Written evidence submitted by the Royal National Institute of Blind People (RNIB) to the Work and Pensions Select Committee inquiry into halving the disability employment gap.

4 May 2016

Executive summary

  1. Only one in four registered blind or partially sighted people of working age is in paid employment, and this number is falling.
  1. Blind and partially sighted people looking for work need specialist support on their journey towards employment, and there needs to be good referral systems to those specialist providers.
  1. Many blind and partially sighted jobseekers are a long way from the labour market, and require a more resource intensive model of support than is currently offered.
  1. There should be a greater role for charities and specialist organisations to deliver services to people with complex or multiple barriers to employment.
  1. Providers should be held to account by including performance targets around supporting blind and partially sighted job seekers, particularly those further from the labour market, into sustained employment.
  1. An innovation fund could be used to take greater risks to support those harder to help or further from the labour market.
  1. The Access to Work scheme is key to supporting employers to recruit disabled people, and should be promoted to employers more widely.
  1. Employment support programmes should be underpinned by a common, robust, and individualised assessment process, which recognises the barriers and enablers to employment faced by blind and partially sighted jobseekers.
  1. Cutting the ESA WRAG rate to the bare minimum, causing hardship, debt and stress, is unlikely to help disabled people seek work effectively, being more likely to disrupt their work capability preparations. Worrying about paying bills and just surviving will make it harder, not easier, to be ready to look for a job.
  1. RNIB supports the findings and recommendations of a 2014 report by the Learning and Work Institute (formerly the Centre for Economic and Social Inclusion), entitled 'Fit For Purpose', which outlines how to improve employment support for disabled people and those with health conditions.
  1. RNIB also supports the preliminary findings of a 2016 report to be published by the Learning and Work Institute, entitled 'On the Right Track', which outline the case for designing an assessment tool to act as a gateway to personalised and tailored support and services.

Introduction

  1. RNIB is the leading charity for blind and partially sighted people in the UK. We are a membership organisation with over 10,000 members who are blind, partially sighted or the friends and family of people with sight loss.Part of our work is to campaign on behalf of and fight for the rights of people with sight loss across the UK.
  1. We also deliver direct support and employment servicesto blind and partially sighted people seeking work, in partnership with other sight loss charities that form part of the RNIB Group: notably Action For Blind People.Employment support is delivered as part of our core services to customers, as well as operating within the supply chain of prime contractors to DWP welfare to work provision such as the Work Programme and Work Choice.
  1. We are therefore pleased to have the opportunity to respond to this consultation.

The facts

  1. There are just over 84,000 registered blind and partially sighted people of working age in the UK [1]. However, only one in four of those are in paid employment, and this number is falling [2]. This figure is even worse for people who are completely blind. Only around one in 10 people with poor functional vision is in paid employment.
  1. 1,010 blind or partially sighted people were enrolled onto the Work Programme between June 2011 and March 2014, yet it helped just 60 (approximately 6 per cent) into paid employment [3].
  1. RNIB currently make up for this failure by using our charitable resources. Last year alone, we supported over 600 blind and partially sighted people to find work or keep their job [4], with almost no access to statutory funding.

To what extent are the current range of proposed measures likely to achieve the Government’s ambition of closing the disability employment gap?

  1. Fundamental changes need to be made to the payment structures that incentivise providers to support those with the fewest barriers to employment, ahead of those with more complex problems such as sight loss.
  1. Most employment support services are delivered by non-specialist organisations that often lack sufficient knowledge about the particular needs of blind and partially sighted jobseekers, and can therefore be unable to deliver the specialist support required.
  1. Funding models for future employment support needs to reflect the complexity that blind and partially sighted people face.
  1. Providers should be held to account by including performance targets around supporting blind and partially sighted job seekers, particularly those further from the labour market, into sustained employment.
  1. Blind and partially sighted people should be able to access specialist support on any government employment programme, provided by organisations with the appropriate skills and tools to support people with sight loss.
  1. Whilst we mostly agree with allowing service providers the flexibility to design a portfolio of services for different client groups, (sometimes referred to as 'the black box approach'), there needs to be tighter service delivery standards, greater transparency around quality assurance of prime providers and their contracted supply chain, and an evaluation of customer satisfaction with services provided.
  1. Service providers should be required to provide a clear and detailed statement of service, so that blind and partially sighted people know what to expect from the programme, and be able to comment on its usefulness in progressing them towards employment.
  1. Providers should be required to give information to disabled people about the Access to Work scheme, and help with applying for support once a person is getting closer towards employment. Our experience tells us that awareness of Access to Work is shockingly low amongst blind and partially sighted people seeking work.
  1. Providers should be required to give, or arrange, in-work benefits advice to disabled people moving into employment. Disabled people reaching the stage at which they are ready to take up work may not be aware of the availability of Tax Credits, in-work Housing Benefit, Universal Credit etc. We would therefore like to see a benefits check offered as a standard part of the welfare-to-work process; either by the provider, or a referral to a specialist organisation.

