DWP’s plan for a ‘sprint finish’ on universal credit roll-out is ‘dangerous’ for claimants

• charity calls for slowdown and safeguards 
• DWP should publish its readiness criteria  

Child Poverty Action Group (CPAG) is calling on the Government to extend its new timescales for moving people from older benefits to universal credit to prevent vulnerable claimants from falling through the cracks. 

The charity says the DWP must pause or slow down its plans, clarify aspects of the process that remain ambiguous – even to advisers - and publish its readiness criteria.    It is seeing cases of people struggling to claim UC and nearly missing their deadline to do so because they don’t understand what’s required of them.  When people don’t claim within their deadline they lose their current benefits and if they claim late, they can lose a cash top-up designed to ensure claimants are not worse off when they move to UC. 

In a phased process known as ‘managed migration, claimants of older benefits are being required to move to universal credit.   Claimants get three months to claim UC from the date they receive their ‘migration notice’.   If they don’t claim within three months, their current benefits are terminated.*  Even if people who miss their migration deadline do eventually manage to claim UC, they will have lost their entitlement to transitional protection** - a top-up which ensures claimants are not worse off at the point of transition to UC, sometimes worth hundreds of pounds a month.

Managed migration began to scale last April when the DWP gave itself a year to send 500,000 migration notices to tax credit-only claimants during 2023/24. It has now revealed plans to send out 440,000 notices in the six months to September to claimants in much more varied and vulnerable circumstances.

CPAG says the sprint-finish timescales are too high-risk, not least because the new cohort includes people who are sick or disabled, have higher support needs than tax-credit-only claimants and for whom benefits are often their sole income.  The charity believes that unless the DWP slows down its managed migration plan, many of the most vulnerable claimants will lose money they need because they won’t understand what they need to do and won’t have access to advice. 

DWP data published earlier this month showed that 25% of tax credits claimants who have reached their deadline to make a UC claim haven’t moved and have had their benefits cut off as a result (affecting 32,000 families).  Yet the DWP has conducted only minimal research into why the ‘no claims’ rate is so high for this cohort. ***  

What’s more, independent welfare rights advisers can’t currently give robust estimates of how much UC people will have when they migrate, because the department’s exact approach to calculating transitional protection for some groups is unclear.   

In addition to demanding a pause on the UC roll-out, CPAG believes the DWP should publish the criteria by which it is gauging its readiness to expand managed migration. ****

Child Poverty Action Group’s Chief Executive Alison Garnham said:

“It may be in the DWP’s administrative interests to barrel almost half a million people on to universal credit at breakneck pace, but for claimants it’s downright dangerous. There’s a high risk that large numbers will slip through the cracks, lose the support they need and fall into debt.  The department must pause the roll-out, prise itself from its self-imposed targets and come up with a watertight process for moving people safely to UC.   Progress at the expense of claimants – some of them sick or disabled - is no progress at all.”

In a Briefing published today, CPAG reports on some of the problems it’s seeing with managed migration which account for one in five cases that came into its Early Warning System (EWS) in the past six months.  The system collates and analyses case work from welfare rights advisers across the UK.  Because they come from welfare rights advisers, most cases on the system are examples of claimants who have got advice early enough to prevent income losses, but there are likely to be many undetected cases of claimants who have not had advice, have misunderstood information about managed migration, are worse off financially and do not know that the outcome could have been different.

Cases from CPAG’s EWS system: 

Barriers for claimants with additional needs:

A tax credit claimant with mental health problems told their benefits adviser that they were thinking of not going ahead with a UC claim because they simply couldn’t cope. They were getting ‘a fair amount’ in tax credits each month but the move was daunting enough that they almost didn’t go ahead. According to the adviser, ‘they persevered with support’ in the end. 

Some people claim precipitously when they receive a DWP ‘tax credits are ending’ leaflet ahead of their migration notice:

A couple receiving working and child tax credits, with three children, became several hundred pounds a month worse off when they claimed UC after mistaking their leaflet for a migration notice. If the couple had received a migration notice, they would have been entitled to transitional protection and they would have seen no drop in their income after moving to UC.

Deferrals safeguard not being applied comprehensively. 

Some people – including those who are terminally ill – are exempt from the requirement to migrate until the DWP has decided exactly what process they should follow.  But CPAG comes across cases where claimants entitled to a deferral, struggle to have their deadline to move to UC deferred: One adviser reports: 

‘I have three [terminally ill] clients who have PIP under an SR1 [and] also receive working tax credit. DWP guidelines state this group will not be subject to managed migration 'until an appropriate system is devised' but they have all received migration notices. We are dealing with them one at a time. The first client has had her migration notice cancelled. My contact at the DWP asked me to send him a copy of the DWP guidance on deferred groups of which he was not aware.’ 

Child Poverty Action Group calls on the DWP to bring in more safeguards for claimants, including automatically transferring at-risk claimants rather than asking them to claim, granting at least one, one-month deadline extension to any claimant who requests it, and boosting home visits.  

The DWP must also:

• Pause managed migration until it has clarified ambiguities about how the policy will be delivered, provided independent services with information to support claimants and can deliver an intensive support package at scale 
• Before migration notices are sent out, check claimants’ records to identify any indications that a claimant may be vulnerable and consider if it is appropriate to send a notice to the claimant and if additional support is needed. DWP should also work with local authorities to identify potential vulnerability.  

Notes to editors: 

CPAG’s new Briefing on managed migration is HERE

*Unlike other benefits, Personal Independence Payment (PIP) is not terminated when people miss their deadline to migrate to UC

**If people submit a UC claim within 1 month of the deadline day specified on their migration notice, their UC award will start on that deadline day stated in their migration notice, and they will receive transitional protection. Transitional protection is only available to claimants who have been sent migration notice. It isn’t available for new claims for UC.   (amended 28^th Feb 2024) 

*** CPAG’s earlier analysis on the proportion of tax credit claimants not claiming UC within their deadline is here 

****In June last year CPAG submitted a complaint to the Information Commissioner’s Office (ICO) after the DWP refused to answer its FOI request for the criteria against which it has assessed its readiness to scale up managed migration and the assessment of this readiness.  The ICO rejected the DWP’s position that the requested information was exempt from disclosure and ordered the department to disclose it.  The DWP has appealed the ICO’s decision to the First-tier Tribunal (General Regulatory Tribunal).  

The current plans for roll-out have been outlined in a ministerial statement here:

Our plans for 2024/25 are to undertake the issuing of Migration Notices to in scope Working Age benefit households sequentially, starting with Income Support claimants and those claiming Tax Credits with Housing Benefit from April, Housing Benefit only claimants from June, Employment Support Allowance with Child Tax Credits from July and Jobseekers Allowance in September. 

The table below shows the number of people within scope of managed migration in 2024/25 by benefits current received: 

Source: Question for Department for Work and Pensions, UIN 12821
 

This work has been funded by the abrdn Financial Fairness Trust but the views expressed are those of the authors and not necessarily the Trust. abrdn Financial Fairness Trust funds research, policy work and campaigning activities to tackle financial problems and improve living standards for people on low-to-middle incomes in the UK. It is an independent charitable trust registered in Scotland (SC040877). 

Media contact: Jane Ahrends 07816 909302