Submissions and Policy Recommendations 2023

National Strategy for Migrant Integration (November 2023)

CIB made this submission in response to the Department of Children, Equality, Disability, Integration and Youth (DCEDIY) consultation on a new national strategy for migrant integration. The submission noted CIB’s strong and ongoing interest in the policy environment in relation to immigration, integration, and inclusion and highlighted the relatively high representation of migrants amongst the client base in CISs - in 2022, just over 20% of callers to CISs (where country of origin is noted) were recorded as being migrants. Using feedback received from services in their daily interactions with clients, the submission proposed that the new strategy include a necessary focus on access to public services, including housing, income support and healthcare – and highlighted the key role that information provision has in enabling access to such services for migrants. The submission also highlighted the need for a consistent approach to the collection of ethnicity related data by public service providers in order to inform policies and practices in the future.

Migrant Integration Strategy - Citizens Information Board Submission - November 2023 pdf document icon Migrant Integration Strategy - Citizens Information Board Submission - November 2023 Word document icon

National Counter Disinformation Strategy - October 2023

CIB welcomed the opportunity to respond to the government online consultation on preparing a national counter disinformation strategy and is committed to promoting systems and collaborative approaches (including with other statutory bodies) in countering misinformation and disinformation. CIB plays a pivotal role in providing independent information and is a trusted source of information acting as a formal intermediary in disseminating and interpreting information from various sources - public services, financial institutions, utility providers and information on legal rights and consumer rights. The submission focuses on an integrated approach to sharing best practice and aligning Irish policy and regulatory approaches with those of the EU. Read more...

National Counter Disinformation Strategy – Citizens Information Board Response October 2023 pdf document icon National Counter Disinformation Strategy - Citizens Information Board Response October 2023 Word document icon

Budget 2024 Outcomes (October 2023)

This document considers Budget 2024, in the context of CIB's Pre-Budget Submission. We assess the new measures that have been introduced against what we highlighted, and we also comment on related budgetary announcements in the lead up to and after the Budget. CIB's Pre-Budget Submission 2024 was informed by the concerns raised by citizens in their queries to CIB funded services - Citizens Information Services (CISs), Citizens Information Phone Service (CIPS), the Money Advice and Budgeting Service (MABS), and the National Advocacy Service for People with Disabilities (NAS). These services, when combined, deal with over half a million callers each year.

Budget 2024 Outcomes

Legal Aid Board Strategy 2024 - 2026 (September 2023)

CIB's submission was made in the context of our membership of the Legal Aid Board (LAB) External Consultative Panel and the work of CIB funded services. During 2022, CISs dealt with over 18,000 justice related queries - with the key focus of these being legal aid and advice - and also some 20,000 Birth, Family and Relationships queries. The majority of these related to issues such as separation and divorce, custody and access to children, maintenance and also domestic violence. CISs nationwide also host the Free Legal Advice Centre (FLAC) telephone clinics across the country and are involved in significant levels of referrals to these clinics, which are funded through a Citizens Information Board grant to FLAC. Priority areas suggested for consideration in the new strategy included - the provision of appropriate legal information and advice in addition to legal aid as part of an integrated legal aid infrastructure with the potential to prevent the escalation of matters (and associated costs) for individuals; the need for service provision to account for areas of civil law currently not provided including homelessness, housing, social welfare, employment, equality, discrimination, children's rights, and environmental issues and the promotion and wider use and availability of mediation, particularly in the context of family breakdown.

LegalAid Board Strategy CIB Submission September 2023 pdf document icon Legal Aid Board Strategy CIB Submission September 2023Word document icon

'Budget 2024 Priorities - Income Adequacy, Housing, Public and Social Services and Financial inclusion Measures' - CIB Pre Budget Submission (August 2023)

This submission reflects the concerns emerging from the query trends and feedback from the CIB network of services providing information, advocacy, money advice and debt management supports across the country. Citizens Information Services (CISs) saw an increase in demand from the public in 2022 as over half a million people contacted these services with almost a million information and advice queries. A significant number of callers are from low income working households or are dependent on social welfare, with an average of 44% of all queries relating to social welfare over the past few years. Evidence from services indicates that some clients are facing financial hardship and insecurity where income levels are not adequate to pay for high housing costs, food, and energy prices. CIB services encounter the multi-faceted difficulties faced by clients, where inadequate incomes and rising costs, are combining with problems in accessing public services pushing people into more precarious situations. MABS highlights the unprecedented level and scope of utilities’ arrears that they are seeing and the impact of increasing mortgaged interest rates on their clients. NAS concerns relating to people with disabilities and the cost of disability are reflected. Budget priorities on income adequacy, meeting costs of living, housing supports, and health services are outlined with considerations for policy change. MABS recommendations relate to targeted housing supports, mortgage debt, cost of living, and financial exclusion.

