Written evidence from Mr Ed Hodson CLP0025



I am an independent community researcher with, until very recently, 12 years worth of experience working as a Research and Campaigns Officer, and Lead, at Coventry Citizens Advice.

Because of the relatively low wage levels paid in much of the VCSE sector i was also personally in receipt of earnings-replacement based government ‘cost-of-living payments’ in 2022-23, and will be again in 2023-24.

Responses below, focusing primarily but not exclusively on earnings-replacement benefit payments, reflect both my personal experiences and my experience as a Research & Campaigns officer at Coventry Citizens Advice.

Please note - i do not speak for Coventry Citizens Advice in this submission.


Questions and Answers

1. To what extent have the cost of living support payments been sufficient at helping eligible households meet the cost of essentials such as food and electricity?

It is unquestionable that last year’s cost-of-living payments (CoL Payments) were an immensely welcome addition to the incomes of struggling households and that the same will be true of CoL Payments scheduled for 2023-24.

However, their positive impact must be placed in the context of insufficient pre-existing benefit levels; themselves undermined by various reductions, deductions and caps.

It is an accepted fact, outside government circles at least, that earnings-replacement benefit levels - even when paid accurately, reliably and without disruption - are set at below subsistence levels. Claiming these benefits leads those heading towards poverty into destitution, threatens their housing security and leads them into food and fuel poverty.

However, it is also the case that most recipients are not able to access their full entitlement to ‘daily living expenses’ anyway because of several factors listed below:

         Insufficiency of Local Housing Allowance Rates leading to rent shortfalls which are paid for from daily living expense allowances,

         Insufficiency of Council Tax Reduction levels leading to council tax liabilities being paid from daily living expense allowances,

         the application of the two-child limit for UC claimants leading to additional expenses for ‘extra children’ not be covered by daily living expense allowances, and

         the application of the Benefit Cap which leads to benefit recipients not receiving their full entitlement.

The list above - which doesn’t include deductions for benefit overpayments, official errors, essential bills or debt repayments - all undermine any view that planned and delivered CoL payments serve as an addition to a sufficient pre-existing benefit payment. Set at a level roughly equivalent to the notorious £20 per week UC ‘uplift’, these payments served and, i suggest, will continue to serve, to bring benefit payments back to what would be a subsistence level if there was no cost-of-living crisis.

The payments will be extremely welcome and the impact will be seen in temporary pauses to the demand for independent advice services for example but, i contend, those same benefit recipients will still need to visit food banks, claim fuel vouchers and require charitable support to keep them secure in their housing; in short, they will have the same positive but temporary impact the £20 uplift had.

Note - while the £900 payment to those in receipt of earnings-replacement benefits is equivalent to a little over £20 per week if an assumption is made that each third is meant to cover a 3 month period (and thus represents a replication of the UC uplift in scale), the Disability Payment and Pensioner Payment, at £150 each, equate to approximately £3 per week if split over 52 weeks (they are one-off payments). It should not need to be said twice that these amounts will not scratch the surface of additional cost-of-living costs to eligible disabled and/or pensioner recipients.

In their form and value, these latter two payments look more like one-off token charity awards to those the government of the day have identified as “deserving poor” rather than any real attempt to address actual ongoing cost-of-living financial pressures.



2. What role have the following factors played in access to the cost of living support payments:

a) Passporting: Not already being in receipt of certain means-tested benefits, despite being eligible, and consequently being prevented from accessing emergency support;

b) Cliff-edges: Not being in receipt of a certain means-tested benefit, because households failed to meet certain qualifying thresholds.

c) Qualifying period anomalies: issues relating to the timing of benefit payments;

d) Receiving a nil reward on a Universal Credit payment, due to reasons such as sanctioning; or

e) Any other technicality you believe the Committee should investigate?

Confusion for potential recipients is the common thread when identifying the role the factors above have played in accessing CoL Payments. Once an ad hoc payment process had been identified as the delivery method for these payments, rather than a simple equivalent increase in the appropriate basic benefit entitlement, a Pandora’s Box of potential administrative headaches was opened.

What if the potential recipient’s circumstances had changed between the qualifying period and the associated payment period? What if the claim involved a nil award? What if a decision to end benefit entitlement was being challenged through a Mandatory Reconsideration or being appealed at Tribunal? What if, as is common with a large percentage of benefit applications, the status of the claim was uncertain and not settled either during the qualifying period or the payment period? And how to make the answers to all these questions clear to potential recipients; many of whom may suffer from a range of physical and/or mental health issues preventing their easy understanding of “the rules and regulations”?

What is left, from the perspective of the prospective recipient of much needed additional income, is the promise (misleading, for some) of some more money and no real sense of when, or even whether they will receive it; with no encouragement to follow up potential missed or delayed payments. That lack of clarity means that these payments cannot be integrated into weekly budgeting in a way that the government would like and would have the biggest impact. These payments, to many, just seem like a (very small) lottery windfall which is welcome but divorced from their weekly needs.


3. How has the Department’s ad-hoc payment system and its design and use benefitted or limited the delivery of cost of living support?

The welfare benefits delivery system in the UK is complex, made more complex by the design and delivery flaws inherent in an only partially delivered digital-by-default Universal Credit and the need to continue to deliver numerous ‘legacy’ benefits as well.

Despite this complexity, delivering additional support to earnings-replacement benefit recipients in response to cost-of-living pressures should be simple. It should simply be a matter of increasing the weekly benefit entitlement to a rate reflective of the support being promised.

Recipients would see that increase in their regular scheduled payments, or not, which would help them integrate the additional money into their weekly or monthly budgeting. If the payments were missing they would know immediately and be able to respond accordingly. Potential confusion caused by having to look retrospectively for a number of separate lump sum payments outside their normal payment, to which they may or may not be entitled but which they are told will be automatic, would be reduced to a minimum.

But, i contend, for reasons that can have nothing to do with claimant needs or even administrative imperatives, the government chose not to use this method.

Delivering any ad hoc payment(s) across this system would be a challenge in any circumstances. Splitting several lump sum payments across several months, promising an automatic payment, but leaving potential recipients unclear about their own eligibility, seems almost to be designed to cause maximum confusion and uncertainty; negating the ability of households to integrate these additional sums into their regular budgeting. They look, tellingly i feel, like charity awards from a wealthy benefactor trying to look generous in front of others, not vital additions to publicly funded welfare benefits designed to support those most affected by an international crisis (exacerbated by a flawed national economic strategy) not of their making.



4. Are there any examples of international best practice in relation to the delivery of emergency cost of living support that the UK can learn from?

I am not in a position to respond to this question.






May 2023