Submissions and Policy Recommendations 2015

Disability Inclusion Strategy

Publication Date: December 2015

CIB responded to a second phase of the Department of Justice and Equality consultation on a new National Disability Inclusion Strategy the purpose of which was to identify and agree specific objectives under each of the themes identified from the Phase 1 Consultation. CIB proposed the inclusion of two additional themes - active social inclusion and implementing a rights-based approach and suggested a number of additional objectives under the themes already listed.

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Irish Human Rights and Equality Commission Strategy

Publication Date: October 2015

This response to the consultation on formulating the first IHREC strategy focuses on promoting the relationship between rights and citizenship and on rights implementation as a core component of a strategy along with the need for independent advocacy for some rights to be realised. The submission highlights the rights of both individuals and specific population groups and minorities. In relation to the barriers to achieving human rights and equality, a reliance on discretion in respect of the provision of services can act as a significant barrier. The submission proposes a move from a focus on ‘vulnerable groups’ to a focus on shared citizenship and social solidarity and mechanisms to monitor the implementation of legislation and policy along with the availability of legal and other supports to ensure that people whose rights have been infringed have access to effective remedies.

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Draft Principles and Guidance for Public Consultation

Publication Date: October 2015

These guidelines propose to improve the way in which public bodies consult in order to foster greater citizen consultation and involvement in policy and service development. CIB has over the years highlighted the need for stronger consultation mechanisms in order to ensure that the views and perspectives of end-service users form an integral part of policies at planning and implementation stage. In this regard, our service delivery partners – the national network of Citizens Information Services (CIS), the Citizens Information Phone Service (CIPS), the Money Advice and Budgeting Service (MABS), the National Advocacy Service for People with Disabilities (NAS) and the Sign Language Interpreting Service (SLIS) – provide a rich source of data on citizens’ experiences of social services.

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Freedom of Information

Publication Date: September 2015

The Freedom of Information Model Publication Scheme sets out the various types of information that FOI bodies are required to publish. In a response to the Department of Public Expenditure and Reform consultation on the Scheme, the CIB submission suggests that the need for people to seek information under the FOI legislation is kept to a minimum, that the publication scheme is fully accessible, that there are provisions for people who communicate differently, e.g. people with a visual impairment and the Deaf community and that there are specific provisions for people who are unable to easily access information on-line.

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Aras Attracta Review Consultation

Publication Date: September 2015

This consultation undertaken by the independent Review Group focussed on the provision of services and the lives of adults with intellectual disabilities within the context of the current legislative and policy framework, the management and organisational culture of service providers – and the application of quality standards, governance and accountability and recruitment practices. The questions also sought responses in respect of actions that can be taken to afford people in residential settings dignity and respect, and to identify and prevent abuse and/or neglect. The CIB submission highlighted the policy options that, if fully implemented, could make a significant contribution to addressing some of the core issues that have been identified. These include the move from congregated settings, the individualised funding model and the National Housing Strategy for People with Disabilities. The National Advocacy Service also made a separate submission to the Review Group and both the NAS and CIB submissions stressed the importance of enhancing the role of independent advocacy services in residential care settings so that advocacy becomes an integral part of the service and support structure.

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Pre-budget Submission 2016

Publication Date: September 2015

The CIB Pre Budget Submission 2016 argues for a stronger policy focus on low income and financially vulnerable households. Despite the very welcome increase in the numbers at work and the reduction in unemployment, many households remain economically vulnerable, have complex debt problems and find it difficult to move out of social welfare dependency and to navigate the opportunities currently available to them under various activation programmes. The submission sets out key areas where reform is needed in order to continue the Government’s work to build a sustainable economy while, at the same time, meeting the need to provide quality public services and ensure that income support is commensurate with addressing poverty.

The Submission draws on feedback from CIB service delivery partners – Citizens Information Services (CISs), the Citizens Information Phone Service (CIPS), the Money Advice and Budgeting Service (MABS), the National Advocacy Service for People with Disabilities (NAS), National Traveller MABS and the Sign language Interpreting Service (SLIS). CISs and CIPS deal with over 770,000 callers and almost a million queries a year from members of the public and MABS supports over 40,000 indebted clients in its services and National Helpline.

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New Consumer Rights legislation

Publication Date: August 2015

The integration of various pieces of national and EU legislation and regulation currently governing consumer protection under a new Consumer Rights Bill is a welcome and positive development. Consumer-related issues feature in social policy-related feedback from CIB service delivery partners. CISs dealt with almost 24,000 consumer related queries in 2014 and MABS handle a range of consumer related issues in their debt advice work. CIB identifies key areas which need to be addressed in the final drafting of the legislation : the right of consumers to have accessible information, effective redress and complaints mechanisms and the need for further linkages to legislation in financial service areas and related Codes of Conduct.

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Employability Service Review

Publication Date: July 2015

These locally-based services operate through 23 individual companies nationwide, catering for some 2,700 people. The review undertaken by Indecon on behalf of the Department of Social Protection assesses the effectiveness and efficiency of the services, including the level and sustainability of the jobs secured. The CIB submission noted the main issues that were highlighted by service delivery partners whose clients had experience of Employability services. These included a lack of awareness of services locally, access issues, types of jobs and eligibility criteria and made a number of recommendations.

