Prebudget Submission 2002

As the Government clearly recognises, getting people into jobs is the best form of social inclusion. However, the current social policy system in Ireland contains a number of disincentives and obstacles to taking up employment. These disincentives are frequently highlighted in social policy feedback from CICs to Comhairle. Removing these disincentives and barriers is essential if Ireland's economy is to continue performing well, and if poverty is to be tackled effectively. It is particularly important to help women who wish to work outside the home to overcome obstacles to taking up employment as they represent the largest pool of untapped labour.

Increasing labour supply and tackling social exclusion also necessitates improvements in the education system, in adult education opportunities and in the supports available to those who opt for training and education. Enabling people to acquire new skills and to enhance existing ones is the best recipe for social inclusion, and every effort should be made to help those who want to return to education or training at any stage of their working lives. Developing employability is also one of the key objectives that all EU member states set for themselves at the European Councils in Lisbon and Feira (See Note). This is best done through policies that promote the acquisition of skills and lifelong learning, and through ‘modern systems of social protection which promote access to employment' (See Note).

A comprehensive review should be undertaken to make sure that the Irish welfare state as a whole always rewards employment and education more than unemployment. While the structure of social entitlements should always make work pay, social transfers must be adequate for those who have no choice but to live on them. It is clear that these important structural changes cannot take place without enhanced child care provision and help for families with young children.

Key recommendations

Work and Welfare - Disincentives to Work

Unemployment

The Back to Work Allowance (BTWA) and Back to Education Allowances (BTEA) should be incorporated into the unemployment payment system - all unemployment payments should be focused on ‘back to work/education', rather than just cash assistance. There is clear evidence from CICs that the loss of secondary benefits, such as rent allowance and medical card, continues to create work disincentives. Efforts to re-integrate the long-term unemployed into the workforce need to be redoubled and special attention paid to this group now that decreased expenditure on unemployment has freed up resources.

Recipients of Supplementary Welfare Allowance should qualify for back to work schemes and FÁS courses. This would help to improve the position of asylum seekers who (a) succeed in getting refugee status, (b) who have received permission to remain in the country and (c) who have been given the right to work. In order to eliminate a number of negative social and economic consequences, the possibility of giving some asylum seekers temporary work permits should be considered.

There is a difference in the earnings disregards for people with no child dependants and people with child dependants who take up part-time employment while receiving Unemployment Assistance (UA): the former are allowed to keep a larger share of part-time earnings than the latter because of the earnings disregard (which is not applied in the case of people with child dependants). This is clearly unfair and the same benefit should accrue to the part-time worker on UA regardless of family status (see case example below).

Being on the Live Register is a condition of participating in Community Employment programmes and various FÁS courses. This affects women in particular who have been looking after their family and home and want to return to the workforce and who are in many cases not entitled to ‘sign on' (See Note) and, therefore, are excluded from the Live Register. People who want to return to the workforce should be eligible for active labour market measures such as CE and FÁS training courses without having to spend a ‘qualifying' period in unemployment first (provided that they fulfil the condition of actively seeking work). People wanting to start a business also encounter this problem as they are expected to spend a ‘qualifying' period in unemployment before being entitled to a business start-up grant.

Qualified Adult and Child Dependant Allowances

The system of Qualified Adult Allowances (QAAs) works to the disadvantage of married and cohabiting couples as their total payment (basic rate plus QAA) is less than two basic rates. It also reflects the assumption that women stay at home and are given entitlement to benefits and social welfare payments as a side payment to their husbands' entitlements. This results in work disincentives primarily for women, but also for men, as income from work may result in loss of QAA and/or reduction in the level of payment to the primary claimant. The introduction of minimum wages legislation, coupled with labour shortages, has meant that current rates of pay make it difficult to keep earnings below the maximum level of disregard for retaining the QAA. This disincentive applies mainly to women's labour market participation.

It would seem logical that the QAA system should be phased out and entitlements allocated on individual basis. If this is deemed overly ambitious, QAAs (as well as the earnings disregard for qualified adults) should in the very least be significantly increased to take account of the increased wage levels and to remove work disincentives

Employment Rights

Comhairle receives a large number of reports from CICs detailing breaches of employment rights (See Note). On the basis of this feedback, it appears that payment of incorrect wages, denial of holidays/holiday pay, non-payment of PRSI, failure to provide payslips/P.60/P.45 forms, and other breaches of employment legislation are widespread in Ireland. An information campaign is clearly needed to inform all workers and employers of their rights and duties, particularly among immigrant and casual/part-time workers. More inspections should take place to ensure that employers are respecting employee rights.

