On Wednesday 20th September, ILMI attended a briefing led by Minister for Social Protection, Heather Humphreys TD, s and as she published a Green Paper on reform to Disability Payments.
What is a Green Paper?
This green paper is not an agreed policy. It is a proposal by the Department to create a focussed discussion on how disability payments could be changed in the future. No decision has been made as yet, and the Department did say that through consultation it is possible that no changes would be made.
What does this Green Paper propose?
The Minister and Department officials were keen to point out that there needs to be action based on the research from the Cost of Disability report but that the measures proposed alone would not be enough to meet the costs of disability. They pointed out that costs such as transport, medical supports and so on needed to be delivered by other Departments, but that in terms of reducing risk of poverty these proposals would look at changes to payments and measures to try and support more disabled people into employment.
The Green Paper sets out that the main aims are:
1. To encourage a higher level of employment for disabled to enhance their participation in society and reduce the risk of poverty and deprivation;
2. To better protect disabled people who cannot work from poverty and deprivation.
The green paper makes three changes to disability payments as follows:
1) Introduction of a Three-tiered Personal Support Payment:
The green paper is proposing to create a single payment system for disabled people called a Personal Support Payment, unifying different supports like Disability Allowance, Invalidity Pension and Blind Pension) with three different payment rates ( or Tiers) based on the needs of disabled people.
There was no detail on how assessment of need and “ability to work” was going to be carried out, or by whom. The language used below for how the tiers are described come from the Department’s Green Paper.
Tier one: “High support –Very low capacity to work”
This is for disabled people who the department say “are not able to work” and therefore will get a higher payment rate. The proposed higher rate is the same as the State Pension Contributory rate which is currently €265.30 a week
Tier two: “Medium support –Low to moderate capacity to work”
This will be for disabled people who have limited “capacity to work for at least 24 months” but are not “likely to be able to fully support themselves through paid employment alone for as long as their condition persists”. The payment would be €242.65 per week
Tier three: “Low support –Moderate to high capacity to work”
The disabled person is assessed as having a disability that is “ that they cannot do certain types of work activity (including the type of work they were doing before acquiring their disability)” but may be “capable of taking up” work which means it is a “realistic option for them to progress towards sustaining themselves through paid employment alone”. This payment is set at the current rate of €220 per week.
Alongside the new payments are proposals to link these with the offer or obligation to avail of public employment services.
The offer or obligation to avail of public employment services- what is being proposed in the Green Paper?
This would mean that if a disabled person was in receipt of a Personal Support Payment, they will have access to mainstream employment supports (including training and work placements). However, depending on what tier a disabled person is on, these would either be optional
Level 1: Access to and use of INTREO would be at the disabled person’s choice.
Level 2: INTREO will be “proactive” in offering supports and services to disabled people on this Tier 2. Disabled people will “be expected to make reasonable efforts both to engage with Intreo and to take part in training and other programmes appropriate to their circumstances”
Level 3: Disabled people will have to engage with INTREO and will have to take up reasonable offers and “places in training and employment programmes, and take up employment opportunities that are appropriate to their capacity and circumstances.”
The Green Paper says that payments will continue based on the “anticipated duration of a person’s restriction”. For those with a “permanent restriction” payment will not be time restricted and will continue without review. For the other “tiers” the Green Paper is proposing a 2 year period before “review”.
2. Introduction of new in-work supports
The current systems of disregards will be replaced by a working age payment model. This would create a greater link between welfare payments and employment earnings to ensure that a person would experience an increase in income where they take on additional work. The proposal in the Green Paper seeks to develop in-work supports based on the Working Family Payment model where a person receives a payment based on a percentage of the difference between their income and a specified threshold depending on the category they are assigned and the make-up of their family.
This would mean the proposed approach would replace the current income disregard and Partial Capacity Benefit and would provide a minimum income guarantee.
3. Addressing inconsistencies in eligibility
The paper proposes to unify the medical and age criteria of the new contributory and non-contributory payment. People would qualify for the payment based on social insurance contributions or a means test. It is proposed to raise the qualifying age for Disability Allowance to 18 to bring it in line with the other disability payments. In parallel with this, it is also proposed to extend the payment of Domiciliary Care Allowance to 18 years of age.
Concerns raised at the Green Paper launch:
Whilst there is an increase in payment in Tier one and Tier two, neither come close to the cost of disability in the Department’s report.
The “obligation” to engage with INTREO and take up training or work immediately raised concerns as ILMI raised that this sounded not dissimilar to the “Work Capacity Assessments” in the UK which used the language of “welfare reform” to make savings in the welfare budget and push disabled people into work, with huge human costs and suffering.
ILMI also raised concerns about the current capacity of mainstream employment services such as INTREO and the systemic barriers to inclusion of disabled people in the workforce, including the low expectations that systemic exclusion from employment has had on disabled people themselves.
Next steps for ILMI?
It is vital that as a national cross-impairment Disabled Persons Organisation that we crate a strong collective submission into this process.
We are going to have a discussions online to discuss the proposals and develop a clear sense of how to respond as a DPO.
These will take place on Wednesday 18th October at 11am and Tuesday 24th October at 7pm. Both will be on Zoom with agenda and information to follow.
To sign up for the discussions, email info@ilmi.ie and please indicate which session (day time or evening) work best for you.
More about the Green Paper
The Green Paper can be accessed here, which includes details of how the Department will create public consultations.