CIB Pre Budget Submission 2024 pdf document icon CIB Pre Budget Submission 2024 Word document icon

Private Residential Rental Sector Review (August 2023)

This submission to the government review of the Private Residential Rental Sector is informed by the findings of CIB joint research on ‘renting and risk’ in the private rented sector. The review is concerned with what a ‘fully functioning sector should look like in the long term to provide an affordable, secure, viable framework for tenant and landlord’. Our submission draws on the feedback of CIB supported services (Citizens Information Services, MABS, NAS) who have considerable insight into the operation of the private rental sector and into the problems that private renters experience. CISs dealt with over 75,000 housing related queries in 2022. Read more….

Private Residential Rental Sector Review (August 2023) pdf document icon Private Residential Rental Sector Review (August 2023) Word document icon

Wage Subsidy Scheme Review (July 2023)

CIB made a submission to the Department of Social Protection in relation to their public consultation on the Wage Subsidy Scheme (WSS), which gives financial incentives in the form of a wage subsidy to private sector employers to employ people with a disability. The review sought insights on the extent to which the WSS is incentivising employers to employ people with disabilities and enabling disabled employees to become more self-sufficient in the labour market. CIB-funded services regularly highlight barriers and difficulties that people with disabilities continue to face in accessing and in retaining work. The submission noted the positive aspects of the scheme as well as a range of limitations that may be impacting the take-up of the scheme including the fact that the rate of the subsidy is not linked to the National Minimum Wage. Read more on the issues raised….

Wage Subsidy Scheme Review (July 2023) pdf document icon Wage Subsidy Scheme Review (July 2023) Word document icon

Social Welfare Appeals Regulations (May 2023)

The Citizens Information Board (CIB) responded to the Department of Social Protection (DSP) consultation on the proposed Social Welfare (Appeals) Regulations 2023. The submission is based on feedback by individual Citizens Information Services (CISs), and Advocacy Support Workers on their experience in assisting people to negotiate the social welfare appeals process and advocating for clients with appeals, as well as a review of the database evidence recorded on social welfare appeals cases. In 2022, CISs dealt with over 371,000 social welfare related queries and 5,000 specific appeals related queries. Two-thirds of these appeal queries related to three payments, Disability Allowance (33%) Carer’s Allowance (18%) and Invalidity Pension (14%). The number of appeals, and, in particular, the extent to which appeals are upheld by the Social welfare Appeals Office, suggests the need to focus on the level of first-instance decision-making. The reforms proposed in the regulations are welcome. Read more…..

Social Welfare (Appeals) Regulations 2023 (May 2023) pdf document icon Social Welfare (Appeals) Regulations 2023 (May 2023) Word document icon

Family, Care and Gender – Constitutional Referendum Consultation (May 2023)

The Citizens Information Board (CIB) welcomes the opportunity to respond to the public consultation by the Department of Children, Equality, Disability, Integration and Youth on amending Articles 40 and 41 of the Constitution. This follows from the recommendations of the Citizens Assembly to amend the Constitution and, particularly, the recommendation to replace Article 41.2 with wording that is not gender specific, that recognises the societal value of care in both the home and in the wider community and obliges the State to take reasonable measures to support carers. CIB is of the view that the focus in public policy on the need for constitutional reform should not in any way detract from the need to proactively implement current policies as well as introducing reforms allowable under current constitutional and legislative provisions. Constitutional change as proposed should also serve to focus attention on the rights of people being cared for, in particular, to receive care in accordance with assessed needs. Read more…..

Family, Care and Gender – Constitutional Referendum Consultation (May 2023) pdf document icon Family, Care and Gender – Constitutional Referendum Consultation (May 2023) Word document icon

Housing Commission consultation on housing policy (April 2023)

This CIB submission to the Housing Commission on long-term housing policy is based on the significant amount of housing-related data received by CIB from delivery services. The central elements of the submission focussed on the specific concerns from services that relate to accessing social and affordable housing. The submission notes the primary need for an enhanced state-funded social housing sector which has the potential to lessen the pressures that exist across all parts of the private housing sector, thereby increasing accessibility and affordability for all.

Housing Commission consultation on housing policy (April 2023) pdf document icon Housing Commission consultation on housing policy (April 2023) Word document icon

Personal Taxation System (April 2023)

CIB has made a submission to the Department of Finance in relation to their consultation on the personal taxation system in Ireland. This submission was based on the feedback received from delivery services in relation to tax matters as they arise in their dealings with clients and it builds on some of the elements articulated in CIB’s submission to the Commission on Taxation and Welfare in January 2022. In this context, it noted the importance of linking taxation policy with welfare policy and of ensuring that work pays and, specifically that households that are reliant on social welfare (either on a combination of income from work and social welfare) are kept out of poverty.

