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.