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Disability Federation of Ireland

 

Recommendations for Budget 2017

Submission to the Department of Social Protection

 

July 2016

1              Introduction

 

The Disability Federation of Ireland welcomes the new Programme for Partnership statement that

“A fair society must lean on a strong economy. But that strong economy will work primarily to create a fair and compassionate society which people can feel part of and proud of, a society for everyone, at every stage of their lives.”

 

This Government has committed to ratify the UN Convention on the Rights of People with Disabilities by the end of 2016, leading Budget 2017 to be the first to consider its responsibilities to people with disabilities. Budgetary decisions will need to be in accordance with Article 28- Adequate Standard of Living and Social Protection, and the National Disability Strategy.

 

Budget 2017 is the first opportunity that this Government will have to deliver on their promise of social, not just economic repair. During the recession, the levels of consistent poverty in Ireland increased from 4.2% in 2008 to 8% in 2014. Levels of material deprivation also rose from 11.8% in 2007 to 29.3% in 2014, and despite the lowering of the poverty line, the rates of people with disability continue to increase from 14.1% in 2009 to 16.3% in 2014[1]. This had a magnified impact on people with a disability, who spend over one third of an average disposable weekly income to cover disability associated costs.[2]

 

However, Budget 2017 cannot overlook the reality of in-work poverty, and must commit to ensuring that work pays, since disability associated costs still affect them.[3] Additionally, Budget 2017 must commit to long term measures to address both in-work and out of work poverty rates for people with disabilities through the following measures: introduce impact assessments, review measures of poverty, address the associated costs of having a disability through increases in Disability Allowance, and introduction of relevant tax credits.

 

People must be guaranteed minimum income that addresses the cost of living with a disability. This cost must be met by widening the tax base. A low tax economy is incompatible with the delivery of Programme for Government commitments to create a fairer society. Taxation plays a very important role in redistributing wealth, provision of health, and social services required at some point by all citizens of Ireland [4]. Introducing a wider tax base has the potential to reverse the trend of recent regressive budgets which further drive people with disabilities into poverty.

 

Work must pay for people with disabilities. The bottom 20% of earners did not benefit from Budget 2016[5], where people with disabilities are overrepresented. Systemic cross-departmental issues such as medical card eligibility, and functioning of activation and grant schemes must be reviewed, and designed to serve jobseekers.

 

In order to begin the work of social repair, the Department of Social Protection must invest in repairing the relationship and trust in the systems that serve Ireland’s disabled citizens. This is critical not only in giving confidence to potential jobseekers to move from welfare to work, but developing more innovative responses to social inclusion.

 

The 600,000 people with disabilities in Ireland, their families, and supporting organisations have a high expectation that Budget 2017 will make decisions that will raise their quality of life, and the range of opportunities open to them in very tangible ways.

 

Summary of Recommendations

 

Listed below are all recommendations for Budget 2017, in order of their occurrence.

 

1.            Budget 2017 must fully implement the Government Guidelines for carrying out Poverty Impact Assessments.

2.            Introduce a disability–adjusted poverty and inequality estimates, and equivalence scales so that poverty amongst people with disabilities is measured accurately.

3.            Budget 2017 must guarantee a minimum income that gives independence to all people with a disability.

4.            Minimum income must account for the cost of disability.

5.            Extend the work on “making work pay” to address the cost of living with a disability for those not in work.

6.            Introduce an increase of €20 to Disability Allowance as an interim measure to ensure an adequate minimum income for people with a disability that reflects the extra costs of living with a disability, and protect supplementary benefits such as the Household Benefits Package, Domiciliary Care Allowance, and Free Travel Scheme.

7.            Equality proof the design of all activation training and support measures under the auspices of the Department to end discriminatory practices of exclusion of those not on the live register from activation schemes.

8.            Equality proof payment policies, during education and training, to ensure that disabled students can access Erasmus placements and work placements abroad on par with their peers.

9.            Introduce tax credits for those in work to account for the cost of disability.

10.          Invest in the development of multi-stakeholder relationships on an ongoing basis to foster greater trust, building shared understanding, collaboration and innovation.

11.          Introduce protocols for greater flexibility and timeliness for those who move in and out of employment due to their episodic conditions.

12.          Eligibility for medical card must be based on need, and not income for those with long term conditions which are not going to go away.

13.          Devise a replacement for the partial capacity scheme that is responsive to individual circumstance and need in consultation with all stakeholders.

14.          Replace the workplace adaptation grant with a person centred scheme that allows people to access the technology they need in order to progress through to work, and sustain that work using assistive technologies and other equipment that supports them to be active members of society.

 

2. Recommendations regarding income and poverty reduction

 

2.1. Budget and Policy Proofing 

The Programme for Partnership commits to reforming the budgetary process, focussing on developing the process of budget and policy proofing in order to advance equality, reduce poverty, and strengthen rights. We welcome this commitment, and ask that assessments are carried out as a planning tool in advance of budgetary decisions, which must be in line with the current National Action Plan for Social Inclusion 2007-2016. They must also include cost benefit analysis of all relevant taxation and welfare payments. This needs to happen with robust consultation and input from people with direct experience of both living on disability payments, and the Irish Human Rights and Equality Commission.

