Written evidence from the Trussell Trust (HAB0107)

 

The Trussell Trust supports a network of food banks and together we provide emergency food and support to people locked in poverty, and campaign for change to end the need for food banks in the UK.

 

We support more than 1,300 food bank centres in the UK to provide a minimum of three days’ nutritionally-balanced emergency food to people who have been referred in crisis, as well as support to help people resolve the crises they face.

 

Summary

  1. In early 2020, six in ten working aged people referred to a food bank centre within the Trussell Trust network, were disabled. This is over three times more than the rate of disabled people in the general population.[1] The Trussell Trust wants to ensure that disabled people, and those with long-term health conditions, receive the support they need so that they are kept from falling into destitution and relying on short-term emergency support such as food banks.

 

  1. Health benefits play a critical role in preventing destitution and reducing the need for food banks. Analysis by Heriot-Watt University reveals that every 100 failed Personal Independence Payment (PIP) assessments in one year is associated with an additional 93 food parcels being distributed.[2]

 

  1. In the light of evidence that the Department for Work and Pension’s (DWP) assessments and decisions relating to disability benefits are often flawed, this response makes several recommendations to improve the assessment process. The Trussell Trust believes that the DWP should:
    1. Put systems and processes in place that ensure the right decisions are made first time. This will mean more claimants receive the right support in a timely manner and avoid prolonged hardship and the impacts of a stressful appeals process.
    2. Actively seek and consider evidence from the people who know the claimant best, whether a family member, carer, social worker or other, and give this evidence appropriate weight during the initial assessment. This will ensure the assessor has a more accurate picture of how the individual’s health condition impacts their daily life and increase the likelihoods that the benefit award meets their needs.
    3. Invest in increasing capacity for health assessments to shorten waiting times. Consider lengthening the re-assessment cycle for claimants whose condition is unlikely to change.
    4. Improve information and signposting to all relevant benefits and services, including non-health related benefits such as social care and housing. Prospective claimants should be able to choose the type of support that suits them best and ensure that they are supported through the process.
    5. Redesign the application and health assessment processes in collaboration with those who have experience of engaging with that process.

 

  1. With the publication of the recent Departmental consultation ‘Shaping Future Support’, this is a timely inquiry. We hope to see DWP consider the evidence submitted to the Work and Pensions Committee in any future White Paper on the future of health and disability benefits.

 

Background

  1. Between 1 April and 30 September 2021, food banks in the Trussell Trust network provided 936,000 emergency food parcels to people in crisis across the UK.[3] In early 2020, over 4 in 5 (86%) households referred to a food bank were receiving support from the social security system through benefits.[4]

 

  1. Disabled people are disproportionally at risk of needing support from a food bank:
    1. Six in ten (62%) working aged people referred to a food bank in early 2020 were disabled (as defined by the Equality Act). This is over three times more than the rate of disabled people in the general population (19%).[5]
    2. One in five (21%) households referred to a food bank in that period contained more than one disabled person (as defined by the Equalities Act 2010), which is nearly three times the national figure (7.5%).[6]

 

  1. Need for food banks is driven by extremely low levels of income – what can more accurately be described as destitution. In early 2020, 95% of people referred to a food bank were destitute.[7] This is defined by the Joseph Rowntree Foundation as denoting ‘the circumstances facing people who cannot afford to buy the absolute essentials that we all need to eat, stay warm and dry, and keep clean’.[8]

 

  1. 2.4 million people experienced destitution in 2019 – this is a 54% rise since 2017. Prior to the pandemic, 54% of surveyed adults experiencing destitution had a limiting health problem or were disabled.[9]

 