How effective is the Disability Confident campaign in reducing barriers to employment and educating employers?

  1. Evidence suggests that the majority of employers have a negative attitude to employing a blind or partially sighted person [5].
  1. RNIB have produced a guide for employers that has been designed to address those concerns and sets out the benefits of employing a blind or partially sighted person. It covers everything they need to know about employing someone with sight loss, from the recruitment and interview process, to making sure an employee has the right equipment in place to carry out their role.
  1. Employers need to know what workplace adjustments are required for a person with sight loss to carry out particular roles. For example, IT and assistive technology haveopened up many jobs to blind and partially sighted people. Even with little or no sight, most jobs on a computer are entirely possible with assistive technology.
  1. The Access to Work scheme is key to supporting employers to recruit disabled people, and should be promoted to employers more widely.
  1. Assessments provided by the Access to Work scheme should be more holistic, delivered by sight loss specialists, and address the concerns an employer may have, rather than narrowly focussing on a list of equipment and support that ATW can fund.
  1. Blind and partially sighted people should be given greater power and opportunity to choose the provider of an Access to Work assessment from a pool of specialist providers. Applicants and their employers should be fully informed what to expect from a work-based assessment commissioned by ATW, and feedback systematically collected from customers and their employers on the quality of the assessment, which should be measured against a detailed statement of service.
  1. There can be long delays between applying for ATW and the purchase or provision of equipment. In the case of a new job, that delay prevents people from starting work and is frustrating for employers who want a new recruit to start work as soon as possible.
  1. Ambiguity and confusion exists around who the ATW equipment grant is for - the applicant or the employer. Employees can feel excluded when equipment is purchased as they often don't see a full copy of the assessment report, yet the employer is the recipient of the award. Once purchased, employers and employees are often unclear on ownership.

What should support for people with health conditions and disabilities in the proposed Work and Health programme look like?

  1. Blind and partially sighted people looking for work need specialist support on their journey towards employment. In addition to barriers common with anyone out of work for a long period, blind and partially sighted jobseekers have specific needs related to their sight loss.
  1. Most blind and partially sighted jobseekers are a long way from the labour market, and require a more specialised, resource intensive model of support than that currently being offered by the majority of contracted providers.
  1. Blind and partially sighted people who are seeking employmentshould be able to access specialist support, provided by an employment advisor who has the appropriate skills and tools to support blind and partially sighted jobseekers.Key areas include:
  • training to develop assistive technology skills
  • support to develop mobility skills and making the most of residual vision
  • support to develop confidence to communicate sight-specific needs and reasonable adjustments to employers
  • developing and delivering pre-employment training programmes to meet the complex needs of blind and partially sighted people
  • offering peer support to people much earlier
  • removing barriers to work experience
  • engaging local employment organisations much earlier.
  1. We also believe that there should be a greater role for charities and specialist organisations to deliver employment services to people with complex or multiple barriers to employment. However, we mostly find that the current system of prime providers, sub-contracted supply chain providers, and the payment by results model do not encourage participation by smaller providers of specialist services.
  1. RNIB and Action for Blind People have service delivery frameworks in place via our network of regional and local service delivery teams for carrying out direct employment support services for blind and partially sighted job seekers.
  1. Employment support services and policies for blind and partially sighted people of working age should include:
  • specialist employment programmes for blind and partially sighted people, providing increased numbers of job outcomes and retention rates
  • improved referral routes to those specialist employment services for blind and partially sighted people
  • increased availability of pre-employment support that meets the specific needs of blind and partially sighted jobseekers
  • a fair assessment process that accurately identifies the needs of blind and partially sighted people.
  1. Specialist provision should be offered to all blind and partially sighted people on any government employment programme, and there needs to be better systems to refer blind and partially sighted people to those specialist providers. This support should be provided by an employment advisor who has the appropriate skills and tools to support blind and partially sighted jobseekers.
  1. Blind and partially sighted people should be given greater power and opportunity to choose their employment support services from a pool of specialist providers, with specialist advice available to make an informed choice.
  1. RNIB has developed an employment assessment and action planning toolkit to identify the specific barriers and support needs facing a blind or partially sighted jobseeker. This freely available assessment model should be adopted by service providers as a standard tool when working with anyone with sight loss.
  1. RNIB fully supports the findings and recommendations of a 2014 report by the Learning and Work Institute (formerly the Centre for Economic and Social Inclusion), entitled 'Fit For Purpose', which outlines how to improve employment support for disabled people and those with health conditions [6]. We would like to recommend that the Committee studies this report in detail.

