The Citizens Advice Cymru identifies poor administration of sanctions as their main concern with the Work Programme in Wales. They provide several case studies as examples where sanctions were applied even though claimants appeared to have "good cause" for missing appointments, such as conflicting appointments, mental or physical health issues, bereavement, learning disabilities or illness. The Citizens Advice Cymru recommends improved administration of sanctions and stronger safeguards to ensure sanctions are not inappropriately applied to vulnerable claimants.
Pediatric Dental Benefits Under the ACA - What Employers (and dentists) Need ...Spring Consulting Group
This document provides an overview of pediatric dental benefits under the Affordable Care Act and how they may impact dental practices. It discusses how pediatric dental coverage is considered an essential health benefit and must be included in certain health plans. It describes the three structures for how pediatric dental benefits can be offered (embedded, stand alone, bundled). It also outlines some pediatric dental plan benefit options and issues dental practices may face in navigating these new benefits, such as deciding whether to credential with dental insurance providers and how to manage claims processing.
What are the latest payment trends impacting the healthcare vertical? From electronic presentment and payment to mobile payments and beyond – what can we expect to see over the coming years?
This session focuses on Ed Health, a medical stop loss group captive consisting of 11 Boston-area colleges that Spring assisted in the development of. It details Ed Health’s success to date and lessons learned through the development and ongoing management of a medical stop loss group captive.
The document summarizes key provisions of the Affordable Care Act (ACA) or "health reform" and how it will impact Utah families and businesses. Some key points include:
- The ACA aims to expand access to affordable health insurance through state-run exchanges, subsidies, and Medicaid expansion while also containing costs and improving quality.
- It offers immediate benefits like preventing denial of coverage for pre-existing conditions and allowing young adults to stay on parents' plans until age 26.
- It provides tax credits to small businesses that offer employee coverage and establishes an online marketplace ("exchange") for individuals and small businesses to purchase plans.
- The goals of reform are to contain costs through measures like reducing waste and fraud
A document discusses the evolving role of captives within the changing healthcare environment. It notes rising healthcare costs and the growth of accountable care organizations (ACOs) and self-insurance. Captives are increasingly being used to manage ACO and employee healthcare risks. Case studies show how group captives can generate savings for employers by pooling stop-loss insurance and improving risk management. Forming a successful captive requires thorough planning and establishing sound fundamentals.
New CA Laws and Regulations Compliance Overview AlphaStaff
As of January 1, 2013, the state of California has added and amended myriad of new laws that affect employers in a number of important and significant ways. Please join us as we review each of these changes and help employers better understand the impact and importance of these changes to their businesses and employees in California. Presented by Human Resources Account Manager, Rebecca McDonough, CA-SPHR
This document summarizes key provisions of the recently passed US healthcare reform legislation. It outlines major changes occurring between 2010-2014, such as dependent coverage until age 26, elimination of lifetime limits, creation of health insurance exchanges in 2014, and employer penalties for not providing coverage. Administrative impacts are also discussed, such as increased workload from additional required notices and forms. Specific provisions like tax changes, Medicare discounts, and essential health benefits are reviewed.
Pediatric Dental Benefits Under the ACA - What Employers (and dentists) Need ...Spring Consulting Group
This document provides an overview of pediatric dental benefits under the Affordable Care Act and how they may impact dental practices. It discusses how pediatric dental coverage is considered an essential health benefit and must be included in certain health plans. It describes the three structures for how pediatric dental benefits can be offered (embedded, stand alone, bundled). It also outlines some pediatric dental plan benefit options and issues dental practices may face in navigating these new benefits, such as deciding whether to credential with dental insurance providers and how to manage claims processing.
What are the latest payment trends impacting the healthcare vertical? From electronic presentment and payment to mobile payments and beyond – what can we expect to see over the coming years?
This session focuses on Ed Health, a medical stop loss group captive consisting of 11 Boston-area colleges that Spring assisted in the development of. It details Ed Health’s success to date and lessons learned through the development and ongoing management of a medical stop loss group captive.
The document summarizes key provisions of the Affordable Care Act (ACA) or "health reform" and how it will impact Utah families and businesses. Some key points include:
- The ACA aims to expand access to affordable health insurance through state-run exchanges, subsidies, and Medicaid expansion while also containing costs and improving quality.
- It offers immediate benefits like preventing denial of coverage for pre-existing conditions and allowing young adults to stay on parents' plans until age 26.
- It provides tax credits to small businesses that offer employee coverage and establishes an online marketplace ("exchange") for individuals and small businesses to purchase plans.
- The goals of reform are to contain costs through measures like reducing waste and fraud
A document discusses the evolving role of captives within the changing healthcare environment. It notes rising healthcare costs and the growth of accountable care organizations (ACOs) and self-insurance. Captives are increasingly being used to manage ACO and employee healthcare risks. Case studies show how group captives can generate savings for employers by pooling stop-loss insurance and improving risk management. Forming a successful captive requires thorough planning and establishing sound fundamentals.
New CA Laws and Regulations Compliance Overview AlphaStaff
As of January 1, 2013, the state of California has added and amended myriad of new laws that affect employers in a number of important and significant ways. Please join us as we review each of these changes and help employers better understand the impact and importance of these changes to their businesses and employees in California. Presented by Human Resources Account Manager, Rebecca McDonough, CA-SPHR
This document summarizes key provisions of the recently passed US healthcare reform legislation. It outlines major changes occurring between 2010-2014, such as dependent coverage until age 26, elimination of lifetime limits, creation of health insurance exchanges in 2014, and employer penalties for not providing coverage. Administrative impacts are also discussed, such as increased workload from additional required notices and forms. Specific provisions like tax changes, Medicare discounts, and essential health benefits are reviewed.
The document provides information about:
1) The process for reassessing existing incapacity benefits customers, which will involve a medical questionnaire and may include a Work Capability Assessment to determine eligibility for Employment and Support Allowance.
2) Details about the Employment and Support Allowance program, which will place qualifying customers into either the Work-Related Activity Group or Support Group.
3) Plans to introduce a single Work Program by 2011 to provide targeted assistance to those moving onto benefits.
ISCEBS 2014 Presentation: Health Care Reform’s Impact on Disability ManagementSpring Consulting Group
The document discusses key trends in integrated disability management in light of healthcare reform. It notes that integration continues to progress across employers of all sizes, with programs becoming more mature and sophisticated. Health management programs are also broadening in scope. The document highlights expanding ADA accommodation management to be on par with FMLA as a top trend, as well as growing interest in voluntary benefits to fill coverage gaps. Centralizing absence management and standardizing approaches are also discussed as important trends to improve the employee experience and reduce costs. Formal return-to-work and stay-at-work programs are emphasized as best practices.