  1. Health benefits play a critical role in preventing destitution and reducing the need for food banks. Research carried out for the Trussell Trust by Heriot-Watt University reveal the significant numbers of disabled people, and their families, who are not receiving adequate support from the social security system and are, as a result, facing destitution.
    1. Analysis of food bank data revealed that every 100 failed Personal Independence Payment (PIP) assessments in one year is associated with an additional 93 food parcels being distributed.[10]
    2. In early 2020 80% of disabled people who were referred to a food bank were not in receipt of either PIP or Disability Living Allowance (DLA). These households had the highest levels of material deprivation.[11]
    3. Households affected by disability, and were in receipt of with PIP or DLA, had the second highest levels of material deprivation. This suggests that even when disability-related benefits are approved they are not always sufficient to meet the extra costs associated with disability and ill-health.[12]
    4. While ill health and disability are a key driver of referrals for food banks, the inadequacy of the social security system in financially supporting disabled people or people with ill health is the primary, immediate driver of need for food banks.
    5. This is demonstrated by the fact that, while disability and ill health worsens with age, there is a cliff-edge drop in food bank usage past the age of 65 which is when people are entitled to significantly more generous benefit levels. The value of Guaranteed Pension Credit is £177.10 per week for single people, and £270.30 for couples. By comparison those who apply for Employment and Support Allowance (ESA) will be given £74.70 for the first 13 weeks while the claim is being assessed. Pre-pandemic Universal Credit (UC) standard allowance represented 45% of the value of Guaranteed Pension Credit.[13]
    6. This demonstrates the imperative to support access to disability benefits, and to review their adequacy to effectively meet people’s needs.

 

  1. The evidence for this submission was gathered from the Trussell Trust’s ‘State of Hunger’ reports and recently published mid-year stats, as well as discussions with sector partners. We have gathered insights from our Help through Hardship financial advice helpline, delivered in partnership with Citizens Advice. We have also incorporated insights from our debt and deductions research project with experts by experience – an ongoing participative research project looking at people’s experiences of benefit deductions.

 

Suitability of Assessments

 

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

 

  1. Many of the issues with assessment processes date back to 2008 when the Work Capability Assessment was introduced and was followed by the assessment process introduced during the roll out of PIP in 2013. These two assessment procedures often cause significant stress for disabled people so much so that the Disability Benefits Consortium (DBC) have described the systems as creating ‘hostile’ environments.[14]

 

  1. Organisations working in the disability sector have pointed to poor practice by assessors, flawed assessment criteria and ineffective evidence collection as reasons why disabled people often fail to access the support they need first time.[15] If an individual takes their case to a tribunal the evidence is heard by a panel of experts, in contrast to a single assessor at the initial assessment, and this may help to explain why so many tribunals find in favour of the claimant. The consideration of the evidence in full, a range of people involved and their level of expertise, seem to be reasons why so many tribunals find in favour of the claimant. This indicates the kinds of changes needed during the initial assessment.

 

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

  1. The DWP should implement measures to ensure that decisions made are ‘right first time’.[16] This would mean that disabled people get the support when they need it which will, in turn, improve their health and increase independence. The current assessment process drives too many people into destitution and having to turn to food banks.

 

I think it's one of the PIP things, where they just no matter what, turn you down until you

appeal it and gather more evidence, just to be persistent about it.’ Participant in State of                             Hunger research, interviewed in early 2020.[17]

 

‘We went for a PIP interview with him [son], we had to take him. He can't cook, he doesn't know how to read or write. He can't tie his laces and things like that, and he’s [an adult]. He struggles daily and he doesn't understand things, and they failed him. Whereas I'm fitter than him and I'm a carer for a disabled son, and they don't take the mental health issue really into account. It's like more physical. So I says, ‘but [my son] can't cook, he can't clean, he can't work a washing machine. He tried to make a dinner one day and set the bloody house on fire. He's not safe living on his own’...and they still failed him…’ Participant in State of Hunger research, interviewed in early 2020.[18]

 

  1. The Trussell Trust recommends that DWP takes steps to ensure providing relevant evidence is as easy as possible and ensure that it will be collected and considered in full by assessors. This evidence should include testimony from those who have the best understanding of the claimant’s condition(s) and how it impacts upon their daily life. This may not be a medical professional. In the case of a person with learning disabilities, for example, they may not have seen a doctor for some time due to the stability of their condition. In such a case a carer or family member may be best placed to give evidence on how their condition affects them. Currently, such evidence is not sought as early in the process as it could be and, if it is gathered, not always given adequate weight.[19]

 

  1. The high rate of successful appeals raises concerns for individuals who accept an initial decision as final, and do not challenge it. This may be due to a belief that the system will not treat them fairly, an absence of support to engage in the appeals process, or not knowing how the system works. The result is that people are  being denied critical support that they need, and this may account for the significant number of ill or disabled people referred to a food bank who are not in receipt of PIP or ESA. In early 2020 just under one in ten households referred to a food bank in the Trussell Trust network were receiving PIP.[20] Ensuring anyone who wishes to apply for a disability benefit has knowledge, and access to, support during application and assessment would help to effectively minimise the likelihood of a future appeal.

