Submissions and Policy Recommendations

Every year, the Citizens Information Board contributes to public policy formulation by responding to policy consultations and preparing submissions. Many of these are in response to invitations by government departments and working groups undertaking a review of an old or a proposed new policy. These submissions are available for the following years.

Submissions 2018

Barely Getting By - Citizens Information Board highlights citizens’ concerns ahead of Budget 2019

CIB Pre Budget Submission (Sept 2018)

Over one million queries inform Citizens Information Board pre-budget submission.

Citizens Information Board funded services dealt with over one million queries and assisted over 700,000 callers to access a wide range of social, public and financial services in 2017. Drawing from those experiences, CIB’s ‘Barely Getting By’ pre-budget submission makes recommendations in areas that include housing, debt and affordable credit, welfare supports and the provision of benefits and services. The submission evidences the key difficulties that impact on the lives of people who are using information, advocacy and money advice services – many of whom are ‘barely getting by’ and, for whom, supports delivered through public services are essential to their ability to cope with limited means in difficult circumstances. In 2017, for the first time, there were 100,000 housing queries to Citizens Information Services. The submission calls for greater rent regulation measures and increased supports for vulnerable households to access suitable accommodation.

Barely Getting By - Citizens Information Board highlights citizens’ concerns ahead of Budget 2019 .pdf pdf document icon .docx Word document icon

State Pension reform proposals - Total Contributions Approach (September 2018)

Publication Date: September 2018

This response to the consultation on proposals to introduce a Total Contributions Approach (TCA) to calculating state pension entitlement highlighted priorities for reform – notably, the removal of anomalies, the need for greater equality between men and women and the requirement that periods of low PRSI coverage should be acknowledged in the design of the scheme. CIB recognise the scale and significance of this reform and believes that the general approach to this policy initiative should be underpinned by commitments to provide clarity for all current and future pensioners. The CIB response also highlighted the need for a transition period between the old (yearly averaging) and new (TCA) contributory pensions systems.

State Pension Reform and TCA .docx Word document icon

Mental Health Commission (MHC) Strategy ( August 2018)

Publication Date: August 2018

The Citizens Information Board has a particular remit to provide advocacy for people with disabilities and in that context supports mainstream advocacy for people with disabilities, including people with mental health difficulties, through the CIS network and supports the National Advocacy Service (NAS) for people with disabilities This response to the Mental Health Commission consultation on its Strategy is based on NAS’s engagement with mental health service users through its representative advocacy work. Key factors that will impact the work of the MHC are the commencement of the Assisted Decision-Making (Capacity) Act 2015, the development of the Decision Support Service (DSS) to ensure that assisted decision-making may be fully implemented and the recent ratification by Ireland of the UN Convention on the Rights of Persons with Disabilities. Other considerations for a strategic focus include promoting best practice in adult safeguarding policy, recognition of the diversity of mental health services users and a more joined up approach to mental health care planning.

MHC Strategic Plan Survey Response .docx Word document icon

Moneylending and Consumer Protection - CIB Submission to Central Bank

Publication Date: June 2018

In June 2018, CIB in conjunction with MABS prepared a submission in response to the Central Bank review of the Consumer Protection Code for licensed moneylenders. The review proposes new measures to enhance the protections that are in place for customers of licensed moneylenders. The submission stated that any review of the Code must be considered in the broader context of the alternatives available to low-income borrowers – noting that many MABS clients have few choices when considering credit options and are, thus, reliant on the moneylending sector. In this context, CIB highlighted the role of the Credit Union “It Makes Sense” loans, which CIB was instrumental in getting off the ground and the need to further expand the roll-out of these loans across the Credit Union Sector. An analysis of the repayment and arrears experience of MABS clients for this review indicated concerns around questionable lending, record-keeping and poor information provision amongst some moneylenders.

Moneylending and Consumer Protection - CIB Submission to Central Bank .docx Word document icon

Advance Health Care Directives - Codes of Practice

Publication Date: May 2018

CIB responded to the HSE Consultation on Codes of Practice for: Health and Social Care Professionals, Designated Healthcare Representatives and a Code on How to Make an Advance Healthcare Directive. The requirement for these Directives (and associated Codes of Practice) derives from the introduction into Irish law of the Assisted Decision-Making (Capacity) Act 2015. The submissions welcomed the introduction into law of Advance Care Planning and commented on technical aspects of the three Codes of Practice – focusing on the use and definition of terms within the legislation, compliance and associated liability and the role of healthcare personnel in advance care planning. The need for recognition of the role of independent advocates in the Codes is noted, as health and social care practitioners will encounter advocates who will be assisting people with expressing their will and preference in cases where capacity issues arise.

Advance Health Care Directives .pdf pdf document icon .docx Word document icon

Deprivation of Liberty: Safeguard Proposals

Publication Date: March 2018

This submission is a response to the Department of Health consultation on draft legislation on deprivation of liberty safeguard proposals. Legislative clarity is required on the issue of deprivation of liberty in residential facilities for older people, those with a disability or mental health issues in order to meet obligations under the United Nations Convention on the Rights of Persons with Disabilities. The submission notes that in all cases, deprivation of liberty should occur in accordance with due process of law, and subject to regular review and lawful challenge.

Deprivation of Liberty: Safeguard Proposals.pdf pdf document icon .docx Word document icon

Future of Policing in Ireland

Publication Date: January 2018

CIB prepared a submission in January 2018 to the Commission on the Future of Policing in Ireland in response to a wide-ranging public consultation process. The insights provided were based on the experience that CIB delivery services have in reaching out to vulnerable and marginalised groups in Irish society - such as people on low incomes who are living in deprived communities, people with disabilities and mental health difficulties, Travellers, and new communities/ immigrants. Specific areas which CIB felt require additional attention from An Garda Síochána included dealing with illegal moneylenders, engaging marginalised and new communities and helping victims of abuse.

Future of Policing in Ireland.pdf pdf document icon .docx Word document icon

Previous submissions