Managed migration or Move to Universal Credit: the cover-up of a disaster in the making?

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Apr 082022

The managed migration, or Move to UC as it is now called, is the process by which claimants of legacy benefits will be moved onto universal credit even if their circumstances have not changed. It is a very risky move as it involves a wide range of claimants, notably disabled people claiming Income-based Employment and Support Allowance. The DWP has recognised these risks in the 2019 UC Programme Board Members documents released by DWP thanks to John Slater’s perseverance[1]:

“The overwhelmingly common thread running through these themes is a concern that, in moving people over from legacy benefits, they will fall between the cracks and suffer hardship as a result. This stems from two primary worries:

That DWP will send letters that claimants will ignore or not understand and no-one will be ready to support them and;
That when claimants fail to act on a ‘notification’ from DWP, their benefits will be stopped and they will be made vulnerable or more vulnerable as a result” [2]

Lately there have been some very worrying developments in this area. We learnt that the DWP’s Universal Credit (Transitional Provisions) Regulations 2022 remove the 10,000 migration cap and the requirement for scrutiny of the managed migration[3].

This has been a concern for the Social Security Advisory Committee:

“The Chair noted that, while the Committee was content with many of the proposals, it had identified some concerns – in particular on the effect of regulation 9 which removed the 10,000 cap on migration notices – on which it intended to write to the Secretary of State, together with some potential mitigations for her consideration. The Committee would await a response to those concerns before completing the statutory scrutiny process”.

And

“The proposed regulation 9 has the effect of removing the cap on the number of migration notices (10,000) that could be issued to existing claimants on legacy benefits and the associated Ministerial commitment to report back to Parliament before proceeding further. The main conclusion from our scrutiny of these regulations was that there is a need to consider further the potential consequences of regulation 9, and we would encourage you to retain the cap”. [4]

Meanwhile in 2021, a new tranche of UC guidance has been deposited in the House of Commons library, and the document “safeguarding” had the following sentence removed from previous guidance: “Universal Credit has a responsibility to ensure that anyone who accesses our service and benefits can do so safely”[5]

Finally, the following has to come to light in the past few weeks.

First the DWP has confirmed that the 2019 Prime Minister Implementation Unit’s (PMIU) report: How effective is support for vulnerable Universal Credit claimants? will stay redacted[6].

This document was supposed to identify the gaps in support for vulnerable people, the remedial actions and how this work was now being taken forwards. This was first covered in November 2021 by DNS [7]

What was not redacted in the report was the decision/recommendation.

“Decision / Recommendation 7. (UC) Programme Board is asked to note and comment on the report and support the joint work to progress the recommendations moving forwards. We seek Programme Board agreement to task the Complex Needs Steering Group with tracking and implementing the recommendations of the PMIU report” [8]

Keep in mind that this document was written in October 2019. On the 22 March 2022, Labour MP Karen Buck asked the following question: To ask the Secretary of State for Work and Pensions, pursuant to the Answer of 28 April 2021 to Question 185273, if she will place copies of the (a) agendas, (b) papers and (c) minutes of meetings of her Department’s Universal Credit Complex Needs Steering Group in the House of Commons Library.

A reminder here that in its 2019 report, the PMIU and the UC Programme Team was asking the UC Programme Board’s agreement to task the Universal Credit Complex Needs Steering Group with tracking and implementing the recommendations of the PMIU report (which have all been redacted).

The answer from DWP to Karen Buck is mind-blowing.

“The departments Complex Needs Steering group was disbanded in 2019, any documents relating to it have been destroyed in line with DWP document retention policy”. [9]

In summary, a report written in October 2019 evaluating the effectiveness of support for vulnerable Universal Credit claimants was almost totally redacted, except for its recommendation that the UC Programme Board agree that the tracking and the implementation of the PMIU report was tasked to a Complex Needs Steering Group which was disbanded in ………2019. And this at the time when the managed migration with all the risks associated for vulnerable claimants would have started if it had not been for Covid.

Was the Steering Group already disbanded when the PMIU report was written and the meeting took place, or was it disbanded between October and December 2019, just after the meeting? Who took the decision and who knew about it?

And if the Steering Group was still in existence at the time the report was published, was there enough time to implement the (redacted) recommendations within 2 months? It is impossible to know as all the documents related to the Steering Group were destroyed.

There are a certain number of clues as to why this is happening.

From the 2019 UC Board papers, we know that the DWP miscalculated the number of legacy benefit claimants to be moved to UC. Their number was much higher than forecasted and the decision was taken to extend the managed migration until end of 2024. This had obvious cost implications.There are no reasons to think that the pandemic changed this situation. Although the end of 2024 deadline has been maintained, the number of legacy benefit claimants being moved onto UC is not capped anymore, which means that the migration towards UC can be done more speedily and without scrutiny of the consequences, in order to limit the costs.[10] [11]

Let’s not forget either that the current status of the UC programme is still Amber, and that the above measures might also have been required to protect the already very shaky business case.

Reputational risks: The UC Board papers show that their members are well aware of the reputation of UC among legacy claimants and of their reluctance to claim it. Although the DWP will initially adopt an approach aimed at convincing claimants to claim UC, it recognised that for some claimants, benefits will need to be stopped in order to force them onto UC. The lack of scrutiny in that case, is essential to prevent the migration to be stalled by concerns about negative consequences, especially for the most vulnerable claimants. “We understand from evidence that some claimants will not move without stopping legacy benefits but we want to understand how far we can go with the “who knows me” model to avoid this as far as possible”. [12]

Finally, some of the issues can be attributed to the UC Senior Responsible Owner :

His ideological inability to recognise structural flaws in the UC system,
His unwillingness to accommodate the access needs of those who are unable to navigate it,
and his contention that critics of UC focus too much on the hardest to help, who for him account for a minority, while the majority of claimants benefit, means that the needs and safety of vulnerable claimants are unlikely to be met during the managed migration, and that risks associated to the managed migration are unlikely to be recognised. [13]

In conclusion, what we are seeing here, is the incremental removal of safeguards for people who need the highest protection. While most working claimants on UC are able to adjust their behaviour to a drop in income by working more hours or finding a better job, and to navigate the complexity of the UC system, disabled people on legacy benefits will be totally reliant on the money they receive from the government, subjected to a harsher regime with a highest level of scrutiny and they will receive the support that the DWP deems necessary, rather than as a response tailored to their individual needs. The removal of safeguards and the lack of transparency in how this migration is managed show the direction of travel.

For a summary of all the issues pertaining to DWP difficulties to identify and support properly vulnerable claimants, refer to this FOI request and its associated request for internal review[14]