Disability Living Allowance Reform

							Response to the Public Consultation on Disability
           Living Allowance Reform.

                 February 2011
About us

We’re RNID, the charity working to create a world where deafness or hearing
loss does not limit or determine opportunity and where people value their
hearing. We work to ensure that people who are deaf or hard of hearing have
the same rights and opportunities to lead a full and enriching life. We strive to
break down stigma and create acceptance of deafness and hearing loss. We
aim to promote hearing health, prevent hearing loss and cure deafness.

Our response will focus on key issues that relate to people who are deaf.
Throughout this response we use the term 'people with hearing loss' to refer
to people who are deaf, deafened and hard of hearing. RNID is happy for the
details of this response to be made public.


Comments

RNID welcomes the opportunity to comment on the proposals to reform
Disability Living Allowance (DLA). However, we are disappointed that the
consultation period falls short of the government’s own guidance, limiting the
opportunity for organisations and individuals to gather supporting evidence for
their responses.

We strongly oppose the announcement in the 2010 Spending Review that
people in residential care would no longer be allowed to claim the Mobility
component of Disability Living Allowance. 82% of residents in RNID care
homes currently receive DLA Mobility Component, and this decision will have
devastating effects on them, threatening the independence that this benefit
gives them, and severely limiting their opportunities for meaningful social
participation. We urge the government to take the brave step of reversing this
policy as evidence of their commitment to providing disabled people with real
choice and independence.

We are pleased that the government has taken the decision not to reduce an
individual’s Housing Benefit after twelve months of claiming DLA, a proposal
that may have hit people with hearing loss who have adapted their homes to
suit their needs.

According to the latest DWP figures, around 41,000 people qualify for DLA on
the basis of a hearing loss. However, we estimate that there are just over
400,000 current DLA claimants who either have or would benefit from a
hearing aid. Most of these people (290,000) are claiming DLA in age (ie their
claim has continued past their 65th birthday). For these people it is vital that
people who receive PIP continue to do so after they reach State Pension age,
and for as long as they continue to need support.

We recognize that DLA has exhibited a number of flaws, and that
improvements can be made to ensure that it reaches those people who need
it. However, we remain very concerned that the real driving force for reform is
one of cutting expenditure. The Minister for Disabled People has stated that
there is a target of saving 20% from the DLA bill by 20151, and it has been
estimated that disabled benefits claimants will lose £9 billion over the course
of this parliament2. In this climate, we are worried that the main aim of the
reform programme will be to restrict access to benefits and reduce the
numbers of people able to claim this important financial lifeline. It is our belief
that any reform of DLA should be objective and conducted without the
constraints of tough financial targets.

Reducing eligibility for extra-costs benefits will mean that people with hearing
loss are in danger of being hit disproportionately by the government’s wider
economic proposals. As well as facing cuts in benefits, they are also seeing
social care budgets being cut while facing the same austerity measures as
everyone else, including cuts to public services, the rise in VAT and the rising
costs of living. Set against this background, we believe that the proposals to
reform Disability Living Allowance will serve only to limit opportunity, choice
and control yet further. We urge the government to consider the impact of the
full programme of austerity measures on people with hearing loss and to take
these into full account when implementing reform.

The importance of DLA cannot be underestimated. Its unique value is in
providing disabled people with a degree of financial independence and the
ability to meet some of the extra costs that they incur in the course of their
daily lives. In reflecting this need, we welcome the focus of the proposed
Personal Independence Payment (PIP) on participation and assessing the
impact of disability on an individual.

We are concerned that the consultation document claims that DLA can act as
a ‘barrier’ to work – when in fact the main reason that DLA claimants do not
move into work appears to be a lack of accurate information about eligibility,
rather than the benefit itself3. Indeed, there is evidence that people who are
in work are less likely to claim DLA because they are unaware that it is not
means-tested.


Question 1. What are the problems or barriers that prevent disabled
people participating in society and leading independent, full and active
lives?

For people with hearing loss, the greatest barrier to participation is that of
communication and overcoming the barriers that they face managing
everyday interactions without assistance. Effective communication is
fundamental to effective participation, and we believe that this fact should be
recognised explicitly within the new benefit.



1
  http://ablemagazine.co.uk/exclusive-interview-maria-miller-mp-on-the-dla-consultation/
2
  Wood, C. & E. Grant (2010). Destination Unknown. London. Demos
3
  Thomas, A. & R.Griffiths (2010). Disability Living Allowance and work: Exploratory research
and evidence review. London, DWP.
One of the major barriers to participation faced is that of poverty. Around a
third of all disabled adults aged 25 to retirement are living in low-income
households. This is twice the rate of that for non-disabled adults, as it has
been throughout the last decade4.

