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 2019
Submission on Pathways to Work Strategy 2020 - 2024
Publication date:September 2019
CIB responded to the Department of Employment Affairs and Social Protection public consultation on the development of a new Pathways to Work Strategy to cover the period 2020 – 2024. The CIB submission was based on the social policy feedback submitted by services arising out of queries from people seeking to transition from welfare to work. In 2018, almost 45% of the one million queries handled by Citizens Information Services were social welfare related. Feedback from services cites ongoing difficulties in relation to the quality of employment for long-term unemployed people, the issue of suitability (and choice) of activation programmes and the inability of many qualified adults to access employment supports and activation measures.
Submission on Pathways to Work Strategy 2020 - 2024.pdf 
.docx 
Data from over a million queries informs CIB’s Pre-Budget Submission 2020
Publication date:September 2019
The Citizens Information Board uses insights gained from enquiries to its delivery services to illustrate the impact of government policy and its implementation on people who are trying to secure social and public services. These services dealt with over one million queries and assisted 700,000 callers to access a wide range of social, public and financial services in 2018. Data from these services indicates that many clients are trying to adapt to changing circumstances in their lives, will have experienced a financial shock or will be facing ongoing financial pressures which leave them unable to meet basic essential living costs – rent or mortgages, fuel, food, education, clothing or transport. Drawing on this evidence, the pre-budget submission ‘Meeting Basic Living Costs’ describes some of the problems experienced by callers and suggests particular policy changes that could help people in meeting the costs of living. Areas featured include: in-work welfare and income security; income gaps for people with disabilities, those experiencing illness and also carers - there were almost 120,000 queries made to Citizens Information Services in 2018 related to these payments and supports; the availability and affordability of housing - staff in information services responded to over 95,000 housing queries during 2018 and problem debt and financial inclusion.
Pre-Budget Submission 2020.pdf .docx
Cost of Disability Research
Publication date: August 2019
We welcome the fact that the Department of Employment Affairs and Social Protection has commissioned this independent cost of disability research. CIB has a specific remit to provide advocacy supports for people with disabilities. In that context, CIB funds and resources the National Advocacy Service (NAS) to meet the needs of people with disabilities who are in vulnerable situations. It is internationally recognised that people with disabilities incur many extra living costs as a result of their disability and the research aims to inform policy direction in relation to the appropriate level of support required to meet these costs. This submission is intended to inform the initial planning phases of the research.
Submission on Cost of Disability Research
Capping the cost of licensed moneylenders
Publication date: July 2019
This submission was in response to a Department of Finance consultation on capping the cost of licensed moneylenders and other regulatory matters. The question of whether or not to introduce interest rate restrictions in the legal moneylending sector needs to be considered in the broader context of financial exclusion. The responses to the questions asked in the consultation document are prefaced with some wider observations on poverty, financial exclusion and access to affordable credit and draw on MABS experience of casework with clients with moneylending debts. Access to credit is one of the main pillars of financial inclusion and is a key enabler that allows people to, manage their consumption patterns and to cope with unplanned items of expenditure. CIB and MABS have been to the forefront in the development of the personal micro credit loan scheme through the credit union movement.
Submission on Cost of Licensed Moneylenders
A more equitable Ireland for Travellers
Publication date: June 2019
The Citizens Information Board (CIB) in its submission to the Seanad Public Consultation identified a number of key areas that need to be addressed when looking at inequality and social exclusion among the Traveller community. These include ongoing policy implementation issues in relation to the delivery of Traveller accommodation at local authority level, the recognition of traveller ethnicity (with specific reference made to the collection of data around the use of public services), financial inclusion and the development of an innovative approach to Traveller employment and participation.
Traveller Equality Submission to Seanad Public Consultation Committee
.docx
Submission on Review of Direct Provision and the International Protection Application Process
Publication date: May 2019
This submission to the Joint Oireachtas Committee on Justice and Equality on the direct provision and international protection process was in response to the Committee seeking the views of interested parties and stakeholders regarding what can be done in the short to medium term to develop a better accommodation system for asylum seekers and a more streamlined and efficient international protection application process. The CIB submission noted that, despite a good deal of evidence from a number of different sources and reviews in recent years, significant difficulties remain for people who are living in Direct Provision and in the administration of the international protection application process.