The document discusses paid sick leave compliance and best practices for employers. It provides an overview of the expansion of paid sick leave laws from one state and seven jurisdictions in 2014 to three states and eighteen jurisdictions currently. It reviews the key details and requirements of paid sick leave laws in states like California, Connecticut, and Massachusetts as well as various cities. These include eligibility, accrual, usage limits, family definitions, and certification processes. The document also discusses challenges employers face in managing paid sick leave and provides resources for continued compliance.
The document discusses various deadlines and regulations related to the Patient Protection and Affordable Care Act (PPACA). It notes that deadlines vary based on plan renewal dates and that regulatory clarifications continue to be issued. It also discusses the impact of the Supreme Court ruling upholding the individual mandate and notes that implementation of the law will continue to move forward. Grandfathered plans are discussed, including allowable changes without losing grandfathered status. The small business tax credit provisions are outlined. Coverage of adult children up to age 26 and new preventive service mandates are also summarized.
This document summarizes key changes to a collective bargaining agreement between a state government and its employees. It outlines improvements to health benefits and wages negotiated by union leadership in response to concerns raised by state senate orders in June. The updated agreement includes $600 in new health savings incentive payments, more money allocated to employee health reimbursement accounts, and a $300 signing bonus for full-time employees. It is argued to be a better deal for workers by providing additional funds to offset new medical deductibles while still reducing healthcare costs.
The document discusses challenges facing employers who provide post-retirement pharmaceutical benefits and alternatives to address these challenges. It describes the Retiree Drug Subsidy program and its limitations. A key alternative presented is an Employee Group Waiver Plan (EGWP), where an employer contracts with a Part D plan sponsor to provide a Medicare Part D prescription drug plan and receive subsidies directly from Medicare. An EGWP can provide increased subsidies compared to the Retiree Drug Subsidy and outsources administration. The document provides an example comparing the financial impact of these options for an employer with 57,000 Medicare-eligible retirees.
This white paper discusses accounting standards for post-retirement healthcare benefits and how recent healthcare reforms impact employer obligations. It explains that the Patient Protection and Affordable Care Act eliminated tax deductions for the Retiree Drug Subsidy, increasing employer costs. As a result, employers must now record the present value of future tax liabilities as a current expense. The paper analyzes options for employers to reduce costs, such as terminating retiree drug plans, and risks of litigation and reputation damage from doing so. It also outlines accounting rules requiring employers to disclose impacts of the new laws on benefit obligations.
This document summarizes key changes to a collective bargaining agreement between a state government and its employees. It outlines 3 issues that union leadership asked the bargaining team to address in June: maintain the current sick leave plan, get the same or higher raise with an emphasis on helping lower wage workers, and improve the health care offer. The document then details how the state's offer was increased by 20% in October by adding health benefit savings incentive payments and converting part of the initial raise into a signing bonus. It argues this new deal allocates $6 million more for employees and up to $6 million in wellness incentives, addressing union concerns about wages and benefits.
Clermont County 2018 Horan Renewal Update - Commissioners PresentationClermont County, Ohio
The document provides an agenda and updates on Clermont County's 2018 benefits renewal. It summarizes 2015-2016 financials and claims data, provides 2017 financials year-to-date, and projects 2018 medical and dental renewals. UHC and Humana were selected as finalists for medical based on cost and plan details. UHC offered higher pharmacy rebates and potential savings from plan changes. Dental was projected to be flat, with DCP selected over MetLife due to network match. Other benefits were noted to be under rate guarantees.
Primary Care spend in the State of Rhode island and its impact on overall cost trend a report worth reading for sure
Primary care Spend in RI went up from 47 million in 2008 to 67 million in 2013
BUT !!!
Total Spend went down from 823 Million in 2008 to 661 Million in 2013
Health Care Reform - Summary 2010 to 2012Banyanllc
This document provides an overview of key provisions in the 2010 health care reform legislation that employers need to consider for 2010 through 2012. It outlines 30 provisions, including requiring coverage of adult children up to age 26, eliminating lifetime limits on coverage, establishing internal and external claims appeal processes, prohibiting pre-existing condition exclusions for children, providing free preventive care, and increasing the tax on indoor tanning services. The summary provides details on who each provision applies to, a brief description, and the effective date. It notes many provisions take effect for plan years beginning after September 23, 2010 and that further guidance is still needed to clarify some aspects of the new rules.
CARES Act - Key Takeaways for Healthcare OrganizationsCitrin Cooperman
The document summarizes key provisions of the CARES Act for healthcare organizations. It discusses expanded coverage of COVID-19 testing and preventative services, increased Medicare reimbursement rates, suspension of Medicare sequestration cuts, postponed reductions to DSH payments, and advance Medicare payments. It also reviews expanded telehealth coverage and reimbursement, the Public Health and Social Services emergency fund, PPP loan forgiveness criteria, EIDL loans, payroll tax credits, and modifications to net operating loss deductions.
Health Reform Bulletin 133 | Executive Order Directing Modifications to the A...CBIZ, Inc.
An Executive Order, signed on October 12, 2017, promotes modifications of certain aspects of the Affordable Care Act (ACA) (also see press statement). In a nutshell, this Executive Order directs the ACA’s governing agencies (Health and Human Services/Labor/Treasury) to address three
elements: formation of association health plans, expansion of short-term, limited-duration insurance, and expanding the rules to allow individual premium to be reimbursed through health reimbursement arrangements (HRAs). Briefly, this Executive Order directs the governing agencies to
President Obama was re-elected, ensuring that the Affordable Care Act will continue to be implemented without further challenges. Employers must prepare for upcoming requirements, such as providing a summary of benefits and coverage and limiting health FSA contributions to $2,500 per year. Additional regulations on issues like the employer mandate and nondiscrimination rules are expected. While implementation of the law will continue, questions remain about whether all parts will be operational by deadlines due to challenges like insufficient agency staffing.
Coronavirus Aid, Relief and Economic Security (CARES) Act & Families First Co...Parsons Behle & Latimer
This document summarizes a webinar about the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Families First Coronavirus Response Act. It provides an overview of the following:
- The webinar format and presenters covering various aspects of the Acts.
- Key provisions of the CARES Act including the $349 billion Paycheck Protection Program for small business loans, loan forgiveness terms, tax credits and delays, student loan and disaster relief payments.
- Provisions of the Response Act including expanded paid sick leave and FMLA leave for child care reasons during school/daycare closures due to COVID-19.
This document outlines Family Medicine's requests to support and modernize primary care training in the United States. It asks Congress to: 1) fund primary care training programs at $71 million; 2) provide $300 million to the National Health Service Corps; and 3) cosponsor legislation to pilot new primary care medical residency models funded through Medicare. It provides arguments and responses to counter potential objections about the costs and effectiveness of these programs and policies. The document emphasizes that without reforms and increased funding, the primary care workforce will not be able to meet the growing demand for services.
