Written evidence from Project 17, The Unity Project and The Children’s Society (CPN0019)

This submission has been prepared jointly by Project 17[1], The Unity Project[2] and The Children’s Society[3]. Our three organisations are committed to ending child destitution and ensuring all families, regardless of the parents’ immigration status, are able to access the welfare safety net. We all have experience of working directly with families affected by the ‘no recourse to public funds’ (NRPF) policy and supporting families to apply to have the NRPF condition lifted. This submission should be read in parallel to our extended submission on the ‘Change of Conditions’ (Coc) application procedure to remove the NRPF condition (pages 13 – 18) as well as the submission by United Impact highlighting voices of people with lived experience of NRPF (pages 19 - 24) and letters from children affected by NRPF (pages 25 - 29). This submission has also been endorsed by the Immigration Law Practitioners Association[4], Praxis[5] and Together with Migrant Children[6]. In addition, we want to acknowledge the help of the Migration Observatory at the University of Oxford in helping us detail some of the complex data around NRPF.

Summary:

Thousands of children are facing extreme poverty in the United Kingdom because strict immigration rules prevent their families from accessing the welfare safety net. The coronavirus pandemic has exposed the precariousness of daily life for thousands of families without access to public funds. Despite numerous calls from campaigners and politicians to suspend the ‘no recourse to public funds’ (NRPF) policy with immediate effect, the Home Office have continued to apply the NRPF condition to the majority of applications for leave to remain, pushing more families into deep, long-term poverty and destitution. Throughout the pandemic, the Government has sought to re-emphasise their commitment to the NRPF policy and point to other available measures or other support schemes as the reason why no further support is needed. In practice, these schemes are limited and offer little to no help. Additionally, the lack of a welfare safety net for these families has serious public health implications.

The founding principles behind this policy are to ‘reduce burdens on the taxpayer’, ‘promote integration’ and ‘tackle abuse’[7]. Yet the effectiveness of this policy in any of these respects remains un-evidenced and is increasingly being called into question. The destitution and hardship it causes to families can surely never be a legitimate means of pursuing policy goals. Research and government statistics show that the policy disproportionately affects non-white single mothers (among others)[8], successive court cases have proven that the policy is operating unlawfully[9]; and leaves many low-income migrant families reliant on support from their local authority and charitable organisations. While this policy might save one government department money, it shifts the financial burden onto other government departments, local authorities and civil society. The policy is defended on the basis that local authorities, charities, other governmental support schemes and the ‘Change of Conditions’ application procedure safeguard against harm; we hope the below illustrates to some extent why that is not the case.

The number of children affected by NRPF remains an estimate as the only Home Office published data covers applications to have the NRPF condition lifted, rather than applied.  From our direct work with people affected by NRPF we know that many families are unaware that they can make this application and struggle with destitution for years before receiving the information and support needed to make such an application. The number of children in families without access to public funds is set to rise, following the end of the EU Settlement Scheme (EUSS) deadline as well as the introduction of the Nationality and Borders Bill.

Based on this, our key recommendations are:

-          To end the NRPF policy to mitigate negative impacts on children in families with NRPF

-          Until such time as this comes into effect, at the very least, immediate measures should be taken to ensure the rights of all children are protected – for example:

• Home Office must collect data and monitor impact on children in families with NRPF
• Free School meals (and the associated pupil premium grant) should be extended permanently to all eligible children regardless of their parent’s immigration status
• Passported benefits must be reviewed and changes made to ensure eligible children are not excluded due to their parent’s immigration status

Approximately how many children in the UK live in households that have NRPF? What are the challenges involved in estimating this accurately? How many children in the UK are undocumented or have an insecure immigration status?

Estimates suggest that there are hundreds of thousands of families and children living in the UK without a welfare safety net to fall back on, and this number will continue to grow over the coming months.

Calculating the exact number of children (or adults) in the UK with NRPF is not currently possible due to lack of data. Despite repeated requests from campaigners and politicians, the Government does not produce data on the overall number of people living in the UK with NRPF attached to their immigration status or the number of dependants in those households. However, as it is Government policy to apply NRPF to all grants of Limited Leave to Remain, we can safely assume the overall figure is high.

The Migration Observatory at The University of Oxford estimate by the end of 2019, there were at least 175,000 children under 18 in families who would be expected to have NRPF and over 1.4 million adults[10] . As mentioned in The Children’s Society’s ‘A Lifeline for All’ report, there are some significant gaps and unknowns here as this figure does not include the numbers of children who are British citizens or who are making applications to register as British citizens but who are nevertheless affected by NRPF conditions on their parents’ status[11]. Nor does it include all children and families who have leave to remain but entered on other routes (such as visit visas or asylum routes) and some people who have switched routes or who had longer gaps between grants of leave to remain[12]. Immigration and welfare policy is a complex area of law and policy, and it is difficult to know precisely how various groups are affected. Therefore, the figures are likely to represent a minimum number of children and adults affected by NRPF conditions on their leave to remain.

In addition to those with the NRPF condition attached to their leave to remain, the Greater London Authority and University of Wolverhampton (2020) have estimated that there are currently 215,000 undocumented migrant children living in the UK, including more than half of which were likely to be UK-born children, who will have no recourse to public funds[13]. However, there is very significant uncertainty around the estimates, because of the inherent difficulties measuring irregular migration[14].

The number of families without access to public funds is set to rise, following the end of the EUSS deadline as well as the introduction of the Nationality and Borders Bill. There is already evidence of many vulnerable families, including victims of domestic abuse who have missed the EUSS deadline and are struggling to regularise their status and may not be able to access public funds[15]. The Nationality and Borders Bill will also introduce a temporary protection status with a ‘no recourse to public funds’ condition and there are no current plans to exempt families with children[16]. The Bill will also implement provisions from the 2016 Immigration Act which will push appeals rights exhausted families into destitution[17]. We do not yet have an idea of the numbers who may be affected[18].

It is vital that the Home Office monitor, record and publish statistics on the numbers of children affected by an NRPF condition – both those who are directly affected and those living in families affected by NRPF conditions. As the agency responsible for imposing NRPF conditions, the Home Office has a responsibility to monitor both the number of children and families affected and the potential negative consequences this may have on children. At present this is not happening.

Is it possible to determine how many children who live in households with NRPF are British citizens?

It is not possible to estimate this with the data publicly released by the Home Office.

Children can be denied access to public funds because of their parents’ immigration status, even though the children themselves might be British. As explained above, we do not know the overall number of households with NRPF, so cannot know how many of them include British children.

