who offers advice and "helps them access specialist support". I'll explore the intention behind this in point 3 below, but introducing conditionality into the DLA process is a huge shift. Whilst there's been some debate about whether conditionality in employment benefits is right or wrong, introducing it in a disability setting - where people have already passed through so many tests based on their often intimate and personal circumstances - will feel to many like they're being kicked when they are down.
3. Throughout the reform consultation there are references and suggestions that DLA should no longer cover the sorts of support it used to, to take account of the fact that aids, adaptations and equipment are now more part of the general landscape. So, where the mobility test used to be based on ability to walk, the mobility test will now be based on being able to get around - and if there's a wheelchair involved, that will suffice.
The question of how that wheelchair has been paid for - private money, health money, social care money - appears not to matter, which is obviously wrong. If an individual has paid for it, then they clearly had a mobility need. If the NHS or a Council has paid for it, then they obviously thought there was a mobility need. Though it seems innocuous, the intention of the conditionality above will actually require a potential recipient of DLA to explore what "specialist support" is avaliable apart from DLA. By introducing this, and the very narrow focus on what support is in place at the time of assessment, the impression is created that, so long as the need isn't met by the DLA budget, it doesn't matter where it's met from. What wider impact this will have on NHS and social care spending is currently unknown, but I'll bet they won't be pleased by this subtle but important chance.
4. The idea that DLA itself is a barrier for disabled people into employment (para 1.19) just isn't credible. Indeed, the DWP's own evidence (pdf) suggests otherwise. Even if we take this assertion at face value, I'm already hearing of restrictions of what Access to Work will and won't fund to enabled disabled people into employment. Thus, with the government also seeking to reduce what proportion of DLA is spent on aids, equipment etc., these two changes combined means the government significantly risks undermining its own policy of supporting people back into work.
5. The reform paper paints a very confused picture on costs and numbers. It states that over 3m people receive DLA - of which 1.8m are of working age (16-64) - with total spend this year being "forecast as £12bn". But the Dilnot Commission, based in the Department of Health, says that DLA for 16-64 year olds costs £5.487bn (in 2009/10). Furthermore, the DWP's own figures said that DLA cost £6.2bn in 2009/10. In the emergency budget, the government said they would save £1bn (or 20%) of the DLA budget, suggesting they were using the £5.487bn figure. If that's right, why quote the £12bn figure? (Quite aside from this, the government fails to mention that Attendance Allowance currently costs £7.505bn. More on that another time.)
6. A massive change - different to anything we've heard before - is that the DLA reforms are to extend beyond working age to cover children and those over 65 (paras 0.3, 1.14 and throughout). I don't recall the government saying that the DLA cuts will affect this group of 1.2m people, in either the CSR or the Budget. If this is true, the impacts will be huge (and go some way to explaining why the £12bn figure above is included.)
7. There is a mixed picture on the role of self-assessment. The government appears not to trust people applying for DLA under the current system, but thinks that self-review under the new one is fine (para 2.32). If self-assessment in social care, with its considerably larger budget, is acceptable (under the banner of personalisation), then why isn't it acceptable for DLA assessments?
8. In paragraph 1.10, the reform consultation states that "measuring each individual's expenditure would be administratively complex and expensive". And yet they think that checking everyone's needs won't be.
9. Paragraph 2.4 notes that the PIP will require a "new, fairer, objective assessment, which will allow [the government] to identify those who face the greatest need, in a more consistent and transparent manner". Transparency is, of course, to be welcomed. I will therefore look forward to full details of the contract between ATOS - who carry out the medical assessments for DLA on behalf of DWP - and the DWP, along with all its financial information, performance information and details of targets etc.
10. Paragraphs 2.33 and 2.34 talk about the "penalties" that will be put in place for individuals who don't report changes in their circumstances. It's a shame the report didn't take the opportunity to note that the fraud rate for DLA is 0.5% - a rate significantly lower than Income Support (2.9% fraud rate), Incapacity Benefit (1%) and Jobseekers Allowance (2.8%). Indeed, it's lower than the office error rate for the DWP, which stands at 0.6% (data: Benefit Scrounding Scum).
It's only fair to note that there are some good points in the reform paper:
1. Paragraph 2.18 talks about bringing the definition of those who could potentially get DLA into line with the legal definition of disability. This makes sense.
2. Maintaining DLA as a non means-tested, non-taxable, non-NI contributions dependent benefit is right, as is recognising its role as a passport to many other publicly-funded services.
3. Looking to align assessments across benefits, health and social care, and sharing information (with permission) across professionals about those assessments, could be a big win, for both individuals going through the process and to streamline administration (para 0.11). In its Right to Control work (on which I've written a series of posts) the government is developing an infrastructure that could enable this to happen.
4. Throughout this document, the government has finally and explicitly acknowledged that DLA is "not an income-replacement benefit for those who are out of work due to disability" (para 1.1). It's just a shame that the government did so much to encourage the perception of disability as an out-of-work benefit.
Overall, I'm afraid to say there is a lot for disabled people to be worried about in these proposals. There is no getting away from the fact the government has decided it wants to spend less on DLA and is justifying where it is going to draw the line to save the 20% they're looking for.
The most superficial of all the proposals is renaming what has become the potent "Disability Living Allowance" and replacing it with a "Personal Independence Payment", which has the unfortunate acronym PIP, which puts me in mind of Great Expectations.
The problem being, of course, that the government's reforms aren't something that disabled people can think of in terms of hope and promise. Instead, the reforms confirm the very Worst Apprehensions that we held over these reforms.