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 2021

National Disability Housing Strategy (May 2021)

This submission to the Housing Agency on the development of a new Disability Housing Strategy identifies ongoing difficulties for people with disabilities, including a shortage of accessible accommodation for wheelchair users, the length of time on social housing waiting lists and the difficulties for people with disabilities aged under 65 years who are inappropriately placed in nursing homes. People with disabilities and their families seek assistance in CISs on general housing issues as well as more specific information and advice on housing supports, such as housing adaptation grants. The National Advocacy Service identifies housing difficulties experienced by people with disabilities on an ongoing basis, with 50% of advocacy cases related to housing and accommodation needs.

National Disability Housing Strategy - CIB Submission May 2020 (pdf)pdf document icon

National Disability Housing Strategy - CIB Submission May 2020 (.docx) Word document icon

Housing for All (May 2021)

CIB responded to a Stakeholder Consultation on the Housing for All Policy Statement and Action Plan coordinated by the Department of Housing, Local Government and Heritage. CISs deal with approximately 90,000 housing queries each year (63,000 in 2020, due to the closure of face-to-face services). The majority of these queries relate to access to social housing, Housing Assistance Payment (HAP) and private rented sector tenancies. Issues highlighted included experiences of affordability of rents and ongoing insecurity of tenure for those in the private rental sector. Actions proposed included further forms of rent regulation and rent certainty to combat the obvious difficulties arising from a free market approach and additional resourcing for the inspection of accommodation (private and public) provided under social housing policy.

Housing for All Strategy Questionnaire (pdf)pdf document icon

Housing for All Strategy Questionnaire (.docx) Word document icon

Well-Being Framework (May 2021)

The development of a national well-being framework for Ireland is a commitment in the 2020 Programme for Government. The National Economic and Social Council (NESC) was requested by the Department of the Taoiseach to support work towards developing a well-being framework which will be used across Government to inform policy-making, and complement existing tools for policy analysis. CIB in its response noted that well-being for many people is likely to be determined primarily by the difficulties associated with their life situation – low incomes, poverty, inadequate housing, indebtedness and a lack of access to appropriate services in a timely manner.

Well-Being Framework (pdf)pdf document icon

Well-Being Framework NESC Survey Response (.docx) Word document icon

Review of SUSI Grant Scheme (April 2021)

This review which was a commitment in the Programme for Government is examining a range of areas including eligibility criteria, the maintenance grant, the impact of increasing grant values and/or adjusting income thresholds and the impact and costs of widening supports to include part-time provision. The CIB submission made 16 recommendations based on the range of issues highlighted by services and included a series of case examples submitted by services in their social policy feedback. Key recommendations related to: concerns around eligibility criteria, including the lack of access to part-time courses and the ineligibility of courses in private colleges and in the PLC sector; the use of the ‘benefit and privilege’ rule for those aged under 24 years living at home; supports for part-time and post-graduate provision; the definition of an approved course, and the progression rule; and the need to revise income thresholds and maintenance grants.

SUSI-Grant-Review-Submission.pdf pdf document icon

SUSI-Grant-Review-Submission.docx Word document icon

UN Convention on the Rights of Persons with Disabilities (UNCRPD) – April 2021

The submission, in response to the consultation on the Initial Draft State Report on the UNCRPD, acknowledged a number of national strategies and initiatives that have been put in place in recent years - these include the National Disability Inclusion Strategy and the Comprehensive Employment Strategy for People with Disabilities. The CIB submission called for the full and immediate implementation of the Assisted Decision Making Act, in addition to the following measures: development of a comprehensive framework of adult safeguarding legislation, which includes health and social care services; provision for statutory entitlement to independent advocacy; enactment of Deprivation of Liberty legislation and statutory safeguards; provision of statutory entitlement to home care and strengthening of the regulation of health and social care services to include the regulation of home care; and tighter timelines for implementing Time to Move On.

UNCRPD-Initial-State-Report-042021.pdf pdf document icon

UNCRPD-Initial-State-Report-042021.docx Word document icon

Child Maintenance Review (March 2021)

CIB supported services frequently raise issues about income supports for lone parents and family-related matters, including access or guardianship rights, child maintenance issues and, specifically, difficulties around enforcing maintenance orders and problems with payment arrears. This consultation was concerned particularly with certain aspects of the treatment of maintenance by the Department of Social Protection. Our submission noted that the core issue for some parents is having to go through the courts system to secure child maintenance payments– which is the only option for many in cases where a maintenance agreement cannot be reached between the parents.

Child_Maintenance_Review_032021.pdf pdf document icon

Child_Maintenance_Review_032021.docx Word document icon

Sustainable State Pensions (March 2021)

In 2020, there were almost 726,000 page views on the website related to information for older and retired people – half a million of those related to state pension entitlements for older and retired people with 75% of this traffic specific to the contributory State Pension. CISs have handled almost a 1,000 queries a week relating to state pensions. The nature of queries to CISs and CIPS suggests strongly that there is a lack of knowledge and a high level of confusion among the public in relation to pensions. CIB’s submission to the new Pensions Commission consultation suggests that one of the main underlying principle of the state pensions system should be that people have eligibility for and entitlement to a contributory pension in their own right.

Citizens Information Board Submission to the Pensions Commission (pdf) pdf document icon Citizens Information Board Submission to the Pensions Commission (Word doc)Word document icon

National Minimum Wage (March 2021)

This submission to the Low Pay Commission on annual minimum wage rates highlights CIB’s delivery services experience engaging with people at the lower end of the household income spectrum between low-paid and precarious employment and social welfare benefits. The need to address the link between poverty, under-employment and low-income employment is highlighted along with the importance of debate on a living wage.

National Minimum Wage Submission to the Low Pay Commission (pdf) pdf document icon

Right to Disconnect (Jan 2021)

This submission to the Workplace Relations Commission (WRC) on the development of a new Code of Practice on the ‘right to disconnect’ addressed the need for clear guidance for both employees and employers to ensure awareness of requirements and entitlements under both existing legislation and any new provisions that may be introduced. A Code of Practice, apart from providing practical guidance, would clearly be important in the context of investigations by the WRC and the Labour Court relating to alleged breaches of employment law.

Consultation on Developing a Code of Practice on the ‘Right to Disconnect’ Submission to the Workplace Relations Commission by the Citizens Information Board (pdf) pdf document icon

Previous submissions