4 th March 2013 Contact: Paul Ginnell. EAPN Ireland, 16 Upper Ormond Quay, Dublin 1, Tel:

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1 EAPN Ireland Europe 2020 Working Group Submission to Department of the Taoiseach on National Reform Programme th March 2013 Contact: Paul Ginnell. EAPN Ireland, 16 Upper Ormond Quay, Dublin 1, paul@eapn.ie Tel: EAPN Ireland Europe 2020 Working Group welcomes the opportunity to make a submission to Ireland s National Reform Programme (NRP) The submission focuses on what are the key issues for the Working Group. The European Anti-Poverty Network (EAPN) Ireland convenes this working group to ensure the implementation of the social inclusion and equality commitments of the Europe 2020 strategy. It is made up of the following organisations: Age Action Ireland Congress Centres Network Disability Federation of Ireland EAPN Ireland Irish National Organisation of the Unemployed Irish Traveller Movement Migrant Rights Centre Ireland National Adult Literacy Agency National Youth Council of Ireland National Women s Council of Ireland One Family OPEN SIPTU Introduction Last year the Working Group wrote to the Taoiseach urging the Government to submit a full NRP despite the Commission s decision not to require Member States in Troika programmes to do so. We feel that not to submit a full NRP would signal that we are taking a back seat in conversations on the future of Europe and that it would be a missed opportunity to lay out in an integrated way how Ireland will address economic, environmental and social goals. While we are pleased that the Government plan to go beyond the update letter that is required by the Commission we are again disappointed that they have again decided not to submit a full NRP. We understand that the Government has a challenge in closing the budget deficit and is currently in a Troika programme but we still believe the Government has choices which could reduce the negative impact of the crisis in terms of poverty and social exclusion and inequality. We continue to urge the Government to engage fully with the 2013 questionnaire as part of National Social Report on social protection and social inclusion and in 2014 to submit a full National Social Report (NSR). The NSR process should be clearly linked to the NRP process and be based on the Guidelines developed by the EU Social Protection Committee. This would give an opportunity to tease out in greater detail the social impact of the crisis and the strategic development of policies to reduce poverty and social exclusion in a process which actively engaged with stakeholders including community organisations and people experiencing poverty and social exclusion. In the submission below we focus on a number of specific issues which need to be addressed in the NRP 1. Poverty as a cross cutting issue 1

2 A major overall concern for the Europe 2020 Working Group is that the macro-economic policies, with a focus on austerity as a means of closing the budget deficit, are undermining social goals including the poverty target, while also damaging the economy. Since 2008 consistent poverty has been on the increase in Ireland reaching 6.9% in Meanwhile unemployment has remained over 14% for over two years with long-term unemployment becoming a reality for a greater number of people. Priority 4 of the EU Annual Growth Survey is to tackle unemployment and the social consequences of the crisis. Within this a key element is promoting social inclusion and tackling poverty. The NRP Guidelines for 2013 ask Member States to take an integrated approach in their programmes. Specifically this means addressing the relationship between economic, social and environmental measures and the impact of structural reforms on each area. The issue of poverty and social exclusion and wider social concerns must therefore be a cross cutting concern across the full NRP. It is essential that an honest approach is taken to addressing this challenge in the macroeconomic section of the NRP and then presenting greater detail in the sections dealing with each target. The NRP must reflect the integrated approach as envisaged in the Europe 2020 Strategy and not one where certain elements dominate while progress towards others is secondary or postponed. As required by the NRP Guidelines, the NRP must present strategies for achieving this integrated approach. The recent Commission Communication on the Social Investment Package also presents a range of areas which Member States should be addressing in their NRPs 1. Poverty Impact Assessment The Irish NRP 2011 states that the application of poverty impact assessment to policies and programmes at design and review stages will continue in a transparent and constructive manner, including analyses of the poverty impact of the tax and welfare measures in the annual Budget using micro-simulation models. This does not currently appear to reflect the reality in the application of Poverty Impact Assessment which has the capacity, if implemented in a thorough manner, to be a very useful tool for limiting the negative poverty impact of policies. However it must be applied in a transparent way to all relevant policy areas, including Economic Policy. 2. Meeting the Poverty target The revised national social target for poverty reduction adopted by the Government in 2012 is to reduce consistent poverty to 4% by 2016 (interim target) and to 2% or less by 2020, from the 2010 baseline rate of 6.2%. However, between 2010 and 2011 consistent poverty increased from 6.3% (revised 2010 level) to 6.9% or more than 308,000 people. Therefore, without immediate and serious focus and policy change it looks unlikely that even the new less ambitious target will be met