We could have an indication of this by looking at households with NRPF who make Change of Conditions applications:

-          According to the Home Office’s own file review in 2019, '46% of change of condition applications were made by applicants with a British child’[19]. This was based on a review of 240 case files but the Home Office does not have/publish data about this more broadly. This data is collected on the online form for the Change of Conditions applications, so should be possible to extract.

Other sources of information can be found in the work carried out by NGOs:

-          Of the 240 families affected by NRPF who were supported by Project 17 between May 2020 and May 2021, 50% were primary carers of British children.

-          The Unity Project’s Access Denied: The cost of the ‘no recourse to public funds’ policy report found that 90% of the families involved in their study had at least one British child[20].

What proportion of children with NRPF are living in poverty? How does this compare to children whose families do have access to public funds?

Having NRPF means that affected individuals, and their children, are prevented from accessing in-work and out-of-work benefits such as Child Benefit, Tax Credits, Universal Credit, Income-related Employment and Support Allowance, Income Support, Local Welfare Provision, Housing Benefit and social housing. It means domestic abuse survivors cannot access most safe accommodation if they are fleeing domestic abuse. Children from low-income families with NRPF are usually also denied free school meals, though some are temporarily able to access this support because of the pandemic (currently subject to a Department for Education and Home Office review).

People with NRPF attached to their immigration status pay the same taxes as every other in-work person living in the UK; they pay income tax, national insurance and council tax, but also face exorbitant immigration charges in the form of immigration application fees and the Immigration Health Surcharge[21]. Not only were these charges in place during a global pandemic, but the already significant Immigration Health Surcharge was increased by 64% in October 2020[22].

Previous research[23] has highlighted the high risk of poverty among children with foreign-born parents. CASE research[24] before the pandemic highlighted that almost half of children in migrant families who have been in the UK for 10 years or less were on relatively low income after housing costs (48.3% for non-EEA and 44.9% for EEA origins). This compares to 26.9% of children in UK-born/long-term resident families. A recent JRF briefing[25] flagged that nearly 4 in 10 BAME workers whose characteristics mean they are likely to be subject to ‘no recourse to public funds’ are paying unaffordable housing costs compared to 1 in 10 White workers. This suggests that many more families will be struggling on low income but will not meet the destitution threshold to get the NRPF condition lifted and apply for vital benefits.

Even before the pandemic, families that were interviewed for The Children’s Society’s report A Lifeline for All reported struggling to pay for essentials like food, utility bills, rent, and clothing with nine out of the eleven families interviewed reporting using food banks. Around a third of The Children’s Society’s service users who were affected by NRPF were also affected by debt. The report found a very worrying and direct impact on children’s emotional and physical health and well-being. One mother believes her young son has suffered emotionally because of their precarious situation and their experiences of immigration enforcement, explaining how fearful he is of officials whom he believes will be coming to take him away. Project 17’s report Not Seen, Not Heard: Children’s experiences of the hostile environment[26] highlighted the impact on children who had been left street homeless, in inadequate or unsafe accommodation, and without enough money to eat. Children interviewed for the report spoke of feeling socially isolated, distressed, ashamed and unsafe. As part of this submission, we have also provided an appendix of letters to include the voices of children affected by NRPF.

What impact has the pandemic had on children with NRPF? Has the lifting of restrictions made any difference?

There is no reliable published data on the impact that the Covid-19 pandemic has had on children with NPRF. However, while anyone is vulnerable in a crisis, including otherwise healthy single adults, single-parent families from Black, Asian and ethnic minority backgrounds with dependent children are more likely to have been negatively impacted by having NRPF[27] as well as being disproportionately affected by the pandemic[28].

People with NRPF are more likely to be in informal and low-paid types of employment. These forms of employment were particularly hard hit during the pandemic and many lost their source of income or saw their income reduced. Research from the Resolution Foundation found that while the average UK household spending dropped and savings increased during the Covid crisis, this was not the case for most low-income families who saw basic living costs drastically increase. The research identifies three main causes of this increase in expenditure: higher expenditure, less availability of cheap products and loss of family and community support[29].

Thousands of children faced extreme poverty during the pandemic because strict immigration rules prevent their families from accessing the welfare safety net – even if they were unable to work during the COVID-19 crisis[30]. This lack of financial support has serious public health implications. During lockdown, children and families were forced to stay at home, in overcrowded accommodation, with no room to play or do their home learning for those who have been in school closure bubbles. Families have had to depend on food parcels from foodbanks, charities and faith organisations and many have had to take on crippling debt, just to be able to provide for their children’s basic needs.

Many of these families were particularly vulnerable to forms of abuse, exploitation and destitution because of the barriers they face in accessing support. Access to the welfare system and legal tools can provide protection from abuse and destitution. Conversely, perpetrators of abuse can weaponise their victim’s lack of access to support and public funds, putting them and their children at serious risk of violence[31]. The Children’s Society have supported mothers who did not know their current immigration status because it had been tied to their abusive partners and they were kept uninformed. Project 17 frequently see women and children who are forced to stay in abusive situations due to having NRPF making it difficult to access support from local authorities.

This situation was compounded during the pandemic and one woman told us “when there was lockdown. My children, they can’t go anywhere. I can’t go anywhere. Before when they were going to school, they were not seeing things. But during lockdown they saw a lot of the things that we were going through. It has affected them a lot.” Fifteen percent of people who approach The Unity Project for assistance with CoC applications are survivors of domestic abuse – this number and the severity of harm dramatically increased during lockdown.[32] The NRPF condition – and particularly an irregular or undocumented immigration status – leads to a high level of vulnerability and often perpetuates the abuse and exploitation of parents subject to NRPF conditions.

Some early indications of the drastic and negative effect that the pandemic is likely to have had on children with NRPF can be found in evidence from Home Office and NGOs:

-          The Home Office data on ‘Change of Conditions’ applications showing the numbers of individuals who had applied to have the NRPF condition lifted. This revealed a significant jump – 568% – in the number of applications received at the beginning of the pandemic, from Q1 to Q2 of 2020[33]. Numbers of applications remain high.

