Submissions and Policy Recommendations 2013
Submission on Assisted Decision-Making (Capacity) Bill 2013
Publication Date: November 2013
The CIB has made a submission to the Department of Justice and Equality on the Assisted Decision-Making (Capacity) Bill 2013 and welcomes the publication of this very important Bill. The submission broadly acknowledges the changes made to the draft legislation since the publication of the previous Scheme of Mental Capacity Legislation on which the Board made a submission in 2010.
Two specific provisions in the Bill are identified in the submission as particularly important in terms of enabling people to manage to the fullest extent possible their own affairs, including their money and where they live (issues which are regularly referenced in the work of the National Advocacy Service (NAS): these are the provision for individuals to make legally binding agreements with others (decision-making assistants) to assist and support them in making their own decisions and the requirement for decision-making assistants and co-decision-makers to ascertain and to give effect to the will and preferences of the person in all decision-making in so far as this is reasonably practicable. The submission calls for greater consideration to be given to including provision in the assisted decision-making legislation for people having access to independent advocates whose role would be to support and maximise the decision-making capacity of the individual. The need for the assisted decision-making legislation to be integrated with other measures is also highlighted – in particular, the provisions of the Mental Health Act 2001 and the HIQA National Standards for Residential Services for Children and Adults with Disabilities.
Local Property Tax Submission October 2013
Publication Date: October 2013
The CIB made the following submission to the Revenue Commissioners in relation to the introduction of the Local Property Tax based on feedback from the network of Citizens Information Services (CISs) and the national Citizens Information Phone Service (CIPS). These services were signposted in the information distributed by Revenue, and they received a high volume of LPT queries during the period of introduction of the new tax. As such the services were well positioned to offer a view as to the issues arising. The submission covers issues relating to hardship, deferrals and exemptions; property valuations; payment options, liability for payment; administration and filing of returns.
Defined Contribution Pensions - Submissions to Pensions Board (October 2013)
The Citizens Information Board and MABSndl recently made submissions in relation to the Pensions Boards consultation on defined contribution pensions. The submissions welcome the focus on improving the regulation of these schemes and propose greater co-ordination between the Pensions Board and bodies involved in the different aspects of pension regulation such as the Revenue Commissioners and Central Bank. Minimum standards for trustee knowledge, understanding and behaviour should be developed. These minimum standards should include an understanding of the particular scheme as well as investment strategies in order to provide adequate oversight and information to members. Legislation may be required to ensure that standards are enforceable as well as a robust supervisory regime. The lack of knowledge about pension arrangements among scheme members also needs to be addressed. The Pensions Board can set out clearly the quantity and quality of the information which schemes must provide to members.
Pre-Budget Submission 2014
Publication Date: July 2013
This submission sets out the social protection concerns and related tax issues identified by services providing information, advice and advocacy and concerns relating to indebted clients identified by MABS. Citizens Information Services, the Citizens Information Phone Service and MABS continue to report that their clients are going through difficult times, negotiating the rising costs of living, with reduced incomes, fuel poverty, the prohibitive cost of schooling, and problems with rent supplement as an effective housing and income support. The cumulative effect of recent budgets and increasing unemployment are reflected in the complex queries received from the public. Many are struggling within an information environment which is rapidly changing as decisions from recent budgets take effect and have a negative impact on household income. In 2012, CISs dealt with over 600,000 callers and over 900,000 queries from members of the public. Almost half of all queries (47%) were social welfare related.
National Entrepreneurship Policy Statement Consultation June 2013
Publication Date: June 2013
This CIB submission on the National Entrepreneurship Policy Statement draws on the CIB policy report, Hard Times for the Self-employed: Citizens Information and MABS Experience which highlighted a range of issues affecting self-employment in Ireland. The submission focuses on the need for policies aimed at actively promoting the option of self-employment and stimulating development through the implementation of support programmes and incentives; the regulatory framework conducive to entrepreneurship and responsible risk-taking and social policies (including, social insurance and pensions) that underpin the longer-term well-being of the self-employed.
Submission to Review Group on Transport and Mobility supports
Publication Date: April 2013
The CIB welcomes the opportunity to submit to the Review Group established to seek alternatives to the Mobility Allowance and Motorised Transport Schemes to meet transport needs for people with disabilities. Transport and mobility supports play a crucial role in combating social exclusion and in enabling access to health and social services. It is acknowledged nationally and internationally that people with disabilities incur many extra living costs as a result of their disability. This submission draws on an earlier policy report published by the CIB Getting There: Transport and Access to Social Services which highlights key issues relating to access to transport for people with disabilities. The submission proposes that any alternative mechanisms put in place should be located in the context of longer-term mobility and transport supports and broader policy reforms relating to people with disabilities, in particular, the move towards an individualised supports system currently under consideration.