3 In its recent report on Ireland the European Parliament highlighted that the Government has focused its spending cuts on areas of social spending and that as a result it may be difficult for the government to reconcile these austerity measures with the EU 2020 poverty goals 2. In its NRP (2011) and the 2012 NRP Update the Irish Government has highlighted that as a result of the crisis but also significantly because of the programme of fiscal consolidation in the early years fewer people may be lifted out of poverty or indeed the numbers may increase 3. The experience of recent years is that income supports and access to services have become more and more restricted and that despite the lack of jobs, the focus of solutions for those of working age have become more an more focused on access to employment. In the meantime poverty and social exclusion continue to grow particularly for more disadvantaged groups and communities. The focus of austerity measures with short term goals of reducing the budget deficit will result in long term social costs. This situation is unacceptible. The NRP 2010 in outlining the Government s approach to addressing poverty clearly states that a joined-up and multi-disciplinary approach to policy, involving a wide range of actors, is critical to meet the poverty target. The lifecycle approach in the National Action Plan for Social Inclusion highlights three inter-connected policy themes for tackling poverty: income support, activation and services. The joined-up approach is underpinned by the EU concept of active inclusion based on minimum income, inclusive labour markets and access to quality services. The Working Group agrees with this stated approach and the Commission Guidelines for NRPs specifically requires Member States to outline how they are implementing an active inclusion strategies. However, EU Joint Employment Report for 2013 has raised concerns about the lack of implementation of an integrated active inclusion approach at Member State level 4. The Irish NRP needs to outline a clear strategy for meeting its poverty target and addressing social exclusion along the lines of the multi-disciplinary approach outlined above. This must include addressing the specific needs of children, lone parents, people with disabilities, people in jobless households, migrants, Travellers, ethnic minorities, the homeless, carers and the working poor. It must also specifically address the needs of women who have been disproportionately hit by budget measures in the past number of years 5. The following are some of the issues the NRP 2013 needs to address if it is to take an integrated multi-disciplinary approach to meeting the poverty target and other social targets. i. Income supports Setting a minimum income standard: Since 2008 changes have been made to a range of income supports which have reduced rates or restricted access. These measures continued in Budget All of these measures further increase poverty levels for those on the lowest 2 page National_Reform_Programme/ TACS, Analysis of Budget 2011 and TASC (2012), Winners and Losers: Equality Lessons for Budget 3