-          Since the start of the pandemic, frontline services have seen a rise in families affected by NRPF restrictions seeking support, including many who had been refused support by local authorities as well as those who had not applied previously. [34]

-          Of the 159 families referred to Project 17 in the year between April 2020 and March 2021 almost 70% of clients reported difficulties related to Covid-19. The most common issues were reduced support from friends/family/religious organisations (37%), loss of employment (25%) and difficulty accessing enough food (16%). Forty-nine percent of families reported they would have faced significant barriers to self-isolating according to Government guidelines due to inadequate space, overcrowding and living in accommodation with shared facilities. Forty percent of families reported that their children could not access school during the pandemic due to lack of access to devices to access online teaching (44%) and insufficient access to Wi-Fi or mobile data to follow online teaching (33%). Many parents reported that their children, even some who were able to go into school some days a week, were not able to keep up with their school work at home. Despite the recognised increase in expenditure for low-income families (and the subsequent £20 uplift of Universal Credit) very few families supported by social services through section 17 of the Children’s Act 1989 reported being provided with additional support to offset increased expenditure associated with the pandemic, though there were some examples of good practice. 

-          The Trussell Trust reports that prior to the pandemic around 2-4% of people referred to food banks were likely to be subject to NRPF conditions – this rose to 11% by mid 2020[35].

The NRPF policy has been a continuous feature of successive governments[36] – but it does not mean the policy is fit for purpose. The coronavirus pandemic has exposed the precariousness of daily life for thousands of families without access to public funds and how children are often left to suffer the consequences.

What other financial support from the Government is available for families with NRPF who are facing financial hardship? How effective is this support?

Families with NRPF cannot access ‘public funds’. For immigration purposes, benefits and services classed as public funds are set out in s115 of the Immigration and Asylum Act 1999[37] and at paragraph 6 of the Immigration Rules[38]. This is an exhaustive list so payments or services that are not on that list are not public funds.

Benefits that are not classed as ‘public funds’

Public funds include most of the main welfare benefits, but not those that are based on national insurance contributions (‘contribution-based’) or most of the benefits that rely on past work. For example, the following benefits are not public funds: Bereavement Support Payments; New Style Jobseekers Allowance and contributory-based Jobseeker's Allowance; New Style Employment and Support Allowance and contributory-based Employment and Support Allowance; Guardian's Allowance; Incapacity Benefit; Maternity Allowance; Retirement Pension; Statutory Maternity Pay; Statutory Sickness Pay.

There is complex guidance relating to certain (limited) benefits that certain (limited) groups of people may be able to access, despite the NRPF condition[39]. However, the financial support available is designed to supplement public funds, not replace them.

-          Some of the above financial support may only apply in very rare cases (e.g. bereavement benefit and guardian’s allowance).

-          Some are very limited and don’t account for child-related costs (e.g. statutory sick pay).

-          There is very limited awareness of some financial support (e.g. ‘New style’ or contribution-based Jobseeker’s Allowance (JSA) and Employment and Support Allowance (ESA)). Since its launch, The Unity Project has routinely asked applicants if they are receiving these benefits and in over 4 years only 1 applicant (of hundreds) has been receiving them. Their CoC application was successful, meaning that the HO acknowledged that they were destitute, despite being in receipt of this financial support. Academic research has found that ‘80,000 people were probably eligible for the new style JSA did not claim this’.[40]

‘Passported benefits’

Technically people with NRPF are only barred from accessing ‘public funds’ as set out in the exhaustive list. In reality many financial support schemes are only accessible if one is in receipt of a qualifying benefit included on the list of public funds, while others have eligibility requirements relating to the immigration status of the parents.

This means that people with NRPF are excluded from a wide range of financial support[41]. Below we mention a few, though this list is by no means exhaustive:

-          Subsidised child care: Families with NRPF are entitled to 15h p/w free childcare for 3-4-year-olds and some are eligible for early years places for 2-year-olds. However, parents with NRPF are not eligible for the extended 30hr free childcare for 3-4-year-olds. This obviously limits employment possibilities.

-          Healthy Start vouchers: Parents with NRPF cannot access support for healthy eating vouchers for their children as these are tied to eligible benefits. The Department of Health and Social Care has temporarily extended eligibility to all eligible British children regardless of parents’ immigration status following legal challenge[42].

-          Sure Start Maternity Grant: New mothers with NRPF cannot access the Sure Start Maternity Grant which provides a one-off payment of £500 to help towards the costs of having a child as these are linked to qualifying benefits.

-          Free School Meals: Access to free school meals after the universal free provision is dependent on a child’s parent or carer needs to be in receipt of qualifying benefits. It is estimated that hundreds of thousands of children, despite living in poverty, are not currently eligible for free school meals, and are therefore often forced to skip lunch as their parents cannot afford the cost[43]. Eligibility has been temporarily extended for some during the pandemic and is under review.

-          Pupil Premium: The Pupil Premium Grant is extra money schools can claim to ensure additional funding reaches the most economically disadvantaged pupils in order to promote their educational attainment. Eligibility is tied to free school meals so excludes many with NRPF. This has been temporarily extended to match FSM extension for 2020-21 following legal challenge[44].

Financial support available to children in families with NRPF

Section 17 of the Children’s Act 1989[45] imposes a statutory duty on local authorities to safeguard and promote the welfare of ‘children in need’ in their area. This applies to children in families with NRPF where the child cannot achieve or maintain a reasonable standard of health or development without such support. Some adults will be ineligible for such support, unless the situation is so serious that a failure to provide support would breach human rights[46].

From Project 17’s casework we see how the inadequacy of section 17 support as a safety net leads many of the children in such families to grow up in exceptional poverty, at high risk of homelessness, exploitation and abuse. Many of our clients are unaware of section 17 support, do not understand how to access it or have attempted to access support and been wrongly refused. Many experience hostile ‘gatekeeping’ practices by local authorities including: being turned away, being refused due to their immigration status; being told to rely on other support networks, and threats to take children into care. Even when section 17 is provided, the financial support often falls below the minimum amount required for survival and people experience considerable delays (many waiting weeks or months) before receiving subsistence payments. Accommodation provided is frequently ‘temporary’, overcrowded and unsafe for children. The evidence from our casework clearly demonstrates the inadequacy of local authority support as a safety net for those with NRPF as well as the devastating impact this can have on the health and development of the children in these families[47].

The Care Act: In theory, adults with care needs in families with NRPF and pregnant women may be able to access support under the Care Act. However, this is often very difficult to access with individuals facing significant barriers to care.

Other support

Exceptions for some nationalities: Technically, some nationalities can access certain public funds due to ‘reciprocal social security agreements with the UK’. In our collective casework, we have never encountered anyone in receipt of benefits due to these agreements, most seem unaware of their existence and funds available are very limited.

