Submission to the Social Security Advisory Committee

The Social Security Advisory Committee has invited comments about the new draft regulations, with a deadline of 27th July. Details of the consultation are here. My submission is available here.

These are the main points I have raised:

  • Couples. There are gaps in the definitions which require filling, including specification of relationships and identification of transitions.
  • Periodicity. The frequent references to days and weeks, e.g. in qualifying conditions, work requirements and sanctions, need to be reviewed to be consistent with monthly operation
  • Discretion. Wherever discretion is to be exercised, there need to be appropriate mechanisms for review and redress.
  • Sickness while unemployed. The allowance made for everyday sickness – that is, periods of sickness that do not amount to “limited capacity for work” – is too low.
  • Limited capacity for work related activity. We are still waiting for regulations that might clarify how this is defined.
  • Work search. The proposed requirement to engage in work search for 35 hours each week is not meaningfully related to the process of job-seeking and inconsistent with effective administration.
  • Contributory benefits. Regulations governing contributory entitlements need to be reviewed for consistency with the new mode of operation – filling gaps, reviewing periods and making consistent requirements.

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