4 incomes including many who are at work. The NRP needs to begin to outline a strategy for formally putting in place a process for identifying what a decent income standard is for various family types and then how these standards can be achieved. This standard must be based on meeting people s physical, social and psychological needs. The work already done by the Vincentian Partnership for Social Justice on Minimum Income Standards provides an essential starting point for work on this area. The recent European Commission Social Investment Package highlights the importance of establishing reference budgets, and urges Member States to progress this in their NRPs alongside other measures in the context of active inclusion 6. Single working age payments: The EAPN Europe Working Group in principle supports a single social assistance payment for all people of working age in principle provided that this is backed up by the necessary services, supports and pathways to employment, in line with the EU s Active Inclusion approach. Such an approach was outlined in the Department of Social Protections own proposals. The Report of the Joint Oireachtas Committee on Jobs, Social Protection and Education states that now is not the time to introduce a single social assistance payment as this integrated approach cannot be achieved. The 2012 NRP Update highlighted that the key objective of the major reform of child income support and of working age social assistance welfare schemes as implemented in Budget 2012 were to better support the transition from welfare to work. Many of these reforms impacted on lone parents with changes to eligibility for the One- Parent Family Payment and reductions in the earnings disregard. The actual impact of these measures is an increase in poverty levels and to further increase barriers to access to the labour market. The NRP therefore needs to reassess the implementation of elements of single social assistance payment in their context both of the impact on poverty and its own objective of supporting the transition from welfare to work. 3. Employment While we welcome the recent Quarterly National Household Survey showing the first increase in employment in 4 years the employment rate was 59.3% an increase of only 0.3% on a year previously 7. Unemployment in has remained at over 14% for two years and is now at 14.2%. This highlights the challenge of achieving Ireland s Europe 2020 employment target of increasing employment levels to 69-71% the employment rate for women and men aged from a level of 64.9% in Especially challenging in a context of limited investment. Apart from tackling the employment crisis in general and the growing levels of long term unemployment (now 59.9%) the Europe 2020 Working Group is particularly concerned that access to the labour market is approached in an inclusive manner and involves access to quality jobs. This involves ensuring that measures to address the creation of jobs and supporting people into employment, including those measures outlined in the Action Plan for Jobs, have a focus on the particular needs of those most distant from the labour market including. This includes lone parents, people with disabilities, Travellers, migrants, those living in disadvantaged communities and those with low educational and literacy levels etc

5 i. Pathways to Work Strategy The EAPN Ireland Europe 2020 Working Group is supportive of the Government s Pathways to Work Strategy. However, it is essential that the strategy not only meets the needs of those newly signing onto the live register but all those of working age distant from the labour market including those who are long term unemployed. a. Operation of Intreo Offices In July, the Department of Social Protection opened the first Intreo offices. These offices are an important element of the Government s Pathways to Work Strategy to reform the activation system in Ireland. The role of the Intreo offices is to support clients to access their welfare entitlements as quickly as possible and to identify options which support access to employment or training and education. There are a number of issues which should be highlighted in the context of the NRP and that need to be addressed if the Intreo offices are to be effective in providing a pathway to work for people of working age which should be addressed in the NRP. Intreo offices currently only provide services to those on the live-register and particularly to those newly signing on with the aim of preventing the drift into longterm unemployment. This results in little focus in Intreo offices on those already on the live register, almost 60% of whom are long term unemployed. Addressing the needs of this group is a key priority of the Department of Social Protection. The focus on engaging with those on the live register also excludes other people of working age, including those on lone parent and disabilities payments, who may be looking for support in moving from welfare to work. The full range of services in Intreo offices needs to be accessible for all people of working age and be sufficiently resourced and staffed to do so. Additionally to the above are deeply concerned at the deterioration in the non-intreo social protection system, the apparent collapse of the Supplementary Welfare System into the mainstream system and the lack of availability of a public employment service for those not in receipt of a Jobseekers Payment. There must be a greater balance within the Intreo contracts. The current contracts, which are signed by both the client and service provider, recognise that both the service provider and the client have responsibilities. However, while the client faces penalties for failing to meet its responsibilities or promises, there is no penalty on the Intreo service for failing to uphold its responsibilities to the client. Intreo staff must be able to provide clients with accurate and up to date information. Currently there are weaknesses in this system and reports of incorrect information leading to clients not accessing correct social welfare supports or having greater difficulty accessing employment, education or training options than should be the case. This must be addressed through on-going training or improved working methods whereby staff draw on expertise within their office or wider public services. The ability of jobseekers to access appropriate education and training options is key to taking up employment opportunities. It is therefore essential that the relationship between the Intreo service and the developing SOLAS and Local Education and Training Boards is clearly defined so that clients can move seamlessly between them. These services must also be open to all people of working age who need them and not just those on the live register. Activation services must continue to develop a relationship with employers who have a key role to play in supporting jobseekers gain greater work experience and skills. This must be monitored to ensure that it does not result in job displacement or exploitation of jobseekers. 5

