Promoting Opportunity and Realising Potential by dfhercbml


									                       BASE Response to “No-one Written Off”


   1. The British Association for Supported Employment (BASE) is the national
      trade association representing over 200 organisations that provide specialist
      supported employment services to disabled jobseekers and employers. BASE
      was formed in 2006 through the merger of the Association for Supported
      Employment (AfSE), representing specialist supported employment provision,
      and the National Association of Supported Employment (NASE) representing
      supported factories and businesses.

   2. The customers that BASE represents are those considered to be furthest
      away from the labour market and who require specialist support services to
      help them to find and keep work. This includes people with learning
      disabilities, autism, Asperger‟s syndrome, and people with severe physical
      and/or sensory impairments. Although employment levels among these
      groups have increased slightly over the last decade, they remain
      disappointingly low, with some groups experiencing over 90% unemployment.

   3. BASE view this submission, and previous responses to DWP, as an
      opportunity to engage in dialogue towards the national modernisation agenda
      and in enabling significantly greater numbers of their customers to access and
      hold onto paid jobs.

   4. BASE has previously responded to the DWP Commissioning Strategy Interim
      Report, and the proposed changes to the WORKSTEP programme contained
      in the consultation document „Improving Specialist Disability Employment

   5. BASE is a company registered in England. Registration No. 05794990

   Promoting Opportunity and Realising Potential

   6. BASE welcomes the principles behind No-one written off. We welcome the
      commitment to promote opportunities for all as an evidence-based approach
      to tackling poverty and ill-health. A fundamental concept of Supported
      Employment is that all persons have the capacity to work if appropriate and
      ongoing support can be provided.

   7. However, we see no evidence that these proposals will support the most
      severely disabled people into employment. There is considerable concern that
      the people placed in the Support Group will, in fact, be written off! Indeed the
      80% target rate reinforces this view.

No-one Written Off – BASE response (Oct 2008)                                       1
                       BASE Response to “No-one Written Off”

   8. We think the aspirational aim to deliver the vision of equality for disabled
      people by 2025 is inadequate. Further, we believe it reinforces the notion of
      20% of the population being written off.

   9. BASE has concerns about how people with disabilities access the system to
      claim benefits and we believe that 28 weeks is too long before a capability
      assessment is carried out. We are aware of jobcentre staff actively
      discouraging requests for face to face interviews and believe that a reliance
      on telephone claims will impact unfairly, particularly at 40p per minute when
      using a mobile phone.

   10. We appreciate that the creation of the Support Group is intended to be
       supportive and note that they will be entitled to access vocational support on a
       voluntary basis. However, placing people in the Support Group will lower the
       expectation of the individual and society and not address the historically low
       employment rates for particular groups of disabled customers.

   11. Whilst accepting that people placed in the Support Group may volunteer to
       take part in job-seeking activity, we believe that the most significant barrier
       towards supporting these people into employment is the funding of the
       appropriate support. We see no evidence in the Green Paper that this issue
       will be resolved.

   12. We know that despite the range of Jobcentre Plus funded programmes, only
       25% or so of those people with mental health needs are in work. The rates fall
       substantially for people with more enduring mental health needs or with
       learning disabilities. We know that people want to work but are unable to find
       the support that they require to make this a reality.

   13. The Government, rightly, wishes to develop a personalised approach to
       supporting people back to work. No-one Written Off acknowledges the
       benefits of using personalised action plans, having a focus on job outcomes,
       practical jobsearch support and preparing people so that they present
       themselves well to employers. These are all integral parts of the Supported
       Employment approach that has been implemented across the world for many
       years. Indeed, we think the Green Paper fails to address two further critical
       components of Supported Employment; ongoing support to both employer
       and employee and the recognition that interviews have rarely been a
       successful means to recruitment for people with significant disabilities.

   14. BASE believes that the “Place and train” model is significantly more effective
       at ensuring that certain groups of people, for example, people with a learning
       disability, move from dependency on health and day services to sustainable
       employment. This model is not funded and not referenced in these proposals.
       Neither is much consideration made as to how to improve the work focus on

No-one Written Off – BASE response (Oct 2008)                                            2
                       BASE Response to “No-one Written Off”

       health and social care services that have a major role in raising individual
       aspiration and motivation.

   An Obligation to Work

   15. BASE accepts the notion of rights and responsibilities that drives recent and
       proposed welfare reforms. We believe that it is reasonable to expect people to
       seek to improve their skills and return to employment.