This document provides an overview of Medicare and insurance options from Boone Insurance Associates. It defines key terms like deductible and coinsurance. It describes the main parts of Medicare including Part A for hospital coverage, Part B for medical coverage, Part C for Medicare Advantage plans, and Part D for prescription drug coverage. It also outlines some options for supplemental coverage through Medigap plans. The document discusses factors to consider when analyzing and choosing a health insurance plan, and lists the different enrollment periods for making changes.
Price reduction for late delivery:
conflicting views on excise value
Background: Where excise duty is charged as a percentage of the value of the goods, there are two methods of determining the assessable value. For goods that are under MRP and notified for the purpose of MRP-based assessment under section 4A of the Central Excise Act, there is no difficulty in arriving at assessable value. For other goods, the ‘transaction value’ is the value for assessment, as provided in section 4 of the Central Excise Act. Transaction value means the price actually paid or payable for the goods.
Core hcr presentation rental association wo videoJosh Nickell
The document discusses key provisions of the Affordable Care Act including the employer mandate, individual mandate, premium tax credits, metallic levels, deductible and out-of-pocket limits, medical loss ratio, guaranteed issue, adjusted community rating, essential health benefits, and employer options. It provides an overview of the timeline for implementation of various ACA provisions from 2010 to 2018. The presentation is for the GA Chapter of the American Rental Association to explain health care reform and what employers can do.
The document discusses flaws in the current UK debt management framework and calls for reforms. It proposes a new model with:
1) A simplified governance structure with single bodies for debt advice regulation, remedies administration, and over-indebtedness strategy.
2) Streamlined debt remedies that encourage early intervention and rationalize formal/court-based options.
3) Comprehensive consumer information to facilitate early resolution.
4) Improved financial education and a centralized debt advice portal to empower consumers.
The proposed reforms aim to produce more consistent, predictable outcomes for both borrowers and creditors through a less complex system.
The document provides information about:
1) The process for reassessing existing incapacity benefits customers, which will involve a medical questionnaire and may include a Work Capability Assessment to determine eligibility for Employment and Support Allowance.
2) Details about the Employment and Support Allowance program, which will place qualifying customers into either the Work-Related Activity Group or Support Group.
3) Plans to introduce a single Work Program by 2011 to provide targeted assistance to those moving onto benefits.
ISCEBS 2014 Presentation: Health Care Reform’s Impact on Disability ManagementSpring Consulting Group
The document discusses key trends in integrated disability management in light of healthcare reform. It notes that integration continues to progress across employers of all sizes, with programs becoming more mature and sophisticated. Health management programs are also broadening in scope. The document highlights expanding ADA accommodation management to be on par with FMLA as a top trend, as well as growing interest in voluntary benefits to fill coverage gaps. Centralizing absence management and standardizing approaches are also discussed as important trends to improve the employee experience and reduce costs. Formal return-to-work and stay-at-work programs are emphasized as best practices.
The document discusses paid sick leave compliance and best practices for employers. It provides an overview of the expansion of paid sick leave laws from one state and seven jurisdictions in 2014 to three states and eighteen jurisdictions currently. It reviews the key details and requirements of paid sick leave laws in states like California, Connecticut, and Massachusetts as well as various cities. These include eligibility, accrual, usage limits, family definitions, and certification processes. The document also discusses challenges employers face in managing paid sick leave and provides resources for continued compliance.
The document discusses various deadlines and regulations related to the Patient Protection and Affordable Care Act (PPACA). It notes that deadlines vary based on plan renewal dates and that regulatory clarifications continue to be issued. It also discusses the impact of the Supreme Court ruling upholding the individual mandate and notes that implementation of the law will continue to move forward. Grandfathered plans are discussed, including allowable changes without losing grandfathered status. The small business tax credit provisions are outlined. Coverage of adult children up to age 26 and new preventive service mandates are also summarized.
This document summarizes key changes to a collective bargaining agreement between a state government and its employees. It outlines improvements to health benefits and wages negotiated by union leadership in response to concerns raised by state senate orders in June. The updated agreement includes $600 in new health savings incentive payments, more money allocated to employee health reimbursement accounts, and a $300 signing bonus for full-time employees. It is argued to be a better deal for workers by providing additional funds to offset new medical deductibles while still reducing healthcare costs.
The document discusses challenges facing employers who provide post-retirement pharmaceutical benefits and alternatives to address these challenges. It describes the Retiree Drug Subsidy program and its limitations. A key alternative presented is an Employee Group Waiver Plan (EGWP), where an employer contracts with a Part D plan sponsor to provide a Medicare Part D prescription drug plan and receive subsidies directly from Medicare. An EGWP can provide increased subsidies compared to the Retiree Drug Subsidy and outsources administration. The document provides an example comparing the financial impact of these options for an employer with 57,000 Medicare-eligible retirees.
This white paper discusses accounting standards for post-retirement healthcare benefits and how recent healthcare reforms impact employer obligations. It explains that the Patient Protection and Affordable Care Act eliminated tax deductions for the Retiree Drug Subsidy, increasing employer costs. As a result, employers must now record the present value of future tax liabilities as a current expense. The paper analyzes options for employers to reduce costs, such as terminating retiree drug plans, and risks of litigation and reputation damage from doing so. It also outlines accounting rules requiring employers to disclose impacts of the new laws on benefit obligations.
This document summarizes key changes to a collective bargaining agreement between a state government and its employees. It outlines 3 issues that union leadership asked the bargaining team to address in June: maintain the current sick leave plan, get the same or higher raise with an emphasis on helping lower wage workers, and improve the health care offer. The document then details how the state's offer was increased by 20% in October by adding health benefit savings incentive payments and converting part of the initial raise into a signing bonus. It argues this new deal allocates $6 million more for employees and up to $6 million in wellness incentives, addressing union concerns about wages and benefits.
Clermont County 2018 Horan Renewal Update - Commissioners PresentationClermont County, Ohio
The document provides an agenda and updates on Clermont County's 2018 benefits renewal. It summarizes 2015-2016 financials and claims data, provides 2017 financials year-to-date, and projects 2018 medical and dental renewals. UHC and Humana were selected as finalists for medical based on cost and plan details. UHC offered higher pharmacy rebates and potential savings from plan changes. Dental was projected to be flat, with DCP selected over MetLife due to network match. Other benefits were noted to be under rate guarantees.
Primary Care spend in the State of Rhode island and its impact on overall cost trend a report worth reading for sure
Primary care Spend in RI went up from 47 million in 2008 to 67 million in 2013
BUT !!!
