Mandatory consideration of revision before appeal - CPAG's response to the DWP's public consultation
Clause 100 of the Welfare Reform Bill as introduced enables regulations to be made to require claimants who disagree with a decision to request consideration of revision before they may appeal against a decision. CPAG believes that the proposed implementation is a highly retrograde step which will adversely affect the interests of claimants.
In particular, we believe it will:
- increase delays in the resolution of disputes;
- add complexity, bureaucracy and costs to the disputes process;
- disproportionately affect the most vulnerable claimants;
- cause hardship, and in extreme cases homelessness and destitution, while payments are stopped pending revisions, which are not subject to any time limit.
These effects could seriously compromise claimants’ access to justice. They are also inimical to the Government’s aims of simplifying the benefit system (e.g. by introducing universal credit), while protecting the most vulnerable claimants.