On 12 March the Minister for Disabled People, Mark Harper, made a statement laying out the changes he is making to Access to Work. Our Access to Work special interest group responded in a letter.
Whilst we welcome your statement, we are disappointed you will not respond to the Work and Pensions Committee in full before the general election. Whilst you have clearly taken it on board, you have not addressed many of its recommendations.
We agree many of the changes you are making will improve Access to Work for deaf people, in particular the removal of the ’30 hour guidance’. We believe personal budgets will be transformative, providing people are given the right level of grant and the support they need to make it work for them. The sector will have a role in that and is happy to contribute.
We are also glad the service will become increasingly digital. And BSL users will be pleased to know they will soon be able to access it in their own language. We will appreciate confirmation that by ‘digital service’ you mean you will be working towards online accounts. They will make the administration of personal budgets easier for everyone.
We also welcome the fact you are now meeting service standards and would appreciate you sharing the KPIs and outcome data. We are still being told about invoices unpaid and grants not being awarded quickly, so it will be helpful to know what operational improvements have been made and how they are being measured.
Regarding self employment, we are glad you recognise its importance for some disabled people who have experienced significant barriers to employment. We welcome the introduction of a specialist team.
We will appreciate clarification of whether you intend to simply apply the Universal Credit rules or use them as the basis for Access to Work rules. In particular, owners of some very successful businesses as measured by turnover may not meet the specified level of personal income.
We are happy to identify a group of entrepreneurs to talk to your officials about the details.
Cap on awards
We are concerned you have chosen to introduce a cap on awards. As Dame Anne recently said, it is directly contrary to the conclusions and recommendations made by the Work and Pensions Committee. Even at one and a half times average salary it will have a negative impact on the employment of deaf people.
If instead of a cap you had introduced the need for a review when an award reached a certain level, we would have supported you. But a simple cap will require some employers to make an unreasonable adjustment, or alter or withdraw employment.
It therefore sends the message to employers that there is a legitimate limit on the worth and aspiration of disabled people. That will have a negative impact on a significant number of deaf people, especially those in senior positions and those with multiple or complex needs.
We understand your aim is to make sure more people benefit from Access to Work. We support that, but not by any means. Support for some should not be provided at the expense of limiting it for others.
We therefore want to know
- if you carried out an equality impact assessment;
- how many people you think this will affect;
- what you think the impact will be; and
- how you will measure the actual impact and use it to evaluate the policy.
Crown Commercial Service language services framework agreement
Regarding the Crown Commercial Service’s language services framework agreement, there is concern about the impact it could have on access to communication and language support if the specifications and terms are not drafted carefully. As you know, many of us have been working with the CCS to make sure that happens.
It could also have a negative impact if the tendering process is not conducted on a level playing field. The organisations that are steeped in and understand the communication and language market are SMEs run by people who have worked hard to develop a quality service. If they are squeezed out by the ability of large organisations without that understanding to undercut them, deaf people will receive an inferior service.
As with the Ministry of Justice framework agreement, awarding a contract based on the lowest bid is a false economy that creates more problems. We trust we have your support in making sure the tendering process values quality of service and cost of service at least equally.
If the DWP decides to issue a call off under the framework agreement, we are glad to know you will want to take the advice of deaf sector organisations. In particular, making sure only qualified and experienced professionals, preferably those registered with NRCPD, are used is of utmost importance.
There are some issues we identified in our vision for Access to Work that were not addressed by your statement. We will appreciate you confirming that
- requests for support at interview will be responded to within 24 hours;
- if their needs aren’t clear, applicants will be quickly granted an interim package of support when they start a new job;
- people receiving support from Access to Work will have a named first point of contact;
- there will be wide and ongoing consultation with people who receive Access to Work support, the professionals who provide that support, service providers, employers and organisations that work with and for disabled people; and
- if the government intends to review its legal responsibilities under the Equality Act and the UN Convention on the Rights of People with Disabilities with a view to making the scheme statutory.
With regard to the last point, we note your reference to the Disability Confident campaign. As you may know, many disabled people view it with scepticism. It is now five years after the introduction of the Equality Act and 20 years after the introduction of the Disability Discrimination Act. Yet the Government still has to resort to celebrating employers for simply meeting their legal obligations.
Deaf people are around 50 per cent more likely than hearing people to be unemployed. Include economically inactive people and that rises to 75 per cent. In 2015, we think that is simply unacceptable. We therefore ask you to commit to exploring what else needs to be done to make sure employers meet the equality duty. When they do, disabled people will have confidence in their willingness to make employment decisions based solely on expertise.