Direct Provision and the International Protection Application Process
.docx
Consultation on Draft National Social Enterprise Policy for Ireland 2019-2022
Publication date: May 2019
This submission was in response to a Government consultation on a draft national social enterprise policy. CIB welcomes the inclusion of a social enterprise policy as part of a suite of measures for the development of the voluntary and community sector. Our submission notes the need for social enterprise policy to be located clearly within a local development framework.
Consultation on Draft National Social Enterprise Policy for Ireland 2019-2022
.docx
Evaluation of Community Banking and Local Provision of Banking and Financial Services
Publication date: April 2019
Community Banking and the local provision of banking and Financial services (April 2019) The Citizens Information Board (CIB) in its submission to this Department of Finance commissioned evaluation highlights community banking as an initiative that can help address issues relating to financial exclusion and access to credit for small-scale local enterprises. Any new model of public banking needs to recognise low income consumers as having real potential as customers, provide low cost overdraft facilities and low cost credit for low income groups along the lines of personal microcredit scheme and ensure that there is an appropriate balance between different banking objectives that is, between the prudential side and that of consumer choice and protection. The submission also notes the value of Credit Unions in the Irish context and states that, as Credit Unions extend their role and move more in line with mainstream banks, care must be taken that they retain a focus on lower income groups.
Evaluation
of Community Banking and Local Provision of Banking and Financial Services .docx
Primary Care Reimbursement Service Strategic Plan 2019-2021
Publication date: April 2019
HSE Primary Care Reimbursement Service - Strategic Plan 2019-2021 (April 2019) The main area of engagement by CIB and its delivery services with the PCRS is through its National Medical Card Unit (NMCU) and CIB has highlighted a wide variety of issues that have been identified by services and clients around medical card application processes and some aspects of eligibility. The Strategy places much emphasis on the online development of its service, especially in relation to the implementation of Slaintecare. While welcoming the benefits of online systems, CIB is of the view that there is a significant need for assisted digital channels and supports for people who do not easily have online access because of affordability issues.
Primary
Care Reimbursement Service Strategic Plan 2019-2021 .docx
National Volunteering Strategy
Publication date: February 2019
This submission to the Department of Rural and Community Development on a National Volunteering Strategy provides observations on a range of specific questions laid out in the consultation in relation to key areas: the role of volunteering and Volunteer Involving Organisations (VIOs) and volunteer supporting structures (including central government, local government and business,) in developing volunteering; the actions that should be included in a volunteering strategy to encourage training, development and retention of volunteers and actions to raise awareness of the benefits of volunteering, of volunteering opportunities and of the explicit participation of young people and marginalised groups in volunteering; and the need for the development of a code of conduct for volunteers (and for VIOs).
National
Volunteering Strategy .docx
Submissions 2018
Automatic Enrolment Retirement Savings System for Ireland
Publication date: December 2018
On average, Citizens Information Services receive over 1,000 queries per week in relation to state pension provisions. Based on this level of service engagement on pension concerns, CIB responded to the consultation on a Strawman proposal for an Automatic Enrolment pensions scheme. As part of the five year Roadmap for Pensions Reform 2018-2023 the Government noted its intention to introduce an Automatic Enrolmentâ (AE) supplementary retirement savings system by 2022.
Auto
Enrolment submissions .docx
National Digital Strategy
Publication date: December 2018
The CIB submission notes key areas that the Strategy should focus on: digital public services, inclusion and well-being, and trust, security and privacy. The submission suggested that one of the main challenges in the delivery of digital public services was the unintended consequence of reducing access to public services among low income groups (including older people, those with disabilities, and those with low levels of education, literacy or computer literacy), a trend which seems to be increasing amongst clients who attend CICs having encountered barriers in accessing online services. The submission noted that these groups are further impacted by issues of affordability (in terms of connectivity and equipment) as well as the uneven penetration of broadband across the country. While the submission agreed with the broad principle that services should be digital by default, it emphasised the need for an assisted or alternative route to services for those who cannot (or do not want to) access them digitally.
Digital
Strategy submissions .docx
Barely Getting By - Citizens Information Board highlights citizens; concerns ahead of Budget 2019
Publication date:September 2018
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, CIBs;Barely Getting By 2019; 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 2019; concerns ahead of
Budget 2019 .pdf .docx
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.
StatePension
Reform and TCA .docx
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.
MHCStrategic
Plan Survey Response .docx
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
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 .docx
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 .docx
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 SÃochána included dealing with illegal moneylenders, engaging marginalised and new communities and helping victims of abuse.
Future
of Policing in Ireland.pdf .docx