National Demographic Dataset HIQA (for use in health and social care settings)
Publication Date: April 2013
The Citizens Information Board (CIB) welcomes the opportunity to comment on the draft National Demographic Dataset and Guidance for use in health and social care settings in Ireland published by HIQA. Issues of access to health records and of communication between providers of health and social care services are frequently reported by users of services provided by CIB delivery partners. The use of a Unique Health Identifier system as envisaged in the Demographic Dataset has the potential to provide more effective linkages between the primary and secondary health care domains and between the public and private sectors irrespective of the locations of service. It should also eliminate the need for people using health and social care services to provide personal details at every contact with the system which is unnecessarily time consuming. This CIB submission outlines a number of considerations and recommendations.
Review of the Code of Conduct on Mortgage Arrears (CCMA)
Publication Date: April 2013
This submission, prepared by MABSNdl to the Central Bank's Review of the Code of Conduct on Mortgage Arrears draws on the experience of MABS in working with clients in mortgage arrears and includes observations on the operation of the CCMA and the Mortgage Arrears Resolution Process (MARP) in these cases. The submission makes a number of recommendation including the need for timelines for each stage of the MARP, the need for an objective process for determining non-cooperation by borrowers and independent evaluation of the sustainability of solutions as well as the need for recourse to an independent appeals mechanism along with the right to appeal to the Financial Services Ombudsman. The submission also proposes that there be no change to the existing level of permissible unsolicited contact between lender and borrower.
School Costs Submission (Oireachtas Joint Committee on Education and Social Protection)
Publication Date: March 2013
The Oireachtas Joint Committee on Education and Social Protection is "compiling a Report on the prohibitive costs for parents sending children to primary and secondary school." The CIB Pre-Budget Submission 2013 named a number of priorities for the budget, based on feedback from its delivery partners regarding the most pressing concerns of the people accessing their services. One of these priorities concerned the need for "further supports to meet the educational costs for low-income families" and the importance of reducing these costs. The submission noted that an increasing number of families seek information and advice from Citizens Information Services (CISs) and the Citizens Information Phone Service (CIPS) about how to get additional assistance with schooling costs. Evidence from MABS points to the risk of parents borrowing to meet necessary costs associated with schooling. The cost of school books, uniforms and school transport have been particularly prohibitive with other costs also putting strain on families including school outings and voluntary contributions. These and other issues are raised in this submission which includes a number of related recommendations.
Consultation on Charities Regulatory Authority
Publication Date: March 2013
The CIB in its submission to the Department of Justice on key priorities for the Charities Regulatory Authority highlights the issue of how charities registration requirements and related compliance are to be monitored, the need to put in place detailed sets of standards for the charities sector and an inspectorate to monitor their implementation. The submission also focuses on the role of the Authority in providing clear information about the requirements of the Charities Act 2009 in relation to registration, financial accountability and financial activities as well as the establishment of the Charities Regulatory Authority as a reliable repository of information on charities – compliance requirements, standards and best practice. The need to co-ordinate and minimise duplication in reporting requirements with other regulators and funders was also noted in the submission.
Submission on Report on Pension Charges
Publication Date: February 2013
The Citizens Information Board welcomes the publication of the Report on Pension Charges. The report provides significant information about, and analysis of, pension charges and raises a number of issues which were not its direct subject matter but which are very relevant to overall pension issues. These include the quality of the information provided about all aspects of pension products, the complexity of the regulatory regime for pensions and the role of trustees in pension schemes. CIB considers that much needs to be done to improve the quality of the information provided to pension contributors and, indeed, to all customers of financial services. The Board considers that pension charges have to be viewed in the context of, among other things, the need to encourage increased uptake of pensions and the need for effective consumer protection.
Submission to HIQA on a consultation document on Standardising Patient Discharge Summary Information
Publication Date: January 2013
Submission to HIQA on a consultation document on Standardising Patient Discharge Summary Information. 9% of all queries to Citizens Information Services relate to health related entitlements. While these queries do not generally refer to the specific medical aspects of people's health, they frequently refer to people (particularly older persons and their carers) being very unsure about what post-discharge supports are available, in particular, care packages, who to contact and whether a public health nurse, GP or any community care services person will make contact. This submission highlights the crossover between a person's medical condition and his/her personal and social care needs as central to an effective post-discharge care management system being put in place.
Submission to HIQA on a consultation document on Standardising Patient Discharge Summary Information.doc
Submission to HIQA on a consultation document on Standardising Patient Discharge Summary Information.pdf