The role of the assessment

  1. Research has shown that a specialist, individualised assessment is crucial in determining the needs of blind and partially sighted jobseekers [7]. An assessment should identify a person's distance from the labour market, and / or job-readiness, in order to establish a baseline that can be compared with a reassessment following intervention. This can then record evidence of measurable success towards paid employment, enabling service providers to be paid for "soft outcomes" or the distance a person has travelled towards employment. Otherwise, the system will encourage neglect of those furthest away from work-readiness.
  1. An assessment should also be able to equip service providers with an accurate profile of their clients, based upon each individual’s particular skills, barriers and personal circumstances, and thereby identify and design effective interventions (an action plan) that are sensitive to the complex needs and circumstances of someone with sight loss.
  1. The assessment should also not just be seen as a one-off event. In-depth assessment can only occur over a period of time, particularly where there are multiple barriers, so any assessment system should include an in-built review – with the ability for individuals to move between levels of employment support, where circumstances change or new information becomes available.
  1. RNIB fully supports the preliminary findings of the forthcoming 2016 report to be published by the Learning and Work Institute, entitled 'On the Right Track', which outline the case for designing a better assessment tool that can act as a gateway to accessing personalised and tailored support and services. We would like to recommend that the Committee studies this report upon its publication.

What are the likely impacts on disability employment of the abolition of the Employment and Support Allowance Work Related Activity component?

  1. The Government has argued that the reduced income will provide a stronger incentive to seek work. This may be true of some individuals, but we consider (on the basis of the many communications received from visually impaired people during the passage of the Welfare Reform and Work Bill) that the Government is creating strong incentives in the opposite direction.
  1. Cutting the ESA WRAG rate to the bare minimum, causing hardship, debt and stress, is unlikely to help disabled people seek work effectively, being more likely to disrupt their work capability preparations. Worrying about paying bills and just surviving will make it harder, not easier, to be ready to look for a job.
  1. Moreover, the financial differential between the WRAG and Support Group would become hugely problematic. At current benefit rates, it is £7.15 per week. Under the proposed regime, it would be £36.20.
  1. Among the effects of this are:
  • those in the Support Group who might be interested, in spite of their ill-health or disability, to try their hand at some work-related activity, would now face a huge disincentive;
  • those in the WRAG with the most serious health problems or disabilities would have a strong incentive to seek to move into the Support Group;
  • those wrongly placed in the WRAG, who should be in the Support Group, would be even more severely disadvantaged than now by poor decision-making;
  • the anomaly whereby visually impaired people who are Braille readers can be excluded from the Support Group would be even more unfair in its effect (visually impaired people who would otherwise be in the Support Group can be placed in the WRAG if they can read Braille, even if they have no realistic prospect of moving into work).
  1. The forthcoming Work and Health White Paper is likely to lead to a review of the interface between employment and benefits. This would present an opportunity to invest in a better level of financial support for people in the WRAG. While this would mean narrowing a gap that the Government has just legislated to widen, it may be politically acceptable in the context of measures greatly to improve the back-to-work support on offer.
  1. On the specific point of the “Braille anomaly”, we would like to see this removed. It is simply untrue that the ability to read Braille enhances employment prospects.

Conclusion

  1. RNIB hopes that this inquiry will contribute to a successful approach to halving the disability employment gap. There needs to be a sea-change in the proportionof blind and partially sighted people of working age achieving greater independence through paid employment.
  1. We hope that lessons can be learned from the shortcomings in the current Work Programme, which has failed blind and partially sighted participants, and an innovative approach developed to supporting more blind and partially sighted people find and keep work.
  1. Should the Committee so wish, we would also be happy to provide oral evidence in relation to these issues.

References

1. RNIB, 2014. Evidence based review: people of working age. Available from