Submission to the Office for Social Inclusion on their Consultation on preparation of Ireland's National Action Plan against Poverty and Social Inclusion 2006-2006
1. Introduction
Comhairle has a statutory remit to support the provision of information, advice and advocacy services for all citizens. To this end, Comhairle is involved in the development of Citizens Information Services, including the development and support of the nation-wide network of Citizen Information Services (CISs), the Citizens Information Phone Service (CIPS) and the Oasis Website (www.oasis.gov.ie).
One of Comhairle's statutory functions is to promote and develop the provision of information on the effectiveness of current social policy and services and to highlight issues that are of concern to users of those services. In carrying out this function, Comhairle relies heavily on feedback from CISs and CIPS based on the needs and experiences of users of the CIS and CIPS services. Information providers in CISs, deal with all areas of a member of the publics' life. Information is given on a broad range of topics and data is gathered from clients to feedback to Comhairle.
CISs and CIPS report queries with a social policy dimension to Comhairle where they are analysed and used as the basis for policy submissions and reports. During 2004, the CISs registered almost 650,000 queries and the CIPS almost 73,000. Of these queries, 1,649 were deemed by CISs and CIPS to have social policy implications and were reported to Comhairle in separate social policy records. These were queries where it was considered that the service available fell short of what was needed or appropriate in the particular situation.
Issues relating to poverty and social exclusion span all the headings under which CISs report to Comhairle. Comhairle's 2005 survey of CISs examined the types of information needed by clients. Preliminary figures (see below) from the survey show that many of the queries of clients presenting to the CIS are income related. In all, 9001 queries presented by clients of 9 CISs in this survey. These were classified into 14 broad categories (see table below). Social Welfare (34%) queries were the most common queries presented to information givers at CISs nationwide. For the purposes of this survey employment has been split into two distinct categories; Employment Rights queries which include holiday entitlements, contracts and payment of wages. Employment queries deals with more income based queries and refers to questions about returning to work, employment schemes and apprenticeships. Both of these employment categories have implications for the income of those in low paid work or for those returning to work. The majority (51%) of queries received in CISs span these three categories.
We have selected a number of priorities under some of the headings in the guidelines to assist with written submissions.
2. Facilitating Participation in Employment
In April 2001 Comhairle submitted its input to the review of the National Anti-Poverty Strategy Working Group on Employment. Many of the issues highlighted are issues that information providers in CISs continue to deal with. Issues such as, lack of enforcement mechanisms for employees to adequately enforce their employment rights, the lack of protection afforded to EU - non national employees, welfare work traps and access to work issues for those with disabilities or who live in rural areas with no public transport. We expand and add to these issues in the section of this submission that is to follow.
2.1 Childcare Costs
Childcare costs continue to be identified as an issue by CIC users, particularly in relation to women's participation in the workforce. The availability and cost of quality childcare is a key issue for all working parents who find it difficult to integrate work and family life due to the lack of available and affordable childcare services. The problem is more acute for lone parents. Comhairle welcomes the additional grants allocation to childcare initiatives under the Equal Opportunities Childcare Programme. However a more proactive approach by Government is required in order to develop sufficient accessible and affordable childcare facilities at local level.
- A nationwide quality and affordable childcare system with an emphasis on care and curriculum as well as infrastructure and regulation, needs to be developed and properly funded.
- Childcare facilities need to be developed as part of a comprehensive programme of community based childcare schemes.
- Support the further development of family-friendly policies in workplaces.
- Additional pre-school childcare places, which are accessible to low-income families, should be provided at local level.
2.2 Continuing to Combat Long-term Unemployment
Policies to ease the transition from unemployment to employment have enjoyed some success in lowering the numbers of long-term unemployed over the last number of years. Those unemployed for 12 months were eligible for Back to Work Allowance up until April 2001. Budget 2003 restricted the Back to Work Allowance to those who have been five years unemployed. It is important that policies continue to work in a preventative way to limit long-term unemployment. To this end the decision in Budget 2003 to restrict the Back to Work Allowance to those who have been five years unemployed should be reviewed. Area based measures to reduce long term unemployment should also be further supported.
2.3 Back to Education Allowances and Low Paid Workers
Employees who wish to improve their employability by returning to full time (or part time) education are not supported in the same way as those who are unemployed. Consideration should be given to the provision of some support to people who wish to break the cycle of low pay by returning to education.
