their legacy benefits cease and we should remember that not all of – those claimants affected will be in touch with an agency that can help. 2.3 This might be the appropriate point for us to emphasise that it is essential for all communications with claimants on all aspects of the transfer to be clear and specific and in the claimant’s required format: communications really must be accessible and in the “All claimant’s required format, or the incidence of late or ineffective claims from people with sensory impairments or with other accessibility needs will be even worse than is generally expected”. [Universal Credit, e-mail message, Royal National Institute of Blind People, 19/8/18]. is important to stress that everything needs to be accessible”. “It [DBC draft response to UC regulations, e-mail message, Sense, 14/8/18]. 2.4 The turmoil surrounding the sudden cessation of legacy benefits is also likely to throw into sharp relief the DWP’s unsustainable policy of demanding repeated consent” in order to communicate with “explicit claimants’ advisers. The restoration of an orderly system of “implicit consent” must be achieved before managed migration commences. 3. Transitional protection [draft reg. 48 and following] 3.1 Perhaps better described as freezing”, the idea of TP is “transitional to avoid cash losses at the point of change. TP has a long history in the evolution of the benefits system, but it is not usually the case that transition from one regime to another takes a number of years. Thus, there are many opportunities for the subjects of UC migration” to “natural lose their access to TP. Even after migration” commences, TP “managed will be easily lost. We recommend that every opportunity should be taken to transitional protection”. “protect The following are causes of particular concern: 3.2 The likelihood of claims” (including where there has been “defective a delay in providing evidence or information) is bound to be high, as claimants struggle to navigate the process. So the loss of TP under draft reg. 48(2) seems particularly harsh. TP should not be removed as a
their legacy benefits cease – and we should remember that not all of those claimants affected will be in touch with an agency that can help. 2.3 This might be the appropriate point for us to emphasise that it is essential for all communications with claimants on all aspects of the transfer to be clear and specific and in the claimant’s required format: “All communications really must be accessible and in the claimant’s required format, or the incidence of late or ineffective claims from people with sensory impairments or with other accessibility needs will be even worse than is generally expected”. [Universal Credit, e-mail message, Royal National Institute of Blind People, 19/8/18]. “It is important to stress that everything needs to be accessible”. [DBC draft response to UC regulations, e-mail message, Sense, 14/8/18]. 2.4 The turmoil surrounding the sudden cessation of legacy benefits is also likely to throw into sharp relief the DWP’s unsustainable policy of demanding repeated “explicit consent” in order to communicate with claimants’ advisers. The restoration of an orderly system of “implicit consent” must be achieved before managed migration commences. 3. Transitional protection [draft reg. 48 and following] 3.1 Perhaps better described as “transitional freezing”, the idea of TP is to avoid cash losses at the point of change. TP has a long history in the evolution of the benefits system, but it is not usually the case that transition from one regime to another takes a number of years. Thus, there are many opportunities for the subjects of UC “natural migration” to lose their access to TP. Even after “managed migration” commences, TP will be easily lost. We recommend that every opportunity should be taken to “protect transitional protection”. The following are causes of particular concern: 3.2 The likelihood of “defective claims” (including where there has been a delay in providing evidence or information) is bound to be high, as claimants struggle to navigate the process. So the loss of TP under draft reg. 48(2) seems particularly harsh. TP should not be removed as a