UC and complex needs

01 August 2019
Issue 271 (August 2019)

Owen Stevens discusses attempts by third parties to make DWP aware of ‘complex needs’ among universal credit (UC) claimants.


Identifying ‘complex needs’ among UC claimants is of key importance. DWP staff identifying a claimant’s vulnerability can be important for accessing alternative payment arrangements, deciding whether there is good cause for failing to comply with conditionality or whether a claimant should be offered home visits, or in cases where benefits have been stopped if the claimant fails to claim UC under the managed migration pilot.

Complex needs

Rather than‘vulnerability’, defined (as in employment and support allowance (ESA)) as whether someone has a mental health condition, learning difficulty or condition affecting cognition, UC considers ‘complex needs’. Guidance states complex needs could arise from personal circumstances, life events or health problems or disabilities and people may move in and out of having complex needs. The DWP recognises some claimants may have complex needs because of UC’s design – eg, claimants lacking IT skills. This approach puts greater emphasis on DWP staff to identify complex needs.

DWP failures

DWP staff have repeatedly failed to identify vulnerability among ESA claimants, despite a much simpler definition. DWP’s failure to identify and respond to vulnerability has been raised multiple times in DWP peer reviews (carried out after serious incident or death).1 Will DWP staff cope with UC’s nuanced definition of vulnerability?

According to the National Audit Office(NAO):2 ‘Identifying which claimants are vulnerable is important so that the Department can properly target support and set appropriate conditions on welfare (for example, reduced work search requirements). However, the Department’s research in October 2017 shows that some staff found it difficult to support claimants because they:

  • lacked the time and ability to identify claimants who needed additional support;
  • lacked the confidence to apply processes flexibly and make appropriate adjustments; and
  • felt overwhelmed by the volume of claimants reporting health problems.’

The Public Accounts Committee (PAC) stated that:3

‘The Department is failing vulnerable claimants because it places too much reliance on the discretion of its work coaches to identify and manage the needs of people requiring extra support. The Department relies on work coaches in Jobcentres to tailor aspects of Universal Credit to a claimant’s individual needs, such as the number of hours they must spend looking for work. But appropriately tailored conditions are not always being set in practice, resulting in claimants being subject to unrealistic expectations, leaving them at risk of sanctions and in some cases exacerbating health issues.’

In response, the DWP has made recording complex needs easier with pinned notes on claimant records, providing staff training and ensuring job centres develop ‘complex needs plans’. These are welcome developments. However, complex needs training is not new and did not prevent earlier failures, and it is hard to see pinned notes as a sufficient response to failures to identify claimant vulnerability. Complex needs plans (see letter from Neil Couling, Senior Responsible Owner for Universal Credit, to Public Accounts Committee Chair Meg Hillier MP, 27 June 2019) are largely signposting tools to local services, inadequate in themselves at enabling DWP staff to identify and take responsibility to support vulnerable claimants.

Monitoring complex needs

The PAC found that the DWP is unable to monitor the treatment of ‘vulnerable’ claimants.4 Ministers say the DWP is working on capturing data on claimants, including those with complex needs.5

The Work and Pensions Select Committee stated that the DWP should not proceed with managed migration until it can measure vulnerability.6 The Social Security Advisory Committee (SSAC) stated that the DWP should publish triggers for deceleration or suspension of managed migration and that these might include people in vulnerable situations not being identified and supported.7 SSAC asked the DWP to review whether legislation should include a check on vulnerability,8 and the Work and Pensions Committee added:9

‘Witnesses therefore emphasised that simply saying that the migration programme will contain safeguards is not enough. As [SSAC’s] Victoria Todd explained: “having that safeguard is one thing”, but “being able to deliver it and having the information they need to be able to do that is entirely another”.’ 

Identifying complex needs The DWP will test a ‘who knows me’ approach to supporting claimants with complex needs during managed migration into UC in which third-party organisations assist the DWP with claimants’ readiness to move to UC and to help them with the move.10 Could the DWP take a similar approach to identifying complex needs outside the managed migration context? It seems that it can if it wants to.

