There are a few issues over its rigour:
“It was never intended that ESA for those in the Work Related Activity Group (WRAG) should be paid for an unlimited period to people who, by definition, are expected to move towards the workplace with help and support.”
Who says so? This needs to be supported by a clear policy statement elsewhere
“Government intervention is required to help ensure that ESA is paid for a temporary period for those placed in the WRAG, thereby encouraging a return to work and stopping people being trapped on benefits for a lifetime”.
The WCA determines who is and who isn’t fit for work and the frequency with which an individual attends allows their return to work in line with their recovery. This does not cause them to be “trapped” (whatever that means) and there is therefore no justification to apply an arbitrary time limit other than simply to
a) Save money
b) Create a financial “back-stop” because the WCA is not working effectively.
Quote #3 – Policy Objectives
1. “To ensure that ESA is paid for a temporary period thereby creating a culture that does not allow people to stay permanently in the WRAG, that they are expected to move towards work or into the Support Group if there is deterioration in their functional impairment.”
This can be automatically achieved through an effectively managed WCA programme – see above.
2. “Simplification of the benefit system, better alignment of contributory ESA rules with contributory Jobseeker’s Allowance in the run up to the introduction of Universal Credit.”
There is no logic or sound basis for “aligning” ESA with JSA. Being ill is NOT the same as being jobless.
[As an aside for ESA aficionados, UNUM quite openly declare they believe that sickness and disability are both hidden forms of unemployment.]
3. “Reductions in social security spending to ensure that money is targeted on those most in need will help the UK's challenging fiscal position.”
Ah, so at last we have the real reason!
Quote #4 - What policy options have been considered? Please justify preferred option
1. “Do nothing.
2. Time limit contributory ESA for those in the WRAG to one year. “
Options around the coverage and length of the time limit were considered. One year was selected as the best balance between providing people claiming contributory ESA in the WRAG with enough support and reducing the cost of contributory ESA. It was decided to exclude customers in the ESA Support Group on the basis that they are the most severely disabled or terminally ill and therefore least likely to move into work.”
As you can see, there is no evidence-based information to support a 12 month limit, so it is completely arbitrary.
This section of the IA requires the preferred option to be justified. The paragraph above does not constitute justification. It does not, for example, explain why say 18 months is a poorer option.