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National Travellers and Roma Inclusion Strategy

Publication Date: July 2015

This consultation on a revised National Traveller and Roma Inclusion Strategy is focusing on key areas such as anti-discrimination and anti-racism, cultural identity, accommodation, health, employment, education, family and children and political participation. CIB in a submission to the Department of Justice and Equality noted a number of dimensions of social inclusion which are particularly applicable to Traveller and Roma communities and need to be included in the revised National Traveller and Roma Inclusion Strategy. The submission also identified access to financial services as a key component in social inclusion and drew on the experience of National Traveller MABS in this regard. CIB is in the process of putting in place a mechanism to collect ethnicity-related data across service delivery partners.

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National Disability Inclusion Strategy

Publication Date: June 2015

A new National Disability Inclusion Strategy is being developed by the Department of Justice and Equality in conjunction with the National Disability Authority and the National Disability Strategy Implementation Group. The CIB submission focused on key aspects of social inclusion relating to income supports, the right to independent living and housing and accommodation needs, equal opportunities to work and the importance of mainstream employment support; access to social care, health services and individualised supports. More emphasis is required on the cost of disability and the impact of other measures, e.g., transport and mobility supports. The continuing need for integrated policy development was highlighted.

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Central Credit Register (MABS submission to Central Bank)

Publication Date: June 2015

MABSndl prepared a response to the Central Bank's Consultation Paper on a ‘Central Credit Register’ which is deemed to be an important reform within the financial sector that will contribute to financial stability and consumer protection. The CCR is intended to be a database of personal and credit information, that is to be created by means of a national mandatory credit reporting system being established by the Central Bank under the Credit Reporting Act 2013. Lenders will be obliged to provide personal and credit information relating to credit applications and credit agreements to the CCR, where the amount of the credit applied for is €500 or more and will also have to check the CCR when considering credit applications for an amount of €2,000 or more. The MABS submission highlighted the particular areas of importance for it’s clients with regard to the establishment of the Register. The submission recommended that the Register should be capable of being used constructively by consumers to reflect a payment history in respect of a wide range of debt types – and thus, enable consumers who have up-to-now being excluded from mainstream credit to build up a positive credit rating.

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Partial Capacity Benefit Review

Publication Date: May 2015

This review was initiated by the Department of Social Protection to consider the effectiveness of the scheme from the perspective of its 1,200 recipients and the review also sought to consult with potential applicants who have not engaged with the scheme. This is a new scheme with a small cohort of recipients. In taking account of the data and case evidence received from service delivery partners, the CIB submission highlighted the positive aspects of the scheme such as the fact that there is no requirement that the work a person does while on PCB has to be for rehabilitative or therapeutic purposes and that there is no restriction on earnings or number of hours a person can work. Some of the issues highlighted in respect of the scheme based on feedback related to insufficient information for applicants on how capacity is defined, assessed and measured; a fear amongst some potential applicants that this assessment could result in the withdrawal of an existing benefit, where the assessment deems the disability to be mild; and the timescale for processing applications can, in some cases, result in the loss of an employment opportunity. The qualifying payments for consideration for the scheme are also restricted.

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Universal Retirement Saving System

Publication Date: May 2015

CIB made a submission to the Department of Social Protection Universal Retirement Savings Group on the establishment of a new, universal, supplementary workplace retirement saving scheme. The scheme is to be “an employment based defined contribution scheme” which is intended to “progressively achieve universal pension coverage, with a particular focus on lower-paid workers”. In making the submission, CIB noted its view that a universal supplementary pension scheme is a desirable aim and that universal means applying to everyone – reflecting the view that voluntary schemes do not work. The submission also held that any scheme should be designed to ensure that it minimises work disincentives for people of working age and encourages work past the normal retirement age. The submission suggested that the State’s contribution to pensions should be equitable across all income groups and that there is a strong argument, on grounds of equity, that the State contribution to the State Pension itself and to any supplementary pension should be commensurate with its contribution to the occupational/private pension system and that the scheme should be implemented using existing mechanisms with contributions collected through the tax system and payments made through the social welfare system. Finally, the submission argued that the funds for a supplementary scheme should be retained under State control and that the National Treasury Management Agency would be the appropriate controller of these funds.

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Disability Act 2005 and National Disability Strategy Review (Submission to Oireachtas Joint Committee on Justice, Equality)

Publication Date: May 2015

The Oireachtas Joint Committee on Justice, Defence and Equality is reviewing the operation of the Disability Act 2005, ten years on from it’s introduction. The Act sets out the obligations on public service providers to work proactively towards the improvement of the quality of life of people with disabilities. The Committee is also considering the extent to which certain elements of the National Disability Strategy (which underpins government policy in the area) is being implemented. Drawing on the experiences of service delivery partners, (with a particular focus on the case evidence provided by NAS, the National Advocacy Service for People with Disabilities and SLIS the Sign Language interpreting Service) the CIB submission focused on a number of specific elements of the Disability Act - that is, the assessment of need, the provision of services by public bodies and the provision of accessible transport.