The Work and Pensions Committee recommended that, in addition to using pinned notes, the DWP should take the example of existing protocols with local authorities (LAs), never sanctioning care leavers until a work coach has made contact with the claimant’s LA adviser (and taken account of information received) and allow for consent to discuss any matter with the adviser. The government agreed.11

Care leavers

Doncaster Council gives each care leaver the option to sign a consent enabling the LA and Jobcentre Plus staff to work together until the care leaver turns 21. The LA is notified of the care leaver’s appointments and the job centre will not impose a sanction until it has spoken with the care leaver’s adviser (although the DWP will not stop benefit for other reasons). If an issue cannot be resolved between the personal adviser and work coach, the protocol sets out an escalation procedure. The LA acknowledges an initial need for staff training on conditionality. The LA says that resolving benefit problems had previously taken up a lot of staff time but that since the introduction of the protocol, issues with benefits are now rare.12

Each care leaver supported by Trafford Council has the option to sign a consent enabling the LA and job centre to work together for as long as the care leaver is being supported by the LA – once this is in place, consent issues no longer arise. Care leavers can be reluctant to take up support offered by the LA and there is a need for the LA to ensure that staff are aware of the support offered by job centre. The protocol commits the job centre to liaise with the LA ‘if any issues or concerns arise’. The LA will disclose care leaver status and is reluctant to disclose any more than is required through the agreement, although it would disclose further information where appropriate. The LA says the protocol means that the job centre is no longer seen by staff as a faceless organisation and has reconfigured it to enable it to support care leavers. The LA believes that the joint working protocol could be a valuable model which could be used for other client groups. However, despite these positive experiences, the LA notes that care leavers struggle to survive on the low benefit rates available to them.13


How about a client group other than care leavers? The DWP identified the Newcastle Homelessness Prevention Trailblazer (funded by the Department of Housing, Communities and Local Government between January 2017 and March 2019) as an example of job centres working with partners, in this case Crisis and Newcastle City Council.14 The scheme began around the introduction of the Homelessness Reduction Act 2017 and the Council’s work to prepare for UC. The service supports people at risk of homelessness and in the two years following homelessness.

The agreement allows for information sharing and referrals between services. Once a referral takes place, there is an opportunity to highlight complex needs to partners. Crisis says the agreement has helped its coaches to support clients and that there are no problems with consent. Crisis is not always notified by Jobcentre Plus of problems with benefits but does have consent to access clients’ UC journals so can check for problems in that way. The relationship with Jobcentre Plus has improved considerably. Jobcentre Plus now participate in meetings on supporting vulnerable claimants and homelessness training. Crisis says that showing how the partner services have a shared purpose helps embed change. However, it also says that joint working arrangements need to be sustainable and should be led by the job centre/LA, not by a third party.

Crisis and Jobcentre Plus have also worked together in Edinburgh: the arrangement resulted from co-location in Jobcentre Plus rather than a formal agreement. Nobody supported through this arrangement has been sanctioned, instead job centre staff proactively discuss concerns with Crisis who either supports clients to comply with conditionality or negotiates adjustments to conditionality. Crisis notes that support at management level is very important but also that it needs time to get front- line support. Joint working is now being rolled out across all job centres in Edinburgh.15

Local authority benefits department

The Royal Borough of Greenwich (RBG) has developed a ‘benefits safeguarding alert’ which allows claimants to declare a mental health condition, or other vulnerability, to the LA. The form provides details of a third party (eg, a support worker or health professional) to be contacted in the case of claims ending or conditionality not being met.

The borough’s benefits department will, for clients with an alert in place, take additional steps to contact the client or third party when benefits are suspended or stopped, and refer to advice services where needed. Its revenues department aims to avoid using bailiffs where possible. Other departments within the LA are exploring how they could incorporate it within their processes.

