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negative behaviours or overtly negative outcomes such as disengagement and entrenched marginalisation.

The complexity of the current system also increases the likelihood of clerical errors which in turn causes frustration and non engagement with the system, and further marginalisation of those already most excluded.

Question 4 – To what extent is structural reform needed to deliver customer service improvements, drive down administration costs and cut the levels of error, overpayments and fraud?

We believe that if “customer” is to be a meaningful term then the DWP should move away from customer driven efficiency and correspond to the private sector “customer” model.

Structural reform is clearly needed to improve take up of entitlement opportunities; improve efficiency and simplify an overly complicated and bureaucratic system. We would welcome a system that removed the error margin caused by the need to multiply report change of circumstances.

Question 5 – Has the government identified the right set of principles to use to guide reform?

We would like to see a definition of vulnerability bolstering the principles. As previously stated we are concerned by the apparently overreaching conditionality enshrined in the principles and would welcome a balanced approach based on individual circumstances and need.

We consider it to be a glaring omission that a commitment to the learning and development of DWP staff to a level that enables universal, consistent implementation of the system is not embodied as a principle. We would advocate for a system that supported a cultural shift in attitude within JCP, where supporting individuals rather than administering conditions of entitlement or processing people, was seen as beneficial to all.

As a principle we would also have welcomed an enshrined commitment to service user involvement and targeted consultation.

We feel that there is too much emphasis on fraud and stopping entitlement and not enough on rewarding endeavour and people improving their situation outwith concept of conditionality.

Question 6 – Would an approach along the lines of the models set out in chapter 3 improve work incentives and hence help the government to reduce costs and tackle welfare dependency and poverty? Which elements would be most successful? What other approaches should the government consider?

We would welcome a model that simplified the system and provided increased accuracy and efficiency for the customer.

We would have concerns with any model that operated on the basis of “the credit being paid to the household member making the application”, on the grounds that this would imply that other benefits such as DLA would be potentially be factored into the equation, and also on

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