6 b. The role of community and voluntary sector in activation The community and voluntary sector plays a very important role in activation programmes. This includes running a wide range of training and education programmes and providing placements for unemployed people through the Community Employment and Tus programmes. The close connection of community and voluntary organisations with the people and community they serve gives them an expertise and unique ability to develop and deliver these programmes in a way which best meets their needs. These organisations also deliver value for money for the programmes they deliver. Between 2008 and 2012, community and voluntary organisations experienced cuts in funding of approximately 35%, 8 with further cuts in There have been other changes which have resulted in the loss of independence of many of these bottom-up organisations, bringing them under more centralised control. These changes are doing damage to the infrastructure which enables the Government to engage people from more marginalised communities and groups in activation measures. The Government is also aligning the Local and Community Development Programme with local authorities. This will also potentially result in greater damage to the capacity to deliver on activation measures at local level 9. c. Gendered activation It is essential that in developing its activation measures that the Government recognises the different needs of women and men and adopts a gendered approach. The National Women s Council of Ireland report Careless to Careful Activation- making activation work for women 10 shows how well designed activation can play a positive role in enhancing gender equality. However this requires an ethic of care where policy and practice facilitate care and enable greater sharing of both care and domestic work between men and women. ii. In-Work Poverty and Decent Work While job creation including the successful implementation of the Action Plan for Jobs is essential the focus must be on creating quality jobs. This must also be a guiding principle for the implementation of the Youth Guarantee agreed at EU level. Between 2009 and 2011, in work poverty increased from 1.1% to 2.1%. This clearly indicates that access to work is not, in itself, a route out of poverty but must be accompanied by policies which ensure access to a decent income. The EAPN Ireland Europe 2020 Working Group is concerned at the increase in precarious work due to rise in casual, temporary and part time work under flexible conditions where more workers have little control over their working conditions. Part-time under-employment now represents 32.4% of total part-time employment having been 26.9% two years earlier 11. Increased flexibility of workers hours based on employer needs also reduces the capacity of part-time or under employed workers to access extra income either through additional work or access to social welfare supports. Research by the Mandate Trade Union 12 in 2012 has also shown the rise in precarious work where many employees, particularly in part-time work and with flexible terms and conditions, _ildn_position_on_key_proposals_ pdf Mandate Trade Union (2012), Decent Work? The Impact of the Recession on Low Paid Workers, 6

7 are extremely vulnerable to situations where they cannot earn a sufficient income to pay for essentials. Due to the nature of their employment and conditions for access to welfare supports they cannot supplement this income through additional work or access to the social welfare supports such as the Family Income Supplement. The report shows that workers had to borrow to meet basic needs which included borrowing from money lenders. Women and migrant workers are particularly highly represented amongst workers in precarious work situations. While access to quality work, including good working conditions and a decent wage, is the ideal, many low paid workers rely on access to social welfare supports to supplement their income. However, many elements of the social welfare system are inflexible and many very low paid workers cannot qualify for supports. The following are some of the specific issues which would contribute to improving the situation for workers. Under the current system, part time workers can only qualify for jobseekers payments (Jobseekers Benefit and Jobseekers Allowance) if their hours are worked within three days or less in a week. Many low paid part-time workers, even if working only a small number of hours, have their hours spread over more than three days thus making them ineligible for social welfare support. The criteria for access to jobseekers payments should therefore be changed from one based on days to one based on hours. The Social Welfare Act 2011 reduced the length of the social welfare week from 6 to 5 days for those in receipt of Jobseekers Benefit. This change was presented as a measure to encourage people to take up work by making it a more attractive alternative. However, in the experience of EAPN Ireland members it is having the opposite impact and acting as a barrier to employment due to the reduction in the ability of part time workers to earn an adequate income by combining income work and social welfare supports. The social welfare week for Jobseekers Benefit should be changed back to a six day week. The Family Income Supplement (FIS) plays an important role in supplementing the income of low paid workers protecting them from the worst impact of low income from work. However, despite information campaigns on FIS, many people who are eligible do not access it. The application process for FIS also involves the employer, which can act as a barrier to application even for those who are aware of it. The Family Income Supplement needs to be reformed so that those who qualify for it automatically receive it. Following the coming into force of the the Industrial Relations (Amendment) Act 2012 which reforms the Joint Labour Committees and Registered Employment Agreements (REAs) wage-setting mechanisms, the Labour Court is in the process of putting in place the infrastructure for the new JLCs. It is essential that the JLCs are set at a level which provides workers with a fair wage for their work. The NRP needs look at the above issues and outline in a comprehensive manner how the issue of in-work poverty and decent work will be addressed as an integrated part of its jobs strategy. 4. Education The Working Group believes that the education target needs to be broken down into sub targets for marginalised groups with a lower educational achievement across the education spectrum than the general population. This is particularly important as in recent years cuts 7