The right to claim unfair dismissal should be extended to all workers who have been dismissed while trying to enforce their statutory rights irrespective of the length of service (See Note). At the moment, only those employees who have been working for more than 12 months have full rights if unfairly dismissed. For instance, an employee with less than one year's service who is trying to secure entitlement to public holidays can be dismissed without any protection under employment law. Given that short-term workers are often in the weakest position, it would be particularly important to improve their rights in the workplace.

More checks need to be done to ensure that employers are paying PRSI contributions for their workers. CICs have informed us of instances where people discover that they are not entitled to, or that there are delays in getting, social insurance payments due to non-compliance of their employers.

CIC feedback indicates instances where foreign nationals' basic statutory rights are violated, particularly in relation to working conditions and holiday and overtime entitlements. More resources must to be dedicated to informing and monitoring employers hiring foreign nationals, and regular inspections need to take place, followed by effective sanctions for employers who are found to be violating employees' rights. The possibility of giving foreign nationals general rather than employer-specific work permits should be investigated: this would ensure that foreign workers are not dependent on exploitative employers and are free to seek work elsewhere.

Education

Recent OECD surveys have shown Ireland to have one of the lowest literacy rates in the developed world (third lowest in 22 countries included in the survey published in 2001). Half of Irish secondary school graduates (aged 16 to 25) are below the International Adult Literacy Standard. OECD surveys have also established that the countries with the highest literacy rates are those that invest most money on education (See Note). Comhairle has received some feedback from CICs indicating that people experience difficulties in applying for payments because they have literacy problems. Eradicating literacy difficulties among the adult population should be a high priority due to its social and economic cost.

Education is crucial in lifting people out of poverty and disadvantage: investment in primary education is a particularly effective tool in breaking the vicious cycle of social and economic deprivation. However, it is also very important that more young people from deprived areas stay in education until they have obtained a third-level qualification. It is widely recognised that this group is under-represented in most third-level institutions Interventions are needed from the earliest stages of schooling to bring about an increase in the proportion of children from deprived backgrounds who complete third-level education. The current grants are so small and the means-testing so tight that potential third-level students from low-income families opt for working instead of studying, and many students have to work part-time (See Note). Student grants, even at the maximum rate, compare very unfavourably with social welfare payments and benefits, not to mention even very low wages, and this leads to large numbers of students dropping out of college or never taking up the offer of a third level place (See Note).

Grants for third-level students from low-income families and for mature students with low family income should be increased and means-testing of these grants should be eased.

Third level grants should be paid at the start of the academic year rather than 6-8 weeks into the term: this would help students from low-income families.

CICs have drawn attention to the fact that recipients of short-term benefits (such as Disability Benefit and Unemployment Benefit) whose children are in full-time education only receive child dependant payments until the age of 18, whereas persons on long-term payments receive support for children in full-time education until the age of 22. This creates an additional barrier to children from disadvantaged families to enter third-level education and should be remedied. Indeed, consideration should be given to the possibility of paying child benefit until the age of 22 in respect of every child who remains in full-time education until that age.

It is also important to focus on progression from unskilled or semiskilled employment to more skilled jobs i.e. to ensure that people are not ‘stuck' in low-paid jobs throughout their lives. More financial support for adults during time spent in education would play a particularly important role in this. Financial support during periods spent in education/training should be available without the requirement of spending a ‘qualifying' period in unemployment.

Families and Children

Families

There is evidence from CICs that not all people who are eligible for Family Income Supplement (FIS) know about it. The scheme should be promoted more widely. It would also be advisable to base the FIS payment on income after childcare expenses have been deducted as this would help lone parents in particular to overcome a major disincentive to work. The qualifying working hours for FIS should be reduced to 17.5 as many lone parents are job sharing (a 35-hour week being increasingly common) and many fail to qualify for FIS due to number of hours worked.