 

Recommendation 1.

Budget 2017 must fully implement the Government Guidelines for carrying out Poverty Impact Assessments.

 

2.2 Measuring poverty amongst people with disabilities

 

Without an accurate measure of poverty amongst people with disabilities, policy responses to addressing poverty will be ineffective. Current measures of measuring poverty do not include costs of living with a disability, and under-estimate poverty and deprivation levels.   The way in which poverty is measured needs to be changed to ensure that people with disabilities’ living circumstances are accurately reflected, and that the Poverty Impact Assessments are accurate. The Survey on Income and Living Conditions  is primarily grounded in measures based on income, which does not take into account the fact that the cost of disability is based on expenses they incur because of having a disability. Deprivation levels for people with disabilities have risen from 30% to 53% since 2008, which tells us that poverty is rising. However, these figures do not account for how much of this is due to costs associated with disability, such as people going without fulfilling prescriptions, or participating in their communities.

 

Recommendation 2.

Introduce a disability–adjusted poverty and inequality estimates, and equivalence scales so that poverty amongst people with disabilities is measured accurately. 

 

 

2.3. A Secured Minimum Income

 

Over half of those living in jobless households are either children or adults with a disability. Households headed by people with a disability are twice as likely to experience unemployment as other households . They have a right to an income that supports them to live with dignity under the UNCRPD. Budget 2017 must honour that commitment regardless of work status. 

Income must also reflect the reality that having a disability costs money. The economic costs of living with a disability are about 35% of income (€207) per week.  This includes additional income required by households at median income levels to attain the same standard of living as an equivalent non-disabled household.

Examples of these costs include prescription charges, consultant fees in order to get applications for benefits over the bar, and vital therapies such as speech and language therapy. Furthermore, water charges, property tax, and bin charges disproportionately affect people living with a disability who already face extra costs, but this was not considered when the policies were formed.

Addressing the income issue requires commitment to a systemic response to addressing costs across several government departments. The programme of research being conducted on making work pay must to be expanded to include those living on Disability Allowance, and associated disability payments. In the meantime, the very real effects of the recession are being felt by people with disabilities on a day to day basis, and this needs to be addressed in the short term.

 

Recommendation 3.

Budget 2017 must guarantee a minimum income that gives independence to all people with a disability.

Recommendation 4.

Minimum income must account for the cost of disability.

 

Recommendation 5.

Extend the work on “making work pay” to address the cost of living with a disability for those not in work.

Recommendation 6.

Introduce an increase of €20 to Disability Allowance as an interim measure to ensure an adequate minimum income for people with a disability that reflects the extra costs of living with a disability, and protect supplementary benefits such as the Household Benefits Package, Domiciliary Care Allowance and Free Travel Scheme.

 

3 Employment and Making Work Pay recommendations

 

3.1 Equality of Access:

 

The Department of Social Protection must proactively engage with people with disabilities and work towards developing a more positive relationship with disabled jobseekers. This is central to the delivery of real outcomes under the Comprehensive Employment Strategy.

 

It must also involve equality proofing of all activation and training schemes, not only to end the practice of exclusion, but to actively engage and support people to engage and participate. Gateway, Momentum and the Youth Guarantee must form part of the suite of options offered to disabled jobseekers. The long standing issue of exclusion from the Youth Guarantee, for example, is not remedied by changing the policy to “not exclude” people.

 

Young people with a disability must have supports in education and training to prepare them for employment through various means, such as the retention of payments in education, support to participate in Erasmus programmes, and access to work placements abroad without threat to payment.

 

 

Recommendation 7.

Equality proof the design of all activation training and support measures under the auspices of the Department to end discriminatory practices of exclusion of those not on the live register from activation schemes.

 

Recommendation 8.

Equality proof payment policies, during education and training, to ensure that disabled students can access Erasmus placements and work placements abroad on par with their peers.

 

3.2 Tax Credits

 

An obvious mechanism for issuing a cost of disability payment to those in work is to utilise the tax credit system. A precedent exists with the blind tax credit which can be emulated across different cost of disability measures to create different bands of credit, dependent on level of need. It can account for different levels of costs associated with getting to work, (e.g. rural versus city public transport) and other associated costs that ensure that work pays in a targeted way.

Recommendation 9.

Introduce tax credits for those in work to account for the cost of disability.

 

3.3   Invest in developing Relationships

 

Much trust was lost during the recession years, when people with disabilities were kept at the back of the queue while those on the live register for a short period received the most supports. As people with disabilities were deprioritised for Community Employment (CE) schemes, and medical card eligibility was reviewed, a chasm of mistrust developed. It is borne out in the research carried out by the Department’s own survey of people on Disability Allowance (DA) and their concerns about returning to the workplace. People have become more risk adverse, as they fear that they would not be able to re-enter the welfare system on the same terms if they risked taking up an offer of employment.