Student finance/higher education: Student finance and higher education are not public funds. However, people with Limited Leave to Remain must meet certain residency requirements (including demonstrating 3 years lawful residence) to qualify. There is widespread confusion about eligibility with many missing out on education possibilities as a result.

How have families with NRPF benefited from the new support that the Government introduced in response to the pandemic, such as the Coronavirus Job Retention Scheme and the COVID Local Support Grant?

The measures put in place in response to the pandemic are largely inaccessible for those with NRPF.

According to the available guidance and several local authority websites, people must be claiming Universal Credit or Working Tax Credits to be eligible for the Test and Trace Support Payment Scheme, de facto excluding people with NRPF. Those who do not fulfil the criteria can access a discretionary local fund, however the discretionary fund is very poorly advertised, little instruction has been given to local authorities on how those with NRPF can access it or whether there is a set amount per local authority or a central pot of funding. We are not aware of any central monitoring to establish whether people with NRPF have been able to access this[48].

Twenty two percent of families that The Unity Project assisted during lockdown had underlying health conditions that put them ‘at risk’ from the virus. Of these, 54% were forced to continue working throughout lockdown, despite the potentially fatal consequences. The majority of people supported by The Unity Project are living in overcrowded accommodation which makes it impossible for them to self-isolate. Statutory Sick Pay only applies to those who cannot work due to illness, so it offers nothing for those who have lost income for other reasons. Even then, SSP only provides £96/week and does not account for child-related costs.

Most migrants live in private rented accommodation, and very few of the families our organisations support are homeowners and therefore in a position to apply for mortgage holidays.

While there was the opportunity to access the furlough or self-employed schemes, we are not aware of any monitoring on data of migrants who were furloughed and able to access the schemes.  Many parents with NRPF are on informal or zero-hours contracts, and these schemes do not provide any support to those who have seen their contracts terminated or hours reduced. For example, less than 13% of families assisted by The Unity Project in the first six months after lockdown had been able to access the furlough scheme and less than 3% had received a self-employed grant, due largely to being in precarious employment. Furloughed workers still have to apply to have their NRPF condition lifted due to poverty, highlighting the limits of these schemes for those with NRPF. 

Although the Government has pointed to such measures to justify their commitment to the NRPF policy, these measures offer little to no support to families with NRPF. It should be noted that a significant majority of the parents supported by The Children’s Society, Project 17 and The Unity Project are frontline key workers at an increased risk of contracting COVID-19. Thirty-two percent of those The Unity Project helped during lockdown were key workers[49].

The Government has extended eligibility for free school meals to some categories of children with NRPF on a temporary basis. What has been the impact of this policy?

In April 2020 the Government in a welcome move gave some children from low-income migrant families temporary access to Free School Meals during the Coronavirus pandemic. However, this is still only a temporary measure. More than sixty organisations including The Food Foundation and FareShare wrote[50] to the Education Secretary in August 2020 asking for this extension to be made permanent for families to have the stability and certainty of this continued support.

It is also vital that children from undocumented households, who also have no access to public funds, are given free school meal access. Not only does Free School Meal provision save a family around £400 a year per child, whether a child is able to eat and learn at school should not depend on their parents’ immigration status. This extension is currently under review, however there is no clear timeline on when/if this will be made permanent.

Parents affected by NRPF whom we support through our services and partner organisations at the Children’s Society have stated how Free School Meal provision has helped to ease the pressure on household finances over the past few months.

One parent told The Children’s Society that:

“It was quite a relief…if we were to carry on having Free School Meals especially during holiday times that would be the perfect and best thing ever for this government to do. Because it is quite a relief to those of us who do not have access to public funds, or those of us who don’t have access to work. We have to live on £35 a week with the children. We have other bills to pay. We have to have internet in the house for the children to access schoolwork”.

Another parent said:

“It puts me at ease… it saves me money that can go towards electricity or gas top-ups, especially now it’s colder”.

Parents reported that in school holidays during which there was no Free School Meals provision, they had to sometimes cut back on a meal themselves.

While the extension continues to be under review with the Department for Education and the Home Office, uncertainty about children’s eligibility has led to some children being denied Free School Meals. The Unity Project and Project 17 both assist families with NRPF to access free school meals on a weekly basis, either because they or their schools do not know about the temporary extension. This policy should be made permanent, and the Department for Education should lead a targeted awareness campaign to ensure all schools, parents and pupils are aware of these new and continued entitlements.

What role do other bodies, such as local authorities and third sector organisations, play in supporting children with NRPF?

For many families with NRPF, excluded from the social security safety net, the only support available comes from charities and local authorities.

Data provided to us from the NRPF Network[51] showed that 8,117 families with at least 16,331 dependents were supported by local authorities under Section 17 Children Act 1989 between 2015 and 2019 in England and Scotland. As described above, many more would have been unaware of the support available, were turned away or were subject to hostile gatekeeping practices. Where support is provided this is often very limited – sometimes as little as £3 per child per day – making it impossible to meet the needs of a child. In addition, the Government have also given contradictory statements about whether other forms of support – such as council-run welfare assistance schemes – are ‘public funds’[52], meaning families may be missing out.  

The Local Government Association[53] has called for a suspension of the NRPF policy because access to welfare benefits would help prevent people from becoming homeless. Although emergency Covid time measures have been put in place, including £63 million for Local Welfare Assistance during the summer of 2020 and a further £170 million for the winter in 2020, there has been a lack of clear messaging around whether these are public funds, which would automatically exclude those with NRPF.  This means that not only local authorities, but also support organisations are often unsure whether people with NRPF can access these emergency local funds.

What impact has the pandemic had on these organisations’ capacity to support children with NRPF?

Many of the organisations supporting families with NRPF are smaller grassroots organisations who have been working at full capacity since the start of the pandemic. Many have been overwhelmed with referrals for support and the needs of families and children including food poverty and digital exclusion.

TUP received more referrals in the first 3 weeks of lockdown than it had received in the preceding 6 months, and continues to receive more than before the pandemic.

Partner VCS organisations that The Children’s Society works with via its Coordinated Community Support (CCS) programme frequently cited the NRPF condition as a concern for service users who lost their jobs and were unable to access support, leading to difficulties for families to meet basic needs and feed their children. According to one CCS partner organisation, “People with NRPF are largely unaccounted for in this crisis. Families who are living in hard to reach communities and whose incomes have relied upon unconventional work patterns have had their financial stream stopped and it is very difficult to support such families, often with a few children, some very young.”