The fact that unmarried couples are treated as a couple for social welfare purposes, but as separate individuals in the tax system is clearly inconsistent, encourages welfare fraud, and causes hardship for the adults as well as the children. Comhairle recommends that the treatment of married and cohabiting couples is harmonised in both the tax and social welfare systems It is noted that cautious support for change in the tax treatment of cohabiting couples is expressed in the Report of the Working Group Examining the Treatment of Married, Cohabiting and One-parent Families Under the Tax and Social Welfare Codes. (See Note).

Children and childcare

While explicit gender discrimination has been removed from the social welfare system, many parts of it affect women differently than men. Moreover, many shortcomings of the social protection system are felt more acutely by women than by men. The burden of supporting children in lone parent families falls disproportionately on women, and the disincentives to work thatface thisgroup are a particular concern (See Note). For instance, a number of CICs have pointed to the fact that the cost of childcare is creating a disincentive to work for many lone parents. In the case of two-parent families, too, childcare is an issue that tends to concern women more than men. Rules concerning maintenance payments are also of particular relevance for female lone parents.

More childcare facilities and supports should be available for the children of parents who work or are in education, and for children from lone parent families in particular. Reasonably priced, good quality child care enables parents to participate in the labour market: in those countries where childcare is subsidised or provided by the state, the tax revenue derived from working parents covers the cost of day care for the most part (See Note).

The option of using refundable tax credits to finance child care should be explored. In this regard it is relevant to note that a health insurance tax credit is already in existence.

For parents on low income (who would not benefit from tax credits), day care vouchers could be made available: these vouchers could then be used at a day care centre of parents' choice. In this context, the recent initiative to give £50 per week towards child care costs to mothers participating in FÁS courses (See Note) is to be welcomed as a step in the right direction.

Comhairle welcomes the recent extension of parental leave while recognising that it tends to have a disproportionately heavy impact on small employers. Some additional provision should be made to support this group in making parental leave available to their employees. However, in comparison with other EU countries, maternity and parental leave entitlements in Ireland are very short which makes it difficult for those women who have to, or want to, work to combine motherhood and employment. For instance, in the Nordic countries the (paid) maternity leave entitlement is around one year, and paid paternity leave is available. Parental leave and/or maternity leave should be extended and a parental benefit should be payable during the leave.

Comhairle's attention has been brought by CICs to cases where lone parents were not given a One Parent Family Payment (OPFP) because they were accused of not having made enough effort to secure maintenance from the absent parent. Rules on seeking maintenance state that a lone parent may be disqualified from receiving OPFP where s/he does not co-operate in making efforts to seek maintenance when it would be feasible and reasonable to do so. The circumstances in which lone parents should not be obliged to seek maintenance need to bemore clearly defined and practices need to be monitored to ensure that guidelines are properly and fairly implemented.

Groups outside the labour force

People with disabilities outside the labour force

Since 1997, in recognition of the cost of disability, couples who are eligible for Disability Allowance (DA) have been able to receive the full DA each, instead of receiving one full payment and a Qualified Adult Allowance. Since 2001, couples where one person is receiving DA and the other a social welfare payment such as Unemployment Assistance have been able to retain their respective payments in full (subject to the relevant means-test). While this policy of effectively individualising DA is welcome, it was introduced without considering the impact of this change on other payments, the rent allowance and free schemes in particular. In other words, the extra income that incurs to couples in this situation is effectively lost through clawbacks. The means-testing of rent allowance should be eased and the entitlement to free schemes should be granted to couples in this situation: the current regulations only result in extra administration and no real benefit for the recipients of these payments.

More home help and transport services should be available for people with disabilities. Grants for vehicle adaptations are currently only available to employed people with disabilities: these grants should also be made available to those who are undertaking training, or need to travel to day care centres.

The Free Companion Travel Pass is only available to people on Invalidity Pension (IP) who are blind or wheelchair users. There is an anomaly in that both IP and Disability Allowance recipients are entitled to a Free Travel Pass. However, while the Companion Pass is available to people on DA who are medically certified as unfit to travel alone it is not available to those on IP. All persons who are medically certified as being unable to travel alone should be given a Companion Pass regardless of the benefit they are receiving.