 

  1. Signposting to advice and support agencies must be coupled with improved internal processes and assessor training. DWP should, therefore, take steps to ensure that all assessors have access to improved and ongoing training on physical and mental health conditions. Due to the range of health conditions, and the multiplicity of conditions that can affect one individual, it may be difficult to ensure an appropriately trained assessor is available to review each case. Assessors should, therefore, have easy access to a pool of internal ‘experts’ who should be consulted when considering applications.

 

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)?

 

  1. The assessment process for different benefits needs to be improved for those who are claiming multiple benefits. Whilst one assessment process would, from a claimant’s perspective, improve navigation of complex system it would need to maintain the important nuances between the benefits.

 

  1. In reviewing the assessment process, the DWP should concentrate on improving the quality of decision-making. With the number of incorrect decisions being so high there is a risk that a combined assessment process would compound the problems currently facing claimants. Each disability benefit has been designed with discrete purposes and criteria which may be at risk if a combined assessment process was implemented. In particular, PIP is a non-means tested benefit with no employability element. Combining PIP with ESA or UC, as suggested in the green paper ‘Shaping Future Support’, would put people at risk of losing all their financial support because of an inaccurate assessment which, as acknowledged in this inquiry, is an all-too-common experience.[21]

 

What are your views on the Department’s “Health Transformation Programme”? What changes would you like to see under the programme?

 

  1. The Trussell Trust welcomes the Department’s “Health Transformation Programme” which aims to improve trust and transparency in the assessment process. The programme also aims to take a holistic view of people’s lives which is important because every individual exists within a unique context. Considering how the right support can be given to ensure that the risk factors that could result in destitution are mitigated, should be a key aim of any changes to the assessment process. The Trussell Trust’s hope is that the Health Transformation Programme does this and, in doing so, will improve people’s experience of the assessment process and social security system overall. We look forward to hearing more specifics relating to the programme, and the outcome of the trial currently underway in the Health Transformation Area. We would recommend that in reviewing the outcome of this trial, the DWP should carefully consider and respond to feedback and insight from people in the community who have taken part.

 

  1. We would urge caution, however, regarding the aspiration for a single digital platform. For those who face practical, financial and/or physical barriers to technology a viable alternative to accessing and managing their benefit claim needs to be readily available. A ‘digital first’ approach does not mean the Department needs to pursue a ‘digital always’ policy.

 

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?

 

  1. The Scottish Government[22] and Northern Ireland Executive[23] support a move to bring assessments in-house as they believe this will improve issues related to the assessment process. In England and Wales, this is being piloted as part of the Health Transformation Programme and we await the results of that trial.

 

  1. DWP has acknowledged that the assessment process needs to be redesigned. The priority must be to ensure that this is done in partnership with people who use the benefits system. A new assessment process that is truly the product of co-design, will improve trust in the overall system.

 

  1. The Trussell Trust has conducted a research project into government debt and deductions carried out with a group who have direct experience of these issues in the benefits system. The group co-designed three principles which would have improved their experience of the benefits system and, whilst designed in relation to government debt, are applicable across the benefits system. The group asked for increased clarity (‘having all the information I need’), flexibility (‘making choices and changes and feeling that the government responds to my needs’), and respect (‘being treated as an individual’). These principles demonstrate that, whether DWP or a third-party assessment provider, people’s trust in the process can be increased if the right approach is adopted.

 

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?

 

  1. To help people consistently access health-related benefits DWP should improve information and signposting to all relevant benefits and services. These include non-health related benefits such as social care and housing, national support charities, and independent advice agencies, such as the Help through Hardship helpline. This would enable people to choose the type of support that suits them.

 

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

 

  1. Sufficient funding for independent advice provision must be given to ensure that people get the help they need at an early stage. High quality benefits advice will not only ease the process of applying for a health-related benefits (and any subsequent Mandatory Reconsideration (MR) or appeal) but will improve the likelihood that the right information is provided at the right time and should, therefore, mitigate the need for an appeal. This would reduce the administrative costs to the DWP and the cost of tribunals. This would also rely on assessors taking this information into consideration as mentioned above.