Due to Covid restrictions, many such organisations have had to continue working remotely. This has made communication with service users more time intensive and reduced informal opportunities to raise awareness about support available to people beyond the core client group. Some local authorities have been proactive and have consulted with NGOs and community groups to try and inform people about support available. They have also sought to improve access to support for people who are isolated or may be struggling to complete forms by themselves.

People with leave to remain on family or human rights grounds can apply to have the NRPF condition lifted in some circumstances. How effective has this measure been at preventing families from falling into serious hardship?

A very limited number of migrants with leave to remain in the UK can apply to have the NRPF condition removed if they are facing destitution. This process is extremely complex and time-consuming, and often requires expert advice that is largely unavailable. We have all worked with hundreds of families who have struggled to – or been unable to – apply to have the NRPF condition lifted, and have continued to live in poverty as a result. We want to give this topic proper consideration so have made a separate submission focusing on this complex issue (please see separate submission from page 13 onwards.)

Joint submission to the Work and Pensions Committee Inquiry into Children in poverty with no recourse to public funds

September 2021

Change of Condition Applications

This submission has been prepared jointly by Project 17[54], The Unity Project[55]and The Children’s Society[56]. This submission should be read in parallel to the submission of voices of people with lived experience of NRPF made by United Impact and the wider joint submission.

Question addressed:

People with leave to remain on family or human rights grounds can apply to have the NRPF condition lifted in some circumstances. How effective has this measure been at preventing families from falling into serious hardship?

Introduction

A very limited number of migrants with leave to remain in the UK can apply to have the no recourse to public funds (NRPF) condition removed if they are facing destitution. The application to remove the condition is called a ‘Change of Conditions’ application (or ‘CoC’ application). The process is extremely complex and time-consuming for applicants, and often requires expert advice that is largely unavailable. It also places an unnecessary administrative burden on the Home Office, which does not need to exist. Even when CoC applications are successful, it is already too late to prevent avoidable destitution and distress, including that of children.

The Unity Project is a specialist organisation set up in 2017 to assist people to make CoC applications, given the substantial obstacles that people face in doing so. In 2020, The Unity Project was approached by over 400 families from across the UK seeking assistance in making such applications. The barriers to applying to have the condition lifted are also seen in the casework of other organisations that work with families with NRPF, including Project 17 and The Children’s Society.

The Unity Project published a research report which details in Chapter 6 (pp. 50-54) the inadequacies of the CoC application procedure[57]. The report was published in 2019, but the issues remain current as there have been very limited improvements since. We provide a summary of some of the issues below, with updates where relevant.

Only a fraction of people with NRPF can apply for recourse to public funds

Many people don’t know about the application; most families that we assist have been destitute for months or years, but have only recently found out about the possibility of applying to have the NRPF condition removed.

The application is, as the question states, only available to people ‘with leave to remain on family or human rights grounds’ (and, more recently, BNO visa-holders from Hong Kong). This includes tens of thousands of people, but it is only a subsection of the total numbers with NRPF.[58]

Some of these people are allowed to apply for settlement after 5 years in the UK; this is often referred to as the ‘5-year route to settlement’. However, if someone in the ‘5-year route’ finds themselves struggling financially and makes a successful application for recourse to public funds, the Home Office will transfer them onto the ‘10-year route to settlement’. This means that they are punished by having to wait twice as long (a further 5 years) before they can apply for settlement.

This is significant for 2 major reasons:

1. Settlement (Indefinite Leave to Remain) brings stability and security and enables children to start to know that the UK truly is their home, as has been recorded, for example, by the organisation ‘We Belong’ in a recent report[59]. 
2. Being moved from the 5-year to the 10-year route also means two more applications to extend your limited leave to remain, and at present each application (with the Immigration Health Surcharge, ‘IHS’) will cost at least £2,593 per person (subject to regular increases and excluding solicitor fees)[60]. The Migration Observatory’s recent briefing sets out how these costs add up for a parent with one child over 10 years (£23,982) and 5 years (£15,360).[61]  That is an enormous amount of money for most people, let alone someone who is paid the minimum wage (currently £8.72 per hour), for whom a single application represents almost two months’ wages (let alone the multiple applications required for dependants and/or themselves over 10 years)[62].

The Unity Project is aware from its casework and work with Deighton Pierce Glynn Solicitors that the Home Office does have a discretion available to keep someone in the ‘5-year route’ following a successful CoC application.[63] However the Home Office has not published any information or guidance on this, including in which situations they will consider exercising this discretion. It is unclear how an unassisted applicant would be aware of this.

This means that many families find themselves facing an impossible choice where a successful application, in which the Home Office has accepted that they are destitute and require access to public funds, will result in an additional debt burden of over £5,000 per person (being the cost of the additional two applications required in the ten year route). Fee waivers are technically available, however again these applications are hugely complicated and difficult to make successfully without assistance, due to barriers similar to those associated with the CoC application. Historically fee waivers have a very high refusal rate,[64] which itself can act as a deterrent from applying. It also increases the risk of parents leaving children off their applications, which causes difficulties for children securing citizenship and settlement once they reach 18.

The application process is unnecessarily burdensome

The application is online, and the form spans dozens of pages. You can see an example for a fictional applicant here, to get a sense of the questions asked, which includes, for example, providing the employment details of all dependent minors. This is difficult for all applicants, but often impossible for those with low levels of English/technical literacy.

There are several issues with the quantity and type of evidence requested, including the below:

-          In 50% of cases, the Home Office requests further information and evidence from applicants, which strongly suggests that the application process and the evidence requires simplification. In our experience, these requests simply delay the process (they double decision times in our experience)[65], asking for evidence that has already been provided, or explained to be unobtainable, or immaterial. To give two typical examples, we recently received a request for an applicant with long-term, diagnosed (and medically evidenced) mental health issues and therefore no income, who was being temporarily hosted in overcrowded accommodation; the only way that the Home Office acknowledged the mental health issues was in requesting updated evidence that these issues were persisting. We also recently received a request for historic bank statements for a street-homeless man, whose recent bank statements clearly showed that his precarious employment could not cover rent and living essentials, and who had already explained that the bank had refused to provide him with older bank statements.

-          The Home Office often requires hundreds of pages of evidence. Among other things, the Home Office demands 6 months of annotated bank statements in order to make its assessment; what occurred in bank accounts 6 months ago is mostly completely immaterial and irrelevant, and the stipulation causes delays for applicants and for Home Office.