Total Spend went down from 823 Million in 2008 to 661 Million in 2013
Health Care Reform - Summary 2010 to 2012Banyanllc
This document provides an overview of key provisions in the 2010 health care reform legislation that employers need to consider for 2010 through 2012. It outlines 30 provisions, including requiring coverage of adult children up to age 26, eliminating lifetime limits on coverage, establishing internal and external claims appeal processes, prohibiting pre-existing condition exclusions for children, providing free preventive care, and increasing the tax on indoor tanning services. The summary provides details on who each provision applies to, a brief description, and the effective date. It notes many provisions take effect for plan years beginning after September 23, 2010 and that further guidance is still needed to clarify some aspects of the new rules.
CARES Act - Key Takeaways for Healthcare OrganizationsCitrin Cooperman
The document summarizes key provisions of the CARES Act for healthcare organizations. It discusses expanded coverage of COVID-19 testing and preventative services, increased Medicare reimbursement rates, suspension of Medicare sequestration cuts, postponed reductions to DSH payments, and advance Medicare payments. It also reviews expanded telehealth coverage and reimbursement, the Public Health and Social Services emergency fund, PPP loan forgiveness criteria, EIDL loans, payroll tax credits, and modifications to net operating loss deductions.
Health Reform Bulletin 133 | Executive Order Directing Modifications to the A...CBIZ, Inc.
An Executive Order, signed on October 12, 2017, promotes modifications of certain aspects of the Affordable Care Act (ACA) (also see press statement). In a nutshell, this Executive Order directs the ACA’s governing agencies (Health and Human Services/Labor/Treasury) to address three
elements: formation of association health plans, expansion of short-term, limited-duration insurance, and expanding the rules to allow individual premium to be reimbursed through health reimbursement arrangements (HRAs). Briefly, this Executive Order directs the governing agencies to
President Obama was re-elected, ensuring that the Affordable Care Act will continue to be implemented without further challenges. Employers must prepare for upcoming requirements, such as providing a summary of benefits and coverage and limiting health FSA contributions to $2,500 per year. Additional regulations on issues like the employer mandate and nondiscrimination rules are expected. While implementation of the law will continue, questions remain about whether all parts will be operational by deadlines due to challenges like insufficient agency staffing.
Coronavirus Aid, Relief and Economic Security (CARES) Act & Families First Co...Parsons Behle & Latimer
This document summarizes a webinar about the Coronavirus Aid, Relief, and Economic Security (CARES) Act and the Families First Coronavirus Response Act. It provides an overview of the following:
- The webinar format and presenters covering various aspects of the Acts.
- Key provisions of the CARES Act including the $349 billion Paycheck Protection Program for small business loans, loan forgiveness terms, tax credits and delays, student loan and disaster relief payments.
- Provisions of the Response Act including expanded paid sick leave and FMLA leave for child care reasons during school/daycare closures due to COVID-19.
This document outlines Family Medicine's requests to support and modernize primary care training in the United States. It asks Congress to: 1) fund primary care training programs at $71 million; 2) provide $300 million to the National Health Service Corps; and 3) cosponsor legislation to pilot new primary care medical residency models funded through Medicare. It provides arguments and responses to counter potential objections about the costs and effectiveness of these programs and policies. The document emphasizes that without reforms and increased funding, the primary care workforce will not be able to meet the growing demand for services.
This document provides an overview of Medicare and insurance options from Boone Insurance Associates. It defines key terms like deductible and coinsurance. It describes the main parts of Medicare including Part A for hospital coverage, Part B for medical coverage, Part C for Medicare Advantage plans, and Part D for prescription drug coverage. It also outlines some options for supplemental coverage through Medigap plans. The document discusses factors to consider when analyzing and choosing a health insurance plan, and lists the different enrollment periods for making changes.
Price reduction for late delivery:
conflicting views on excise value
Background: Where excise duty is charged as a percentage of the value of the goods, there are two methods of determining the assessable value. For goods that are under MRP and notified for the purpose of MRP-based assessment under section 4A of the Central Excise Act, there is no difficulty in arriving at assessable value. For other goods, the ‘transaction value’ is the value for assessment, as provided in section 4 of the Central Excise Act. Transaction value means the price actually paid or payable for the goods.
Core hcr presentation rental association wo videoJosh Nickell
The document discusses key provisions of the Affordable Care Act including the employer mandate, individual mandate, premium tax credits, metallic levels, deductible and out-of-pocket limits, medical loss ratio, guaranteed issue, adjusted community rating, essential health benefits, and employer options. It provides an overview of the timeline for implementation of various ACA provisions from 2010 to 2018. The presentation is for the GA Chapter of the American Rental Association to explain health care reform and what employers can do.
The document discusses flaws in the current UK debt management framework and calls for reforms. It proposes a new model with:
1) A simplified governance structure with single bodies for debt advice regulation, remedies administration, and over-indebtedness strategy.
2) Streamlined debt remedies that encourage early intervention and rationalize formal/court-based options.
3) Comprehensive consumer information to facilitate early resolution.
4) Improved financial education and a centralized debt advice portal to empower consumers.
The proposed reforms aim to produce more consistent, predictable outcomes for both borrowers and creditors through a less complex system.
Funding Good Outcomes- Using social investment to support payment by results.PDFrhoddavies1
This document discusses payment by results (PbR) contracts and how social investment can help address challenges they present for non-profit organizations. It provides examples of government programs using PbR in areas like employment, families, health, and criminal justice. While PbR allows more flexibility, they require upfront capital that non-profits often lack. The document examines how social investment can help by providing loans or guarantees. However, it notes key issues around balancing risk between parties and ensuring fair returns for investors, non-profits, and commissioners.
The document provides an overview of recent and upcoming employment law changes in the UK. It discusses proposals around parental leave including unpaid leave for fathers for antenatal appointments and a new shared parental leave period. It also covers flexible working rights and statistics on employment tribunal claims. Other sections discuss the equality act review, TUPE regulations, employment status, social media issues, legal representation rights, and abolishing the default retirement age. Future impacts on employment are also addressed.
The document discusses social finance and social benefit bonds, with a focus on New South Wales' social benefit bond pilots. It provides 3 key points:
1. Social benefit bonds are financial instruments that pay investors based on the achievement of agreed social outcomes, allowing private funding to support social services while generating savings for the government.
2. New South Wales has launched three social benefit bond pilots focused on reducing foster care, recidivism, and reoffending. The pilots involve private funding of social service providers contingent on improved social outcomes.
3. The pilots aim to test social benefit bonds and generate lessons around defining and measuring outcomes, payment-for-results contracting, and targeting resources to maximize outcomes.
The document summarizes key topics from a presentation on employment law, including managing sickness and holidays, the Equality Act 2010, and managing staff in a challenging economic climate. It discusses case studies related to accruing holiday time during sick leave. It also outlines challenges employers may face in retaining talent and key personnel, containing costs, and maintaining staff engagement as the economy recovers.