Without the financial capacity to meet the costs of daily life, people with
hearing loss are unable to take advantage of many of the opportunities that
non-disabled people take for granted. DLA plays a significant role in enabling
disabled people to participate in social life, allowing them to meet costs such
as paying for assistance in communication, for taxis where public transport is
inaccessible or unavailable and for small aids and adaptations or the informal
care and support that make everyday life easier.



Question 2. Is there anything else about DLA that should remain the
same?

We welcome the announcement that PIP will remain as a cash benefit
allowing disabled people to meet the extra costs they face in the way that they
choose. We agree that PIP should not be means-tested or taxable and will
continue to be available to people irrespective of their employment status.

There are a number of further features of DLA that we believe must be carried
over into PIP, the main of which is the ability of the disabled person to make a
claim from closer to the onset of their condition or impairment, rather than
waiting for six months before becoming eligible. The onset of disability is a
time of great change for people, and when the need to be able to meet the
costs of adaptations and support is at a premium. Without the financial help
that DLA provides, some disabled people might find themselves incurring
debts in order to meet the challenges of their new lives. We believe that the
government could meet their intention to bring the eligibility criteria into line
with the legal definition of disability without changing the three month
qualification period for the benefit.

The news that PIP will not be means-tested is welcome, as is the fact that it
will continue to be available for people in work (and will not form a part of
calculations for Universal Credit). We also welcome the confirmation that
people claiming PIP will not be subject to the cap on household benefit
income.

The government claims that DLA is ‘not fit for purpose’ – that it is too complex,
misunderstood, poorly administered and not targeted efficiently. It also claims
that DLA ‘can act as a barrier to work’ as unemployed people receiving the
benefit may not know that they can keep the money after they move into paid
employment. While this may be true for some, there are also people with



4
    Households below average income, August 2010, DWP.
hearing loss who are in work who are unaware that they may be eligible for
DLA5, so that work may equally be seen as a barrier to the benefit.

While some of these claims are undoubtedly true – particularly regarding
complexity, our own research6 shows that misunderstandings and
maladministration lead to fewer people with hearing loss receiving the benefit
than are actually entitled to it. One of the major problems with DLA has been
the way it has been administered and delivered. RNID’s own research has
shown that amongst deaf people who had a claim for DLA rejected and who
decided to appeal this decision at a Tribunal, fully 85% had the rejection
overturned.

The fact that PIP will be based on an assessment of the impact of disability on
an individual’s life is likely to result in varying awards for people with identical
or similar impairments. This may result in confusion over eligibility, and may
serve to raise the number of appeals if inconsistencies are perceived to have
occurred. It is vital therefore that claimants are given comprehensive
information about both the assessment and the appeals process.

It is important that older people who claim PIP before State Pension age
continue to receive the benefit in full after this time, so long as they remain
eligible. We also believe that the upper age limit for new claims for PIP
should rise in line with State Pension age once it has equalized for men and
women in 2018.


Question 3. What are the main extra costs that disabled people face?

The extra costs faced by disabled people are not necessarily limited to areas
of daily life directly affected by disability, and each individual’s costs will
depend upon their own personal circumstances.

While many people do use their DLA for paying for formal care services, or for
paying to get out and about where public transport systems are inaccessible
or inadequate, we also know that people who are deaf or hard of hearing do
use their money for communication support in specific circumstances, even
though the actual costs of communication support are far higher than DLA
rates. In this way, DLA has always been understood as a form of individual
budget that people can spend as they see fit, often using it to pay for informal
care and support where formal provision proves beyond their means.



Question 4. The new benefit will have two rates for each component:




5
    Who benefits? http://www.rnid.org.uk/VirtualContent/84924/3676_Research_Report.pdf
6
    Who benefits? Ibid.
      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?

There is no reason to believe that having two components with four rates
across PIP will make any real difference in terms of administration or
comprehension. What is important is that the benefit is administered
efficiently and fairly, and that claims are dealt with in a transparent and swift
manner.

The consultation document states that the new mobility component will re-
focus on an individual’s ability to ‘get around’, a broader definition than
currently exists under DLA. Some people with hearing loss currently receive
lower-rate DLA mobility because of the difficulties they face in navigating in
unfamiliar places and the difficulties of communicating effectively enough to
gain assistance from others, and we believe that the support that these
people require should continue to be recognized under PIP regulations.

