Submissions and Policy Recommendations 2017

Personalised budgets for people with disabilities

Publication Date: December 2017

CIB responded to a Department of Health consultation on plans for the introduction of a system of personalised budgets in Ireland, with an initial focus on HSE funded services. The submission outlines issues relating to the likely use of budgets by individuals, the advantages and challenges of such an approach to service provision, and the supports and planning necessary for people with disabilities to effectively use this model.

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Returning Emigrants

Publication Date: October 2017

The CIB noted in its submission to the Department of Foreign Affairs and Trade consultation that many of the concerns of returning emigrants were common to that of the general population – for instance, the availability and cost of housing, access to schools and childcare, and access to public health services. The submission also addressed the specific administrative difficulties for this cohort that have been evidenced in feedback from information services during the past number of years. These include regaining their Irish driving licence, accessing affordable motor insurance (in the context of benefitting from claims-free driving while living abroad), returning to live with a non-EEA spouse or civil partner (who has no automatic entitlement under Irish law to join them in Ireland) and awareness and clarity around the Habitual Residence Condition when applying for social welfare benefits. The submission also noted that the need for integrated information is particularly important because of the fragmentation of the service delivery system and the diversity of the returning emigrant population.

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ComReg Review of Non-Geographic Numbers (NGNs)

Publication Date: October 2017

In October 2017, CIB made a submission to a ComReg review of “Non-Geographic Number” (NGN) - namely 1800, 1850, 1890, 0818 and 076 telephone numbers. ComReg preliminary research findings had suggested that the NGN platform was not working effectively for either the consumer or for the organisations using NGNs to provide services. The CIB submission noted that the overall experience within CIB delivery services was broadly similar to ComReg’s initial research – that service user attitudes to these numbers are negative and that the lack of transparency around costs seems to discourage the use of NGN numbers. The submission also drew attention to people on low incomes and those experiencing indebtedness who are particularly vulnerable when trying to access public services by telephone.

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Home Care Services

Publication Date: September 2017

This response to a Department of Health consultation on Home Care services highlights the challenges reported by people with disabilities and older people in getting the supports they need to live at home. The submission identifies the positive aspects of home care provision which enables older people with care needs to remain living at home, where that is their preferred option and allows families to continue caring for their relatives with a disability who have complex care and support needs. Also home care supports gives care recipients and their families a greater say regarding the source and types of care services used. The submission notes that linkages between hospitals and community health services are underdeveloped and that the absence of legislative entitlement and inadequate resources can result in carers feeling overwhelmed by their caring role.

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Pre-budget Submission 2018

Publication Date: September 2017

The 2018 CIB Pre Budget Submission “Supporting People in Transition” is based on feedback from CIB’s delivery 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). The submission focusses on transitions with a particular emphasis on the issues that are reported by staff within delivery services as they seek to assist their clients who, typically, will be looking for information, advice or advocacy at key transition times in their lives. The main shifts or transitions in peoples’ lives or circumstances are identified as becoming unemployed and moving from welfare to work, retiring or ageing, and becoming ill or acquiring a disability, or taking on a caring role. The submission also looks at the underlying issue of housing in the context of these transitions, and at how finding or keeping a home is a key concern for CIS and MABS clients as well as issues of income adequacy and access to credit.

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Rebuilding Ireland Review

Publication Date: August 2017

Citizens Information Services (CISs) and the Citizens Information Phone Service (CIPS) supported by the CIB deal with queries relating to housing difficulties, including social housing needs, tenancies in the private rental sector and those at risk of homelessness. These services responded to over 100,000 housing related queries in 2016. The submission also draws on the experience of MABS in dealing with people in mortgage arrears. Issues highlighted include inadequate social housing provision generally, unaffordable rents in the private sector and the need for further measures to address concerns about security of tenure.