FMC's Annual Employment Law Client Seminar Now Dentons
This presentation was delivered by FMC's Catherine Coulter at FMC's Annual Employment Law Client Appreciation Seminar on Febraury 22, 2012. It addresses new and upcoming trends in Employment Law, restrictive covenants, contractual termination packages, the 24 month cap, Bill 160, Family Caregiver Leave, The Tort of Privacy, and the Accessability for Ontarians with Disabilities Act.
The document summarizes upcoming changes to incapacity and disability benefits in the UK. It notes that (1) the incapacity benefit form (IB50) is being replaced by a new form (SA50) focused on daily abilities rather than limitations. (2) All current incapacity benefit claimants under the pension age will be reassessed. (3) Decisions will place people into one of three groups: support, work-related activities, or no longer entitled to benefits. Additionally, the disability living allowance is being replaced by a new personal independence payment, with 2,000 people per week reassessed over three years starting in 2013.
The document discusses plans to reform the Disability Living Allowance (DLA) benefit in the UK. It proposes replacing DLA with a new benefit called Personal Independence Payment (PIP). Key points include:
- DLA has become too complex and unclear over time, and the rising caseload is unsustainable. Reform is needed to target support better and make the system simpler.
- PIP will be introduced in 2013/14 and will assess working-age DLA recipients' needs in a new, objective way focusing on daily living and mobility. It aims to prioritize support for those facing the greatest challenges.
- Automatic entitlements based just on health conditions will end. Each case will consider the
1. The evaluation strategy outlines DEEWR's plan to evaluate the effectiveness, efficiency and accessibility of the new Disability Employment Services (DES) model that began in 2010.
2. The evaluation will compare the new DES model to the previous model (DEN/VRS) and assess whether the key changes in DES have improved outcomes. It will also assess the overall impact of DES on labour market participation of people with disability.
3. The strategy identifies four main questions that will guide the evaluation: 1) Whether all eligible job seekers receive timely and appropriate services; 2) Whether access to services is similar across different groups; 3) Whether DES has led to increased skills/sustainable employment and satisfaction; 4)
Universal Credit Vision & Jobseekers Allowance - Claimant Commitment - DWPGood Things Foundation
The document discusses the introduction of the Jobseeker's Allowance Claimant Commitment, which aims to pave the way for the new Universal Credit system. Under Universal Credit, claimants will have increased requirements to actively seek work, treat job searching as a full-time job, and have detailed work plans outlining their search activities. The Claimant Commitment requires claimants to have clear work responsibilities documented in a plan and commits them to taking all reasonable steps to find employment. It is expected to increase structure around claimants' work search and use of digital job search tools.
Social Security Administration Regulatory Reform Plan August 2011Obama White House
The Social Security Administration (SSA) outlines its final plan for retrospective review of regulations as required by Executive Order 13563. Over the next two years, SSA plans to review medical listings used to determine disability benefits eligibility. The plan focuses on increasing transparency and simplifying listings to reduce complexity and paperwork burdens for beneficiaries. SSA will also streamline work activity report forms and implement electronic authorization to expedite the disability review process. Public comments were incorporated into the final plan to ensure opportunities for input from stakeholders.
Legal newsletter for owners, directors and HR professionals with updates on current employment law. In this issue: Also in this issue: The National Minimum Wage / National Living Wage; Family Friendly Rights; Current rates and limits for unfair dismissal and redundancy; pulling a sickie
The social care common inspection framework (SCCIF): an introductionOfsted
The document introduces the Social Care Common Inspection Framework (SCCIF) which provides a common approach to inspecting various social care services in England. It outlines that the SCCIF was developed based on feedback from extensive consultation, and establishes consistent principles, processes, and criteria for evaluating services based on the experiences of children, protection of children, and effectiveness of leadership. The SCCIF aims to prioritize inspection of services most in need of improvement while maintaining flexibility to address different types of services.
In this month's edition the team look at:
pre-action protocol for debt claims progresses?
the latest Euro-Dynamics case
sentencing in health and safety and food safety cases
buying local and the tale of the Spanish hospitals
members and officers - the key to a successful relationship?
This document summarizes a regulatory review presentation on home health and hospice issues. Key points include:
- Medicare has four jurisdictions for home health and hospice administrative contractors.
- Providers need to stay up to date with contractor instructions by signing up for newsletters.
- New rules assign providers a screening level of limited, moderate or high risk for fraud based on their category.
- The hospice benefit policy manual and conditions of participation were updated. Hospices received new comparative billing reports to examine their practices.
Work in Progress - 10th Year Anniversary - Employment Law Update VisualBee.com
The document provides an employment law update covering several topics:
1) The abolition of the default retirement age means employers can no longer force retirement based on age unless objectively justified. This may impact performance management, succession planning, and employee benefits.
2) New maternity and paternity provisions allow fathers to take up to 26 weeks of additional paternity leave in the first year. Employers must update family friendly policies.
3) The Equality Act consolidates previous anti-discrimination laws into a single act. The Bribery Act strengthens anti-corruption laws and requires adequate procedures to prevent bribery.
4) Agency worker regulations provide equal treatment for benefits and opportunities after 12 weeks to
Similar to Citizens Advice Cymru response to the Welsh Affairs Committee Inquiry impact of Work Programme (20)
This document discusses a "Fight Back!" campaign to enact change together. It encourages working as a group to fight and make a difference through united effort. The campaign aims to empower people to take action and enact positive change.
The initial decision on appeals is made by advisers (37%), appeal panels (15%), or managers (7%), with some decisions made by more than one adviser or other parties. Audit processes to review decisions and maintain consistency exist for some (33%) but many are unsure (35%) or feel they do not adequately consult students (29%). The vast majority have a formal appeals process (94%) but an informal meeting is not generally required beforehand (76%).
This document surveys universities about emergency assistance and scholarship funding. Regarding emergency assistance, most respondents expect no change but anticipate providing emergency grants or loans within a few days. For scholarships and bursaries, opinions are mixed with 37% expecting an increase and 26% a decrease in funding. The survey also lists various types of scholarships and bursaries administered by the universities.
The document discusses reforms to hardship funds across the UK. It notes that funding from the Access to Learning Fund in England has been transferred to HEFCE to create the Student Opportunities Fund. Additionally, the Welsh Government plans to abolish the Financial Contingency Fund in Wales and require higher education institutions to provide more support from their own budgets. The research survey captured data between April and May 2015 from across the UK on the impact of these reforms. It included responses from 57 individuals representing higher education institutions, further education institutions, and students' unions, with most being from higher education institutions and located in Wales.