-          The documents requested would be difficult and time consuming for anyone, but the more difficult your situation, the more difficult it is to evidence. People who are being mistreated or exploited, whether this is their working and living conditions, or relationships, unsurprisingly find it difficult to obtain evidence from the perpetrators (e.g. landlords, partners, employers, etc). We have sometimes seen requests for evidence from abusive partners, and often see requests for formal tenancy agreements where an applicant is being temporarily and informally hosted in inadequate accommodation.

-          Again, we refer you to our report (particularly at pp. 50-53) for more specific detail and for examples taken from Home Office decision letters, which continue to recur.

Many people withdraw from the process due to stress and/or the fear that requesting access to public funds may jeopardise future applications to remain in the UK.

Even if an individual succeeds in getting their NRPF condition lifted, it is not permanent – each time they have to renew their leave, every two and a half years, they have to ask the Home Office not to reimpose the NRPF condition, and provide the same amount of evidence again.

People are left in poverty for months while applications are processed

In 2020 Q2, applicants had to wait 46 days for a decision on their applications. In the most recent stats from Q2 2021, 30% of applications had not yet been processed, and applicants are still waiting over a month[66], only to then face the prospect of an additional five week wait to access Universal Credit. This timescale does not account for the months (and sometimes years) that families have spent in poverty whilst unaware of the application, and the time taken to gather the necessary evidence. This leaves some families destitute, reliant on food banks and charities, and falling into arrears on rent and bills for months, with damaging consequences for their children’s welfare[67].

We would note that temporary, emergency accommodation under Section 17 of the Children’s Act is not an adequate safeguard for people in this situation for the reasons set out in more detail in the general joint submission.

Home Office decision-making is often poor

Nationally, 69% of applications are successful. In 2020, 100% of applications that TUP submitted were successful; we assist everyone that approaches us and we often have to challenge unlawful refusals (largely from people who approach us having submitted their own application and received an initial refusal).

Usually, for the reasons outlined above, applicants contact us before making the CoC application so that we can assist them. In the past 6 months, however, we have been contacted by 9 applicants who submitted their own applications and were subsequently refused. Without our assistance, they would have been unable to challenge this decision. With our assistance, 6 of these decisions were overturned and the 3 other applicants (all families) withdrew from the process due to stress and/or fear that challenging the Home Office might have negative repercussions for their future leave to remain. Our records show that on average, the initial applications took over 65 days to be processed (one took 136 days), and once challenged, applicants had to wait a further 31 days on average to receive the new decision - that meant over 3 months of prolonged destitution.

We have asked the Home Office to provide data to show how they are evaluating decision-making (e.g. reasons for refusal; number of decisions challenged/overturned with/without legal assistance; timeframes, etc), and in the meantime can only rely on our own experience, which suggests that refusals that are challenged with legal assistance are often overturned.

We are deeply concerned about the thousands of people whose applications have been refused, seemingly only because of the lack of good quality legal support - many of these families will be continuing to live in destitution. The Home Office refuses to provide data on the numbers of applicants who have legal representatives as opposed to those who apply without help, and has also not presented any evidence to refute our experience that applicants are much less likely to be successful in their applications if they apply without good legal support.

Alongside this concern and the damaging effect on applicants who are refused recourse to public funds, we also want to note that the majority of applications are successful which calls into question whether the procedure is needed at all.

The policy and procedure has been declared unlawful

The NRPF policy which outlines the CoC procedure has been ruled unlawful twice, most recently in April 2021 for the fact that it does not adequately safeguard children[68]. Over six months later, the guidance has still not been amended in response, and any amendments that are made are unlikely to not mitigate all of the issues outlined above.

People with NRPF cannot find the legal advice they need

For all the above reasons, people often need legal advice in order to make successful applications. This advice is not available.[69] The Unity Project is the only organisation in the UK known to specialise in this; prior to 2020, it was entirely reliant on volunteers - it now has 2 part-time casework staff. We consistently have an overwhelming waiting list.

Home Office monitoring data is limited and opaque

The Home Office publishes some statistics about CoC applications on a quarterly basis[70]. Whilst indicative of the numbers of CoC applications, waiting times, refusal rates and gender/nationality breakdown, the data is opaque and extremely limited. The data also only relates to individuals who are aware of the CoC application process and who are in a state of crisis. Via FOIs, PQs and meetings with the Home Office, we have repeatedly asked the Home Office to provide further data in relation to the CoC procedure (such as reasons/procedure for refusals), and in relation to the demographics and vulnerabilities of applicants (e.g. the numbers of applicants who have disabilities or are pregnant). This data is essential to accountability and effective monitoring of the impact of the NRPF policy. We hope that the relevant data will be provided as part of this inquiry.

Joint submission to the Work and Pensions Committee Inquiry into Children in poverty with no recourse to public funds – September 2021

This is a submission to the Work and Pension Committee into Children in poverty with no recourse to public funds made by United Impact with the support of Project 17. This submission should be read in parallel with the joint submission made by Project 17, The Unity Project, The Children’s Society and ILPA.

United Impact is a group of families with dependent children affected by the No Recourse to Public Funds (NRPF) policy. The group is convened and supported by Project 17. The group brings together people with lived experience of the NRPF policy with an aim to provide a platform for the voice of people with lived experience and to provide solidarity and peer support. United Impact currently has 35 members.

On the 8th of September 2021 the group convened to discuss the questions raised by the Work and Pensions Inquiry with a particular focus on the 4 questions. 12 members participated in the discussion. The members contributions and thoughts have been anonymised and remain the opinions and experiences of individuals within the group.

1.                 What impact has the pandemic had on children with NRPF? Has the lifting of restrictions made any difference?

All of the families who participated in the workshop reported that the impact of the pandemic on their children had been severe and continued to affect them. Most of the families reported that having NRPF meant they could not access support and many were turned away when approaching local authorities for assistance. Many were only able to access help through the advocacy of a charity. Below are some of the accounts provided by members:

One participant explained:

“NRPF and the lockdown affected my children – it affected them physically emotionally and psychologically. Physically, about the time when the lockdown started was the time when the local authority kicked us out of where we were staying. Since we were subject to immigration control the local authority evicted us and because of NRPF policy we were evicted and we had to move from hotel to hotel. I have six children and they would not let us all stay in one hotel room and the children could not sleep by themselves. So, I had to separate my children, some of them had to go stay with their father. So, the children had to be separated. And this was very traumatic for everyone. And it had a ripple effect. And with the NRPF policy still in place and Home Office were taking their time with their decisions and not paying attention to the effect of what they do on people affected. This continues to affect my children to this day and causing anxiety both in children and parents. Financially you see other kids wearing things that you cannot afford because of your situation. So, children are discriminated and this has a very negative effect.”