The ‘key activities’ component will prioritize those people deemed to have the
greatest barriers (and thereby the highest costs) to independence. We note
that unlike DLA, interaction with other people is seen as one of the key
activities that may be included.

Being able to interact and communicate effectively with other people is
fundamental to social inclusion, and is a specific barrier for people with
hearing loss. For this reason, we would like to see communication included
within PIP as a separate component aside from daily living and mobility that
would better capture the needs of those people for whom this represents the
greatest barrier to participation.


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?

There would be few cases where entitlement would be automatic, but there
could be many where, following an initial assessment, claimants can be given
a lifetime award on the basis that their disability is of such severity that their
needs are unlikely to change or is likely to deteriorate.

If one of the principles of reform is greater financial efficiency, then repeated
and unnecessary assessments should be avoided as wasteful. For example,
profoundly deaf users of British Sign Language are always likely to need to
access specialist support in order to be able to communicate effectively with
other people.
Question 6. How do we prioritize support to those people least able to
live full and active lives? Which activities are most essential for
everyday life?

One of the fundamental activities essential for everyday life is that of effective
communication, something that poses a significant barrier to people with
hearing loss, and can lead to reduced opportunity to participate in everyday
life.

There is no direct correlation between those people with greater need and
specific impairments or conditions. For example, a person who uses British
Sign Language (BSL) may be able to mobilize effectively, but would need to
pay for communication support in order to have even the most basic
conversation, a fundamental element of many social interactions, and we
reiterate our call to have Communication recognized as a separate
component of the new benefit.

Any new assessment must seek to take full account of the situation in which
an individual may need the support that DLA has traditionally been used to
access. The question as to which activities are ‘most essential’ is somewhat
misguided, as they will depend entirely on individual circumstances, and
individual priorities may change with time.

There are also dangers if question of prioritization is allowed to dominate the
new benefit. In social care, prioritization has led to the restriction of provision
to only the very needy. The danger of concentrating on those with the
greatest need is to leave a large number of people still experiencing high
levels of unmet need.


Question 7. How can we ensure that the new assessment appropriately
takes account of variable and fluctuating conditions?

Considering the needs of people with Menières Disease, a fluctuating and
often degenerative condition that can remain dormant for months at a time,
we recognize that while they do not provide a detailed picture of an
individual’s needs, the increased use of existing medical records would be
able to evidence the longevity and severity of any condition. Even if the
person is not continuously affected by specific symptoms, both the social
model of disability and equalities legislation allows that they are treated as
disabled for the duration of the condition.

Proving that a disability or health condition is enduring does bring PIP in line
with the existing legal definition of disability in the Equalities Act 2010.
However, the proposal that people will have to wait for six months (and be
able to prove that they are expected to remain disabled for a further six) does
not. The Equality Act states that a disability “is likely” to last for twelve
months, whereas the proposals for PIP state that it must be “expected” to last
for that time. In the interests of consistency, we believe that the wording in
the new benefit should mirror exactly that of the Equality Act.
The proposal to extend the qualifying period to six months could see people
lose out on a potential source of income at the time they may need it the
most. Being able to claim PIP from an earlier point would allow claimants to
use the money to help meet the costs they incur when adapting to disability,
and may actually serve to lessen the immediate impact of becoming disabled
and bring about medium- and long-term health benefits. We believe that the
current three-month period should be retained.


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?

The use of aids and adaptations already forms part of the current assessment
for DLA. However, the presence of an aid does not determine its usefulness,
and may actually itself be a barrier to participation. It would be mistaken to
assume that the availability of adaptations should be confused with their
function. RNID knows that while there are four million people in the UK with
hearing aids, in many situations their usefulness is compromised by the fact
that the loop systems designed to improve communication for people with
hearing aids in public areas are often poorly maintained or unused.

In such cases, existing and previous legislation designed to promote inclusion
and equality has proved to be a poor tool at effecting widespread change, and
legislative remedies are often financially inaccessible to disabled people. We
believe, therefore, that the benefits system should not be based on the
assumption that any individual adaptation or intervention can be assumed to
be a practical aid to participation.

Taking account of hearing aids already occurs within DLA, but the proposals
suggest that PIP will take more explicit note of the effects of adaptations. For
instance, the use of assistance animals, such as hearing dogs is likely to be
factored into decisions regarding eligibility. We do not believe that the use of
support workers, including BSL interpreters, speech-to-text operators or
lipspeakers should count as adaptation under PIP rules, as their presence
and effect are not constantly available, and may incur significant cost to the
individual.

