Citizens Advice response to the Timms Review call for evidence

The executive summary of the report is published below. Click here 901 KB to download a pdf version of the full response, and click here to download an editable Google doc version.

Executive Summary

Theme 1 - Role and purpose of PIP

Personal Independence Payment (PIP) has a vital protective effect on our clients’ budgets. The disabled people we help with debt are 28% more likely to be in a negative budget if they don’t receive PIP. PIP helps cover the extra costs associated with a health condition and supports people to live more independently. 1 in 5 people we help with PIP are in work, and for many, the support they receive from PIP enables them to stay in work. Without PIP, many of the people Citizens Advice helps would be pushed into poverty. 

Whilst PIP is essential, it’s often not enough to address the complex problems facing the disabled people we help. A more holistic approach to supporting PIP claimants could help connect people with the further support they need to live fuller, independent lives. Many of our advisers would like to see PIP applicants signposted or referred to additional support, such as advice services, healthcare, and employment support. However, this would need to be offered in addition to PIP, not as a replacement for cash support. If an additional support offer for PIP applicants is implemented, it must be voluntary, holistic and tailored to the individual.

Theme 3 - Experience of claiming PIP

We help nearly 900 people every day with issues relating to PIP - that’s a sign the system isn’t working as it should. Our advisers describe the current PIP claims process as difficult, long and complex. Applications place a large burden on disabled people and can be overwhelming. Unnecessary assessments and award reviews create stress for claimants and slow down decision-making. Crucially, too many people are incorrectly rejected and have to fight through an appeals process before receiving the help they need.

Reforms to PIP must prioritise making it straightforward and fair to access for those who need it. Citizens Advice would like to see the following key changes:

• A more straightforward application process. Forms should be more accessible and user-friendly, with longer submission deadlines. Providing supporting evidence should be easier, with the option for claimants to request that the DWP collect evidence on their behalf. A fully digital service should be rolled out as soon as possible, with non-digital options retained.

• Make more decisions without a medical assessment by awarding PIP based solely on applications where possible, and moving away from an assessment-by-default model. The Timms Review should also consider the value of a fast-track process for claimants with certain diagnosed conditions with a high level of functional impact.

• Get decisions right the first time. Assessment reports must be evidence-led, including ending the use of informal observations and ensuring assessors have the necessary relevant medical expertise. The decision-making process should be rebalanced to reduce reliance on assessment reports. Transparency and accountability in the decision-making process should be improved.

• Reform Mandatory Reconsiderations (MRs) to correct more wrong decisions earlier in the process.

• Fewer unnecessary award reviews, especially for those with lifelong conditions whose awards are very unlikely to change.

Theme 4 - Changing context and the impact on PIP

Plans to abolish the Work Capability Assessment (WCA) and use the PIP daily living component as the single gateway to the new Universal Credit (UC) health element will have significant implications for disabled people. This proposed model places significant pressure on the reliability of PIP assessments, which must be fundamentally improved.

The alignment of eligibility criteria for the PIP daily living component and UC health risks creating an ‘all or nothing’ support system. We are particularly concerned about people with work-limiting conditions not covered by the PIP criteria, people with temporary conditions, and people who qualify only for the PIP mobility component. Under new rules, these groups could lose out on additional health-related support in UC. The removal of the WCA will also necessitate finding a new way to determine levels of conditionality in UC. To avoid conflating work capability with eligibility for PIP, we recommend keeping the PIP assessment separate from conditionality.