People with disabilities should be accurately informed of the payments they are entitled to. CICs have identified situations where inappropriate transfers (e.g. unemployment assistance) are sometimes paid instead of Disability Allowance. This also means that the recipient may miss out on secondary entitlements that are due to them. There is an ongoing need for more streamlined and comprehensive information and specific protocols from statutory agencies in this regard.

Greater access to low vision aids is required to enable people with visual impairments to access technology. In this regard, Comhairle's attention has been drawn by a CIC and local voluntary organisation to problems in respect of access to low vision clinics in some parts of the country which need to be addressed.

Pensioners

Evidence from CICs indicates that older citizens sometimes experience difficulty in applying for the benefits and services to which they are entitled. Ideally, benefits/social welfare payments and free schemes should be paid to older people without the need to apply for them. Where applying is deemed necessary, the forms should be simple and not require a lot of information.

The availability of public transport plays an important role in enabling people, particularly in rural communities, to access health and social services. There is ongoing evidence from CICs that older people and people with disabilities in particular can have problems accessing hospitals and other healthcare providers due to lack of appropriate means of transport. There is evidence that lack of public transport leads to some older people foregoing health care (See Note). Consideration should be given to extending the times of the day when free travel passes can be used, and it should be possible for holders of free travel passes to reserve seats on trains.

While it is to be hoped that some of the transport access issues encountered will be addressed under the Rural Transport Initiative, it will be necessary to ensure that there is a co-ordinated and integrated approach to transport and services. For example, there should be co-ordination between hospital/other health care providers and transport services so that appointments for people who rely on public transport could be made with bus timetables/availability of transport in mind. There should be very flexible modes of transport (such as minibuses) that could be booked and used at low cost by people living in remote areas who need medical services. These should also be adapted or adaptable for people with disabilities, and drivers should be trained to assist passengers with disabilities or mobility problems.

More generally, timetables for buses and other means of transport should be drawn up in consultation with local communities, and those without any other means of transport in particular.

Improved arrangements should be put in place for refunding the cost of trips to hospitals for people who are on low incomes and need transport services. At the moment, Medical Card holders may receive refunds from Health Boards for expenses incurred in travelling to hospitals and out-patient clinics. However, this scheme has been subject to cutbacks in recent years, and payments are largely at the discretion of Community Welfare Officers and vary considerably between different areas.

The effect of spouse's earnings is disproportionately high for the old-age non-contributory pension as compared to other means-tested transfers such as unemployment assistance, the pre-retirement allowance and the disability allowance. This is seen by some CICs as constituting a disincentive for the spouses of old-age non-contributory pensioners to work.

The means-testing of widow's/widower's non-contributory pension is tighter than in other social welfare payments (because there are no disregards) which creates a strong disincentive to work. For instance, a person in receipt of unemployment assistance is allowed to earn more than a person in receipt of widows'/widower' non-contributory pension without losing his/her payment. Means-testing of payments should be made uniform across social welfare payments.

Carers

Carers do a very valuable job, both socially and economically. Considerable amounts of money are saved due to the low cost of informal, low-paid care at home. As labour market opportunities outside the home are increasingly attractive and plentiful, and as women's labour market participation rates are increasing, Irish society can no longer rely on home-based carers. In the years to come, fewer and fewer women (and men) will be prepared to stay at home to perform caring duties for a very low payment. This problem will be exacerbated by the fact that the number of older people in need of care is also set to increase as the Irish population ages. If Ireland is to continue relying on home-based care for older people and for people with disabilities, which is widely accepted as the preference of most people, payments for carers need to be increased. In this regard there is a need to actively acknowledge that the alternative to care at home , i.e. institutional care, is considerably more expensive and that a significant re-balancing of exchequer resources is required.

The means-testing of Carer's Allowance should be eased in recognition of the work carers do. Large numbers of carers are not eligible for the allowance because of a means-test. Also, when these carers take a break from their caring duties, they need to pay a substitute carer, which can be very expensive. Respite grants should be improved and made available to all carers, including those whose incomes are too high to qualify for CA. CICs have pointed out that the cost of hiring a substitute carer can be so high that some carers can never afford a break from their caring duties.

