I have now finished my submission to the Smith Commission, and there is a copy of it here. The main points are these:
- Benefits are complicated. They serve a wide range of needs and circumstances, delivered to meet a wide range of objectives. Any reform of benefits that is based on a single principle, or on a narrow focus, is liable to compromise other principles.
- If benefits are devolved, they must be expected to vary in their terms and conditions. The ‘parity principle’ applied in Northern Ireland states the opposite; that would not fulfil the remit of the Smith Commission.
- If devolution was confined only to the delivery of specified benefits, the power of a devolved government to alter those benefits would be limited by finance, administrative constraints and interactions with other benefits.
- The devolution of powers implies not only that the criteria and conditions for benefits may be modified, but that new benefits will be permissible.
- Any reform which does not deal with the package of benefits overall for identifiable categories of claimant will lead to inconsistencies and anomalies.
- Specific proposals to devolve only Housing Benefit and Attendance Allowance have not been thought through sufficiently. The devolution of Housing Benefit will require changes in Universal Credit; the devolution of Attendance Allowance must extend to DLA/PIP.
- There is a danger that a detailed specification of powers will get in the way of further reforms in the existing structure of benefits.
- Change is difficult. The benefits system deals with a huge variety of circumstances, often providing for people on very low incomes who are highly vulnerable to the effects of change. Everything has to be done carefully.