2.4 Family Income Supplement
A number of problems continue to arise in relation to Family Income Supplement. These include low take-up rates, information in relation to entitlement, entitlement when working atypical hours, assessment of maintenance, calculation of entitlement, assessment of differential rents and the non-availability of FIS to the self-employed.
Many people (particularly lone parents) are job sharing (a 35 hour week being increasingly common) and many fail to qualify for FIS due to the number of hours worked. The qualifying working hours are averaged over a week or a fortnight. However, a growing number of people working in atypical employment (casual, part time and irregular hours) find that while hours worked, averaged over a monthly period, exceed this limit they may not qualify for FIS where the hours worked are calculated on a weekly or fortnightly basis. The qualifying working hours for FIS should be reduced from 19 to 17.5 hours per week. Calculation of FIS entitlement should take atypical work situations into account when making decisions around entitlement.
2.5 Older People in Employment
As the numbers of older people in the population increases, pressure on people to continue working will increase. Legislation needs to keep pace. People who have decided to continue working after age 66 do not pay PRSI but they are also not covered by employment or equality legislation. Employment protection and equality legislation need to be updated to cover all those legally in employment including those over the age of 65.
2.6 Welfare to Work Traps
Welfare to work traps still make it difficult for some people on social welfare and HSE payments to enter education or make the transition from welfare to work. Loss of Rent Supplement, Medical Card or One Parent Family Payments can leave families in a worse financial situation on entering the work force. Transitional arrangements and the prescribed income ceiling, which has not changed since 1996, need to be reviewed.
3. Facilitating Access by All to Resources, Rights, Goods and Services
3.1 Advocacy
Comhairle's key functions are “to support the provision of independent information, advice and advocacy services and to assist and support individuals, in particular those with disabilities, in identifying and understanding their needs and options and in accessing their entitlement to social services”.
Access to resources, rights, goods and services is, in the first instance dependent on access to information. “Information helps us all to make decisions and choices about our lives and enables us to live independently, to access social rights and take part fully in society”. Comhairle provides accurate, comprehensive and accessible information to the public on a wide range of social services. Comhairle delivers this information through three main channels: the network of Citizens Information Services, the Citizens Information Phone Service and OASIS (Citizens Information Online). However, many groups are at a significant distance from the people who provide information and services. These groups include people with disabilities, minority ethnic groups, Travellers, homeless people, those living in institutions and people who are socially isolated. Comhairle is working to support the development of advocacy skills for information providers within the network of Citizens Information Services so that they will be better equipped to help people find the information they need, negotiate complex information and access their entitlements. They also support those taking appeals under social welfare, employment and equality procedures. The Comhairle Amendment Bill 2005 gives Comhairle the added responsibility of setting up a personal advocacy service for people with disabilities.
A Comhairle report, Developing an Advocacy Service for People with a Disability, which was commissioned from Goodbody Economic Consultants in 2004, sets out a strategic approach to developing these services. There are three strands to this approach: a Personal Advocacy Service, a Programme of Support for Community and Voluntary Organisations and a Community Visitors Programme. Comhairle is currently focussed on the development and support of advocacy services for people with disabilities in the community and voluntary sector.
The main aim of all these advocacy initiatives is to facilitate access to information and entitlement to civil and social services, particularly for those who are more vulnerable, marginalised or isolated.
It is important in the preparation of Ireland's new Action Plan against Poverty and Social Exclusion that the importance of advocacy to facilitate vulnerable people in accessing their rights and entitlements is acknowledged.
Helping the Most Vulnerable Groups
In writing this submission we have identified some of the vulnerable groups whose issues come to the attention of information providers in CISs.
4.1 Children : Child Income Supports
Comhairle welcomes the request to the National Economic and Social Council to examine child income support arrangements and specifically the possibility of a Child Benefit Supplement being paid to low income families. This supplement would replace FIS and Child Dependant Allowance and possibly also the Clothing and Footwear Allowance and would not be affected by employment or lack of it. In the short term, as well as increasing Child Benefit in accordance with promised NAPS targets, substantial increases should be made to the Child Dependant Allowance in order to target income to the poorest families.
4.1.2 Back to School Clothing and Footwear Allowance
Households with children of school going age are at a relatively high risk of poverty particularly when parents are unemployed. The risk increases with family size. This can contribute to early school leaving and unequal access to further education. However, the Back to School Clothing and Footwear Allowance excludes a number of welfare dependant and low-income families at present. The means test for the Back to School Clothing and Footwear Allowance should be adjusted to take into account family size and the range of supports already received. If families are already receiving support such as a social welfare income support payment, back to work payment, Revenue Job Assist, FÁS training, CE or FIS, they should automatically receive this payment.
