Control Strategy 2019-2023
"A critical aspect of ensuring people are in receipt of the correct payment is the provision of clear, relevant and timely information"
In late February, 2019 the Irish National Organisation of the Unemployed (INOU) made a submission to Department of Employment Affairs and Social Protection’s (DEASP) Control Strategy 2019-2023. The INOU noted that the DEASP’s Statement of Strategy 2017-2020 says its mission is “To promote active participation and inclusion in society through the framework of employment rights and the provision of income supports, employment services and other services”; and that the Department’s overall objective for 2017 to 2020 is “To continue putting our clients at the centre of all our operations, providing an efficient and effective service and to continue developing our staff, structures and processes.”
Dealing with a Complex System
Ireland’s social protection system is complex: it consists of payments based on entitlement built up through work and PRSI contributions; to payments accessed through meeting the eligibility criteria associated with a payment, including a means test; to the only universal payment, Child Benefit. Then for people of working age in receipt of a Jobseeker’s payment, there is the application of the activation model which should assist people to access employment or an appropriate employment, education and training programmes. However, the INOU are aware that referrals to existing supports do not necessarily match the person to the most relevant or useful option for them. While INOU affiliates have raised concerns about whether the people they are trying to work with are on the most appropriate social protection payment.
Application and Assessment
A critical aspect of ensuring people are in receipt of the correct payment is the provision of clear, relevant and timely information. Given the changing nature of the labour market, it will be important to ensure that social protection supports meet people’s needs and that potential clients do not find themselves cut off from badly needed supports.
At all stages of the process the correct information must be provided, and at no stage in the process should it be assumed that people know everything they need to know, good sign posting, spelling out all the steps required, is essential for a client centred service, and should help to reduce error.
Under Objective 1, ‘Put the Client at the Centre of Services and Policies’ it notes that the Department will “Ensure speedy access to accurate decisions, payments and reviews for all schemes and services, which are clearly communicated to the client”. Through the INOU’s welfare rights work concerns have been raised about a lack of clarity in the information provided and cases going to appeal that should have been resolved at the local Intreo Centre / Social Welfare Office.
Being called in for interview
It would be important that the person making or in receipt of a claim should be formally advised in writing of the purpose of the interview. The person should be clearly informed that they could have a named representative present. The person should be afforded the right of full and complete disclosure of documents prior to any such interview. The person should also be presented with any records or notes of the interview at the conclusion of the interview. The person should have the right to request that any inaccurate or incomplete information contained in the records or notes are corrected or amended, and a record of such request be made. The person should be advised of any procedure or process that the Department may undertake stemming from the interview.
Dealing with overpayments
The INOU has concerns, from a welfare-to-work and work retention perspective, that the receipt of Attachment of Earnings Notice by an employer could unduly and unnecessarily prejudice any current and future prospects for continued employment for the person subject to the notice.
It would be generally accepted that the Department’s overarching emphasis is not only to support the return to work of jobseekers, and those of working age, but to actively promote the long-term sustainability of such employment as evidenced by the number of direct, and indirect, back to work supports and initiatives provided by the Department.
It is therefore essential, in cases where the Department are not actively seeking formal prosecution of what technically constituted a fraudulent offence, that any action taken by the Department in seeking to recover any outstanding debt does not undermine or impede the claimant’s ability to seek, obtain or sustain employment in the longer term.
The Department has highlighted its use of data matching for control purposes. With the introduction of the Public Services Card, concerns have been raised by a range of commentators about the use of biometric data and data harvested through on-line activity.
It seems odd that such data can be used for control purposes, yet the dissemination of targeted data that would assist people to make the welfare to work journey seems to be so hit and miss. Better and more constructive engagement between the system and the person would lead to less control issues arising and could ensure the development of staff, structures and processes to efficiently and effectively put the client at the centre of services and policies, in keeping with Departmental objectives.
Good monitoring and reporting on the Department’s control functions are important. In popular discourse there is an assumption that fraud is wide scale. Yet, the evidence shows that most control issues arise because of misunderstandings and miscommunication resulting in misinformation and error, on both sides of the counter. To that end it will be important to support frontline staff to deliver a person-centred service with good guidance and information on the most suitable options for the person concerned.
Many people living on the margins of Irish society fear to engage with the system, as they are concerned that it will worsen their circumstances. Yet, the opposite may in fact be the case. So, it is absolutely critical that there is good engagement between service delivers and service users, and that clients or potential clients see their local Intreo or Social Welfare office as the place to go to get help; what that help may be; and how best to address any changes in their lives that may arise.
To read the full submission please follow this link https://www.inou.ie/download/pdf/inou_submission_on_control_strategy_20192023.pdf