Carer's Allowance should not be automatically removed in those cases where the person being cared for takes up rehabilitative employment (for instance when a child with a disability takes up such work) as they still need care outside the working hours. The maximum permissible distance the carer lives from the person they care for should be increased to at least a ten-mile radius. In rural areas, in particular, distances are often long and many carers end up travelling 10-20 mile trips several times every day without any financial assistance.

The introduction of Carer's Benefit for those who want to take leave from work in order to care for their relatives or friends is a welcome measure. However, opting for Carer's Benefit is not an attractive or realistic option in the absence of a right to return to work. Some provision should, therefore, be made in respect of employees' right to return to work. Such provision will obviously need to take cognisance of the rights of employers.

Sickness

The sickness allowance payment that was due to be introduced in October 1997 should be implemented. At present there is no coverage for people who are sick in the short term and do not have sufficient PRSI contributions to qualify for Disability Benefit. This means that some workers (most likely in relatively precarious employment) need to take recourse to Supplementary Welfare Allowance (SWA) in order to have any kind of income during illness. As the means-testing for SWA is tight, even people on low incomes often do not qualify for payment. This can result in people not taking days off during illness, or losing income during short-term illness.

Self-employed people cannot claim Disability Benefit (DB) during sickness even if they have a PRSI record. This is due to the fact that self-employed people paying Class S PRSI contributions are not covered for DB. Since the lack of entitlement to DB puts self-employed people at a relative disadvantage, consideration should be given to extending entitlement to Disability Benefit to self-employed persons.

Supplementary Welfare Allowance

Delays are occurring in the processing of Supplementary Welfare Allowance (SWA) claims which are frequently reported by CICs. This problem is being addressed through the creation of a common database for social welfare offices and health boards, but efforts should be made to ensure that staff shortages and other factors do not cause delays in processing SWA applications.

Supplementary Welfare Allowance as well as the Exceptional Needs Payment under the SWA scheme can only be claimed when the recipient is working less than 30 hours per week. This limit results in unfairness. The access to SWA and the Exceptional Needs Payments should be based on income rather than on the number of hours worked.

Housing

There is an ongoing serious housing crisis, particularly in Dublin, as demand for housing far exceeds supply in many areas and prices have consequently increased dramatically. The lack of affordable housing in some areas creates a barrier to employment. Housing policy should make better provision for improving the mobility of the workforce through, for example, more housing exchange programmes.

Evidence from CICs is that people of all ages, and Irish nationals (including people with disabilities) as well as non-nationals, are experiencing a lot of difficulties in securing local authority or private rented accommodation. Some private landlords are not willing to accept tenants in receipt of rent allowance (See Note) and many people end up living in sub-standard accommodation.

Local authority affordable housing schemes are often unaffordable for people on low incomes, i.e. those who need such housing most. In the light of the current housing and rental market, it is essential to increase the supply of housing and to remove obstacles to the speedy construction of affordable, good-quality housing both in the private and public sector.

Rent allowance is reduced as income from work increases, which in many cases creates a disincentive to take up employment (See Note). In order to remedy this situation, more help must be offered to low-income tenants in private rented accommodation. The income limits and conditions attached to rent allowance should be relaxed so that the unemployment trap is reduced. This is a particularly relevant issue for lone parents considering taking up employment: if virtually all the extra income they gain through work goes towards paying rent (previously covered by rent allowance), the incentive to work is reduced. There is currently a £25 disregard for income from part-time work: this should be increased.

The situation is particularly bad for people on Community Employment(CE) schemes whose rent allowance is reduced by 25 per cent during the first year, and by 25 per cent in the second and subsequent years (see case example below). Furthermore, the rent allowance for CE participants who live in private rented accommodation is not increased if their rent increases during the period in a CE scheme. This has in some cases led to CE participants having to move into emergency accommodation or even becoming homeless (See Note). The differential between CE and Unemployment Allowance is quite small and losing the rent allowance eliminates all or most of the financial advantage of participating in CE even in the first year. Such obvious and strong disincentives to train/work should be immediately eliminated by calculating the rent allowance on the basis of actual income and rent, and by making sure that work/training in no case leads to lower income than non-participation in the labour market/training.

