What Are the Proposed Changes?

Department for Work & Pensions consultation on aids and appliances and the daily living component of Personal Independence Payment (PIP) – brief outline

The DWP is considering making changes to the assessment of entitlement to the PIP daily living component and is currently conducting a public consultation. The consultation period ends on 29 January 2016. Information about the proposals and consultation is here

What are the proposed changes?

The DWP says that (as of September 2015) around 35% of people receiving the standard daily living component of PIP have been awarded points solely on the basis of the descriptors around the need to use an aid or appliance to complete a daily living activity. The DWP also says that the proportion of people awarded the daily living component on this basis is rising.

The DWP considers that PIP claimants who receive an award solely on the basis of their need to use aids and appliances are likely to have a low level of disability and also a low level of extra costs related to their disability. They draw on a very small-scale survey in support of this (see below).

As a result of this, the DWP is considering reducing the importance of the need to use aids and appliances in the assessment of entitlement to the PIP daily living component. The consultation sets out five proposals to achieve this. All of the proposals would result in a reduced level of entitlement to PIP, with many blind and partially sighted people no longer entitled to any payment of the daily living component at all.

Briefly[1], the proposals for affected claimants are:

1. A one-off lump sum instead of a regular benefit payment.

2. A lower rate of benefit.

3. A requirement that some points must come from other descriptors.

4. A restricted definition of aids and appliances.

5. Halving the number of points from 2 to 1.

But what’s the problem with the current rules?

It is necessary to be awarded at least eight points to qualify for the daily living component of PIP and some claimants indeed achieve this substantially or entirely through the “aids and appliances” route. The DWP sees this as a problem, somehow indicating a low level of extra costs of disability among these claimants. We do not see it as a problem – it merely reflects the range of activities which their disability affects.

We would not wish to see the consultation focused around a comparison of the DWP options, as it is clear to us that none of them is remotely satisfactory. PIP may not be perfect, but in respect of the role of aids and appliances, it is not broken and does not need to be fixed.

Dubious research

The DWP claims to have evidence of a low level of extra costs and cites a small survey of 105 claimants. This is obviously a very small sample and runs contrary to our experience of the additional daily living costs faced by blind and partially sighted people – such as extra heating due to being at home more; and paying for help with shopping, cleaning, gardening, decorating and so on.

A proxy

It is important to be clear that the use of aids and appliances is intended to act as a proxy for extra costs that a person with disabilities would be expected to incur. In places, the consultation document recognises this; but elsewhere seems to suggest that the purpose of the benefit is to purchase the aids and appliances in question. It is not – it is to help meet the extra costs of disability. This is a significant confusion that needs to be weeded out of the debate.

The need to use an aid or appliance is not an indication of a low level of disability, or of low ongoing disability-related extra costs.

The cost of an aid or appliance cannot be directly related to its usefulness to a disabled person, or be seen as a measure of the level of a person's disability. Just because an aid or appliance may also be used by non-disabled people does not mean that it may not have a high importance to a disabled person.

The need to use an aid or appliance was designed as part of the PIP assessment process to be a proxy for having a level of disability not necessarily covered by the 10 daily living activities.The principle of using aids and appliances as a proxy measure of disability was important to the overall design of PIP. The 10 listed daily living activities do not cover all the areas of difficulty a disabled person may have in daily living (for example, getting out of bed) so the aids and appliances descriptors were designed as a way to recognise and account for impairments and difficulties that may affect activities not specifically included in PIP.

Many visually impaired people receive PIP on the basis of their need for aids and appliances. Visually impaired people who have some usable sight may not score points via descriptor 8e (cannot read signs, symbols or words at all) - but may score via 8b for their use of an aid, such as a magnifier. If that person is also assessed as needing an aid in all the other relevant activities, such as washing, dressing, managing medication, they will be at risk of losing entitlement to the daily living PIP component completely under all five of the DWP's proposed options.

T: 020 7391 2123

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rnib.org.uk

[1]See consultation document, paras. 23 and following, for full details.