Written evidence from Citizens Advice Sutton (HAB0022)



This submission is made by Citizens Advice Sutton.  We are well placed to understand the needs of our community and the difficulties our clients face in applying for, undergoing assessment and challenging decisions in relation to health-related benefits. Our response, based on our advisor experiences and client difficulties has been coordinated and summarised along with several case studies to provide insight to the committee on the difficulties within the application and assessment processes which we are keen to see improved.

1. How could DWP improve the quality of assessments for health-related benefits?

Assessments need to focus on the individual claimant and ensure that evidence (written self-assessment, clinical condition, physical presentation, verbal evidence and medication) is analysed and triangulated and reasonable for the claimant’s condition.


Assessments should be probing in answering the impact of the claimant’s condition on daily living over an extended period and not a snapshot from the assessment appointment which may not be typical. Assessments need to consider how conditions fluctuate and whether a client’s ability to carry out a function is safe, reliable, can be repeated and within a reasonable timescale.

Case Study Example

A client who had suffered from a chronic condition for many years and relied on care, support and medication undertook a PIP assessment and was awarded zero points and just several more at appeal.  This decision was set aside by the Upper Tribunal and a further Appeal Tribunal considered whether the claimant could undertake activity safely, to an acceptable standard, repeatedly and within a reasonable time period.  The tribunal awarded 12 daily living points (stopping when the threshold was reached) and 12 points for moving around – as the tribunal found the claimant significantly limited.  The claimant’s award was backdated for 2.5 years.





Assessors should not make assumptions or extrapolate - ‘what a client can/cannot do.’

Assessors should put less emphasis on medication.  Many claimants do not take medication that may be beneficial to help them manage their condition because the side effects are intolerable and they find other ways to manage.

Case Study Example

As part of a recent health assessment a client included within the history section of their condition that ‘’they will not take anything with codeine as they had been addicted to prescription drugs in the past and is scared of being addicted again. They take paracetamol but this is not helpful"

The claimant failed to be awarded any points – the assessor reported "However, they have no pain management referral and no other non-medical methods for relieving their pain".     The conclusion that ‘as the claimant cannot take certain drugs and there is no other way of addressing their pain, they are not restricted by pain’ was reached despite the PIP Assessment guide stating at 2.1.4 "whether the claimant can repeat the activity within a reasonable period of time and to the same standard (this clearly includes consideration of symptoms such as pain)"


Probing during assessment is particularly important in relation to telephone assessments for people suffering with mental health conditions.  Many MH claimants reflect more positively on their capabilities over the telephone and their condition may be less obvious to a non-mental health specialist.

Subsequent assessments in relation to claimant’s long-term conditions should be considered in conjunction with evidence from the original assessment.  Particularly where the claimant has reflected a worsening or no change in their condition and impact.

Decision makers should demonstrate assessment of all sources of evidence and consider the claimant’s condition and their written and presenting evidence in relation to what is ‘reasonable for that condition’ from ‘Medical Guidance for decision makers.’


a. Have you seen any specific improvements in the process since the Committee last reported on PIP and ESA assessments, in 2018?



3. Do the descriptors for PIP accurately assess functional impairment? If not, how should they be changed?

Descriptors for PIP focusing on personal health are too restrictive, they should include the claimant’s ability to run a home and manage in their living environment and the claimant’s ability to shop for basic necessities. 

For example, keeping the house clean, washing clothes/dishes.  The environment impacts significantly on health and it would complement the questions about personal hygiene and their ability to prepare food.   It would also enable consideration of how mental health conditions impact on the claimants living environment – for example hoarding behaviours.

Additionally, the impact the claimant’s physical and/or mental condition has on the claimant’s ability to shop for necessities should be included within the assessment.

There is confusion between the questions about ability to speak/communicate due to sensory impairment and the ability to do so due to psychological factors or learning disability.  This could be clarified.

The DLA assessment incorporated ‘Supervision and Watching’ and ‘Nighttime needs’ that are not incorporated within PIP and these difficulties are not easily able to be reflected under individual descriptors.


5. DLA (for children under the age of 16) and Attendance Allowance usually use paper-based rather than face-to-face assessments. How well is this working?

It is appropriate to use paper-based claims for children as it would not be suitable for them to have the ordeal of a face-to-face assessment.


a. Before PIP replaced DLA for adults, DLA was also assessed using a paper-based system. What were the benefits and drawbacks of this approach?

There is a view that the benefit of a face-to-face assessments are limited as many claimants' report that their presentation and description of the impact of their disability is often overlooked. Face to face assessments can be extremely anxiety provoking and often disempowering experiences.


