CIH response to Income related benefits: estimates of take-up, proposed cessation of the national statistics series October 2012 For attention of Simon Lunn at IRB.Takeup@dwp.gsi.gov.uk This consultation response is one of a series published by CIH. Further responses to key housing developments can be downloaded from: http://www.cih.org Shaping the Housing and Community Agendas Page 1 of 5
A. Introduction The Chartered Institute of Housing (CIH) is the professional body for people involved in housing and communities, with over 22,000 members across the UK and Asian Pacific. We are a registered charity and a not-for profit organisation. Our mission is to maximise the contribution that our members make to the wellbeing of communities. Our vision is to be the first point of contact for and credible voice of anyone involved or interested in housing. We believe the timing of this proposed cessation will be detrimental to the ongoing evaluation and implementation of welfare reform and is ill conceived. Whilst it is evident that in their current form the benefits related to this consultation will cease under universal credit, which is being rolled out from October 2013, those benefits will still be in operation for the foreseeable future and into 2016/17 for some existing claimants. Indeed the current ONS consultation on the production and dissemination of claimant count statistics, following the introduction of universal credit (released 3 rd October 2012) specifically notes: In October 2013, Universal Credit will start to be rolled out for JSA claimants across the country. Initially, new claimants will move to Universal Credit instead of JSA, with a migration of the existing caseload following later. Currently, the migration of JSA claimants is expected to be completed in 2015. Recipients of other welfare benefits and tax credits will move onto Universal Credit between 2014 and 2017. Therefore, to cease publication of take up statistics now, given there will be potentially four more years before all existing claimants move to UC coupled with the inherent time lag between collation and publication of statistics, is deeply worrying and we would urge DWP to reconsider this position. B. Specific comments on consultation questions Q1: Do you use information from income related benefits: estimates of take up? Yes, we currently use the information in a wide variety of ways, including and not limited to: understanding current take up and costs understanding estimates of need and demand understanding the amounts of unclaimed benefits and potential reasons for non takeup to increase awareness and take up of benefits aiding research and policy influencing/lobbying activities Page 2 of 5
and to aid our ability to support MPs, Ministers and Lords in terms of parliamentary questions and debates Q2: What would be the effect of not having this information? The take up statistics are vital to understand the process of claiming, estimating numbers of eligible but not claiming, and therefore gaining an understanding of the dynamics of the process. In our opinion, these statistics need to be produced for the foreseeable future. Their collation, monitoring and dissemination form a vital part of being able to compare take up of such benefits before and after the introduction of Universal Credit. If such comprehensive statistics are not available, government/ministers and others will not know if Universal Credit is achieving its stated aims. We would also note that take-up statistics are an indicator of demand. Without information on take-up the government will not be able to predict the saving to be expected from changing to UC. The current February 2012 report of the 2009/10 statistics, notes the total amount of unclaimed benefit was between 7.52 and 12.31 billion. Given the time lag with which the report takes to produce, it would not be feasible to stop production of these statistics until at least 2016 (based on 2013 take up figures at the point at which UC comes into play for new claimants). As UC will be rolled out to existing claimants up until 2017, we would question whether in actuality, anything should change to these statistics up until the point all existing claimants are switched from existing benefits to UC? Further in order to evaluate the overall success of UC and welfare reform, comprehensive statistics on take up before UC comes into play for new claimants and in transition for existing claimants, then these statistics will need to be contemporaneous and reliable at that switch point and onwards. To remove these statistics leaving only 2009/10 data would compromise the evaluation of welfare reform overall. Q3: Have you any other views or comments on the proposal to discontinue the statistics? We do not support the proposed cessation of income related benefit take up statistics. As it stands currently, the proposal is retrospective in ceasing publication of statistics, which cover the period up to 2009/10 (released in February 2012). Ceasing publication of statistics that only show 2009/10 data means the last three years worth of statistics related to take-up under the Coalition government would effectively disappear. This would not enable the transparency agenda or to see the impact of the current recession on benefit take-up. Page 3 of 5
A three-year time lag as it stands would only make comparison worse for both government/ministers and users of the statistics; indeed, we would question how government would be able to compare UC with previous statistics and make the necessary claims of saving money? We would suggest that there is a real need for DWP and ONS to consider how UC statistics will need to be formulated to give a complete picture and enable comparison with take up statistics of CTB, PC and so on as now. Given UC will be rolled in over time it makes sense to continue collation and publication of statistics relevant to each benefit statistic immediately before, during and after implementation of UC to ensure consistency, transparency and robustness of data. Whilst complete and direct comparison may not be possible, some formulation and methodology could be developed to enable a seamless transition. For example, in UC statistics, it will be important not to simply collect numbers of recipients of UC/costs, but also the breakdown of the different elements within that, so that it becomes possible to see the consequences of CTB transition into CTRS; in work and out of work benefits and housing costs. The consultation document gives staffing costs as the justification for the cessation of these statistics which we do not believe to be adequate justification to cease publication. The view that scrapping these statistics would save two full time equivalent posts is surprising; given an expectation that as the production of such statistics is a repeated procedure over time, hence such statistics should take fewer staff than newer statistics. The paper makes a number of assertions and fails to make clear what they mean: it suggests the reduction in number of statistical staff would enable a focus on the delivery of priority statistics without any mention as to what those statistics are it also makes some strong claims that option 1 do nothing would require the cessation of other work to resource it without specifying what that other work would be. Based on these points, it is therefore difficult to judge the real impact of cessation of production of the statistics. Q4: If you are not in favour of the main proposal, which if any of the options do you prefer and why? It should be evident from our response above, that in our view, the publication of the statistics should continue as before. Option 1 do nothing is therefore our preferred option. None of the alternative options are particularly welcome or appropriate. Looking at options 2 and 3 we make the following observations:: Page 4 of 5
Option 2: same range of benefits with a simplified methodology would rely on a simulation model, running a projected or forecasted data modelled on existing statistics. This would not be as reliable. It also states that this option would need substantial development work for the 20/13 survey year when UC is introduced yet this would be the same for any option! Given the current situation whereby data captured in 2009/10 was released in February 2012, it is likely that a longer time lag will be needed to ensure accurate statistics are available and reported. Option 3: publication of a reduced set of benefits this is not helpful. It would not enable comparison (even in a limited way) of benefits through time. Pension credit is not the only relevant benefit data that would be needed and it is not clear why this would be more relevant than other benefits. C. Conclusion Given this is a time of major reform of the social security system, it is ever more important to understand what is happening in terms of benefit take up rather than less information. Consequently, as the current range of benefits within this publication series are effectively to be deleted at the point at which all existing claimants are moved onto UC (potentially in late 2017), publishing a reduced set of benefits is not likely to be meaningful in the short to medium term. As previously stated, there is a need to know the equivalent take up statistics for UC in the future and hence we would request access to more complete data not less and therefore strongly urge DWP to continue the publication of the current set of statistics as per option 1. Contact: For further information on our welfare reform policy activity, please contact Siân Sankey, Policy Manager, CIH Email: Sian.sankey@cih.org Tel: 024 7685 1741 Page 5 of 5