Personal Taxation System (April 2023) pdf document icon Personal Taxation System (April 2023)

Pathways to Work 2021 – 2025: Mid-term Review (March 2023)

CIB has made a submission to the mid-term review of the Pathways to Work 2021-2025 Strategy, which lays out the Government’s national employment services strategy. The CIB submission highlighted the extent to which CISs are frequently contacted by people seeking information about eligibility criteria for the range of activation supports available and about what options would be most appropriate for them - including how best to combine social welfare payments and participation in work/training programmes. While acknowledging the significant progress in the delivery of the goals set out in the Strategy up to this point, the submission used the feedback from delivery services to point to key areas of focus for the remainder of the strategy.

Pathways to Work 2021 – 2025: Mid-term Review (March 2023) pdf document icon Pathways to Work 2021 – 2025: Mid-term Review (March 2023) Word document icon

Strawman Proposal on Pay-Related Jobseeker’s Benefit Scheme (February 2023)

This submission to the Department of Social Protection sets out CIBs response to the ‘strawman’ consultation paper on Pay Related Jobseeker’s Benefit, which lays out the broad parameters of one potential approach in designing a Pay Related Benefit scheme. Pay-Related Benefit is common in European countries and links a person’s previous earnings and work history to their jobseeker’s payment. The CIB submission was based on the feedback from delivery services in the 30,000-plus unemployment-related queries submitted during 2022. In welcoming the proposed reforms and the extension of the concepts of social protection and the contributory principle, the submission looked at the rationale for such a scheme and also at issues such as coverage, qualifying conditions, level and duration. It went on to highlight that these specific reforms can only be effective within the context of the provision of a broader range of integrated measures and services that will help jobseekers to cope with a sudden loss of income, while also navigating a return to work and, crucially, accessing the public services that they require.

Strawman Proposal on Pay-Related Jobseeker’s Benefit Scheme (February 2023) pdf document icon Strawman Proposal on Pay-Related Jobseeker’s Benefit Scheme (February 2023) Word document icon

Civil Legal Aid Scheme Review (February 2023)

Enabling access to justice and related legal services continues to be a core element of the work of CIB-funded services—the Citizens Information Services (CISs), the Citizens Information Phone Service (CIPS), the Money Advice and Budgeting Service (MABS) and the National Advocacy Service (NAS) for people with disabilities. CIB has contributed to the funding of the Free Legal Advice Centres (FLAC) to provide information and advice clinics on legal matters in CISs and is a member of the Consultative Panel of the Legal Aid Board (LAB). In addition, CIB collaborates with LAB and the Insolvency Service of Ireland (ISI) in the operation of Abhaile, the national mortgage arrears resolution service. In 2022, CISs dealt with over 18,000 justice related queries, with the key focus of these being legal aid and advice. Services also assisted clients with around 20,000 queries relating to family relationships and covering issues such as separation and divorce, custody and access to children, maintenance, problems with relationships and domestic violence. Services also dealt with 39,000 employment rights queries and made almost 10,000 referrals to legal services, clinics, or mediation services during 2022. Issues identified in our submission include - complex eligibility rules and out-of-date income thresholds (unchanged since 2006), long waiting times, which can aggravate problems and dishearten applicants; and lack of awareness of alternative dispute resolution mechanisms such as independent advocacy and mediation. The need to benchmark income assessment to the living wage is one of the recommendations in the submission. Read more….

Civil Legal Aid Scheme Review (February 2023) pdf document icon Civil Legal Aid Scheme Review (February 2023) Word document icon

Department of Social Protection (DSP) Strategy 2023-2026 (February 2023)

CIB has made a submission to the Department of Social Protection (DSP) in response to an invitation to contribute to the development of its new Statement of Strategy for 2023-2026. The submission acknowledged the important role that CIB has in supporting and supplementing the work of the Department - by informing, enabling and facilitating people to access and benefit from DSP supports. Issues encountered by the public relating to income supports, social protection, access to housing, indebtedness, poverty traps and pathways to work received by CIB in feedback from our funded services provide a useful benchmark for considering the adequacy of existing policies in many of the areas which fall within the remit of the DSP. The submission uses this feedback to inform our response to the Department's consultation on its new Strategy for the next three years.

Department of Social Protection (DSP) Strategy 2023-2026 (February 2023 pdf document icon Department of Social Protection (DSP) Strategy 2023-2026 (February 2023 Word document icon