6. How practical would it be for DWP’s decision makers to rely on clinician input, without a separate assessment, to make decisions on benefit entitlement? What are the benefits and the drawbacks of such an approach?

Whilst Clinicians can confirm a client’s condition, they will not always have detailed knowledge of how a claimant’s condition affects them to be able to comment on the impact of the condition on the claimant’s daily living and how and to what extent the claimant’s condition affects this.  A requirement for detailed clinical reports is likely to cause capacity issues and delay and there is a danger that clinicians will be seen as gate keepers to benefits. The claimant is unlikely to see the same clinician consistently and the clinician is unlikely to have the time to input the level of detail required to support an assessment. 

There may be a few chronic conditions where clinical confirmation is sufficient and an assessment unnecessary.


7. Appeals data shows that, for some health-related benefits, up to 76% of tribunals find in favour of the claimant. Why is that?

There is a general belief that PIP was designed to reduce the cost of disability benefits, for example changes to the mobility test thresholds and narrower focus.   There is also a concern that assessors are trained to exclude rather than include and that they work to targets for the number of people refused benefits.

Many conditions have ups and downs and clients who have managed to get to an assessment centre feel they should try to show what they can do rather than what they cannot or struggle to do.

Additionally, assessors are not always aware of the impact of mental health problems on the claimant’s ability to function.

Assessments tend to be very narrow and there appears to be inadequate analysis of evidence and triangulation of evidence against the reasonable impact of a condition on an individual.

Technically, the DWP decision maker needs grounds for revising the previous award and they tend to rely on the new assessment as being more up to date as grounds.  What they never do, neither are they required to do – is to identify an actual change in circumstances e.g., evidence other than an assessment that the claimant’s condition has improved.   It is as if each assessment is treated as a new claim.  For any appeal, the DWP are required to provide the adjudication history, however they never seem to address the previous award or give detailed reasons for reducing a previous assessment score.

Lack of meaningful mandatory reconsideration (MR) by decision makers and the time scale for MR review means that the claimant at the time of the MR is unlikely to have an assessment report and scoring to draw together a comprehensive challenge. This results in very few cases being overturned at MR stage and virtually all going to appeal.

At Tribunal, experience shows a more comprehensive approach is taken, which is more probing and assesses more widely the impact of the claimant’s condition.

a. What could DWP change earlier in the process to ensure that fewer cases go to appeal?

Be more willing to accept what a person says about their abilities and consider medical evidence early in the process, contacting the GP more frequently if there is any query.


Automatically review all cases where a client with a chronic condition has ‘scored’ on assessment less than their previous assessment and urgent review where there are zero points, particularly where the claimant has advised that their condition has worsened or has not changed.  The decision maker should be required to justify the reduction in assessment score rather than rely on a new and potentially flawed assessment.

There are numerous client examples where claimants have received zero points following an assessment, particularly where a client suffers from mental health conditions or has both physical and mental conditions and subsequently at appeal clients receive an enhanced award. 

Case Study Examples

The following examples demonstrate the impact of numerous assessments:


A client suffering with chronic conditions, physical deformities impacting on mobility and functional ability as well as learning and mental health conditions has been reassessed three times in four years, 2016, 2017 and 2020. Each time on assessment, the client received fewer or zero points and their claim stopped.  The decision at appeal had been overturned and the client’s award reinstated twice and the client is now awaiting the results of their third appeal. 


A client was awarded PIP in 2015 following an assessment where they scored 13 for daily living and 8 for mobility.  In 2018, this was reduced to 2 points for reading.   On appeal the Tribunal awarded 13 points for daily living and 14 for mobility.        A subsequent assessment awarded no points for daily living or mobility.  The client has PTSD, depression, learning difficulties, atypical autism, asthma, chronic joint pain and IBS and is in receipt of Employment Support Allowance and Severe Disability Premium.      The decision maker in this case stated, ‘the decision maker isn’t bound by the previous decision and must determine entitlement afresh.’


This continual requirement to demonstrate a client’s eligibility to PIP causes significant anxiety and stress as well as financial hardship. 


8. Is there a case for combining the assessment processes for different benefits? If not, how else could the Department streamline the application processes for people claiming more than one benefit (e.g., PIP and ESA)?

The assessments are evaluating different things.  PIP is focused on functional ability whether the claimant works or not whereas ESA/LCWRA assess ability to carry out work related tasks.

There is greater commonality between assessment processes in relation to mobility and there may be scope for combining assessment processes or relying on a recent assessment for clients with significant mobility difficulties.

An ability to combine assessment processes could potentially save time and paperwork for the claimant and the DWP. Particularly as clients often do not realise the assessments are separate at present and wonder why they must jump through more hoops or repeat similar information multiple times.

