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 2022

Roadmap for Social Inclusion: Mid-Term Review (October 2022)

CIB made this submission to the Mid-Term Review of the Roadmap for Social Inclusion 2020-2025. The submission is informed by the experience of, and feedback from, CIB-funded services. These services have a significant engagement with individuals and households experiencing social exclusion or poverty in one form or another. These include welfare dependent households, people in low-income and precarious employment, people who experience difficulties in transitioning from welfare to work, over-indebted families, people with disabilities and older people who require long-term care and support. The review is welcome in the context of current inflationary and energy costs pressures, and it is hoped that it will provide new impetus for implementing the Roadmap aims across the various relevant domains – income, housing, health services, education and energy.

Social Inclusion Roadmap – Mid Term Review Submission (pdf)pdf document icon

Pre-Budget Submission (September 2022)

CIB’s Pre-Budget Submission 2023, ‘Caught in a bind’: Targeted Supports Needed to Alleviate Cost of Living Pressures on Citizens’, draws from the concerns raised by citizens with our funded services (Citizens Information and the Money Advice and Budgeting Service (MABS)). The evidence continues to demonstrate the pressures people are facing with the costs of living as well as their experiences of being ‘caught in a bind’ between eligibility requirements for a range of schemes involving different means tests, income thresholds, and disregards combined with increasing rents, energy, and food prices. Budget priorities relating to housing supports, energy costs, income adequacy, financial inclusion, and mortgage debt are outlined with targeted measures and more flexible welfare supports proposed for consideration.

Pre-Budget Submission 2023 (pdf)pdf document icon Pre-Budget Submission 2023 (.doc)Word document icon

Referendum on housing (September 2022)

CIB made this submission to the Housing Commission’s public consultation on a referendum on housing. It draws on the feedback from CISs, CIPS, MABS and NAS to evidence the concerns and challenges experienced by clients in trying to access suitable, affordable, quality housing. Much of this feedback reflects the concerns of clients who are experiencing particular difficulties in accessing housing – those working on low income, people on social welfare, lone parents, generations of families living in overcrowded homes, older renters, people with disabilities, Travellers, single adults, and separated parents sharing custody of their children. The submission restates the CIB view that housing policy needs to be developed in a human rights framework within which people’s right to adequate housing is regarded as a core component of citizenship and social inclusion.

Referendum on housing submission 2022 (pdf)pdf document icon Referendum on housing submission 2022 (.doc)Word document icon

Model for health information standards (August 2022)

CIB made this submission in response to the draft recommendations prepared by HIQA on a modal for health information standards. The submission welcomed the opportunity to comment and highlighted how the development of health information standards would be a significant move towards a more integrated and accessible health and social care system and centrally relevant to the implementation of Sláintecare.

CIB response to consultation on health information standards model 2022 (pdf)pdf document icon Health information standards submission 2022 (.doc)Word document icon

Review of Freedom of Information Act (August 2022)

CIB made this submission to the latest phase in the ongoing review of the Freedom of Information Act by the Department of Public Expenditure and Reform. The submission highlighted how CIB - through our delivery services and our core activities - is acutely aware of the necessity of developing and facilitating public access to government and state body-held information in a manner that is effective, clearly structured and timely.

Review of Freedom of Information Act 2022 (pdf) pdf document icon Review of Freedom of Information Act 2022 (.doc)Word document icon

Draft Regulations for Providers of Home Support Services (August 2022)

This submission outlines CIB’s views on the draft regulations for home care providers as presented by the Department of Health, which set out the minimum requirements that public, private, and not-for-profit providers of home support services will be required to meet to obtain a license to operate. The submission highlighted that personalised care provision must be at the core of the regulatory system and that the regulations should focus on outcomes, as well as on processes, and that the focus remains on ensuring that everyone gets the best possible quality of care both currently and as their care needs change.

Home care regulation online pdf submission 2022 (pdf) pdf document icon Home care services regulation submission 2022 (.doc)Word document icon

Legal Services Regulatory Authority Strategic Plan (August 2022)

The Citizens Information Board (CIB) took the opportunity to respond to this survey from the Legal Services Regulatory Authority in the context of providing input to their Strategic Plan 2023 - 2025. Access to justice and legal services is a core element of the work that CIB delivery services provides to clients. Each year, CISs and MABS deal with between 80,000 and 100,000 justice and legal queries from clients attending their services, and the feedback indicates that access to justice in a timely and cost-effective manner is a key issue. The planned reforms within the Irish legal landscape in the coming years will provide a unique opportunity to improve access, modernise the courts system and open up professional legal education. Anticipating these changes, and maximising the leverage that the Authority has within the context of the reforms, will be a key challenge during the lifetime of this Strategy.

