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the basis of potential for negative control and abuse of funds by a single household member.

We would advocate for a higher initial disregard level and longer, graduated taper for homeless people on the grounds of vulnerability and as a preventative tool in saving potential future housing and social breakdown costs.

Homeless people living in hostels and other supported accommodation often have to pay high rent charges which can make it difficult to benefit by working, a higher earnings disregard in situations of acute housing need such as these would have far reaching impact on the employability aspirations and reality of homeless people.

We feel that the Mirrlees model would increase child poverty and aggravate the other negative factors such as poor educational attainment and health and well-being that can emanate from this.  We would also have great concern at the introduction of any model that cuts benefit rates from their already meagre amount, as this would also significantly impact on the aforementioned factors and indeed on levels of homelessness.

Streamlining the system via any of these models will only make it more accessible and efficient if there is in-built flexibility to individually assess and support those on the margins who are hardest to reach, the paper offers no suggestion that the necessary safeguards would exist.

Question 7 – Do you think we should increase the obligations on benefit claimants who can work to take the steps necessary to seek and enter work?

We object to the underlying notion that most claimants are ‘at it’. We believe that conditionality as a blanket force does not work long term but would again reiterate the importance of a tailored approach. We would prefer an investment in employability as opposed to a target led focus on employment as this would better incorporate those people furthest from the labour market, and support those closer to it that still face additional barriers.  Non-financial sanctions that support a person’s employability as part of the process would be preferable.  A drive towards buy in for work placements by employers would be preferable but not necessarily achievable. There is a fundamental lack of preparation for work that is not provided in a coercive context.

Question 8 – Do you think that we should have a system of conditionality which aims to maximise the amount of work a person does, consistent with their personal circumstances?

No. We believe that, in the both the short and long term, taking a strong arm approach to maximising hours will alienate people from the employability process and create more problems than it would solve. Access to ongoing advice and support to those on lesser working hours would be more beneficial.

Question 9 – If you agree that there should be greater localism what local flexibility would be required to deliver this?

There would need to be a greater opportunity to holistically assess customers through frontline worker up-skilling and training and empowerment to make decisions based on local factors such as the local job market, housing and travel costs. This should also be tied into awareness raising of social areas in local areas, and more formal dialogue with contracted

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