Disability Act 2005 and National Disability Strategy Review (Submission to Oireachtas Joint Committee on Justice, Equality May 2015).pdf pdf document icon .doc Word document icon

Local Property Tax

Publication Date: April 2015

In May 2015, the Citizens Information Board made a submission to the Department of Finance’s Review Group on the operation of the Local Property Tax (LPT). The review was established with particular regard ‘to the recent residential property price developments, the overall yield from LPT and its contribution to total tax revenue, and the desirability of achieving relative stability in LPT payments from liable persons’. The Department also intends that the review will make recommendations on the efficient and effective administration of the tax. The CIB submission noted that a key consideration of the review should be the ongoing pressures on low-income households (and the associated problem of household and personal indebtedness in Irish society), and also that every effort be made to eliminate the various administrative difficulties that the submission went on to identify from feedback from Citizens Information Services (CISs) and the national Citizens Information Phone Service. During 2014, Citizens Information Services dealt with over 10,000 queries in relation to the LPT and over 15,000 related queries in 2013. Concerns around the impact of LPT also featured significantly in social policy feedback from services since the introduction of the tax.

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Draft Information Governance and Management Standards for the Health Identifiers Operator

Publication Date: April 2015

The Citizens Information Board (CIB) welcomes the opportunity to comment on the Draft Information Governance and Management Standards for the Health Identifiers Operator. The consultation process is particularly important because of the fact that a Unique Identifier system for health and social care is being introduced for the first time in Ireland. The use of a Health Identifier system has the potential to provide more effective linkages between the primary and secondary health care domains and between the public and private sectors and should also eliminate the need for people using health and social care services to provide personal details at every contact with the system. The use of a Unique Health Identifier system for both individuals and service providers has the potential to facilitate better service and care planning for individuals. Given the wide range of 'health and social care' providers in the system further clarification is required as to how health and social care providers are to be defined and understood and which service providers are included.

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National Minimum Wage consultation - Low Pay Commission

Publication Date: April 2015

The CIB submission to the Low Wage Commission welcomes the focus on using an evidence-based approach to the setting of the minimum wage to achieve an appropriate balance between the needs of low income work-households, eliminating welfare to work traps, 'making work pay' and ensuring that employers can maintain the momentum in job creation. Ensuring that wages for those at the lower end of the scale are fully reflective of economic recovery is at the core of social inclusion and social recovery. The concept of a 'living wage' which has been gaining traction in Ireland, as well as in other jurisdictions, in recent years is important and should be actively considered. While cost of living factors are not directly the responsibility of the Low Pay Commission, they are centrally relevant to its deliberations on the minimum wage. This submission draws on feedback from Citizens Information Services who have significant interaction with low waged individuals and families and those interacting with the social welfare system and low paid work.

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Draft National Framework Policy for Local and Community Development

Publication Date: April 2015

CIB has in various submissions highlighted the need for a more integrated approach to local development. CIB service delivery partners -- the national network of Citizens Information Services (CISs), the Citizens Information Phone Service (CIPS), the Money Advice and Budgeting Service (MABS) and the National Advocacy Service for People with Disabilities (NAS) -- have significant engagement with individuals and local communities through their information, advice and advocacy roles. This submission highlights the need for a strong and effective voluntary/statutory partnership in order to develop and maintain active citizenship (including volunteering) as well as the need for a Framework Policy to be fully integrated with other government strategies and programmes, including, the social housing and the migration integration strategies and the range of work activation and community child-care programmes.

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Amalgamation of the Offices of the Financial Services Ombudsman and the Pensions Ombudsman

Publication Date: March 2015

The CIB favours the further development of alternative dispute resolutions mechanisms such as the Ombudsman offices and considers that the proposed amalgamation of these two offices provides an opportunity to create a user friendly integrated service. The proposed amalgamation has the potential to provide a better customer service and possibly a seamless and co-ordinated service to citizens who are aggrieved by the providers of financial services including pensions. A significant element of the work of the Pensions Ombudsman involves providing information to people who are unsure about the redress mechanisms that may be available to them. Complaints in relation to mortgages feature strongly in the FSO‘s workload. There needs to be more clarity in relation to the respective roles of the regulatory authorities (the Central Bank and the Pensions Authority), the Ombudsman offices and the Competition and Consumer Protection Commission in relation to consumer complaints.

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Competition and Consumer Protection Commission Strategy Statement Submission

Publication Date: February 2015

The amalgamation of the competition and consumer agencies should, as anticipated, provide a more cohesive approach to consumer protection generally. The three interrelated roles of the Commission -- advising Government and its agencies on the whole area of regulation; working with businesses in relation to enforcement and compliance; and empowering consumers to make better choices for themselves -- provides an important and necessary context for developing a stronger citizen-centred response to consumer protection. This Submission focuses primarily on the compliance and enforcement aspects of the Commission’s remit, the role of information in ensuring that people know their consumer rights and the gap between legislative protection for consumers and the ability of individual citizens to enforce their consumer rights generally and in relation to specific products/services.

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