This document summarizes survey results about university hardship fund application processes in the UK. It finds that:
- Most universities use the current NASMA guidance for hardship fund applications, though some report processing times ranging from same day to over 2 weeks.
- The most common reasons for hardship fund applications are shortfalls in income, family or housing crises, and academic expenses.
- Income considered in applications includes parental contribution, student employment income, and partner's income, among other sources.
1) A survey was conducted to understand the anticipated effects of changes to a hardship fund on respondents. 44% agreed the changes would affect them, while 33% partly agreed and 23% disagreed.
2) The largest concerns about changes were around eligibility criteria (40%), the application process (31%), and the amount of funding (16%).
3) Respondents expected a range of impacts on funding levels from increases of over 50% (19%) to decreases of over 50% (6%). Most anticipated little or no change to student retention or widening participation programs.
Hardship Funds are in the process of reform across the UK. This research aims at providing Higher & Further Education providers with key data on how those reforms are taking shape. Full findings to be published later this summer 2015.
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise boosts blood flow and levels of neurotransmitters and endorphins which elevate and stabilize mood.
This report summarizes data collected between May 2012 and April 2013 regarding mental health services in Ceredigion, Wales. The data shows concerns about a lack of collaboration between third sector organizations and statutory services. It also highlights issues reported about healthcare access, welfare benefits, and housing for clients. Key recommendations include improving coordination between third sector groups, adopting a human rights-based approach to service delivery, and using community budgeting to design more integrated services with the user at the center.
Citizens Advice Cymru response to the Welsh Affairs Committee Inquiry impact of Work Programme
1. Response from Citizens Advice Cymru
to the Welsh Affairs Committee
Inquiry: the Work Programme in Wales
December 2012
2. _______________________________
1
Summary of recommendations
Poor administration of sanctions is a main area of concern for the Citizens
Advice Cymru service and we recommend:
Improved administration to ensure that sanctions do not arise because
of, for example, failure to record sickness or inability to attend where
this has been notified.
Robust safeguards to protect claimants from inappropriate sanction
must be put in place. When drawing up the claimant commitment and
considering sanctions, guidance must ensure that Jobcentre Plus
advisers consider:
whether there is any long-term health condition or impairment for
which reasonable adjustments need to be made
with clients permission a summary of claimants health record to
be checked by Jobcentre Plus prior to claimant commitment
being drawn up or sanctions being imposed (see further
information under General welfare reform/health heading below)
whether there is suitable childcare available for the claimant’s
children
1. Introduction
1.1 Citizens Advice Cymru welcomes the opportunity to submit evidence to
this inquiry. In the 12 months to September 2012 Citizens Advice
Bureaux in Wales saw 153,482 clients and helped with 458,513 issues.
Benefits/tax credits and debt are the two biggest areas of advice and
account for just over 75% of issues advised on.
1.2 Between October 2011 and September 2012 Citizens Advice Bureaux in
Wales have responded to 1,607 employment enquiries of which 118
were specifically about schemes for the unemployed representing a 51%
annual change comparing the last 4 quarters with the previous 4
quarters.
1.3 Groups at risk of poverty are over-represented among Citizens Advice
Bureaux clients in Wales1
:
44.5% of clients are disabled or have a long term health problem
16.3% identify as permanently disabled
15.8% are lone parents with dependent children
1% are either homeless or living in hostels
1.4 The following qualitative evidence is for the most taken from bureaux
across Wales. However, we have also included some pertinent evidence
1
For the period to September 2012
3. _______________________________
2
submitted from a small selection of partners including Swansea Social
Services, Swansea Community Mental Health, and a small selection
from our Bureaux in England.
1.5 Whilst our case recording system does not specifically provide data for
the number of CAB clients seeking advice in relation to a problem with
the Work Programme itself, we have been able to extract some pertinent
evidence and case studies which we submit are illustrative of the core
issues that our clients have with the Work Programme and other related
issues.
1.6 Our main findings demonstrate that there are issues in regard to the
administration of Work Programme related sanctions. Therefore, this will
contribute to the larger part of this submission.
1.7 Specifically, evidence demonstrates issues with regard to the
administration and application of the sanctions regime on claimants that
suffer from mental ill health and/or learning disabilities.
1.8 Our evidence is in respect of clients who have had problems with their
engagement with or access to the Work Programme and we do not have
evidence of the positive effects of the Programme in terms of its
effectiveness in assisting people to return to work. However, there was a
recent press release and you can view the latest figures from the DWP
here2
.
1.9 From an operational point of view, Conwy CAB has a role as a provider
of CAB telephone advice and casework to Working Links participants
across Wales. This makes the CAB service a small part of
Working Link’s supply chain and we are classed as a specialist
provider. Some bureaux in England are in similar relationships with other
Prime Contractors; this will briefly be discussed.
2. CAB service partnership with Working Links in Wales
2.1 In our agreements with Prime Contractors CAB specified the following:
CAB were not prepared to be on the receiving end of any mandated
activity (i.e. participants should not be required to seek our advice) and
with all Primes, CAB retained the right to carry out any social policy
work on the Work Programme, as and when required by our evidence.
2
27 November 2012 – Work Programme is getting people working/ available @
http://www.dwp.gov.uk/newsroom/press-releases/2012/nov-2012/dwp128-12.shtml; and Work
Programme statistics (general)available @
http://research.dwp.gov.uk/asd/index.php?page=wp
4. _______________________________
3
2.2 We are happy to report that in general, Conwy CAB confirms that this
partnership works well. However, it has been noted that referrals from
Working Links into the CAB service are quite low.
3. Problems administering Work Programme-related sanctions
3.1 Bureaux across Wales and the UK have seen similar patterns of issues
arising from Work Programme-related sanctions. In particular, there are
a number of cases where claimants have not been advised that they can
dispute a sanction decision within the given “five working day” window if
they wish to claim ‘good cause’. Consequently, according to our
evidence, sanctions are, in many cases, being applied inappropriately.
Claimants are then left with very limited options. We have found that
often these sanctions unnecessarily contribute towards a deterioration in
the personal health and wellbeing of our clients.
3.2 Sanctions: The rules for sanctions have changed recently on 22nd
October 20123
. They have been revised to be considerably more
punitive with new ‘escalation’ rules punishing claimants with sanctions for
up to three years if they repeatedly fail to participate4
. However, as most
of the evidence provided in this submission relates to issues arising prior
to October, the older rules are worth a brief mention. Further, much of
the old rules with regard to ‘good cause’ (now called ‘good reason’)
remain intact and the DWP have said that they will apply ‘good reason’ in
the same way as ‘good cause’ has historically been applied5
. However,
the new rules are less generous and do allow more discretion for the
DWP in terms of interpreting ‘good reason’6
. This will likely have the
effect of working against claimants in terms of their options to claim
‘good reason’, although this has yet to be demonstrated in practice.