8 have been made to Traveller education supports, supports for Special Needs Assistants and language supports in schools. These cuts and others will have a particularly negative impact on groups already with lower education achievement and the education target needs to capture and prevent such changes while putting in place measures to ensure a more equitable educational outcomes for all children and social group across the whole system. Ireland s National Action Plan for Social Inclusion set a measure to reduce the proportion of the population aged with restricted literacy to between 10% and 15% by 2016, 13 from the level of 25% found in This target implies that the aim of government policy is to have only 301,960 adults of labour force age with serious literacy difficulties in Ireland by With currently 372,200 people in the labour force with less than a level 4 qualification 14, the government s adult literacy target suggests a complete lack of interest in seriously addressing this problem. In 2007 the National Skills Strategy (NSS) suggested that by the year 2020 there should be 45% with qualifications at levels 4 and 5 and 7% with qualifications at NFQ levels 1 to This equates to an up-skilling of nearly 300,000 workers with basic education needs. The latest report on the implementation of the National Skills Strategy shows that the slowest progress made so far has been with up-skilling those at FETAC Levels of 1-3 up to Levels 4 and 5. This group was identified as the most significant challenge to upskill for the period to A key factor in delivering on the targets is ensuring the acquisition of literacy and numeracy skills. 16 The current progress of the participation in lifelong learning benchmark shows that in 2009 the average participation is 9.3%, with Denmark (31.6%), Sweden (22.2%) and Finland (22.1%) being the best EU performers. Ireland is currently at 6.7%, decreasing since 2005 where it was 7.4% EU Funding Structural Funds and other EU Funding including new funds such as the Fund for European Aid for the Most Deprived and the separate fund for implementation of the youth guarantee are a key element of the Europe 2020 strategy. It is essential that the national operational programmes for all EU funds for the period have a clear focus on social inclusion and are geared towards the achievement of the poverty and social targets of Europe The ESF Regulation also recognises that in addressing social exclusion it is important not to focus only on labour market solutions and this must be recognised in the content of the ESF operational programme. Partnership with all relevant stakeholders including civil society organisations and NGOs and is also a key element of the General Regulations for the Structural Funds and this. Community and voluntary organisations must therefore be key partners in the design, implementation and monitoring of all EU Funds. This engagement must start as early as possible in the cycle for developing the Operational Programmes. Community organisations are the best placed to develop and implement programmes to address poverty and social exclusion. However, over the years EU funds including Structural Funds have become increasingly more distant from community and voluntary organisations 13 National Action Plan for Social Inclusion , page CSO website: Table S9a, Q. 4, Expert Group on Future Skills Needs (2007), Tomorrow s Skills: Towards a National Skills Strategy, page Department of Education and Science (2010), National Skills Strategy Implementation Statement 51&language=EN&link=link001&page=1&doc=

9 and more difficult to access. This must be addressed in the developing of the programmes for the funding period Effective Consultation Recital 16 of the EU Integrated Guidelines for Europe 2020 is clear on the importance of stakeholder engagement in the Europe 2020 process at all stages and levels including the engagement of social partners and representatives of civil society. Over the past number of years the EAPN Ireland Europe 2020 Working Group has been disappointed with the process for consultation and engagement on the NRP. This process must be more thorough and effective. While the opportunity to make a submission is welcome the limited timeframe is not. It is essential that any remaining opportunities to engage in the preparation for the NRP update for 2013 involves a good process leading to effective engagement. The input received in this consultation much also be reflected in the content of the NRP and subsequent measures. 9