Re: DWP Public consultation on Disability Living Allowance reform: Response from the GYB Disability Forum

DLA Reform Team

1st Floor Caxton House

Tothill Street

London

SW1H 9NA

Re: DWP Public consultation on Disability Living Allowance reform:

Response from the GYB Disability Forum

This letter represents the collective response of the Great Yarmouth Borough Disability Forum, a Forum that supports and advocates for people with disabilities as defined by the social model of disability. The Forum aims to ensure the values, opinions and concerns of disabled people living in the Great Yarmouth Borough area are heard and taken into account to influence all policy making, commissioning of services and service provision.

The Forum holds bi-monthly open meetings, and at the last meeting held on 8th February 2011 at Christ Church, the Forum hosted the DWP Disability Living Allowance Reform Consultation. Over 70 people attended the meeting representing individual members, carers, statutory bodies and voluntary and community groups which offer services to, and work with people with disabilities (see Appendix 1 attached). The meeting gave the members a chance to express their views and concerns on, and engage in discussions over the DWP’s reforms proposal.

The Forum has collated those views and by way of this letter, is responding to the consultation on behalf of its members, and all those who attended the meeting.

Question 1:

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

Communication, self confidence, transport, money, isolation, security, access/ facilities, equipment, lack of understanding, prejudice, understanding of disabilities, hearing loop, lack of supported living

When carrying out medical assessments, there needs to be a realisation that what an individual is able to do at that particular time could be variable from day to day: that there are good days and bad days.

Question 2

Is there anything else about Disability Living Allowance (DLA) that should stay the same?

Application process – keep self assessment which gives one the opportunity to have expert guidance from a healthcare professional, carer or advice centre.

2 components – care and mobility including entitlement to the Motability Scheme.

Question 3

What are the main extra costs that disabled people face?

Personal care, transport, home maintenance, additional heating, healthcare including aids and adaptations, and some medical appliances that are no longer supplied, communication equipment, social activities, maintenance of work and social networks, clothing as disabled people wear out things more quickly, and extra laundry cost. 

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?

Will the low rate care component be scrapped? If so will the level of eligibility come down on the middle rate?

Thousands of people will not be able to access the allowance because the lower rate will be lost and people will be lost.

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?

Yes such as paraplegia, multiple amputee, terminal illness, progressive and multiple illnesses.

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?

Ability to wash, dress, feed oneself, taking into account all elements of performing tasks i. e. environment and items to meet the needs above.

Activities covered under the Equality Act 2010, and social activities to eliminate isolation and exclusion.

Question 7

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

Record daily life in diary, and a periodic assessment by a carer or healthcare professional

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?

Just because they have adaptations, benefits should not stop as there are usually running costs involved in their maintenance. This errs to the medical model of disability as aids and adaptations only partly assist in achieving an active life.

Need more occupational therapists to speed up help.

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?

Ensure that the questions are clearer and easy to understand; no ambiguity.

Direct that it is mandatory for healthcare providers and statutory bodies to signpost help and guidance to relevant service providers.

Question 10

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

Carer input (Ability to speak and express self).

Support workers, other health professionals – relatives and friends.

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?

Disadvantage: They might not know us personally or understand our abilities or circumstances.

Benefit: the healthcare professionals should be experts in the condition they are assessing, having relevant and up-to-date information. This gives you the ability to express how you feel about your condition.

For people with visual impairment, severe mental health, and physical impairment it is very important to be visited in their own home – it is inappropriate to meet outside their homes.

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?

Why should some one come round and waste resources when the disability is permanent, if the condition is temporary then re assessments should be carried out.  Permanent conditions will not change if there is no cure, and the person will stay at that level.  Furthermore with age, the disability in some cases deteriorates further.

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?

Give precise guidance as to which changes need to be reported.

Introduce a fast track system so they can move back to claiming their benefits much more easily, such as the Linking Rule if conditions warrant it.

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?

Trained advisors or signposting to advisory groups/ organisations

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?

Access to high quality independent advice and support

More one to one advice for the minority of claimants - got to have someone trustworthy especially if the claimant has speech problems

Clear information to be given to people

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?

Pay for it yourself, by saving some of your DLA or from life savings, or go without. If working – an employer may pay, but many are not willing to do so or will not pay for all of it, therefore people use their DLA to pay for aids and adaptations in the work environment.

Yes we would like the option but not if that is the only option but each case should be assessed on an individual basis

We like the fact that DLA is a regular payment that helps us budget and we would not want to lose that.

Question 17

What are the key differences that we should take into account when assessing children?

Physical size

A baby will not have the same care requirement as, for example, a six year old

Medication requirements and effects

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?

It has been useful but there should be automatic linkages between DWP departments and other statutory bodies e. g. when on high rate mobility, an individual should automatically qualify for a blue badge without having to make a special application for it

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?

People would be ‘lost in the system’ and will therefore either miss out or be discouraged from applying. This could lead to people becoming more introverted and isolated which in turn can lead to depression that then becomes another disability, you then loose social skills which in turn makes the above more acute.

Question 20

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

One assessment for one benefit should NOT be used for another benefit

Question 21

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

Advice and guidance on keeping benefit when starting work. Better publicity on entitlement to include minorities

Question 22

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

§ Is it cost effective to do face to face assessments?

§ Regular re-assessment can be positive and negative

§ Expecting people to travel to assessment is unrealistic in all cases

§ Define independent health expert

§ Treat people as individuals not numbers

§ Explanations of the qualifying period i. e. 6 months back/ 6 months forward – how do individuals cope in the mean time

§ Can we suggest decision makers go on disability awareness training?

§ High rate mobility allowance could be increased to cover fuel and insurance

The Forum actively works towards giving a voice to people with disabilities and ensuring that our members’ voices are heard at strategic policy and decision making levels. We are happy to work with you now and in the future to ensure that the proposed changes carry as minimal an impact on our members and on all disabled persons as is possible, especially in this time of austerity.

Yours sincerely,

John Watt

Chairman - Great Yarmouth Borough Disability Forum

Appendix 1: List of Groups and Organisations represented at the meeting

1. Stonham Homestay

2. Great Yarmouth Borough Council

3. Suffolk LINk

4. Centre 81

5. Norfolk Carers Council

6. Great Yarmouth Voluntary Sector Partnership

7. Disability Rights Norfolk

8. Norfolk Coalition of Disabled People

9. DIAL Great Yarmouth (Disabled Information and Advice Line)

10. 55 Yarmouth Day Services

11. Marina Centre Physical Disability Swimming Club

12. Red Cross – Norfolk Coastal Centre for Independent Life

13. SVC Hellesdon Police Disability Forum

14. Carer’s Council Hellesdon Disability Forum

15. Visually Impaired Persons User Group

16. Families First GY – Job Centre Plus

17. 3percentplus

18. Parental carer

19. Family Carer

20. Opening Doors

21. Great Yarmouth & Waveney MS Society

22. Borough Councillor

23. Great Yarmouth Borough Disability Forum