3.3 Good Cause: There are a number of things that must happen prior to the
DWP being able to impose a sanction. Firstly, a claimant must fail to
participate in a mandated activity without ‘good cause’7
. Secondly, a
claimant must have previously been notified in writing what was
expected of them and what would be the consequences should they fail
to participate8
. Further, a sanction may not be imposed within “five
working days” of the notice of failure9
; this gives the claimant a vital
opportunity, within this five day window, to demonstrate whether or not
they believe they have ‘good cause’ within this five day window prior to a
3
The Jobseeker’s Allowance (Sanctions) (Amendment) Regulations 2012
4
As outlined in the Welfare Reform Act 2012, s46 (which replaces s19 of the Jobseekers Act
1995)
5
Explanatory Memorandum to The Jobseeker’s Allowance (Sanctions)(Amendment)
Regulations 2012, para 7.18
6
ibid
7
The Jobseeker’s Allowance (Employment, Skills and Enterprise Scheme) Regulations 2011,
reg 6
8
Ibid, reg 4
9
Ibid, (reg 7 (1))
5. _______________________________
4
sanction being applied10
. Importantly, the DWP must take account of all
the circumstances of the case, including and in particular a claimant’s
physical or mental health or condition11
.
4. Evidence: failure to allow for ‘Good cause’ - case studies
4.1 Below are some case studies, to serve as examples where sanctions are
being applied irrespective of whether claimants have had an opportunity
to demonstrate ‘good cause’. These have been subdivided and sub-
headed for ease of reference.
Case A – Sanctions/ failure to allow for ‘good cause’ (conflicting
mandatory appointment)
45 year old male who sought advice from a Citizens Advice Bureau in
the South Wales, has had his JSA stopped (joint JSA with partner)
because he did not attend a Jobcentre Plus interview. He was
actually attending a Work Programme job-search appointment at the
time and could not be in two places at once. An adviser from the Work
Programme provider had phoned the Jobcentre Plus office and
testified for the client, but they refused to withdraw the sanction
despite ‘good cause’.
Case B – Sanctions/ failure to account for ‘good cause’ (conflicting
mandatory appointment)
A man who sought advice from a Citizens Advice Bureau in South
East Wales, had a Working Links interview on the same afternoon as
he was due to sign on JSA. He said the Working Links advisor told
him there was no problem and that he did not have to sign on that
day. As a result of not attending the interview at the Jobcentre Pls
office, he was sanctioned. He appealed this decision and made a
complaint.
He was then interviewed regarding his JSA. He was asked if he
continued to look for work during the sanction period and he said that
he had looked for work during the sanction period, but not to the usual
extent as he had no money to keep his internet on at home and no
money to travel the four miles to the nearest library to access the
internet. As he admitted that he was not able to fully look for work,
the Jobcentre Plus officer applied another sanction to his benefits. He
states he has not had any money for the past eight weeks.
The man has had an application for a crisis loan refused because he
was sanctioned. He is surviving on food parcels and has had to
borrow money from his family to pay fuel bills. His daughter used to
10
ibid
11
Ibid, (reg 7(3)
6. _______________________________
5
stay with him from time to time but this has had to stop as he cannot
feed her or keep her warm.
Case C – Sanctions/ failure to allow for ‘good cause’ (mental health)
48 year old male who sought advice from a Citizens Advice Bureau in
South East Wales has been sanctioned for six months for failing to
attend his Work Programme appointments. He was also refused
hardship payments as he is not classified as being in a ‘vulnerable
group’. He relies on his daughter to remind him of appointments and
she has been trying to establish contact with him and has found this
very difficult. This is why he failed to attend.
Case D – Sanctions/ failure to allow for ‘good cause’ (mental health)
20 year old female who sought advice from a Citizens Advice Bureau
in the South Wales, missed four appointments and the Jobcentre Plus
office has now sanctioned her until January 2013. She suffers from
periodic depression and memory problems and was previously on
anti-depressants; she no longer takes them as she says she feels
better without them. She does rely on her social services support
worker to remind her of appointments but on this occasion they failed
to support her. She could not apply for a crisis loan because she has
been sanctioned and has no money whatsoever. She is also worried
that she will lose her accommodation as a result of these sanctions.
Case E – Sanctions/ failure to allowt for ‘good cause’ (mental health)
47 year old man who sought advice from a Citizens Advice Bureau in
South West Wales, has been in receipt of JSA for the last two years.
He suffers from anxiety and depression but has not visited the GP
about this because he does not want to acknowledge it. He does not
want to claim ESA because he wants to find work. His mental health
problems have been particularly bad recently to the extent that he
could not leave the house, and so he missed three Work Programme
appointments. His JSA has now been stopped. He was not given any
advice by the DWP on how he can appeal this decision, and so he
missed the five day period in which to demonstrate ‘good cause’. He
has no money and is currently living on food vouchers.
Case F – Sanctions/ failure to allow for ‘good cause’ (learning
disability)
Claimant with learning disabilities was working under an ESF funded
training programme and was then mandated into the Work
Programme; he was forced to abandon the former course – even
though he was doing well on the course as it was highly personalised.
7. _______________________________
6
He was then sent to a Job Club where he was asked to complete a
CV. When he explained he didn't know what to do the adviser told
him that he would have his benefits stopped. This young person is
unable to read or write and was totally incapable of complying with the
request.
Case G – Sanctions/ failure to allow for ‘good cause’ (illness)
47 year old female who sought advice from a Citizens Advice Bureau
in South Wales, did not attend a Work Programme appointment in
Cardiff because she was ill. She was also concerned for her daughter
and did not want her daughter going home to an empty house. Her
ESA was stopped for this reason. She now has no money to pay for
bills or to purchase food for herself or for her daughter.
Case H – Sanctions/ failure to allow for ‘good cause’ (bereavement)
Ongoing case where a man who recently sought advice from a
Citizens Advice Bureau in South East Wales, failed to turn up for WP
mandated training. The reason he failed to attend was that a member
of his family had died. He was sanctioned. When the Training
Company discovered the reason for the no show and contacted the
Jobcentre Plus office with a request to withdraw the sanction, the
Jobcentre Plus office still declined to withdraw the sanction even
though it was clear that the claimant had ‘good cause’.
Case I - Sanctions/ debt and mental health deterioration
A 22-year-old woman with mental health problems who sought advice
from a CAB in Derbyshire in September 2012 had been sanctioned for
six months in May, due to failures to attend Work Programme
appointments. As a result, the client had no income and had been
forced to move to live with her partner’s parents. She reported that
she had now fully re-engaged with the Work Programme, and had
tried repeatedly to contact Jobcentre Plus to try and get her JSA re-
instated, to no avail. She was now heavily in debt and this was
exacerbating her mental health problems.
