Managed migration to universal credit – an irresponsible gamble

The DWP has just confirmed that it's pressing ahead with managed migration (the process by which people on the old ‘legacy’ benefits will move to universal credit (UC)). Here are six reasons for alarm as the government forges ahead with its plans to move 1.7m people by the end of 2024:

  1. ‘Managed migration’ misleadingly implies seamlessly moving people onto UC. Instead, the DWP’s plan is that all remaining legacy claimants will be given a deadline to submit a claim for UC. They will then have three months to make the claim or have their benefit stopped. Ultimately this compulsory self-managed migration will leave people who can’t claim (eg, because of disability) losing their legacy benefit with no UC to replace it.
     
  2. Nearly half of the people remaining on legacy benefits have been on ESA – the benefit for people who are too ill to work - for a number of years. These ESA claimants are likely to have complex needs which will make it difficult for them to go through the managed migration process. The stakes are high: stopping benefit for claimants, particularly the most vulnerable claimants, is something which could have serious consequences including destitution. The past decade has seen a number of cases, such as that of Errol Graham, in which people who have had their benefit stopped have subsequently died.
     
  3. While the secretary of state assured the work and pensions committee that she had made a decision that would mean benefit would not be stopped for any vulnerable claimants during the current phase of managed migration, she was unwilling to publicly state what this decision involved. These assurances are simply not good enough, the safety of vulnerable or disabled claimants cannot rest on a wink and a nod. Vulnerable claimants must, instead, be protected through rights set out in legislation.
     
  4. The DWP estimates that 900,000 people on legacy benefits will eventually be worse off on UC. The government has committed to providing transitional protection - extra payments of UC which stop people from being worse off at the point that they move to UC. However, there are significant problems with transitional protection. For example, someone with transitional protection will lose it if they leave an abusive partner or if their partner dies. See CPAG's Briefing note for the Work and Pensions Select Committee – early insight into managed migration
     
  5. The DWP committed to carrying out a pilot of the managed migration process to learn how best to move people to UC without resorting to stopping benefits. The DWP started the pilot in Harrogate and notified 53 people on legacy benefits that they would be required to claim UC. Thirty-eight of those people had made a claim by the time the pilot was suspended due to the pandemic. Worryingly, it has come to light that six people in the pilot missed their initial deadline for claiming UC. We only know this because of a parliamentary question. The DWP did not publish this information proactively, and has not committed to providing progress reports on the number of people missing their deadline in the rest of managed migration.  The DWP says it does not hold information on whether the people who failed to meet their deadline for claiming UC had complex needs or disabilities. 
     
  6. Parliament initially agreed a 10,000 limit on managed migration cases, after which the DWP would need to return to parliament for permission to roll out nationwide. But instead of continuing the pilot, the DWP is learning about managed migration through a ‘discovery phase’, which began in May 2022. The DWP will start to learn whether people are getting into difficulties between August and October this year. The DWP is not being transparent about the discovery phase. It had planned to publish an evaluation strategy and full evaluation for the pilot, but is not planning this for the discovery phase. The evaluation strategy would have set out key questions DWP would use to evaluate the pilot. The evaluation strategy for the pilot was never published so it is not possible to properly assess the results of either the pilot phase or the discovery phase against these criteria. The limited documents that the DWP has published about the pilot do not fulfil its promise to publish an evaluation strategy and an evaluation. Without these documents neither parliament nor anybody else can hold the DWP to account before managed migration is further rolled out. The DWP now plans to return to parliament to pass legislation to lift the 10,000 cap on the number of people who can be migrated to UC without carrying out a proper evaluation.

The government has chosen an approach to managed migration that risks serious consequences for vulnerable benefit claimants. Remember, these claimants’ circumstances have not changed: the reason they are forced into managed migration is because the government has decided to change the system of support, rather than because their situation has changed. Other choices are available: instead of ending legacy benefits, the DWP could use the information they hold about someone’s legacy benefit entitlement to automatically sign them up for UC, avoiding the need for the individual to make a claim (perhaps subject to subsequent verification, as happened during the pandemic). Such a process would clearly be fairer and safer.

The DWP’s approach to managed migration is an irresponsible gamble. It must redesign managed migration to prioritise the needs of claimants.