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

Pre Budget Submission (September 2021)

CIB’s Pre Budget Submission 2022, “Addressing Citizens’ Concerns on Adequacy of Income, Debt and Money Advice” highlights income adequacy issues that are reflected in the queries raised with our services by people who were particularly impacted by the Covid-19 pandemic or whose situations worsened significantly. The submission places a focus on individuals and families experiencing particular pressures and ‘pinch’ points. Issues are presented relating to income supports, housing, families and children, illness, disability and caring, older people, medical cards, and inclusive public services. Key recommendations include supports for part-time and casual working patterns for those on jobseekers’ payments and those transitioning from Covid-19 payments, supports for lone parents and qualified adults, and for people receiving disability, illness and caring payments. Recommendations relating to families and children highlight the need for universal childcare provision, improved activation and family-friendly employment policies, as well as supports for those experiencing domestic violence. MABS concerns relate to debt, combating arrears and financial exclusion and include the need for a broad-based financial inclusion strategy as well as specific reforms to Personal Insolvency legislation to improve access to Debt Relief Notices, the need for a non-commercial/public personal insolvency practitioner service, a Review of the Code of Conduct of Mortgage Arrears (CCMA) and in relation to housing debt - a national accommodation arrears management strategy, support for renters to clear accumulated Covid-19-related arrears, and new measures for older or retired renters.

Pre Budget Submission 2022 (pdf)pdf document icon

Pre Budget Submission 2022 (.docx) Word document icon

National Risk Assessment (September 2021)

In a response to the Government consultation on a National Risk Assessment process for Ireland, CIB identified specific risks within a broad range set out by the draft consultation document and submitted that the assessment should include a strong focus on social inclusion and citizen well-being based on the significant segments of the population that are particularly vulnerable to social, economic, environmental and technological risks. Of particular importance will be ensuring that groups at greatest risk of marginalisation, financial exclusion, energy poverty, those on low incomes and those who have weak social capital do not bear an unfair or over-burdensome share of the risk and that related structural inequalities are addressed in areas of housing, healthcare, and public service provision.

National Risk Assessment 2021/2022 Public Consultation (pdf)pdf document icon

National Risk Assessment 2021/2022 Public Consultation (.docx) Word document icon

Irish Human Rights and Equality Commission Strategy (August 2021)

CIB welcomed the invitation to contribute to IHREC’s deliberations on a new strategy. CIB supported services – Citizens Information Services (CISs), National Advocacy Service for People with Disabilities (NAS), Sign Language Interpreting Service (SLIS), Money Advice and Budgeting Services (MABS), National Traveller MABS – provide information, advice and advocacy on all aspects of public service provision across key domains, including social protection, housing, employment rights, justice, citizenship, consumer protection and financial inclusion and regularly engage with people who encounter difficulty securing their rights related to disability, age, ethnicity, gender, marital status, family status, and citizenship status. The CIB response highlighted specific rights that may not be well protected in practice in the case of individuals, including: socio economic and financial inclusion rights; right to adequate housing; acknowledgement of each person’s legal capacity, and affordability of care and support and a right to access appropriate health and social care services.

Invitation for Submissions - Irish Human Rights and Equality Commission Strategy Statement 2022-24 Consultation (pdf)pdf document icon

Invitation for Submissions - Irish Human Rights and Equality Commission Strategy Statement 2022-24 Consultation (.docx) Word document icon

National Action Plan against Racism for Ireland (July 2021)

In July, CIB made a submission to the Anti-Racism Committee’s Public Consultation on a new National Action Plan against Racism for Ireland. Citizens Information Services (CISs) are widely used by the migrant population and some 20% of clients, where country of origin is recorded, come from this population group. The observations made in this submission are based on the experience of CIB delivery services, including National Traveller MABS, and draw on previous CIB submissions related to migrant and Traveller and Roma integration strategies. The submission noted that the promotion of equality and inclusion for ethnic minorities is a named objective within many public policy strategies and there is a need for integrating actions across these policy areas. Key recommendations were made on data gathering, the enactment of the Criminal Justice (Hate Crime) Bill 2021 and the development of formalised and accessible mechanisms for reporting racism and racial abuse.

Developing a National Action Plan against Racism A Submission by the Citizens Information Board (July 2021) (pdf)pdf document icon

Developing a National Action Plan against Racism A Submission by the Citizens Information Board (July 2021) (.docx) Word document icon

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 citizensinformation.ie 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