Case J – Sanctions/ excessive demands / mental health problems
A 31-year-old woman with severe, long-term mental health problems
who sought advice from a CAB in Cambridgeshire was in receipt of
ESA and had been placed in the WRA Group. She was determined to
return to work, an ambition supported by her doctors, and had
recently found herself a part-time job. However, her Work
Programme provider was requiring her to actively seek work and
attend training appointments. The client and her doctors were
concerned that the combined level of work and Work Programme
8. _______________________________
7
attendance was detrimental to her mental health, and that her
(permitted) work should have priority. 12
5. Work Programme provider guidance - An opportunity missed?
5.1 Official DWP guidance actually advises Work Programme providers
(WPPs) not to ask claimants whether they have ‘good cause’ prior to
referring them for a sanction:
“Do not ask the participant for a good cause reason to determine
whether or not to raise a WP08. You have no option but to raise
a doubt once the participant has failed to participate in a
mandated activity, irrespective of whether or not they have
offered an explanation afterwards. The LM DM will consider the
reasons given and must make the good cause decision.”13
5.2 Although we understand that it may not be appropriate for WPPs to offer
advice on definitions of ‘good cause’, we are concerned that an
opportunity is wasted to provide information on claimants’ rights with
regard to their opportunity to demonstrate ‘good cause’ – particularly as
the timescales for disputes on this basis are so narrow. Often, by the
time a claimant seeks advice from an independent source (such as CAB)
it may be well beyond the five day time limit for a ‘good cause’ defence,
even when it is clear that in many cases they can indeed demonstrate
‘good cause’.
6. Limited financial safeguards once sanctioned
6.1 Further, according to our evidence, claimants are almost always
financially destitute after a sanction and have very few choices in terms
of financial support. Once sanctioned, claimants will only have access
to Crisis loan support if they are experiencing a ‘disaster’, defined as “a
sudden calamitous event or great misfortune causing loss of, or damage
to possessions or property”14
. Claimants under sanctions are in some
cases also very fearful of losing their residential security and often get
into debt with, for example, council tax or fuel arrears, priority debts.
6.2 The main government source of help in these circumstances is Hardship
payments. Hardship is not clearly defined in the regulations. However, it
is defined further in guidance as “severe suffering or privation”15
.
Nevertheless, although clients do have access to hardship payments in
theory, as we have seen in practice, unless claimants are deemed
12
For further details about the service user experiences on the Work Programme across the
UK, please refer to the ‘Submission by Citizens Advice to the Work & Pensions Committee
inquiry’ (December 2012).
13
Work Programme Provider Guidance - Chapter 6 – Raising a compliance doubt, p1
14
The Social Fund Guide (October 2012)
15
DMG (JSA) Ch 35, para 35155
9. _______________________________
8
particularly ‘vulnerable’, they will not usually get hardship support and will
be left to rely on charitable support instead – such as food vouchers.
Further, most food parcel providers have a limit on how many parcels
they can distribute to any one person within a given timeframe, so this
support is very limited. For those that were already supplementing their
housing benefit and rent out of their main JSA or ESA awards – the risks
in terms of debt, homelessness and/ or deterioration in physical and
mental health clearly are very real.
7. Evidence: Community Mental Health Team (CMHT) in South Wales
7.1 We also have reports that a Community Mental Health Team has noted
an increase in referrals for those needing mental health support due to
Work Programme difficulties and stress.
7.2 Further, one Citizens Advice caseworker who runs a weekly drop-in
service at the local CMHT has stated that around 50% of her clients are
on ESA and of those around 50% are in the Work-Related Activity Group
(WRAG). Some of those in the WRAG are eligible for Work Programme
referrals and mandated activity (depending on their ‘conditionality
grouping’)16
.
7.3 We have concerns that a significant proportion of those on ESA are in
the WRAG even though they have a serious mental health disorder, such
as bipolar disorder or schizophrenia and are at significant risk of self
harm.
8. Conclusion
8.1 It is clear from the evidence that poor administration of sanctions is a
main area of concern for bureaux across both Wales and England.
Significantly, sanctions for failure to participate in mandated activities are
not always applied appropriately as claimants are not always made
aware of the need to show ‘good cause’ within the relevant time scales –
even when there is clearly a reasonable argument for a ‘good cause’
defence against a sanction. According to our findings, the DWP are
applying sanctions inflexibly and are often not taking into consideration
mitigating circumstances, such as conflicting mandated appointments,
bereavement, mental or physical ill-health.
16
It is also worth noting that new regulations came into force on 3
rd
December 2012 (The
Employment and Support Allowance (Sanctions) (Amendment) Regulations 2012) which
include a revised, tougher sanctions regime for ESA claimants in the Work Related Activity
Group. For details on applying these changes to ESA claimants already under a sanction,
please refer to: Work Programme Provider Guidance, Chapter 7 – From 3rd December 2012 -
Re-compliance and Reviewing a Sanction
10. _______________________________
9
8.2 Moreover, we have presented evidence to suggest that there is also a
causal link between the application of sanctions (often inappropriate) and
deterioration in physical and mental health, even when (as is clear from a
number of case studies) there are genuine efforts on the part of
claimants to comply with directions and mandated activities. The DWP
are in many cases applying inappropriate sanctions on the most
vulnerable, such as those that suffer from mental ill health or learning
disabilities. This group are also the least able to manage the
conditionalities of the Work Programme (such as keeping appointments),
or a crisis, without extensive support from family or statutory services.
8.3 The combined long term impact of sanctions, particularly those wrongly
applied on the most vulnerable, has a detrimental effect on claimants’
abilities to cope with their own personal health and well being. As has
been demonstrated, claimants are increasingly excluded and in need of
crisis support - which is in any case very limited. This has a profoundly
negative impact on our clients. Further, there is often a prolonged and
unnecessary pressure on local services and charitable support. In short,
the evidence suggests that some vulnerable claimants are not receiving
the necessary level of personalised, specialist support that they really
need in order to move into sustainable employment.
9. Recommendations
9.1 Improved administration to ensure that sanctions do not arise because
of, for example, failure to record sickness or inability to attend where this
has been notified.
9.2 Robust safeguards to protect claimants from inappropriate sanction must
be put in place. When drawing up the claimant commitment and
considering sanctions, guidance must ensure that Jobcentre Plus
advisers consider:
whether there is any long-term health condition or impairment for
which reasonable adjustments need to be made
with clients permission a summary of claimants health record to
be checked by Jobcentre Plus prior to claimant commitment
being drawn up or sanctions being imposed (see further
information under General welfare reform/health heading below)
whether there is suitable childcare available for the claimant’s
children