The downside is that if a claimant is refused for one benefit; they may not think they can claim another. Or that the PIP assessment becomes ‘more work orientated’ as opposed to a benefit about care and daily living/mobility.


a. (For people claiming) Would you like to be able to manage your benefit claim online?

This may be beneficial for some claimants. However, many claimants are not able to use computers or are digitally excluded, particularly those with Mental Health conditions, so it would not be a solution for everyone and paper / telephone facilities would need to remain in place


b. What would be the benefits and drawbacks of DWP bringing assessments “in house”, rather than contracting them to external organisations (Capita, Atos and Maximus)? In particular, would this help to increase trust in the process?

Bringing assessments ‘in house’ may create benefits:

Disadvantages may include:


10. What lessons should the Department learn from the way that it handled claims for health-related benefit claims during the pandemic: for example, relying to a greater extent on paper-based assessments, or using remote/telephone assessments?

a. Is there a case for making some of the changes permanent?

Telephone assessments are good for some claimants being reassessed. Claimants often have difficulty getting to assessment centres and appreciate being able to speak on the phone.

Whilst many claimants with Mental Health Conditions may prefer telephone assessments because of anxiety associated with getting to and attending an assessment centre.   Our experience tells us that these claimant conditions and their impact are more difficult for assessors to fully understand over the phone and this has been borne out by the number of clients that have received zero points following a telephone assessment.   Consideration should be given to home assessments or assessments being carried out at a local job centre.

Telephone assessments seem to work well for existing claimants with well recognised physical conditions. This should be retained for subsequent assessments.

The use of video calls/conferencing (in line with the NHS) to enable an element of visible assessment may have been helpful to support remote assessments.

12. DWP believes that applications for some benefits dropped sharply at the start of the pandemic because claimants weren’t able to access support (for example, from third sector organisations) to complete their applications. What are the implications of this for how the Department ensures people are able to access health-related benefits consistently?

The advice sector has now learnt how to support clients on the phone instead of in person. This works well for many claimants and saves them time and the stress of face-to-face meetings.


a. How can the Department best help the third sector to support claimants in their applications?

More transparency about decision making and rapid provision of assessment information (assessment report and scoring) to enable challenge. 


Dedicated helplines for agencies to use to contact relevant DWP staff (like EUSS and UC helplines).


Pay organisations to provide a help to claim service similar to UC. This could, be on the phone as well as in person

13. DWP recently published research on the impact of applying for PIP or ESA on claimants’ mental and physical health. What would be the best way of addressing this?

Reduce subsequent assessments for claimants with chronic conditions that are highly unlikely to improve.  Rely on paper based and telephone assessments.


Maintain benefits at preassessment level or a transition rate during the challenge (MR/Appeal) process for those with chronic conditions.  Sudden withdrawal of benefits to support claimants has significant hardship and mental health impact.  This is a particular issue where a PIP award impacts on carers’ allowance and other passported premium benefits associated with e.g., council tax reductions, housing benefit and working tax credit.


Clients find the application process daunting and stressful. The forms are lengthy and although the language is clear, many claimants do not get beyond the first pages before feeling inadequate and unconfident. Are there ways to make the form more attractive and inviting. This could be done quite well online by cutting it into smaller sections (like the UC application) but it is hard to see how this could be done with a paper form.

14. What could the Department to do to shorten waits for health-related benefit assessments—especially for ESA/UC?

Carry out a face-to-face assessment (where appropriate) for a new claimant or a claimant reporting worsening conditions and follow up assessments could either be paper based or held over the telephone where a claimant’s condition has not changed.


Carry out less frequent assessments for those with chronic long-term conditions.


a. How effectively does the “assessment rate” for ESA cover disabled peoples’ living costs while they wait for an assessment? Is there a case for introducing an assessment rate for other health-related benefits?

The assessment rate for ESA is similar to the UC standard single standard rate so it does not adequately cover disabled people’s living costs.  It is intended that it should during this assessment period then the assessment rate should be on top of UC and it would make sense for an assessment ‘PIP’ and ‘LCWRA’ rate to be introduced to at least address some of the additional costs of requiring more support particularly as the assessment process is very lengthy.  However, the assessment benefit would need to be non-repayable if it not awarded.  An assessment rate may be a ‘stop gap’ for existing claimants that are being reassessed to prevent financial hardship.


15. How effectively does DWP work with stakeholders—including disabled people—to develop policy and monitor operational concerns about health-related benefits?
a. What steps could the Department take to improve its engagement with stakeholders?

Provide decision information to claimant at time of decision notification to enable clients to have greater success at MR stage.


Provide a direct helpline for advice services, like that offered to Members of Parliament, to avoid wasted time waiting on the main telephone service line.


November 2021