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Citizens Assembly: Responding to the challenges and opportunities of an ageing population

Publication Date: May 2017

Around 14% of Citizens Information Service (CIS) clients are 66 years or over representing almost 90,000 people. The response to the challenges and opportunities of ageing needs to be twofold – firstly, by facilitating and enabling the many older people who can, and wish, to continue to make a positive contribution to society (through work, creative civic engagement and learning) and, secondly, by ensuring that people who do require support and care get the services they require in a timely manner and in accordance with their will and preferences. The feedback received from information services points to a particular emphasis on housing, income supports and long-term care needs – with some of the commonly reported issues noted as the lack of availability of supported housing, poor public transport links, the erosion of certain community and social supports, delays in getting housing adaptations and specialised equipment, the ongoing digitalisation of public services and also a number of limitations on the Nursing Home Support Scheme.

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Consultation on the Comprehensive Employment Strategy for people with disabilities

Publication Date: May 2017

CIB although not directly engaged in employment support activities, is very much aware of the challenges and difficulties faced by people with disabilities in accessing and retaining employment through the work of CISs and NAS, the National Advocacy Service for people with disabilities which is supported by CIB . A significant component of queries to services by or on behalf of people with disabilities relate to disability income supports and welfare dependency. The submission focussed on the particular elements of the model put forward in the Strategy to support people with disabilities to access and retain employment – namely, co-ordinated and effective pre-activation, the provision of supports to find and keep employment and the establishment of effective protocols for co-operation between Departments and Agencies.

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Personal Insolvency and Debt Relief

Publication Date: May 2017

In May 2017, MABS made a submission to the Insolvency Service of Ireland as a member of its Consultative Forum on the operation of the Personal Insolvency Act. The particular focus of the submission was on the experiences of MABS clients in relation to the Debt Relief Notice (DRN) process. The submission argues for the need to ensure that the legislation works more effectively for low income borrowers and noted three main concerns in this regard: - that no one should be deemed “too poor” to avail of insolvency, that insolvency must facilitate write-off of mortgage debt and that the concept of “excludable debt” means that some low income borrowers are not returned to solvency by virtue of the arrangements. The submission makes a number of recommendations in relation to eligibility, debtors’ obligations and the debt relief notice process itself.

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Assisted Decision Making (Capacity) Act – Guidance for Health and Social Care Professionals

Publication Date: April 2017

The Assisted Decision Making (Capacity) Act 2015 was signed into law on 30th December 2015 but has yet to be commenced. The Act provides a statutory framework for people to be assisted and supported in making decisions about their welfare, their property and their affairs, with legally recognised supports wherever possible. These supports are particularly required where the person lacks the capacity to make the decision unaided. The HSE developed draft guidance to support staff in health and social care organisations to understand the implications and practice of the new legislation practice and sought views and feedback on this. CIB in its response identified a need for further guidance on who can act as an independent advocate and how access to an independent advocate is to be triggered.

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Mortgage market review

Publication Date: March 2017

A MABS submission on the future of the Irish mortgage market was submitted through CIB to the Competition and Consumer Protection Commission (CCPC). The submission draws on MABS role in supporting late stage arrears mortgage clients and laid out concerns in a number of key areas - namely, the regulatory environment, lending criteria, the information that is available to lenders, mortgage switching, the role of Independent Financial Advisers and the role of Credit Unions in mortgage lending.

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Working Family Payment

Publication Date: March 2017

In response to plans to develop a Working Family Payment - a Programme for Government commitment - CIB highlighted the following: integrating a working family payment into the overall welfare and taxation system, the need to link the payment with minimum wage and living wage considerations and the need to cater for part-time, casual and atypical working. Wider considerations include the risk factors for in-work poverty and the need to examine in greater detail issues which impact on people’s capacity to move from welfare to work. Citizens Information Services dealt with over 60,000 jobseeker payment queries in 2016, almost 27,000 FIS queries and a further 15,000 activation scheme queries.

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EU Insolvency Directive proposal

Publication Date: January 2017

This MABS submission is in response to a consultation on a proposed EU directive on insolvency, debt and restructuring and draws on MABS experience working with self-employed people. The directive aims to harmonise the main provisions of national laws and frameworks across Member States in the area of business insolvency. It covers both company debts, and the debts of an over-indebted person who is (or was) carrying on a trade or business with an option to extend the proposal’s application to over-indebted persons with non-business debts. The submission notes that early intervention is key to addressing problem debt and suggests the need for the proposal to extend preventative restructuring procedures beyond entrepreneurs to allow for the same requirements for individuals.

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