   16. We have some concerns about how the work capability assessments will be
       undertaken and would question how realistic it is to review the work capability
       of 2.5 million existing claimants over three years.

   17. BASE believes that the blanket use of sanctions and conditionality is
       inappropriate. Specific concern exists for people who experience severe and
       fluctuating mental health issues. We believe people in this group will require
       the support of appropriate specialist subcontractors with suitable levels of
       funding and the ability to move into the support group element quickly where
       their health condition deteriorates.

   18. Sanctions often disproportionately impact on the most vulnerable. It is not
       uncommon for individuals with severe mental health problems to be unable to
       go out or open their mail and it will be vital that adequate safeguards are put
       in place to protect people on the margins.

   19. We remain concerned about whether contracted medical assessors have
       sufficient awareness of mental health needs and specific conditions such as
       Aspergers Syndrome. People tend to want to present themselves as capable
       and wanting to work but this enthusiasm could set them up to fail if
       personalised support is not made available.

   Benefit simplification

   20. BASE wholeheartedly supports the notion of benefit simplification. BASE is
       persuaded by the case for a single benefit with additional payments for those
       who have a disability, whether in work or not.

   21. We welcome the proposal to withdraw Income Support and a phased transfer
       to ESA. As stated, we have concerns about how this will work in practice over
       such a short timescale. We have doubts as to whether the capacity is there to
       complete this over such a short period. A target-driven rush to review
       claimants will inevitably lead to mistakes and unnecessary trauma for
       particular individuals.

No-one Written Off – BASE response (Oct 2008)                                           3
                       BASE Response to “No-one Written Off”

   22. We regret that the opportunity to simplify the Permitted Work rules has not
       been taken. The current rules are confusing and very few advisors have a
       clear idea of how they work. The current lower limit of £20 per week leads to
       constant confusion as the minimum wage is uprated each year and employers
       are increasingly reluctant to employ people for just a couple of hours each
       week. The proposed rules waste an opportunity to streamline the regulations
       in order to support people who are seeking to re-enter employment, using
       permitted work either as a stepping stone or as a longer term measure to
       support their limited capacity to work.

   23. BASE believes that the rates should be the same for those on contributory or
       means-tested benefits and that the lower limit should be changed to allow
       people to work up to 8 hours per week at the national minimum wage. This
       measure would receive widespread support and allow people who have a
       limited capacity to work to be able to contribute to society through
       employment. We urge the Government to revisit this.

   No-One Written Off

   24. We welcome a review of how best to support people with significant
       disabilities back into the workplace. BASE contributed extensively to the
       recent review of specialist disability services and regrets that a response has
       still not been forthcoming despite the consultation closing nearly seven
       months ago.

   25. We believe that severely disabled people are not being supported back to
       work in any significant numbers by Pathways to Work. The programme simply
       does not offer support that is intensive enough or lasts long enough. The
       programme effectively encourages a cherry-picking approach by providers so
       that they can maximise income.

   26. Many of those seeking to work are currently trapped within health and social
       care services, whose staff know little about employment issues and are ill-
       equipped to answer a customer‟s questions about returning to work. Various
       Department of Health initiatives have sought to improve employment
       outcomes but these have had little impact on mainstream provision. BASE
       has been asking for one accountable lead for employment issues and we
       believe this should be DWP.

   27. BASE believes that there are many people who are further from the jobs
       market who wish to work but who are not supported to do so and we see no
       evidence that this is likely to change as a result of No-one Written Off. We see
       no evidence of inspiration being taken from welfare systems in other countries
       with regards to specialist disability employment provision and would urge the

No-one Written Off – BASE response (Oct 2008)                                            4
                       BASE Response to “No-one Written Off”

       Government to consider the approach taken in Australia where services are
       directly contracted between Government agencies and specialist providers.

   28. The DWP Commissioning strategy is not working to support those furthest
       from employment and we would challenge strongly the statement that money
       saved has been reinvested for those most severely disabled.

   29. Our experience of the Prime Contracting market demonstrates that there is a
       significant risk of losing the specialist expertise that is necessary to provide
       the choice and expertise for severely disabled people. We have responded
       previously to consultations on the DWP Commissioning Strategy and we
       remain firmly opposed to the use of supply chains covering large geographical
       areas as a model for supporting people with significant disabilities back to
       work. We do not believe that the Code of Conduct is adequate or enforceable
       and we regret that such a poor impact needs assessment was approved.

