Universal Credit Frontline Network

Citizens Advice Scotland (CAS) welcomes the opportunity to provide evidence to the Committee’s inquiry. In 2015/16, citizens advice bureaux in Scotland advised clients on 227,561 new issues related to social security benefits. Of those, 98,699 (43%) related to the six legacy benefits that are due to be replaced by Universal Credit. It is likely that Universal Credit will eventually become the largest single issue that Scotland’s CAB Network provides advice on, and in areas where Full Service Universal Credit has already been rolled out, it is quickly beginning to take up a significant proportion of CAB advisers’ time.

Citizens Advice Scotland (CAS) warmly welcomes the opportunity to respond to this consultation. These draft regulations represent the first piece of legislation as part of the social security powers devolved to the Scottish Government under the Scotland Act 2016. The use of the Universal Credit flexibilities has been of considerable interest to CAS, alongside the wider rollout of Universal Credit, which is already a significant impact on many CAB clients.

CAS welcomes the Government’s ambition to reduce the disability employment gap, which is important in ensuring equality, fairness in the workplace and helping people with disabilities and health conditions maximise their incomes. However, it should be recognised that there are people who will not be able to undertake paid work because of their condition or impairment, in a number of cases for the remainder of their life.

Designing a new social security system for Scotland is a major opportunity and challenge. CAS has attempted to bring the best of our unique evidence base to inform the development of the new system based on the experiences of those who work with the current system on a daily basis. In developing a substantial response to the Scottish Government’s recent public consultation on the devolved social security system, CAS carried out specific engagement activity with 144 CAB clients and 102 CAB advisers with direct experience of the current system, in addition to CAB case information which provide real time insights into the daily operation of the system.

Designing a new social security system for Scotland is a major opportunity and challenge. In this substantial consultation response, Citizens Advice Scotland has attempted to bring the best of our unique evidence base to inform the development of the new system based on the experiences of those who work with the current system on a daily basis.

This report presents many of the Universal Credit cases that Scotland’s CAB network has advised on during the first year of the rollout. At this stage, it is a only a small fraction of the people who will eventually receive Universal Credit – single jobseekers with ‘simple’ claims. However, the evidence allows us to start to identify some of the challenges that may stand in the way of the success of Universal Credit and to make recommendations for how these obstacles can be overcome. These challenges fall into three groups – design challenges, transitional and administrative challenges and future challenges.

This briefing focuses on the opportunities that the devolution of social security powers offers to Scotland – it is the chance to design a system that has the principles of dignity and respect at its heart. The following pages outline the challenges and issues that the parliament needs to address to make this system a reality.

 Citizens Advice Scotland is extremely concerned regarding the proposals to reduce the value of the Work Related Activity (WRAG) component of Employment and Support Allowance (ESA). The principle underlying the WRAG is to take people who, while unable to work at present, could do so in the future, and provide them with financial support, advice and training to return to the workforce. The changes proposed in the Bill run counter to this principle and risk serious detriment to the often vulnerable claimants in this group.

In-work progression support provided should be appropriate to an individual claimant’s circumstances. Support should aim to help claimants find a job that is better suited to their skills, experience, ambitions and individual requirements. It should not merely consist of setting targets to apply for a particular number of jobs each week, without regard to suitability or quality. If mandatory requirements are set, caution should be taken that they are reasonable and appropriate.

Citizens Advice Scotland is extremely concerned that a number of the proposals contained in the Welfare Reform and Work Bill would have a detrimental impact on CAB clients in Scotland who have already been negatively affected by changes to the social security system in the last Parliament. These negative consequences include a rise in rent arrears; pressure on homeless services; and an increase in the number of people who are unable to make ends meet, who accrue priority debt or who require a referral to a food bank.