We do not believe that it would be appropriate to take account to be taken of
aids or adaptations that are available but that an individual does not have
access to or use. Some people with hearing loss also live with tinnitus, a
condition that can be amplified by hearing aid use, preventing them from
using them. Likewise, the availability of medical procedures on the National
Health Service should not mean that an individual who refuses to undergo a
voluntary procedure (such as a Cochlear Implant) should not be penalized for
doing so.


Question 9. How could we improve the process of applying for the
benefits 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?


There is a clear and obvious need to improve the process of claiming. RNID
research7 shows that 74% of claimants with hearing loss found it hard to
complete. 63% said that they found it difficult to explain their needs, 47% that
it wasn’t clear what information was needed and 39% (rising to 56% of British
Sign Language users) said they could not understand some of the questions.

Various iterations of the DLA claim form have been introduced over the years,
with little effect. The problem has always been designing a form that can be
completed easily and accurately by people with a wide range of disabilities. It
would be more effective of claimants were allowed to submit a range of
independent medical evidence along with their form rather than be forced to
rely on self-description. The form must be flexible enough to ensure that
claimants have the ability to express the impact of disability on their lives, and
should include clear indications of the sort of evidence required. For those
people who use British Sign Language, clear guidance must be provided in
that format, and plain English should be used at all times.

We believe that a claim for PIP should not be denied on the basis of the
contents of the claim form alone. The combination of evidence provided both
on the form and from independent medical sources should be the basis for
any subsequent face-to-face assessment and decision.

Better information would include ensuring that people are aware that PIP is
not means-tested and that people who are in work or who have savings are
not excluded from it. This would serve to end the misperceptions currently
surrounding DLA and work.

In terms of the method of claiming, there is a continued need to have
electronic and paper versions. Not all people have access to or can use a
computer, and many people with hearing loss will be unable to use the
telephone to make a claim. For these reasons, properly maintained
alternative forms of communication must be provided by JCP. Furthermore, it
will also be the case that some deaf people will require the assistance of a
third party, often a JCP member of staff, to complete their application. Such
assistance should never be denied.

7
    Who benefits? Ibid.
The government also has a role to play in promoting more positive exposure
of the benefits system and disabled people rather than the concentration on
fraud and abuses of the system that have stigmatized both the benefits
system and claimants over recent years.


Question 10. What supporting evidence will help provide a clear
assessment of ability and who is best placed to provide this?

There are a variety of sources of evidence that should be drawn in to provide
the necessary assessment. For people with hearing loss, audiologists can
give an expert opinion of an individual’s degree of hearing loss and the
likelihood of the longevity of the condition, however they will not be in a
position to judge the effect that hearing loss has upon the individual in daily
life, something that will depend on a combination of factors unique to each
claimant. An individual’s clinical ability to hear is not always an indicator of
their ability to communicate effectively without support, and the individual
him/herself must continue to have a role to play in contributing to their own
assessment.

Some people with hearing loss will have contact with social workers or
occupational health workers who may also be able to provide relevant
supporting information. However, even these people could not necessarily
comment on an individual’s capacity for communicating effectively with
strangers. The fact remains that a fine balance has to be struck between an
overly-medicalized model based solely on clinical diagnosis and prognosis
and a reliance on inexpert assessments. RNID would be happy to work with
the government to help develop an evidence-based assessment that fully
accounts for the needs of people with hearing loss.

We do believe that in some cases, the thorough use of independent evidence
can be used as the basis for eligibility without the need for a face-to-face
interview, especially at the review stage. If someone’s condition is such that
they continue to meet existing qualifying criteria, any subsequent assessment
would represent needless expenditure.


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?

Firstly, it is vital that all people with hearing loss who state that they need
specific communication support in order to participate in a face-to-face
assessment should not be expected to participate unless this support is made
available to them. We also believe that anyone assessing the eligibility of a
person with hearing loss should have received deaf awareness training.

We believe that the use of face-to-face interviews conducted by healthcare
professionals should not form the sole basis for decisions on eligibility, and
that evidence gained from them is considered equally alongside evidence
from other sources. There is a danger that a medical-based assessment may
reflect many of the problems that have been encountered with the current
Work Capability Assessment, and result in poor decision-making and
unnecessary appeals.