4.2 One-Parent Families
Lone parent households are at high risk of poverty. Lone parents experience particular difficulties combining their working and caring responsibilities and tend to experience other labour market disadvantages including low educational qualifications. It is becoming more widely accepted that fathers, (including non-resident fathers), should have as big a place in children's lives as mothers, in the best interests of themselves, the mothers and, most importantly, the children. Sharing the care and upbringing is as important as financial provision. It is important that social welfare provision encourages joint parenting and that the rights and needs of the child are central to family policy. The particular needs of lone parents should be fully taken into account in the development and integration of flexible employment and childcare policies and housing needs assessment. Lone parents who are also school leavers are a particularly vulnerable group and a range of policy initiatives should be identified to respond to their needs.
4.2.1 One-Parent Family Payment
The protocols for dealing with applications for the One Parent Family Payment, the pursuit of maintenance and the related interface between the Department of Social and Family Affairs and the Court System should be reviewed.
4.2.3 Support for One-Parent Families
The role that Community Employment, the Job Initiative Scheme and the Social Economy Programme play in assisting lone parents in returning to or entering employment should be fully acknowledged in ongoing reviews and/or re-focusing of such schemes to ensure that these pathways to education and employment are not cut off. Existing legislation in respect of non-marital fathers and social welfare provision in respect of cohabiting couples should be amended to support the concept of joint parenting where appropriate. Existing anomalies should also be dealt with. Mediation should be proactively promoted in situations of marriage/relationship breakdown as a desirable alternative to the current dominant adversarial approach. There should be a much stronger emphasis on the needs of children in such situations.
4.2.4 Grandparents Caring for Grandchildren
CICs have identified issues in relation to the status and rights of grandparents including income and other supports when grandparents are taking care of children full-time. Clear guidelines need to be developed on the State financial assistance grandparents caring for a grandchild should receive and income and other supports need to be put in place for grandparents who are taking care of their grandchildren full-time.
4.3 Older People
The EU Survey on Income and Living Conditions (2005) found that people living on their own are among the groups most at risk of poverty. In 2002, 26 per cent of those aged 65 and over lived alone and this figure is projected to increase to 30 per cent by 2021. The survey found that just over 36 per cent of those aged 65 and over were found to be at risk of poverty compared to 23 per cent of the total population.
4.3.1 Adequate Income
In order to achieve the aim of continuing to live at home, older people need an adequate income. Annual increases in Social Welfare payments for people aged 66 and over need to reflect increases in the cost of living on an ongoing basis.
4.3.2 Living Alone Allowance
The Living Alone Allowance is a supplementary payment for people on social welfare pensions who are living alone. The rate per week for people aged 66 or over is €7.70 with an extra allowance for people aged 80 or over of €6.40. This allowance was rounded up from €7.62 to €7.70 in 2002 but has not been increased in effect since 1995. The Living Alone Allowance should be increased in line with inflation.
4.3.3 Qualified Adult Allowance
The Qualified Adult Allowance (QAA) for a dependent spouse is currently €119.50 (for under 66 years) and €138.50 (for over 66 years) for a dependent spouse of a person on Contributory Old Age Pension (COAP). It is set at €109.70 for a dependent spouse of a person on Non Contributory Old Age Pension (NCOAP). Between 2000 and 2005 the Qualified Adult Allowance increased by 6% of the single rate for those on NCOAP and by 10% of the single rate for those on COAP. There is an inequity here which mostly effects spouses who worked in the home rearing families. In Budget 2001 the QAA rate for those over 66 years of age was increased by £15 per week with pro-rata increase for those on reduced pensions. The Minister announced his intention at the time to increase the over 66 QAA rate to the same level as the NCOAP personal rate (approximately 90% of CP rate). The commitment by Government in Sustaining Progress (page 57) to work towards increasing the level of Qualified Adult Allowance for pensioner spouses to the level of the NCOAP should be progressed, particularly for dependent spouses of people on Non Contributory Old Age Pension (NCOAP).
4.3.4 Refuse Charges
Since refuse services were largely contracted out to private operators up to 20 of 34 local authorities are not operating a waiver scheme. As refuse charges continue to increase this can be a heavy financial burden on an older person on low income. Waivers on refuse charges should be consistent across local authorities and available to all over 65 (and other eligible groups).
