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.
Submission on Statutory Sick Pay Consultation (December 2020)
In a response submitted to the Department of Business consultation on the development of a Statutory Sick Pay scheme in Ireland, the Citizens Information Board highlighted its previous recommendations for a statutory scheme, most recently in the 2021 Pre Budget Submission which was based on the experience of information services in supporting people access income supports while ill and those who lost work or were sick during Covid-19. The consultation was focused on the appropriate minimum rate of payment, the duration the scheme should cover, eligibility requirements, waiting days, supports for employers and reintegration programmes for people recovering from illness. Issues were raised on the extent of SSP coverage, e.g., whether and how agency workers, casual workers, people working from home and self-employed people would be included as well as those on atypical work contracts and the need for an evaluation of the costs that a statutory scheme would place on employers, particularly micro, and small enterprises as well as the level of State supports required to make the statutory scheme operable.
Submission on Statutory Sick Pay Consultation (pdf) Submission on Statutory Sick Pay Consultation (Word doc)
Department of Children, Equality, Disability, Integration and Youth Strategy (November 2020)
The Submission identified principles which should underpin the Strategy of the reconfigured Department, as it takes on a lead role in cross-Government policy development relating to children and young people, equality, disability and integration which will require the Department to adopt a strong integrative role across a wide range of policy domains. This includes the need to address child and family poverty, to deliver specifically on the European Pillar of Social Rights and also to give a stronger voice in decision-making structures to children and young people, people with disabilities, lone parents with child-care responsibilities and ethnic minorities. CIB has in various submissions over the years regularly highlighted issues in relation to children and young people, people with disabilities, migrants and Travellers and other ethnic minorities.
Department of Children, Equality, Disability, Integration and Youth Strategy (pdf) Department of Children, Equality, Disability, Integration and Youth Strategy (Word doc)
Social Protection Strategy (October 2020)
The CIB submission to the Department of Social Protection (DSP) on the development of a new Strategy focused not only on income supports, but also on ensuring that the risks of people falling into poverty are minimised. The Submission noted that the Covid-19 pandemic has brought to the fore the vital role the State plays in providing basic services for its citizens and the importance of a strong welfare state for everyone in society. The submission made recommendations around the provision of adequate, and well-designed, social welfare interventions and the provision of safety net supports (and exceptional needs payments) for those impacted by a sudden loss of income. The submission also noted that while online and digital services have much merit as an alternative way of accessing information, personal records and making applications for services and benefits, this means of access should not be the only one.
Social Protection Strategy (pdf) Social Protection Strategy (Word doc)
Department of Rural and Community Development Strategy (October 2020)
Given the broad range of existing policy ambitions within this area, such as Action Plan for Rural Development the CIB submission noted that the new strategy needs to consolidate and enhance a number of these approaches and initiatives which have been to the forefront of policy on local development over a number of years. The submission makes particular reference to encouraging local communities to develop integrated ‘bottom-up’ approaches and also building community capacity by encouraging the development of untapped potential within communities. During the pandemic, the public health and economic shocks brought into sharp focus the important role of local communities in their own development. In order to mitigate adverse economic shocks into the future, there will need to be a strong strategic focus on building sustainable communities.
Department of Rural and Community Development Strategy (pdf) Department of Rural and Community Development Strategy (Word doc)
CIB Pre Budget Submission - September 2020
This year's Pre-Budget Submission, Leaving Nobody Behind: Protecting Citizens' Rights and Entitlements Post COVID-19 covers a wide range of issues informed by pre- and post-COVID-19 concerns raised by citizens in their queries to CIB delivery services. Policy issues identified by frontline staff during the course of processing queries and related case work provide an evidence base for the submission, which focuses on critical policy areas around alleviating poverty and helping people return to work. MABS concerns and recommendations relating to debt resolution, combating arrears and financial exclusion, drawing on lessons from the previous financial crisis are also addressed in the submission.
