Universal Credit – Inclusion London’s response to the SSAC Committee’s consultation on the 2018 regulations

Inclusion London responded to the Social Security Advisory Committee’s (SSAC) consultation on the Universal Credit, transitional provisions/managed migration amendment regulations 2018.

Inclusion London believes the Universal Credit (UC) system is not fit for purpose and should be stopped and scrapped. But unfortunately the government is determined to go ahead with the full rollout of UC, refusing even to halt it until the current problems have been addressed, therefore we have made suggestions to improve the Universal Credit regulations 2018 in our response.

Download our response here: Inclusion London’s response to SSAC consultation on UC Regs 2018

Below are our key concerns and a summary of the recommendations:

Key concerns

• The UC application and communications system is inaccessible for many Deaf and Disabled people so support is needed, which is not always available, leaving Deaf and Disabled people destitute, unable to pay for rent, food or fuel bills.
• Many Universal Credit claimants are Deaf and Disabled people but the application and communications system has not been designed with Deaf and Disabled people’s access needs in mind.
• The Jobcentre staff and the DWP will not be able to identify Deaf and Disable people/‘people that are vulnerable have complex needs’ so they will be issued with a migration notice and their benefits terminated when they are unable to apply for Universal Credit due to the inaccessible system.
• The flat of £80 for those that used to receive Severe Disability Premium does not compensate Deaf and Disabled people from the losses experienced under Universal Credit.
• Deaf and Disabled people who receive Enhanced Disability Premium are currently not compensated for losses under Universal Credit.
• New UC claimants will not receive the equivalent amount to SDP and EHP in their awards.
• Current regulations are leaving Deaf and Disabled people destitute, unable to pay for rent, food or fuel bills.

Regulations 2018

• All Deaf and Disabled people are deemed to be ‘vulnerable or have complex needs’ and their migration notice is automatically and permanently cancelled.
• All Deaf and Disabled people are able to remain on their existing benefits or be able to claim another existing benefit instead.
• Deaf and Disabled receive the same amount under UC as received under SDP.
• The regulations ensure that all Deaf and Disabled receiving Universal Credit receive an equal amount to SDP or EDP, including new claimants.
• Full-time students who receive either Disability Living Allowance (DLA) or Personal Independence Payment (PIP) to be automatically treated as having “limited capability for work” and so can receive UC, including the housing benefit element during their studies.

Current regulations

• The waiting period is totally scrapped and applications are processed as quickly as possible.
• Welfare conditionality is abolished for Deaf and Disabled people or the government will ‘Conduct a review of the conditionality and sanction regimes concerning the Employment and Support Allowance, and tackle negative consequences on mental health and situation of persons with disabilities,’ in line with the UNCRPD Committee’s recommendations
• In a household where more than one person receives UC, each claimant receives their UC into their own bank account and there are no joint payments to prevent financial abuse
• The government implements all of the recommendations made by UNCRPD Committee regarding all the government’s Welfare Reforms including those below:
  • ‘Carry out a cumulative impact assessment, with disaggregated data, about the recent and coming reforms on the social protection for persons with disabilities…’
  •  ‘…implement and monitor measures to tackle retrogression in their standard of living and use it as a basis for policy development across the State party;’