I am concerned that applicants will not be given sufficient opportunity to submit supporting written evidence. This is particularly important for people with conditions such as autism.
The former Minister for Disabled People Maria Miller agreed that there should be a “tiered” approach to PIP assessments during the passage of the Welfare Reform Act and in answer to a written parliamentary question from 22 May 2012. This would involve considering written evidence submitted initially, proactively gathering additional evidence if none was supplied by the claimant, and only then deciding whether a face-to-face assessment was necessary.
This would prevent unnecessary, costly and stressful face-to-face assessments for people who already have lots of medical and other evidence that sets out their disability and resulting needs in some detail. It would be particularly helpful for people with autism who find it difficult to put their experiences into words. Many also have deficits in social imagination, meaning they cannot foresee consequences of their own and others’ actions, such as not sending evidence with their initial application.
I’m concerned that at the time of writing we haven’t yet seen the guidance that will go to assessment providers Atos and Capita regarding the circumstances when paper bases assessments should undertaken. I’m also concerned that these contractors have been set a target of one month by DWP to complete the assessment process, with day 1 being the day they receive the claimant information from DWP and day 30 being the day they send their report to a DWP decision-maker. Even if they make a request for further written evidence to be sent to them, one month is unlikely to be enough time for it to be received and considered, before arranging a face to face assessment.
What this means is that the default position will in fact be that the majority of claimants, no matter what their condition or individual circumstances, will be asked to attend a face to face assessment, unless they already have a significant amount of written evidence to hand or are particularly capable. This means that less capable claimants, or those with less written evidence to hand, will be significantly disadvantaged.
One potential solution is to extend the 30 day target or at least allow for flexibility in certain cases so as to allow time for assessors to pro-actively gather written evidence and consider it before arranging a face to face assessment. I will be pushing the Government to carefully consider this proposal.