Any development of a medical assessment must learn the lessons from the
Work Capability Assessment, and undertake to incorporate the
recommendations made by Professor Malcolm Harrington in his report of the
first independent review of the WCA.

His recommendations included;

      That people receive a copy of their assessment immediately
      That the assessment is not overly tick-box based and includes free text
       boxes including the reasons behind the assessor’s final decision
      That less influence be held by the medical assessment, and that more
       power be granted to the DWP decision-maker who has access to a
       wider range of evidence
      That the results of appeals tribunals’ decisions and their reasons are
       fed back into the system to ensure that there is more of a learning
       culture at the heart of the decision-making process.

Where the medical evidence is overwhelming, we do not believe that repeated
face-to-face interviews are always necessary. Where they do occur, we would
like to se a more holistic approach to the assessment than a purely medical
investigation. It is vital that any face-to-face assessment must consider
relevant social, cultural and economic factors as well as an individual’s
condition. As before, RNID would welcome the opportunity to work with the
government to develop an appropriate assessment tool.


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?

The frequency of reviews should be based on the likelihood of a condition or
its disabling effects changing within a reasonable period of time. There is a
case for time-limited awards in some cases, and this practice has increased
significantly over recent years within the DLA programme. However, unless
there is clear evidence to suggest that an individual’s circumstances will
change markedly within a specified time, any periodic reassessment based on
time-limited awards would be likely to prove unnecessary.

For those people with degenerative conditions, the periodic collection of
medical evidence could obviate the need for repeated face-to-face
assessments and trigger changes to their entitlement as their levels of
disability are likely to increase.

The notion of a customized approach to assessment has some appeal, but
the basic elements of any system must allow for the capture of as broad an
evidence base as possible. It would not be in the interests of either the
claimant or the assessment process if the latter was to miss out on any
evidence that would support their claim. Similarly, we believe that an
assessment that is based solely on a clinical appreciation of an individual’s
impairment would be less capable of identifying the full range of their needs.


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?

One of the most significant barriers to effective communication between
individual claimants with hearing loss and the Department is the over-reliance
on telephony or the internet. For those people who cannot use or access
these means of communication, alternative means must be available on
demand. For people who are deaf or hard of hearing, the use of textphones
or telephone relay services can be useful, while for others, being able to
inform an official in person would be favourable.

A more comprehensive assessment that might take the issue of adaptation
into account might also make it more difficult for the individual to assess
themselves, and for people with conditions that are degenerative or fluctuating
in nature, the changes can be almost imperceptible or temporary. We believe
that the Department needs to provide greater clarity as to what is expected of
the individual in terms of providing information.


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?

People applying for and receiving PIP will need various types of advice and
information throughout their claim. For many, clear information about the sort
of evidence to include, how eligibility is assessed and decisions are made are
vital. Further information that should be provided as part of the initial claim
includes eligibility for other benefits, advice about sources of practical support
and help for people managing their disability.
Advice and guidance about challenging decisions and how to access legal
support would also be useful to claimants. As mentioned under point 11, we
would also believe that the individual claimant should be given a copy of their
assessment in order to allow them to understand the process and the decision
better.


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?

Signposting people to appropriate support whereby they may be better able to
manage their condition or access help is a laudable aim, and one that may
bring benefits to many claimants. However, we are concerned that it should
not be made a ‘requirement’ of the benefit that people take up such offers.
Conditionality has never been seen as appropriate for extra-costs benefits,
and we would resist the introduction of any requirements that people would be
expected to undertake. We would also be concerned if claimants were being
directed to support in the expectation that this would reduce the likelihood of
their being eligible for PIP.


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?

The majority of hearing aid users receive their aids through the NHS, though a
sizeable minority prefer to use private services. Further aids and adaptations,
such as visible smoke or door alarms, amplified telephones or textphones,
can be supplied by social serviced departments, but are more likely to be
purchased privately. DLA can be of significant assistance in enabling these
purchases.

Even purchasing a large item of equipment does not necessarily constitute a
one-off cost, as the equipment will often entail ongoing expenditure for
maintenance, repair and replacement. Even the most basic equipment may
require that batteries are replaced regularly. Also, as technology evolves or a
person’s condition or conditions change, existing equipment may need
replacing or adapting.

As mentioned in our response to question 8, the existence of an aid or
adaptation does not indicate its usefulness, and a one-off payment would not
necessarily make a real or long-term difference to a claimant’s ability to
participate in society.
Question 17. What are the key differences that we should take into
account when assessing children?

