Written evidence from the Learning Disability Wales (HAB0103)

We welcome the opportunity to feedback on this important issue and would like to draw your attention to several consultation responses and policy documents we have submitted in the past to different recipients that are relevant to this consultation. These documents were all developed as part of the Engage to Change project.

Funded by the National Lottery Community Fund, the Engage to Change (E2C) project is working across Wales to support young people aged 16-25 who have a learning difficulty, learning disability and/or autism to achieve their full potential. It uses a supported employment methodology and job coaching. Project partners are:

Learning Disability Wales, lead partner for the project, is a national charity representing the learning disability sector in Wales. Learning Disability Wales works with people with a learning disability and their families, Welsh Government, local authorities, disabled people’s organisations and the voluntary sector to create a better Wales for all people with a learning disability.

Other project partners are: two supported employment agencies, Agoriad Cyf and Elite Supported Employment; and our research partners the National Centre for Mental Health (NCMH) at Cardiff University. There are resources available that discuss what Engage to Change partners have learned about how to best support disabled people into work, and make recommendations:

Dr Steve Beyer, 2020: Engage to Change briefing: What policy changes are required to provide people with a learning disability or ASD equal access to the labour market in Wales? Available online: http://www.engagetochange.org.uk/wp-content/uploads/2020/08/National-Job-Coach-Briefing-6July20-V6_final.pdf

Dr Steve Beyer, 2021: Engage to Change briefing: Jobs for people with a learning disability or autism - The role of the NHS. Available online: http://www.engagetochange.org.uk/wp-content/uploads/2021/02/Engage-to-Change-The-role-of-the-NHS-Jan21_final_eng2.pdf

Further policy information from the Engage to Change project and Learning Disability Wales can be found on our policy page: https://www.ldw.org.uk/project/policy/


Special difficulties for the people in Wales accessing assessments

Wales has areas of deprivation and pockets of people trapped in poverty due to the lack of decently paid jobs. The benefits system does not always offer appropriate support in areas where unemployment is high and where there are limited job opportunities. The benefits system fails to support those individuals who are unable to travel to areas where there are opportunities or are unable to afford travel. The geography of Wales makes it difficult to access opportunities due to these barriers. Where opportunities are concentrated in more urban areas, the opportunities are thus unevenly distributed and significant parts of the Welsh population are excluded. The benefits system would be much improved in Wales by recognising this to support individuals in rural areas to access job opportunities.

During the pandemic, there was an additional top up to the UC payment that ended in November. The loss of this top up will have had negative effects on people as many will struggle to make ends meet without this additional income.

The reliance on call centres does at times disadvantage people with a learning disability who have limited access to assistance. Prior to Covid, the differences for people living in an area being rolled over into UC, and those living in non-UC areas did lead to reluctance of people with a learning disability and their families in the latter areas to enter paid employment because of the potential loss of any premium payments. This undermined the goals of both the Engage to Change project and the goals of the government to help more people from benefits into employment.



We believe that the use of advocacy should be far more extensive than laid out in DWP proposals so far. We also feel the need to point out that advocacy alone is not a solution to the issues within the benefits system. In 2019 a UN report condemned the United Kingdom for violating its human rights obligations to disabled people through benefits cuts. They particularly mentioned benefits sanctions as contributing to extreme poverty. While advocacy can offer some amount of safeguarding to human rights violations, what is needed is an actual commitment by the government not to continue violating disabled people’s human rights. Every person should be given access to advocacy, provided by independent advocates. The current plan sees advocacy as only important for people who do not have other support. It is the DWP’s responsibility to respect people’s rights and therefore to make sure people receive appropriate support and this responsibility should not be left up to other organisations and people to carry.

In the Health and Disability Green Paper you mention the purpose of advocacy as helping people navigate the benefits system. We would like to have an explicit acknowledgement in here about advocacy supporting people in challenging decisions. We know that many people are left in very significant financial hardship due to benefits sanctions. There is very significant anecdotal evidence that suggests that many sanctions are given unfairly, which means that people will be pushed into extreme poverty without warning and without a way to resolve the issue in a timely manner. Advocates should have an explicit function in supporting people to challenge unfair decisions.

Face to face vs digital assessments

Many disabled people cannot access digital resources for a variety of reasons including lack of digital skills, accessibility issues, lack of suitable IT equipment or due to finances. In some parts of Wales there is the added issue of poor or no internet access. For others, blended working can be effective for resources and some disabled people prefer digital communication. Delivering training can be very successful digitally, however, most support interventions are better in person.


Improved funding is required to assist with the provision of resources. There is a lack of equipment and access to Wi-Fi, so many people are excluded. There is also a lack of understanding around online safety, leaving people vulnerable to abuse and exploitation. Many young people do not have the skills to enable them to work digitally without support or even at all. The importance of a supported employment adviser here is essential.


Making sure people know what they are entitled to

We believe disabled people should get better information about the Work Capability Assessment process and support to complete the form, particularly for people with a learning disability. There should be clearer information on how this enhances earnings as an in-work benefit, similar to the old tax credits, as well as improved budgeting advice.


There should be guarantees that levels of benefits will be maintained. Changes of circumstance often see a loss of premiums received under legacy benefits. “Better off in work” consultations should also be completed at job centres to make sure people are fully informed about what is the best course of action for them.


Other suggested changes

We also recommend a number of further actions to improve work opportunities through Access to Work/Disability Confident:


December 2021