	Rent per month £	Rent per week £	Family's Contribution per week £	Rent supplement per week £	Family income per week £	Family income after rent £
March 2000 (before joining CE)	550	127	6	121	168	162
April 2000 (after joining CE)	550	127	36	91	189	153
May 2000 (after rent increase)	700	162	71	91	189	118
April 2001 (2nd year on CE)	850	196	101	95	197	96

This example is extracted froma circular from Focus Ireland, The Effect of the April 2000 Guidelines on Rent Supplement retained by those participating in Community Employment Schemes, 20.3.2001.

CICs around the country continue to identify a problem in young persons being denied rent supplement (and other social welfare payments) on the grounds that they could have stayed at home. In some cases staying at home may not be an option for these young people due to abusive parents, alcohol problems at home etc. (See Note)

Since April 2000, Back to Work Allowance and Family Income Supplement have not been assessed for the purposes of the weekly income limit of £250 for retaining rent or mortgage interest supplement. Income from Community Employment schemes should similarly be excluded from the assessment.

Many tenants in the private sector are unable to benefit from rent allowance and/or tax credits for rented property because their landlords refuse to supply rent books and their PPS numbers (required when claiming rent tax credits).

The qualifying condition for mortgage interest supplement should be based on money earned, not on the number of hours worked. Someone working 29 hours per week could have a higher income than someone working 31 hours per week. However, because the qualifying condition is working less than 30 hours per week, the person on the higher income would be entitled whereas the person on a lower income would not be entitled.

Grants under the Special Housing Aid for Older People scheme and the Essential Repairs scheme need to be increased, and claims for these grants need to be dealt with more quickly - CICs in various parts of the country report long waiting lists for repairs under these schemes. Local authorities also need to respond more promptly and effectively to tenants' requests for repairs. Comhairle has received CIC feedback about failure by local authorities to carry out repairs and maintenance work. In some cases tenants had to take out loans to pay for the repairs themselves.

There is clear evidence from CICs and other voluntary/community organisations of non-compliance by landlords with regulations in respect of minimum standards, rent and registration (See Note). Repairs and maintenance work are often not carried out. Many tenants do not dare to complain even in the case of extreme violations of their rights due to fear of eviction. Notice to quit is often not given in writing and does not comply with criteria set out in legislation. It is frequently the case that short verbal notice is given following a dispute between landlord and tenant. There is evidence of deposits being withheld by landlords for reasons other than those laid down in legislation, e.g. for general cleaning of a flat after the departure of a tenant. There are issues about increases in rent by landlords and in what circumstances landlords are entitled to raise rents.

Legislation on the private rented sector should be reformed as a matter of urgency in order to improve tenants' rights (See Note). Given that there are serious housing shortages in many areas, tenants tend to be reluctant to enforce their rights due to the fear of notice to quit. Help and advice must be available to tenants who have a grievance against their landlord, and all complaints must be addressed by local authorities. The sanctions for landlords who breach tenants' rights should be severe enough to deter abuse of tenants' rights. The security of tenure should be related to the length of time spent in rented accommodation: the longer the tenant has stayed in the property, the longer the minimum notice should be. Moreover, there should be quick and easy redress for landlords in cases where tenants do not fulfil their obligations.

Under various Housing Acts and Regulations, local authorities have responsibility for monitoring and enforcing standards in private rented accommodation. More prioritisation by local authorities of the regulation of the private rented sector is required.

Health Care

Medical Card Entitlement

The income guidelines for medical cards are too low at present and need to be raised. People on the minimum wage and some social welfare recipients have incomes in excess of the medical card qualifying income. Also, some Family Income Supplement recipients do not qualify for a medical card. A medical card should be automatically issued to everyone in receipt of means-tested payments including FIS. The medical card income guidelines should be aligned with social welfare payments and the minimum wage.

The income limit for a married couple (£144.50 per week) is particularly low considering that the limit for a single person is £100. This should be reviewed to reflect more accurately actual living costs.

Some people who have been in receipt of social welfare payments lose their medical card when they turn 65 and start receiving a retirement pension (until the age of 70). Given that retirement pensions and social welfare payments are relatively low and designed to cover only the most basic needs, it is not reasonable to expect these groups to pay for medical treatment out of their low incomes.