 

  1. Beyond funding, the Department should continue to build relations with the third sector. In recent years DWP has begun, and sustained, some positive work in this regard through partnership managers and local stakeholder forums. The impact of this on internal policy making, however, has been shown to be limited. Therefore, making better use of these forums to drive better decision-making is another way that DWP can support the third sector.

 

The impact of assessment/application on claimants

 

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?

 

  1. The increase in mental health problems, since the Covid- 19 pandemic, has been seen across the UK at food banks within the Trussell Trust network.[24] During the pandemic face-to-face PIP assessments were temporarily suspended and substituted with telephone assessments which, according to the Social Security Advisory Committee, created ‘delays and backlogs in decision making’ and ‘potentially excluding claimants from their full entitlement for indefinite periods’.[25]  Waiting for an assessment, or deciding to request a MR or appeal, is problematic because health-related expenses remain with no additional income to cover them. Barely getting by means people feel anxious and like they’re being ‘pushed to their limit’ psychologically. Poor financial circumstances and poor mental health reinforce one another and make it difficult to get out of a downward spiral. Therefore, steps must be taken to ensure that claimants receive an accurate decision promptly and, whilst waiting for an assessment, are provided with appropriate financial support.

 

  1. The long-term impact, of applying for PIP or ESA, on people’s mental and physical health has a wider societal impact. It can lead to increased pressure on food banks, crisis support and other support agencies who are required to try and help people live independently. It is not right that having a mental or physical condition can contribute to driving people into destitution. Food banks play a crucial role in meeting this need, but we should not accept this outcome and should work to tackle the causes of the need for food banks.

 

  1. The best way of addressing harm in the assessment process is to involve people on benefits in the design of an improved/new application and assessment process. This has most recently been highlighted in the Social Security Advisory Committee’s report which concluded that DWP involving disabled people in decisions regarding the processes that affect them will ‘build the trust it needs to make a success of its policy objectives’.[26]

 

Waits for assessments

 

What could the Department do to shorten waits for health-related benefits assessments – especially for ESA/UC?

 

  1. The wait for benefit payments is a key feature of the social security system that negatively affects people who are then referred to food banks. In early 2020 19% of people referred to food banks were waiting for UC (i.e. in the 5-week waiting period before receipt of first payment) and 21% said they had experienced ‘a long wait for UC’ in the past year.[27] For people without savings, or other means of support, the wait for applications and assessments puts them at risk of destitution and in need of a referral to a food bank. For disabled people, their health-related expenses remain, often with no additional income to cover those unavoidable costs, which forces people to make impossible decisions, such as between heating and eating.

 

‘No, he's trying to get that PIP, but we filled in the form a few months ago before this coronavirus happened, and we haven't heard nothing at all since... So he's not earning and getting anything, apart from what we get off Universal Credit…’ Participant in State of Hunger research, interviewed in early 2020.[28]

 

  1. Increasing capacity for assessments would reduce waiting times, as would increasing the range of locations where people can attend an assessment and lengthening the re-assessment cycle for claimants whose condition is unlikely to improve.[29] In cases where a change in a person’s condition is unlikely, regular reassessments take up resource needlessly and this impacts upon those waiting for an initial assessment.

 

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?

 

  1. The Trussell Trust’s experience of working to support people experiencing hardship suggests that the assessment rate of ESA does not sufficiently cover disabled people’s living costs.  The assessment rate is broadly equivalent to both Jobseeker’s Allowance and the standard allowance of UC, which is not adequate for a disabled person who, on average, faces an additional £583 per month.[30]

 

  1. In July 2020, UKHLS survey participants were asked questions about food insecurity and about income sources, including receipt of income-replacement benefits.[31] Food insecurity at the time of the survey was six times more prevalent among people who were claiming income-replacement benefits (UC, ESA, JSA) in early 2020 than among people who were not (18% and 3% respectively). This suggests that the low level of income from those benefits was a driver of food insecurity.

 

  1. In addition, DWP’s own data, collected as part of the Family Resources Survey, shows that food insecurity is four time higher amongst households claiming Employment and Support Allowance (31%) than all households (8%). It is also significantly higher than the average for household’s claiming any income related benefit (25%) or those claiming any state support (10%).[32]

 

  1. An assessment rate should be set at a standard which will keep people living with a mental or physical health condition outside of being at risk of destitution.