RNID believes that face to face assessments are completely inappropriate for
children, and should not be considered for this group. Face to face
assessments can be very stressful and are likely to harm the self esteem of
children who may not yet have come to terms with having a disability and may
feel very uncomfortable in this situation.

It is also unrealistic to expect most children to present accurate information on
the impact of their disability to a professional assessing their eligibility for
benefit. Children may present contradictory or incorrect information, and may
not be able to understand the reasons for the questions they are being asked.

We know from the National Deaf Children’s Society that in assessment
situations, deaf children are often accompanied by a familiar adult who may
provide informal communication support consisting of specific signs and
gestures. This can give the professional carrying out the assessment an
unrealistic view of the child or young person’s ability to communication in
unfamiliar situations with strangers. For these reasons, we believe that an
assessment based on both personal and objective evidence should suffice for
children.

If young people are to be assessed in this way, the correct communication
support must be provided for those who require it, just as for adults. If
communication support has been requested and is not provided, the
assessment should not go ahead. The healthcare professional should have
deaf awareness training and should be aware and take note of any informal
communication support anyone accompanying the young person may be
giving.


Question 18. How important or useful has DLA been at getting disabled
people access to other services or entitlements? Are there things we
can do to improve these passporting arrangements?

We support the aim of continuing the passporting claimants to other benefits.
PIP being a benefit that is designed to increase an individual’s social
participation, passporting allows for an individual to receive the full range of
available support without the need to undergo a series of differing eligibility
tests for related qualifying schemes. It is vital that DWP works with local
authorities to ensure that current passporting arrangements continue. It is
hoped that the proposals for a more unified benefits system in Universal
Credit will allow for more automatic passporting from PIP

Many people will use DLA payments to supplement inadequate social care
provision, and with eligibility criteria for social care becoming increasingly
tight, more and more people claiming disability benefits will not be receiving
social care or support. It would be a grave error to consider that receipt of
both social care and PIP would constitute any form of double-funding.


Question 19. What would be the implications for disabled people and
service providers if it was not possible for Personal Independence
Payment to be used as a passport to other benefits and services?

RNID can see no good reason for passporting to related benefits to be
discontinued. Should this happen, then it would be likely that some people
would miss out on benefits that they would be entitled to, possibly leading to a
lower quality of life and decreased social participation. We believe that every
effort must be made to ensure that claimants receive the full allowance of
state benefits to which they are entitled.


Question 20. What different assessments for disability benefits or
services could be combined and what information about the disabled
person could be shared to minimize bureaucracy and duplication?

We do not believe that it is appropriate to combine assessments for different
disability benefits or services, particularly where those benefits and services
are deigned to meet different needs or are operated by different agencies.

This is not to say that information collected during the assessment of an
individual for one benefit or service should not be used in a subsequent and
different assessment as supporting evidence, though we disagree with the
increasing practice of information collected in one assessment being sued to
trigger a reassessment for a different benefit or service.

We are particularly concerned that PIP assessments should remain wholly
separate from assessments for social care. The qualifying criteria for the
latter have been set so high by some local authorities as to restrict access to
all but the most critical cases. DLA or PIP should exist to ensure that those
people who do not qualify for social care support still receive some form of
income to meet their extra needs.


Question 21. What impact could our proposals have on the different
equality groups, and what else should be considered in developing the
policy?

There will be an obvious impact upon all disabled people, especially those
who may qualify for DLA but who will, or would, not qualify for PIP. If current
claimants are asked to undergo a reassessment under a stricter regime, then
there will be an obvious financial effect upon those found ineligible. This will
also lead to a loss of choice and control over their lives and further reduced
opportunities for meaningful social participation.
Unless the qualification rules for PIP rise alongside the State Pension age,
older people who are still in work could also lose out as there is no mobility
component in Attendance Allowance, placing older disabled workers at a
relative disadvantage.


Question 22. Is there anything else you would like to tell us about the
proposals in this public consultation?

The proposals outlined in this consultation prepare the way for a radical
overhaul of disability benefits, and much of the detail will only become clear
after this consultation has ended. We would advise, therefore, that the
government sets out a clear agenda and timetable for change and continues
to consult with key stakeholders to ensure that their reforms are fair and take
into account the full range of needs of people with hearing loss. To this end,
RNID would welcome the opportunity to continue this dialogue.



Please contact

Dr. Mark Baker
Head of Social Research and Policy
RNID
19-23 Featherstone Street
London
EC1Y 8SL