The possibility of giving a medical card to all children whose parents' income is below a certain limit should be seriously considered. The current system where income limits for medical cards are very low leads to a situation where many low and medium income parents (who do not qualify for medical cards for themselves and their children) may be reluctant to take their children to the doctor due to the cost of the visit and treatment. Medical card income limits do not take into account many important expenses such as childcare costs and mortgage repayments that can leave families with very little disposable income even when their gross income is clearly over the qualifying income limit.

As an alternative to giving medical cards to children where parental income is above the medical card limit but below a certain level, equivalence scales could be used to set the relative income limits for qualifying for the medical card. This should raise the income limit for families and, therefore, increase the number of families who are eligible.

The Long Term Illness Scheme should be revised and extended.

Administration of Services

In recent years, many entitlements have been increased and improved in a variety of ways. However, the process of applying for benefits and social assistance is still too complex and many people experience it as stigmatising. Consideration should be given to making payments more automatic so that, for instance, all over 70-year-olds are automatically given Free Electricity, TV Licence and Free Telephone Rental without having to apply. Evidence from CICs is that some older and other vulnerable people do not benefit from assistance that they are entitled to because they do not have the capacity or the resources to find out about and apply for their entitlements, or simply because appropriate forms are not always available. PPS numbers and computerisation (including the REACH programme) should make it possible to reduce paper work and bureaucracy involved in administering entitlements.

Comhairle has also received feedback from CICs which indicates that long delays, in some cases of almost one year, are occurring in the processing of applications (for Family Income Supplement, One Parent Family Payment, Carer's Allowance, free schemes, living alone allowance, pensions ). This is obviously causing hardship and frustration among people who are entitled to payments but have to live without them for long periods of time. More efficient use should be made of computerised records in order to minimise the amount of paperwork and duplication of applications and certificates required from social welfare clients. There should be more integration between the customer services of social welfare offices and health boards so that duplication and delays are avoided.

Currently the Department of Social, Community and Family Affairs is not obliged to process claims or to complete appeals processes within a specified time limit. Although DSCFA has set itself targets in this respect, some of them are not being achieved. In particular, CICs report that the appeals system in respect of applications for various services and benefits is very slow and waiting periods of 8-10 months are not unusual.

Comhairle recommends the introduction of an enforceable Charter of Customer Rights, that would outline specific time limits for the processing of claims and appeals, as well as other basic standards of service.

Additional procedures should be put in place that allow people applying for or availing of social services to lodge comments on the quality of service they get - difficulties identified should obviously be addressed where possible.

Miscellaneous

Bereavement grants

At the moment a record of PRSI contributions is a condition for receiving the Bereavement Grant. Recipients of non-contributory benefits are regularly identified by CICs as a group that experience difficulty in meeting the costs of a funeral. Consideration should be given to broadening entitlement to this Grant. A number of CICs have recommended that the bereavement grant should be available to the siblings of deceased lone parents where they foster the surviving child/children and, also, to the parents of deceased adult disabled children.

Free telephone rental

Eircom has a practice of completely disconnecting the telephones of people who have failed to pay all or part of their phone bills even in cases where people are in receipt of Free Telephone Rental. As Eircom continues to be paid for the line rental by the DSCFA , it appears very unfair that not even

incoming calls can be received or emergency numbers dialled. Incoming calls and use of emergency numbers are particularly important for older people living alone and people with medical conditions.

Christmas bonus

The Christmas bonus should be paid to recipients of short-term benefits such as Unemployment Benefit (UB). This bonus is paid to recipients of Unemployment Assistance, and excluding UB recipients appears unfair since UB recipients have contributed towards their benefits.

Free TV licence

While the introduction of free TV licences for all over 70-year-olds is to be welcomed, Comhairle has received reports that people who are about to qualify for a free licence (e.g. turning 70 in May), are still liable to pay the full annual TV licence fee if their licence comes up for renewal shortly before they qualify (e.g. in March). An arrangement should be put in place for paying a reduced fee by those who need the licence for less than a year before qualifying for a free licence.

Pension payments

Recipients of retirement and old age contributory pension can only get their first payment from the first Thursday following their 65^th or 66^th birthday. This means that recipients can lose up to 6 days' payments due to an obscure administrative rule. Those who opt to be paid by direct debit do not receive a payment for two weeks and hence may have to take recourse to supplementary welfare. The payment of these pensions should be streamlined. People who opt to be paid by direct debit should be informed about the gap in their payments.

References