Legal Services Regulatory Authority Strategic Plan 2022 (pdf) pdf document icon Legal Services Regulatory Authority Strategic Plan Submission 2022 (.doc)Word document icon

Living Wage (Phase in) Submission (July 2022)

This submission provides the CIB response to the Department of Enterprise, Trade and Employment public consultation on the phasing in of a living wage, as committed to in the 2020 Programme for Government. The feedback that CIB receives from our funded delivery services indicates the extent of the problems faced by people who are in low-wage employment. The submission argues for the adoption of the Living Wage as a necessary component in addressing the link between poverty, under-employment, and low-income employment, in eliminating welfare-to-work traps and the need to “make work pay”.

Living Wage (Phase in) Consultation 2022 (pdf) pdf document icon Living Wage (Phase in) Submission 2022 (.doc)Word document icon

Consultation on ICT enablement of older persons services – submission to HIQA (May 2022)

CIB submitted a response to the HIQA paper on draft recommendations on ICT enablement of older persons’ services in Ireland. This consultation is intended to ensure that an older person’s health information (that is, information relating to patient identification, medical history, medication, referrals, discharges and assessed health and social care needs) can be shared safely and effectively across all health and social care settings and to address the needs of the healthcare professionals involved, while placing the older person at the centre of care.

Consultation on ICT enablement of Older Persons' Services Submission 2022 (pdf)pdf document icon Consultation on ICT enablement of Older Persons' Services Submission 2022 (.doc)Word document icon

Reasonable Accommodation Fund Grants review (April 2022)

The Citizens Information Board (CIB) welcomes the opportunity to contribute to the Department of Social Protection’s review of the Reasonable Accommodation Fund (RAF). Capturing the experience and perspectives of people with disabilities on seeking, getting and retaining employment is vital as well as an employer’s view on utilising these funds. The provision of grant aid for reasonable accommodation measures is an important element in a combination of state supports that can assist people with disabilities to gain and retain access to the open labour market, as well as encouraging and supporting private sector employers in the employment of people with disabilities – it is important that it aligns with the various measures under the Comprehensive Employment Strategy for People with Disabilities.

Reasonable Accommodation Fund Grants review submission 2022 (pdf)pdf document icon Reasonable Accommodation Fund Grants review submission 2022 (.doc)Word document icon

National Minimum Wage Submission (March 2022)

This CIB submission is in response to the Low Pay Commission's consultation on the National Minimum Wage (NMW) and draws on evidence from CISs and MABS on the problems faced by people who find themselves located between low-paid/precarious employment and social welfare benefits. The submission indicates the need to ensure that the setting of the NMW is viewed as one part of a joined-up set of instruments - that also include social supports, taxation measures, and social welfare transfers aimed at securing a basic, decent living standard for all working households.

National Minimum Wage Submission 2022 (pdf)pdf document icon National Minimum Wage Submission 2022 (.docx) Word document icon

Assisted Decision-Making Codes of Practice (February 2022)

CIB made a submission to the Decision Support Service (DSS) in relation to a number of draft codes of practice for roles to be introduced under the new assisted decision making legislation, including a code for independent advocates which provides guidance to advocates on how to engage, interact with and advise people with decision-making capacity challenges under the ADMC Act. The CIB feedback noted that there is a need for this code and all others to include clear and accessible pathways and information about the roles of the various decision supporters and how they differ from each other.

Submission on the Code of Practice for Independent Advocates (pdf)pdf document icon National Minimum Wage Submission 2022 (.docx) Word document icon

Commission on Taxation and Welfare (January 2022)

A CIB submission in response to the Commission on Taxation and Welfare's (CoTW) consultation on the future of the taxation and welfare systems. This CoTW questionnaire focuses on the elements of these systems that are working well or are not working and the main reforms considered necessary so that the Irish taxation and welfare systems can meet the challenges over the next 10-15 years. A key concern is to ensure the system is sustainable and resilient with sufficient resources available to meet the costs of public services in the medium and longer term.

Public Consultation of the Commission on Taxation and Welfare (pdf)pdf document icon Public Consultation of the Commission on Taxation and Welfare (.docx) Word document icon

Previous submissions