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Response to Improving Lives: The Work, Health and Disability Green Paper

UK Government consultation

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.

This response makes the following recommendations:

  • It is essential to ensure that Work Coaches are appropriately qualified, trained and recognised for any additional responsibilities they have, especially if they are expected to have conversations with those with sometimes serious mental and physical health conditions.

  • Rather than the generalist approach in which work coaches are expected to deal with a mixed case load of clients, and specialist knowledge being only available as second tier support for work coaches, CAS recommends there should be specialisms that work coaches can develop alongside their generalist role.

  • In-work progression support 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.

  • CAS is concerned about how the ‘Work and Health Conversation’ will be perceived by claimants, and recommends that this is voluntary rather than mandatory, and is framed as a ‘work and participation’ conversation which recognises the health outcomes of a number of activities, both paid and non-paid.

  • The DWP should focus on improving the quality of initial decisions regarding someone’s eligibility for ESA. If an individual receives an accurate decision at the initial claim stage and is clear about what financial support they are entitled to, they will be in a much better position to have conversations with health professionals, employers and work coaches about taking steps towards returning to work.

  • Given the ongoing issues with the Work Capability Assessment, separating decisions about benefit entitlement from the discussions about employment support may be a positive step. However, this would depend on any role that conditionality would continue to play in determining ongoing benefit entitlement, the extent to which sanctions would continue as part of the system, and the role of Work Coaches in setting mandatory activities and making referrals for potential sanction.

  • It should be recognised that people will require financial support to be able to take part in work-related activity, visit the Jobcentre, pay for essential living costs such as food and heating, together with any additional costs arising from disabilities and health conditions. Citizens Advice Scotland remains concerned about the potential negative impact of the abolition of the ESA Work Related Activity component and its Universal Credit equivalent.

  • CAS would like to see employment-related support that is voluntary, flexible, not based on the benefit someone is in receipt of, and that offers a menu of choices to create a personalised route to work. CAS recommends that the UK Government works closely with the Scottish Government as the devolved employability programmes are developed. 

  • CAS welcomes the decision to exempt people with the most severe conditions and disabilities for reassessments. In general, CAS supports the introduction of long-term awards where claimants have conditions that are unlikely to improve.

  • CAS recommends that the Government draws on existing research to define what good and appropriate work is, to ensure that people are not forced into low quality, stressful and insecure jobs which may have a detrimental effect on their health.

  • CAS recommends the creation of a statutory Employment Commission to oversee the enforcement of employment law, with the legislative teeth to target rogue employers.

  • CAS welcomes a reform of Statutory Sick Pay (SSP) that would see employees who return to work on reduced hours earning less than the SSP rate (£88.45 per week), have their wages topped up by their employers to reach this level, rather than losing entitlement to any SSP as is presently the case.

  • In order to improve the processing of fit notes CAS recommends that fit notes are sent directly from the health professional to the Benefit Delivery Centre, rather than having to be posted to the centralised mail handling centre.

Rhiannon Sims and Rob Gowans
Publication date
February 2017
Publication type
Number of pages