Another said:

“We got quite a lot of help from other organisations during the pandemic – we had fresh food coming in every two weeks. If it had been the council, I would have been very stressed but since Project 17 got involved I got support and stress was reduced. My son was stressed because he could not meet his friends and could not go out. I was also stressed since I could not go to the council office and speak to people face-to-face. On the phone I was just told that not many people were working during the pandemic so things were more difficult and I ended up waiting for people to come back to me. It is a bit better now that restrictions have been lifted as I have been able to meet with my solicitor and discuss my son’s passport.”

Even for those working the situation was difficult:

“The pandemic had a very big impact on me and my son. I work in a hospital and my son is asthmatic. The local authority was accommodating us at the time but they did not give me anything. They just told me I had to try to work. So, I was ging to work, I was forcing myself to go to work and putting my child to a private childminder. But I was worried since my son has health issues but [the local authority] did not want to hear since I have NRPF. In the end of the day, they kicked me out saying that I was not eligible for support. I went to work one day and when I came back then my room was locked. I went to [the local authority] to ask for help but they said they could not do anything since I have NRPF. If you don’t have the information then there is nothing you can do. You just have to do what they tell you. [The local authority that was supporting me] told me to go to and get help from [another local authority]. Again, they turned me away saying I was working and paying rent, that I was not eligible. But I tried to explain that I was struggling to pay the rent. When lockdown came in and I could not work much because of my son’s health as advice was to stay in [to shield]. My childminder stopped working. It is really really hard for people who have NRPF. Despite the fact that I was working it was so so difficult. ……. I was distressed and did not know what to do. Reached out to Project 17 and got help. They put me in touch with a lawyer who said they have no right to do that and we could bring a challenge.”

Many experienced hostile gatekeeping by local authorities, even during the pandemic:

“Throughout the pandemic I was having a tough time with my children and I was pregnant at the same time. Where we were living, we could not afford to pay the rent anymore. I was picking them up and sleeping everywhere. Someone told me to go to [the local authority] but when I went they were talking aggressively at me and telling me there was no help for me. They talk to you like you have no life, like you were not a human being. I did not know what to do I had to take my children and started sleeping in the church because I had NRPF. Then I heard about P17 – I went to [the local authority] and they did an assessment for me and it was very very bad. I was crying. I was pregnant and I was crying. There were 5 of them on top of only me. And they were just talking from one thing to another, and they were just abusing me. Imagine you don’t have anything, you have children, you are pregnant, you have nothing and they can see the state of you and you have nowhere to sleep and nowhere to wash. They are not supposed to use this against another person. They should take a proper assessment. I could have had a heart attack or anything. They are not meant to treat people in this way. Treating us like animals. We have now been given a place to stay but it is very far away. My daughter has to travel 2 hours and 30 minutes from where we are now to school. We are still battling but I can see where I am coming from and where I am going now so there is a big difference.” 

Some experienced homelessness during the pandemic:

“During the lockdown me and my children were homeless and I was too scared to come out and say I was homeless. We were staying with the grandmother but we had to go. We got support to approach housing, to access housing. The lockdown really really affected myself and my children physically and mentally and everything. I know where I am coming from and I know where I am today. If I think from where I come from. I was pregnant and had a one-year-old boy then and I was homeless. We don’t have a voice.”

Even for families left homeless and destitute experienced gatekeeping by local authorities:

“During the pandemic we have been sleeping in the bus, sleeping in the mosque. I went to [one local authority] and they did not help. I went to [another local authority] and they did not help. We were not allowed to sleep in the mosque anymore but [the local authority] were not accepting me because of my situation [having NRPF]. We did not get help until someone at the mosque gave me the number for Project 17.” 

Many were trapped in abusive situations with nowhere to go during the pandemic:

“This lockdown really affected my children. It will have affected a lot of children. I was in a domestic violence situation before. When there was lockdown. My children they can’t go anywhere. I can’t go anywhere. Before when they were going to school, they were not seeing things. But during lockdown they saw a lot of the things that we were going through. It has affected them a lot. Especially my daughter she was sick, she was down. I don’t want to speak about it a lot. Thank God we have come up from that. When we got to know P17 then things changed really.”

For many children these are experiences which will stay with them forever:

“The pandemic really impacted my children. We as adults we have a way of masking our experiences but the children still have a way of knowing. Suddenly the children could not go out. I have boys that have a lot of energy and we have horrible neighbours who complained about noise. The impact was worst on my youngest child. He is at an age where he needed to explore and express himself and suddenly, he could not. So started throwing tantrums. When the pandemic started, we started having a lot of issues, financial etc. We went to so many charities and they said sorry you are outside of our area. I was just desperate. I tried everything. That is when I found Project 17. Project 17 sent us to the local authority but they were horrible to me. It was too much. They said because we have NRPF they could not help. But the caseworker at Project 17 had to email and intervene for me. We were desperate and almost homeless. The landlord was threatening to come change the lock and I was panicking. And the children were desperate to since we had been homeless before. Especially for the oldest one who could remember. He was asking ‘mummy are we going to sleep in McDonalds again?’ and he was having panic attacks. I have always been scared of social service because of all the terrible stories I have heard. If they take my children away, they are taking my life. At the point I could not put food on the table. Project 17 gave us food vouchers and at least then I had something to put on the table. The [local authority] have to think about the children and the impact this is having on them. These experiences will stay with them forever. Children don’t forget these memories; they stay with them forever. Children are children and they should be helped so they feel like they belong and they are part of the environment they are part of the community and they are someone who is wanted.”

2.                 Eligibility for free school meals was extended to some categories of children with NRPF on a temporary basis during the pandemic. What was the impact of this change on children with NRPF?

The majority of families participating in the workshop were still not able to access free school meals for their children despite the fact that most reported struggling to provide enough food for them. This is due to the fact that the FSM extension only extended FSM to certain categories of beneficiary - such as those supported under section 17 of the Children’s Act 1989. However, many families and children experiencing extreme poverty, including those with an irregular immigration status are still not able to access free school meals.  Even for those who were eligible, the path to securing this provision was often far from straight forward. Below are some of the accounts those who were able to access FSM through the extension shared with us:

“My first daughter was not one FSM before the pandemic. And my son was not – they gave us a list from school of who qualified – but I was thinking he was not qualified for FSM. So, I was struggling with my life. But local authority was doing an assessment and they contacted the school and they said my son should now qualify. So at the beginning of the pandemic they opened a voucher for him. But nothing for my daughter. The £15 they were giving us every month was not really a lot, was not enough. But the social worker and P17 caseworker came along with me to argue for me and then the school opened a voucher from my daughter. So now she is getting meals. The impact now is that everything is fine. The voucher they are giving us now, it helps us a lot.”

