Paul Treloar reviews the first of the official independent reviews of personal independence payment (PIP).
The unfortunate reality of long delays and backlogs in the assessment process for PIP, since its introduction, was a primary focus of comments to the first annual independent review carried out by Paul Gray, Chair of the Social Security Advisory Committee, with the report being issued in December.1">www.gov.uk/government/uploads/system/uploads/attachment_data/file/387981... With implementation being less advanced than originally planned, Mr Gray feels it to be too soon to draw definitive conclusions on many aspects of PIP.
However, on the assumption that these key areas are being addressed, the main focus in the report is the further actions needing to be addressed to avoid similar issues arising in the future. The report explicitly states that it would not be appropriate in this review to consider whether the assessment criteria for PIP are the right ones or not.
Noting the high expectations of several million claimants about their customer experience, as well as the major challenges in assessing PIP eligibility on the basis of functional impact, incorporating physiological, psychological, motivational and social factors, the report focuses on three key areas.
1. Improving the claimant experience
There were particular frustrations from PIP claimants about knowing the status of their claim and how long they would need to wait for a decision. Additionally, the complexity and time taken to complete the PIP2 claim form and mixed experiences of face-to-face assessments were highlighted. To this end, the report recommends that more proactive use of out-bound communications is made with claimants, with improved decision letters, and a longer term ambition of a more integrated digitally enabled process. There is also a curiously specific recommendation to ensure assessment rooms are configured so that assessor and claimant sit at a 90 degree angle.
2. Clarifying and improving collection of further evidence
The report finds a lack of clarity about responsibility for gathering relevant evidence. There is also a tension between claimants’ views of the worth of their own GP’s evidence and that of GPs whose view is often that they are less well placed than other health care professionals to comment on functional impact. Recommendations are made for assessors to emphasise the functional nature of the assessment and limit the emphasis placed on collecting clinical information. Further, Gray feels that more use should be made of evidence from work capability assessments or other sources of information held by the DWP.
3. Assuring fairness and consistency in PIP award outcomes
Despite the earlier statement about not considering whether the assessment criteria are the right ones, the report states that questions have been raised about:
- activity 11 (planning and following journeys);
- the treatment of aids and appliances; and
- assessment of reliability.
On activity 11, there is a report that claimants do not understand the requirement or cannot articulate it clearly and recommends a clear explanation be given to health professionals and claimants. On using aids and appliances, it is claimed there are anecdotal reports that points may be being awarded on the basis of claimants ‘choosing’ to have acquired these items, ‘some of which may cost as little as £1’, rather than needing them. Thus the DWP is instructed to review how aids and appliances are taken into account in PIP assessments against the original policy intention and to make necessary adjustments to guidance and training.
Similarly, it is recommended that DWP should ensure the consistent application of guidance on reliability of managing specific activities and recognising fluctuating conditions. Some claimants reported not having had an opportunity to discuss such issues at assessments, which is presumably explained by health professionals stating they had sufficient knowledge and evidence already to understand potential reliability considerations and fluctuations without probing explicitly on these issues.
Finally, there are recommendations for the DWP to put in place a rigorous quantitative and qualitative evaluation strategy in the medium term, with a scheduled plan for publication of findings. This should have a priority focus on people with a mental health condition or learning disability due to concerns raised about their ability to navigate the assessment process.
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