 

Health assessments in the devolved administrations

 

The Scottish Government intends to introduce its own assessment process for the Adult Disability Payment, which will replace PIP in Scotland from 2022. What could DWP learn from the approach of the Scottish Government?

 

  1. The Scottish Government have committed to delivering a social security system for Scotland based on the principles of dignity, fairness and respect, that challenges the stigma that can surround social security and recognises the vital role adequate social security plays in tackling poverty. Reflecting this, the Social Security (Scotland) Act takes a human rights-based approach to the provision and payment of benefits. Within the Act there is a recognition of the importance of inclusive communication; a right to access independent advocacy for all disabled people using the social security system and a restriction on the use of the private sector in carrying out assessments. The Scottish Government have said the roll out of the new Adult Disability Payment (ADP) will be person-centred, taking into account the specific needs of each individual.

 

  1. While the eligibility rules for ADP will be similar to the DWP’s rules for PIP, a significantly different approach will be taken by Social Security Scotland to both the application and decision-making processes, with the aim of providing disabled people in Scotland with a fundamentally different experience of accessing the social security system. Examples will include:
    1. Rather than applicants having to evidence each and every difficulty they experience, only one piece of formal supporting evidence to support overall care and mobility needs will be required.
    2. DWP style assessments will be replaced with consultations, based on mutual respect and trust; they will not involve any functional examinations.
    3. Any informal observations made during a consultation will be shared with the applicant and they will be given the opportunity to respond.
    4. There will be fewer face-to-face assessments and awards will be for a longer period.

 

  1. While it is too early to evidence the efficacy of these changes, and the impact they will have on the experiences of people claiming benefits, there is much the DWP could learn from the approach taken by the Scottish Government. DWP should also seek to understand and evaluate how changes to the process impact upon outcomes and whether they are effective. This is important because if changes to the process are not enough to mitigate financial hardship, then the Department should look to the value of benefits themselves.

 

  1. If we are to deliver a UK social security system that is accessible, inclusive and fair to people who need to access support, whether ongoing or during a crisis, DWP should monitor the following approaches and assess their impact:
    1. A human rights approach to the delivery of social security, that flows through the system – from application, to assessments, to decision making.
    2. Ensuring that all forms and guidance are easily accessible to all, written in a way that is easy for applicants to understand and that people can apply in a way that works for them.
    3. Involving people with lived experience in shaping the system.

 

PIP started rolling out in Northern Ireland in 2016. Is there evidence that the Department learned from the experience of rolling out PIP in the rest of the UK?

 

  1. PIP was rolled out in Northern Ireland in 2016 and there is clearly much more learning to be done. Issues found in the administration of the benefit during the two NI Independent Reviews into PIP (2018 and 2020) have reflected many of the experiences other parts of  the UK.[33] In addition, the NI Public Services Ombudsman investigation into ‘PIP and the Value of Further Evidence’ pointed to ‘systemic maladministration’.[34] Northern Ireland consistently has a high number of PIP applicants per head of the population compared to Great Britain, particularly as a result of mental health conditions, which means any failures in the health assessment process are magnified.[35]

 

Policy Development

 

How effectively does DWP work with stakeholders – including disabled people – to develop policy and monitor operational concerns about health-related benefits?

 

  1. The Social Security Advisory Committee has recently published a paper that recommends ‘DWP recruit a large-scale panel of disabled people…to consult regularly’.[36] In its consultation the SSAC recorded a range of views on how well the Department engages with disabled people noting that, whilst there have been positive steps towards better engagement, negative experiences resulted from issues such an over-reliance on individual relationships, inconsistency, poor feedback and a lack of trust. The SSAC concluded that, in relation to social security policy and operational design, DWP was ’doing for’ by which they meant engaging and involving people through consultations and information sharing, but not involving disabled people in an equal and reciprocal partnership via co-design or co-production.

 

  1. At the Trussell Trust we committed to working with stakeholders an ensuring that we work directly with people who have lived experience of the social security system. We are creating spaces for people to inform, shape and co-produce the policy solutions. The research currently being carried out with people who have experience of benefit debt and deductions, working with them to co-design new policy solutions, will be published in early 2022. This is an area of work that we will continue to expand over the coming year.

 

What steps could the Department take to improve its engagement with stakeholders?