 

Budget 2017 must invest in the development of more collaborative relationship with disabled jobseekers, those in work, and the wider disability movement. This includes relationships with the organisations that support people around their conditions, and that provide community supports. Greater understanding of issues leads to more effective policy responses and greater innovation both within statutory agencies and within civil society organisations.

Recommendation 10.

Invest in the development of multi-stakeholder relationships on an ongoing basis to foster greater trust, building shared understanding, collaboration and innovation.

 

 

3.4 Flexibility

 

The lack of flexibility in being able to move in and out of work and have a guaranteed income is an issue for some people with episodic conditions. Greater flexibility and seamlessness in moving in and out of payments is necessary in order to support people to remain economically and socially active. The stress associated with the lack of income security renders intermittent, contract or consultancy work unfeasible, resulting in people become more distanced from the labour market and deskilled. Further investigation needs to be done to make self-employment a viable option for people with disabilities.

Recommendation 11.

Introduce protocols for greater flexibility and timeliness for those who move in and out of employment due to their episodic conditions.

 

3.5 Medical Card

 

The medical card offers a vital lifeline to some people with disabilities whose incomes cannot match their medical needs. Its perceived value as an insurance against poor health often outweighs the perceived risk of taking up employment. This barrier to taking up work must be addressed if work is to pay for people with disabilities.

 

Recommendation 12.

Eligibility for medical card must be based on need, and not income for those with long term conditions which are not going to go away.

 

 

3.6 Partial Capacity Benefit

 

Partial Capacity Benefit has not proved an effective pathway into work and continues to have a poor uptake. Nothing short of a total revision of the scheme is required to respond to the diversity of people with disabilities needs rather than having a scheme into which people must fit in order to access part-time work. The application process for the scheme must be keep pace with the timelines of a job application process in order for jobseekers to be able to take up work.

Recommendation 13.

Devise a replacement for the partial capacity scheme that is responsive to individual circumstance and need in consultation with all stakeholders.

 

3.7 Work Place Adaptation Grant

 

The administrative burden of applying for the Workplace Equipment Adaptation Grant (WEAG), along with the lengthy waiting time for a response has resulted in an ineffective scheme. Lack of awareness of the scheme further accounts for the declining take up amongst employers, falling from €71,000 in 2012 to €58,108 in 2015.

 

Ensuring that work is a viable option for people relies on their access to equipment, and assistive technology. This requires a scheme that is fit for purpose and responds to both changes in technology and the workplace. The nature of work is changing. Digitalisation of the workplace has created different demands and opportunities. Ensuring that work pays must respond to the rapidly changing work environment which includes remote working and increased reliance on technology.

 

People must be able to bring their equipment and technology with them during second and third level education, and into their workplace. A new grant scheme must be developed to reflect the changing nature of work; providing both low and high cost equipment and technology as required.  

Recommendation 14.

Replace the workplace adaptation grant with a person centred scheme that allows people to access the technology they need in order to progress through to work, and sustain that work using assistive technologies and other equipment that supports them to be active members of society.

 

CONCLUSION

Budget 2017 must invest in people with a disability so that they are fully included in society, and can participate both socially and economically. The costs of long-term exclusion far outweigh the costs of measures to promote inclusion in the short run. People with a disability are equal citizens of Ireland; they must be given the means and support to live with dignity in accordance with their human rights under the UNCRPD, regardless of employment status.

 

 

 

 

 

For further information on the content of this submission, please contact Joan O’Donnell, joanodonnell@disability-federation.ie.  

 

 

 

The Disability Federation of Ireland (DFI) represents the interests and the expectations of people with disabilities to be fully included in Irish society.  It comprises organisations that represent and support people with disabilities and disabling conditions.      

The vision of DFI is that Irish society is fully inclusive of people with disabilities and disabling conditions so that they can exercise their full civil, economic, social and human rights and that they are enabled to reach their full potential in life.  DFI’s mission is to act as an advocate for the full and equal inclusion of people with disabilities and disabling conditions in all aspects of their lives. 

There are over 120 organisations within membership or as associates of DFI. DFI also works with a growing number of organisations and groups around the country that have a significant disability interest, mainly from the statutory and voluntary sectors. DFI provides:

•             Information

•             Training and Support

•             Networking

•             Advocacy and Representation

•             Research and Policy Development / Implementation

•             Organisation and Management Development

DFI works on the basis that disability is a societal issue and so works with Government, and across the social and economic strands and interests of society.

 

Disability Federation of Ireland, Fumbally Court, Fumbally Lane, Dublin 8

Tel: 01-4547978, Fax: 01-4547981

Email: info@disability-federation.ie Web: www.disability-federation.ie

 

Union of Voluntary Organisations of People with Disabilities trading as The Disability Federation of Ireland is a company limited by guarantee not having share capital, registered in Dublin. Registered No. 140948, CHY No 6177

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