4.3.5 Bereavement Grants
CICs frequently draw attention to the fact that people in receipt of insurance -based payments are entitled to a Bereavement Grant while those on means-tested payments are not. While the latter can apply for a Supplementary Welfare Exceptional Needs Payment to cover funeral expenses, there is no entitlement as of right. Also, the amount of the Exceptional Needs Payment for funeral expenses may be significantly lower than the Bereavement Grant (currently €635). A number of CICs have referred to the fact that covering the costs of funeral expenses can be very stressful for older people on low income. People in receipt of social welfare payments should be automatically entitled to a Bereavement Allowance.
4.3.6 Subvention for Care in the Home
The policy of promoting care at home requires that the supports available for home living are balanced with those available for institutional living. An older person with particular needs requiring a high level of support should, where appropriate, be able to avail of a subvention in order to live at home. Direct payments are preferable to tax relief for the provision of social services but if tax relief is available, it should support relatives in providing home care packages to enable older people to continue living at home as well as supporting institutional care.
4.4 People with Disabilities
Some 38% of people who are ill or have a disability are considered ‘at risk of poverty' compared to 21% of all households*.
4.4.1 Cost of Disability Allowance
Many people with disabilities have significant extra costs related to their disability. These costs vary according to the severity of a disability. A 2003 Comhairle submission to the DSFA Review of Income Maintenance Payments for People who are Ill and people with Disabilities points to the “substantial extra costs of disability, especially for people living alone”. Initial outlay on aids and appliances and the loss of paid employment places a considerable strain on people with disabilities and on family carers. Groups representing people with disabilities have long campaigned for the introduction of a Cost of Disability Allowance. In its 2004 report, Disability and the Cost of Living, the National Disability Authority, has called for the introduction of a Cost of Disability payment because the cost of living is higher for people with disabilities and for families caring for a person with a disability. A Costs of Disability Allowance (non means tested) should be introduced to cover extra transport, heating, education and assistance costs for people with significant disabilities - to reduce disincentives to employment, training and education and to promote independent living.
4.4.2 Disabled Person's Grant
The problems with the Disabled Person's Grant scheme are well documented. CICs receive regular complaints about this scheme. These mainly concern delays in getting an assessment for the scheme, further delays in the processing of applications and inadequate funding. In 2003, Comhairle and the National Disability Authority made a joint submission to the Department of the Environment, Heritage and Local Government Review of the scheme. The recommendations in this submission asked that: A national policy for the administration of the grants needs to be introduced, including a requirement that grants are applied consistently across local authorities. Decisions on grants need to be made within a fixed time limit and there should be an independent appeals system.
4.5 Migrants
4.5.1 Problems Faced by Migrant Workers on the Work Permit Scheme
There is considerable evidence that some migrant workers on the work permit scheme are having difficulty obtaining their basic employment rights including minimum wages, contracts and holiday pay. Their rights are compromised by the fact that the work permit is employer specific and that, as a result, the market option of finding a new job if current conditions are bad is extremely limited. A number of migrant workers have complained to CICs that the cost of the work permit has been deducted from the employee's weekly wage and some claim to have paid large sums, (up to €10,000) to their future employer for a work permit. Work Permits should be issued to individual workers and not to employers.
4.5.2 Habitual Residence Condition
The Social Welfare (Miscellaneous Provisions) Act 2004 and Regulation (EC) No 647/2005 provided for the introduction of a new rule about habitual residence for people applying for social assistance payments and Child Benefit. The habitual residence test means that, in order to get any of these payments, you have to show that you have been habitually resident in Ireland or in the Common Travel Area of the UK, the Channel Islands and the Isle of Man, for "a substantial continuous period" and that that this country is your “centre of interest”. The main issues relating to migrants arising in social policy returns from CISs in relation to the Habitual Residency Condition have been that migrant workers may have no social welfare safety net when a problem arises in their health or employment within the two year period. Foreign nationals, including those from the new member states, who are being encouraged to come to Ireland to work are sometimes finding that accommodation costs are out of their reach and employment is not always that easy to find. Their money runs out and they have no income while they seek employment. Comhairle welcomes the review of the administration of the scheme which is being undertaken by the Department of Social and Family Affairs at present and recommends a broader review of how the scheme is impacting on people on the ground.
Conclusion
Comhairle welcomes the opportunity to contribute to the development of the National Action Plan against Poverty and Social Exclusion. Included in this submission is an outline of the major issues that cause exclusion that personnel in CISs come across. The outline is not exhaustive but indicates major issues presenting to CISs in relation to poverty and social exclusion.