Upon consent, the alert is shared with the local job centre to be recorded on DWP systems. Where the LA is aware that a claimant has moved from housing benefit to UC, the alert is re-sent so that it can be included on the UC account. Work coaches have been trained on taking the alert into account when considering appropriate discretion, and to encourage claimants to complete one if appropriate. Ongoing work is needed to improve take-up and consistency, however the borough says that there is support locally from the DWP and LA to improve the service.16

A welfare rights context

Inverclyde Council sends an alert via the UC journal requesting that DWP record a client’s complex needs – the alert is used with homeless people and people with drug and alcohol problems and is aimed at securing conditionality changes. Local partners are Jobcentre Plus, Inverclyde Council’s Health and Social Care Partnership (HSCP) advice service, a law centre, and HSCP homelessness and drug and alcohol services.

Partners find that relying on the DWP to act on alerts can be ineffective but that it is more effective to use them as a basis for requesting reasonable adjustments and making complaints if this is not done. The DWP says the information is useful as it is not able to find out the information directly from clients.

Partners have found that providing information upfront has improved relationships between job centre staff and claimants with complex needs and that problems are less likely to arise as the job centre immediately contacts a partner agency when a claimant fails to attend an appointment. This has meant that partners have a reduced workload as benefit problems are averted before they arise. Although local arrangements work well, the information provided does not seem to be acted on by the DWP’s debt management teams and there are still consent problems with staff at benefit centres.

Partners feel that an extension of the scheme to other claimants could mean long-term savings to health and social care services, although resource constraints make this unlikely. Inverclyde emphasises the importance of consistently using the alerts throughout the service’s caseload – and the value of identifying discrimination and lodging complaints where this is the case.17

Please be aware that welfare rights law and guidance change frequently. Older Bulletin articles may be out of date. Use keywords or the search function to find more recent material on this topic.



  • 1. See documents 1, 6, 14, 15, 26, 27, 32, 36, 38, and 48 in redacted peer reviews at www.gov.uk/government/publications/dwp-foi-releases-for-may-2016
  • 2. National Audit Office, Rolling out Universal Credit, 15 June 2018
  • 3. Public Accounts Committee, Universal Credit, HC 1183, 26 October 2018
  • 4. See also letter from Neil Couling, Senior Responsible Owner for Universal Credit, to Public Accounts Committee Chair Meg Hillier MP, 27 June 2019
  • 5. House of Commons, Hansard, 15 April 2019, Written question 243556
  • 6. Work and Pensions Select Committee, Universal Credit: tests for managed migration, 30 April 2019
  • 7. The Draft Universal Credit (Transitional Provisions) (Managed Migration) Amendment Regulations 2018, Report by SSAC and Secretary of State for Work and Pensions, November 2018
  • 8. Correspondence regarding the Universal Credit (Managed Migration) Regulations 2018, 12 December 2018, www.gov.uk/government/publications/universal-credit-managed-migration-re...
  • 9. Work and Pensions Select Committee, Universal Credit: support for disabled people, 19 December 2018
  • 10. ‘DWP outlines plan to use stakeholders and partners to help it ensure that people move safely from legacy benefits to universal credit’, Rightsnet, 15 March 2019; and http://bit.do/rightsnet-post
  • 11. Work and Pensions Committee, Benefit Sanctions: government response to the Committee’s Nineteenth Report of Session 2017-19, HC 1949, 6 February 2019: ‘[e]xisting guidance allows staff to proactively disclose information to third parties, such as social services or the police, where they are satisfied a vulnerable person faces risks to their welfare or safety. This would include care leavers facing a possible sanction.’ This is a reference to the DWP’s proactive disclosure guidance.
  • 12. Interview with Neville Brown, Service Manager, Doncaster Children’s Services Trust, February 2019
  • 13. Interview with Denis Owen, Deputy Manager, Transitions Team, Trafford Council, February 2019
  • 14. Work and Pensions Committee, Benefit Sanctions: government response to the Committee’s Nineteenth Report of Session 2017-19, HC 1949, 6 February 2019, para. 65. See also www.newcastle.gov.uk/services/housing/housing-advice-and-homelessness/in...
  • 15. Interview with Jasmine Basran, Senior Policy Officer, Crisis, February 2019
  • 16. Correspondence with Corin Hammersley, Training, Policy and Welfare Rights Services Manager, Royal Borough of Greenwich, July 2019
  • 17. Correspondence with George Coffey, Vulnerable Groups Outreach Worker, Inverclyde Council, April 2019