   30. We welcome the increase to Access to Work funding by 2014 however we do
       not feel that this necessarily address the needs of those severely disabled
       people furthest from the jobs market. We would welcome further discussions
       with DWP on how Access to Work might be developed and would suggest
       that elements of it be made available to support the purchase of specialist
       equipment and other support needed during pre-employment activity, for
       example, work experience placements, where this is likely to increase
       employment outcomes.

   31. We recognise that Access to Work may be very valuable used in delivering
       specific support that may assist a person to retain their job should they
       become ill or disabled. However, we also recognise that many people will
       require more complex assistance to retain their employment and this can be
       provided via the Workstep programme.

   32. We support the main recommendations in Working for a Healthier Tomorrow.
       There is an urgent need to invest in job retention support and we would
       recommend a thorough overhaul of occupational health services, many of
       which are risk averse and work in direct opposition to the best interests of
       disabled employees and jobseekers. We would support any moves to refocus
       GPs on supporting people to retain their employment and believe that
       employment resources within health centres can do much to improve
       retention rates as long as they deliver a practical service to employers and
       customers rather than just offering advice or signposting.

   33. We note that the proposed Fit for Work service may target people who have
       not worked as well as those at risk of losing their jobs. We are therefore
       concerned that the proposed service may duplicate the work already
       undertaken by specialist disability providers and cause additional

No-one Written Off – BASE response (Oct 2008)                                        5
                       BASE Response to “No-one Written Off”

   34. BASE believes that all innovation and sharing of good practice should be
       encouraged. However, it does not believe that the “Right to Bid” model will
       deliver this. We believe that a personalised service with appropriate outcome-
       based funding will deliver more sustainable benefits.

   35. Many people face a long journey towards employment. We welcome the
       bringing together of skills and employment issues and recent flexibilities on
       Train to Gain may certainly have a positive impact. For many people, what is
       needed is a pathway that is funded more flexibly and for a longer duration. It
       will be important to measure individual progress to measure provider
       performance. BASE recommends that any system recognise that definitions
       of outcomes need to be broadened to incorporate distance travelled and
       include targets that demonstrate significant milestones for the user group. A
       one size fits all approach won‟t work.

   Empowerment and Devolution

   36. We welcome the principle of personalisation but are concerned about how this
       could be implemented in practice. We are not aware of any significant
       demand from customers for individualised budgets within the employment
       sector. Supported Employment, by its nature, is a personalised approach and
       our fear is that individual payments will lead to untrained and unsupervised
       workers concentrating their efforts on a limited number of employers. This will
       appear anarchic to employers and will do little to significantly improve
       employment rates.

   37. BASE would support a closer tie between local areas and welfare to work
       services. The use of Multi Area Agreements offers an opportunity to tailor
       services to local need, offer local accountability and lead to more coherent
       provision. We would support the notion of reinvesting from savings made and
       involving local authorities in procuring these services.

   38. Any far reaching proposals will require a coherent strategy for the
       engagement of employers. BASE recognises the employer need for
       coordination but believes that Local Employer Partnerships are fundamentally
       flawed and can be seen to disadvantage existing partnerships between
       employers and specialist providers. They give precisely the wrong message to
       human resource personnel by promoting an insistence on prevocational
       training and suggesting that guaranteed interviews are the way forward.

   39. The LEP model constrains flexibility and squeezes out people with significant
       disabilities by encouraging cherry picking. We have direct evidence of the
       detrimental effects of LEPs on disabled jobseekers.

No-one Written Off – BASE response (Oct 2008)                                           6
                       BASE Response to “No-one Written Off”

   40. We believe that much more needs to be done to encourage the public sector
       to offer employment and training opportunities for people with significant
       disabilities. Recent work through PSA16 has led to a renewed focus in this
       area and guidance has yet again been made available to NGHS
       organisations. This will, unfortunately, have little effect until the workplace
       culture is changed and NHS management encourages disclosure of mental
       health problems. We urge DWP to liaise directly with the Department of
       Health on this issue.

   41. There have been some excellent examples of the public sector doing more to
       recruit and retain disabled employees and we would recommend the
       introduction of a requirement for the public sector to report their employment
       figures against the local population demographics and include figures on
       specific disabilities. Any good practice requirement for the public sector could
       be extended to procurement requirements and include supply chain suppliers
       having a workforce that also reflects local population demographics.

   42. BASE believes that Supported Businesses can play a useful role in offering
       an intermediate labour market and that this would be especially valuable for
       those people with the most significant barriers to employment. However, more
       needs to be done to encourage the purchase of their products and services by
       the public sector. Attempts to achieve this have so far been half-hearted at

No-one Written Off – BASE response (Oct 2008)                                            7

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