Leaving Nobody Behind: Protecting Citizens' Rights and Entitlements Post COVID-19 (pdf) Leaving Nobody Behind: Protecting Citizens' Rights and Entitlements Post COVID-19 (Word doc)
Remote Working (August 2020)
This CIB submission on the issue of guidance for employers and employees on remote working noted that the practices put in place during the pandemic will not be sufficient as home working (either full-time or part-time) becomes the norm for many employees. Given that much of the employment-related queries presented to CISs focus on employment rights and enforcement, the submission also emphasised that employment rights in general for all workers need to keep pace with atypical and different ways of working (including short-term and flexible work contracts) which are likely to be strongly replicated in the context of home working. While guidance for employers and employees on remote working is necessary, it will not deal with the need to ensure that employment protection legislation and related enforcement mechanisms are fully fit for purpose in the largely unexplored area of high numbers of people working from home.
Remote Working (pdf) Remote Working (Word doc)
CIB Submission to Oireachtas Committee on COVID-19 Response
Publication date: July 2020
This Submission by the Citizens Information Board (CIB) to the Special Oireachtas Committee on COVID-19 Response describes the range of initiatives taken by the Board and CIB supported services in response to the COVID-19 pandemic. It also identifies COVID-19 related matters that were raised by citizens in their queries to and contact with these services as well as issues relating to health and social care provision post Covid.
Citizens Information Board Submisson Special Committee on COVID-19 (pdf) Citizens Information Board Submisson Special Committee on COVID-19 (Word doc)
A Regulatory Framework for Adult Safeguarding
Publication date: May 2020
The Citizens Information Board (CIB) welcomed the opportunity to respond to this consultation by the Law Reform Commission on its Issues Paper, A Regulatory Framework for Adult Safeguarding. The Issues Paper, sets out the range of concerns that the Commission considered arise in the context of the reform of the statutory framework for the safeguarding of adults. Significant issues relating to adult safeguarding, particularly in residential and congregated settings emerged during the COVID-19 crisis, which underpin the need for a reformed framework.
Adult Safeguarding Submission LRC (pdf) Adult Safeguarding Submission LRC (Word doc)
National Minimum Wage NMW
Publication date: March 2020
This submission, in response to the Low Pay Commission’s consultation has a particular resonance in the context of the current COVID-19 crisis, which has seen the State intervene to bolster cliff-edge drops in income from employment for over a million workers. CISs deal with many queries from low income workers who have to supplement low pay with welfare supports. The CIB submission was based on the experience and feedback received from services on issues relating to particular clients who seek assistance with employment-related queries (this figure stood at over 70,000 queries in 2019) and focused on in-work poverty, the living wage and the role of work income in alleviating poverty.
National Minimum Wage Consultation March 2020 Minimum Wage Consultation March 2020
Publication date: March 2020
CIB made a submission to this Citizens Assembly consultation drawing on the feedback received from CIB delivery services on the broad range of issues relating to gender inequality, with a particular focus on work and caring responsibilities.. Feedback from CIB delivery services -- Citizens Information Services (CISs) the Citizens Information Phone Service (CIPS) and MABS points to the significant challenge many parents with children, particularly lone parents, face in taking up employment because of the poor availability and cost of child care. The current situation with the COVID-19 crisis has brought into sharp focus the key role that childcare plays in facilitating people to work.
Public Consultation Citizens' Assembly on Gender Equality 2020 Questionnaire
Submission on National Volunteering Strategy
Publication date: January 2020
CIB, having made a response last year to the initial development of the strategy, broadly welcomed the range of proposals as laid out in the Department of Rural and Community Development’s published draft Strategy - including the proposed multi-annual funding approach, public information and awareness programmes and plans for a National Survey on Volunteering. The CIB submission reiterated the need for more of a focus on key areas – the initiation of a Government-wide, integrated response to developing and enhancing volunteering as a core component of active citizenship and the ongoing requirement for a cross-departmental approach to the funding of services and initiatives where there is a strong volunteer component at either management or service delivery level. It also highlighted the need to locate the Volunteering Strategy firmly within the social inclusion context.
Consultation on National Volunteering Strategy 2020-2025 Consultation on National Volunteering Strategy 2020-2025
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
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
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
Evaluation of Community Banking and Local Provision of Banking and
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
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.
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).
Volunteering Strategy .docx
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.
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.
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
By - Citizens Information Board highlights citizens 2019; concerns ahead of
Budget 2019 .pdf .docx
State Pension reform proposals - Total Contributions Approach (September
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.
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.
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
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.
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.
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 SÃochÃ¡na included dealing with
illegal moneylenders, engaging marginalised and new communities and helping
victims of abuse.
of Policing in Ireland.pdf .docx