 

  1. The DWP has improved its engagement with stakeholders with more focus groups than ever before held during the consultation on the recent Green Paper and frequent attendance at meetings of the Disability Benefits Consortium. The Trussell Trust is grateful for the level of the Department’s engagement with us on issues pertinent to the Trussell Trust’s aim to end the need for food banks in the UK. We hope to continue this relationship into the future to both learn from, and inform, future Departmental policy decisions.

 

  1. We appreciate the steps taken to involve people with experience of living on health benefits. This was noticeable in the Independent Reviews of the Work Capability Assessment, for example, which focused on representative organisations in 2013, but in 2014 saw increased claimant involvement. The Trussell Trust is aware, however, that smaller organisations have not experienced the same level of engagement as larger organisations. The Social Security Advisory Committee has also noted this discrepancy and has asked the Department to take action to rectify.[37]

 

  1. An answer to this question will be more informed once a Departmental response or White Paper is published following the recent consultation on the Departmental Green Paper ‘Shaping Future Support’.

 

December 2021


[1] The Trussell Trust, ‘State of Hunger’ (2020), p.39

[2] The Trussell Trust, ‘State of Hunger’, (2019) p.64.

[3] The Trussell Trust, Mid-year Statistics: April 2021- September 2021.

[4] The Trussell Trust, ‘State of Hunger’ (2020), p.48.

[5] The Trussell Trust, ‘State of Hunger’ (2020), p.39

[6] The Trussell Trust, ‘State of Hunger’ (2020), p.39.

[7] The Trussell Trust, ‘State of Hunger’ (2020), p.12.

[8] Joseph Rowntree Foundation ‘Destitution in the UK’ (2020).

[9] Joseph Rowntree Foundation ‘Destitution in the UK’ (2020) p.57.

[10] The Trussell Trust, ‘State of Hunger’, (2019) p.64.

[11] The Trussell Trust, ‘State of Hunger’ (2021), p.39.

[12] The Trussell Trust, ‘State of Hunger’ (2021), p.39.

[13] The Trussell Trust, ‘State of Hunger’ (2021), p.69.

[14] Disability Benefits Consortium, ‘Has Welfare Become Unfair?‘ (2019) p.18.

[15] See evidence submitted to this inquiry by the Disability Benefits Consortium.

[16] See Scope UK’s current campaign Disability Benefits Without the Fight

[17] The Trussell Trust, ‘State of Hunger’ (2021), p149.

[18] The Trussell Trust, ‘State of Hunger’ (2021) p.47.

[19] Paul Gray, ’Second Independent Review of PIP Assessment‘ [17].

[20] The Trussell Trust, ‘State of Hunger’ (2021), p.62.

[21] Department for Work and Pensions, ‘Shaping Future Support: the health and disability green paper’ (2021) [297].

[22] Social Security Scotland statement (2018).

[23] Minister for Communities statement (June 2021).

[24] The Trussell Trust, ’Lockdown, lifelines and the Long Haul Ahead’ (2020) p.27.

[25] Social Security Advisory Committee, ‘A review of the Covid-19 temporary measures’, (November 2020) p.7.

[26] Social Security Advisory Committee, ‘How DWP involved disabled people when developing or evaluating programmes that affect them’, (2021).

[27] The Trussell Trust, ‘State of Hunger’ (2021) p.52.

[28] The Trussell Trust, ‘State of Hunger’ (2021) p.38.

[29] See MS Society’s response to this inquiry.

[30] See Scope, ‘The Disability Price Tag 2019’, (2019).

[31] Understanding Society – The UK Household Longitudinal Study.

[32] Table 9.7 Household Food Security: https://www.gov.uk/government/statistics/family-resources-survey-financial-year-2019-to-2020

[33]Department for Communities, Independent Review of the Personal Independence Payment (PIP) Assessment Process in Northern Ireland) (2018 and 2020).

[34] Northern Ireland Public Services Ombudsman, ‘PIP and the Value of Further Evidence’ (2021).

[35] Work and Pensions and Northern Ireland Affairs Committees, ‘Welfare Policy in Northern Ireland’ (2020) [13].

[36] Social Security Advisory Committee, ‘How DWP involves disabled people when developing or evaluating programmes that affect them’(2021).

[37] See the Disability Benefits Consortium’s response to this inquiry.