“My kids school never asked us once during pandemic if maybe anyone needed help. It was not until our social worker got in contact with them regarding our family’s situation that they helped, even though the school could see we were owing school meal money yet they were not bothered. But after the social worker got in touch with the school they put them on free school meal. The FSM made a big difference to my family.”

“My son was not eligible for FSM. I approached the social worker and asked for help. But the social worker said: ‘you can cook for him. Just cook for him. You are a very disgusting woman’ – I just wanted to know if my son was eligible for FSM. Then I called again and spoke to another person and she said: ‘don’t worry I will send an email to the school and we will sort it out’. The change of the criteria made a bit difference. They just had to send an email to the school but it was not easy getting there.”

“It was quite helpful with school lunches. When I was packing lunches, it was African food and it is not nice to eat cold. Getting warm fresh food from school helps. The local authority know I am eligible but because they know I am not a lawyer they just keep saying NO. They should not put me and my children through what they have put us through where we have to fight for everything. They pretend as if they don’t know you are eligible when they know you are.”

3.                 What role do other bodies, such as local authorities and charities, play in supporting children with NRPF? Is the support provided sufficient?

The views of the participants are naturally influenced by the fact that they are all being supported by a charity working with them to resolve their situation. However, most agreed that despite the invaluable support they had been provided with this should not be the role of charities. Below are some of the thoughts and experiences shared by participants:

“Support from Project 17 has made a big difference. I can do more for my kids now. I moved from the dump I was living in. and my son gets to eat at school. And we are able to get passport for my son and regularise our status. I have money coming in and I have foodbank voucher coming in. The support from P17 is not amazing but it is more than I had. Our life is much better in everything after P17 coming into it.”

“NRPF is horrible. They (charities) are helping. I have been complaining about the local authority only giving us support in the form of voucher. My daughter is in secondary school and I have to but a school uniform. But I cannot buy it with the voucher. The charity helped me apply for a grant to get £80 to buy uniforms. Still the local authority has not changed it, they would not give us cash, only vouchers. “

“I am going thought the same thing. For the last year they have been giving me vouchers but can only spend them in Tesco or Asda which is very far from where I am living. For some people they give them [pre-paid] cards – but they can only spend this in Tesco etc which is so expensive. Cannot use in them in cheap shops. We are placed very far away and my daughter is so tired and cannot even read a book. She has to take two trains every day just to get to school.”

“I been with local authority before with my children and they throw us out. I am shaking I cannot say anything. They say they cannot help me. We are sitting in the council and they say they cannot help us and the children are crying and asking if we are going to stay here. But then I met Project 17 and they helped. When you meet local authority I have fear because they say they can take your children”

“The local authority there is something they need to do. They are not approachable; they are very difficult. Assuming I went straight to the local authority for the problem I would still be in the same situation; maybe I would have been traumatised. Even with P17 support it was not easy. It is mentally draining. The way that P17 talked to me it changed everything. If local authority could put in more empathy this would help. Since many people do not have access to local charities. But local authorities are not approachable. It is like they are following a manual and they do not care if you are living or not. There was one time, about child benefit, I made the application but the letter did not come back. But because I could not produce that evidence, they suspended everything. I asked for a little more time. But they aid no. They don’t even want to know if you are dying or in a vegetable state. People are going through a lot of things. Local authorities are going through process. But there are better ways. If they could review their approach then maybe children would not be going through all these things they are going through. It is not fair; it is not good. If they are able to review certain things then maybe things would improve.”

“Information is power. When I approached this local authority, I did not know what they were supposed to do – I did not have the information about what they should do to help us. Then I got in touch with Project 17 who helped me and now I have full understanding. But what about people who don’t know anything so they just suffer? The local authority Is putting people in a tight spot but Project 17 help people to know their rights. Local authority just push you away somewhere like you were not even human being. And without information you cannot push back”

“I don’t think anyone should be dependent on charity. Government has to be the one to provide for these people. Charity is ok. But what about all the people who are not supported by charity.”

4.                 People with certain kinds of leave can apply to have the NRPF condition lifted in some circumstances (‘change of condition’ application). How effective has this measure been at preventing families from falling into serious hardship?

The majority of participants were still subject to NRPF so were not able to comment on the impact of a Change of Condition application. However, some had been successful in making a Change of Condition application. Of these most agreed that this had not been enough to prevent them experiencing destitution, that having the NRPF had been very helpful to their families as they now had access to mainstream benefits and that they had seen a real change in the attitude of the local authority following the removal of the NRPF condition. Though most emphasised that the transition had not been easy, that they had been given very little support to apply for and secure benefits and that in many cases this had led to a disruption of support.  Below are some of the thoughts and experiences shared by participants:

“People are going through a lot of things and many are not talking. The NRPF is one of the factors which is causing all this trauma. They follow the rules given to them by the Home Office – but I was able to lift the NRPF condition and this really helped me. If this could be ended then children would not have to suffer a little like this. The effect of NRPF I so enormous that you are restricted from helping yourself because the system does not allow you to help yourself. We do not have the choice to find a way to help yourself. So, if you do certain things to help yourself then it becomes illegal, it comes a crime. When you ask for help and they say you are not eligible for that – then you are stuck. And if you help yourself then it is a crime. This is what makes it so difficult. When I made a Change of Condition application with a proof of destitution. You have to convince the Home Office. And if you are being supported then this may be a little bit difficult. It looks so simple but it is not. The assessment is difficulty. But when it is lifted then it changes your eligibility. After three weeks HO sent me a letter changing my BRP card to remove NRPF. Everywhere you go they want to see the letter, it changes the whole approach. From that point every help available. And you meet another local authority entirely. Get access to mainstream help.”

“Even until now I did not even know it existed [the Change of Condition application]. Why can’t local authority direct us to people who can help us? They just say: ‘we cannot help you, there is no one that can help you, so go die’. But when you try to get on the bus and you don’t have an oyster at least the driver tells you where you can buy a ticket. But not local authorities…”

United Impact (with the support of Project 17), September 2021

Anonymised letters from children affected by the No Recourse to Public Funds Policy:

October 2021