Submission re Green Paper on Disability Reform by ME Advocates Ireland (MEAI)

New Submission Deadline - 31st July 2024

Green Paper on Disability Reform

The Minister for Social Protection in Ireland announced proposed radical welfare ouverhaul with the publication of the Government's Green Paper in September 2023. The Disability Green Paper is available to download and view under the heading 'Documents' on the Government page via this link.

Summary of Green Paper Proposals 

(see link to Easy Read further below)

There are three proposals included in this Green Paper:

1.The introduction of a new single scheme, the Personal Support Payment. This section introduces the key principles of the scheme which has three tiers. It sets out how the three tiers and the different payment rates of this new system would work.

People who are placed in tier 3 (moderate to high capacity to work) will be provided with more employment supports than people in the other two tiers. They will be required to take up training and employment offers that correspond to their capacity to work.

Payment durations will be established and linked to the anticipated duration of the person’s disability in tiers 2 and 3.

2. For people who work, a new Working Age Payment model will replace the current fragmented system of employment supports. Currently, people on a disability payment can either avail of an earnings disregard (Disability Allowance and Blind Pension), or can transfer to Partial Capacity Benefit (if they are in receipt of Invalidity Pension). This results in major differences between how mucha person can work and earn.

3. To raise the age of entry of Disability Allowance to 18 years of age and extend the payment of Domiciliary Care Allowance to 18 at the same time.

The existing Disability Allowance, Invalidity Pension and Blind Pension payments will be replaced with a new contributory and non-contributory Personal Support Payment. As with the State Pension, people will qualify for payment either based on contributory social insurance basis (funded by the social insurance fund) or on a non-contributory, means tested basis (funded by the Exchequer) Tiered approach of the Personal Support Payment Rather than assessing a person’s capacity to work on a two-option basis –that is, that a person is either fully capable or fully incapable of work –a tiered approach will be taken. 

This will reflect the levels of disability and capacity so that a person who qualifies for a Personal Support Payment will be assigned to one of three broad categories based on their capacity to take up work and the level of support they need.

The level assigned could be one of the following:

Level 1: High support –Very low capacity to work The person has a high level of incapacity and low capacity to work. This means they are very unlikely to be able to take up any kind of paid employment for as long as their condition persists and for at least 2 years.

Level 2: Medium support –Low to moderate capacity to work The person is assessed as having a disability that is expected to limit their capacity to work for at least 24 months. However, they may be capable of undertaking some types of work and durations of work –for example, part-time as opposed to full-time –but are not likely to be able to fully support themselves through paid employment alone for as long as their condition persists.

Level 3: Low support –Moderate to high capacity to work The person is assessed as having a disability that is expected to persist for at least 24 months. This means that they cannot do certain types of work activity (including the type of work they were doing before acquiring their disability). However, they may still be capable of taking up other forms of employment and to do many types of work activity. This makes it a realistic option for them to progress towards sustaining themselves through paid employment alone.

The Personal Support Payment rate will then be set at three levels based on this categorisation:

• Level 1: The payment rate will be aligned with the State Pension (Contributory) rate of payment. (This rate is currently € 265.30a week.)

• Level 2: The payment rate will be set at a level between the level 3 and level1 rate.(€242.65 a week)

• Level 3: The payment rate will be aligned with the current standard payment rate for Disability Allowance. (This rate is currently €220 a week.)

Green Paper Proposals Easy Read

 

"Compassion for those who are suffering has been replaced by a punitive, mean-spirited, and often callous approach apparently designed to instil discipline where it is least useful, to impose a rigid order on the lives of those least capable of coping with today’s world, and elevating the goal of enforcing blind compliance over a genuine concern to improve the well-being of those at the lowest levels of society.”

ME Advocates Ireland (MEAI) Green Paper Submission

ME Advocates Ireland (MEAI) is concerned about the adequate provision of state services, resources and welfare entitlements for people with Myalgic Encephalomyelitis (ME). 

Where services, resources and welfare entitlements are unavailable, inaccessible, or under threat of being taken away, ME Advocates Ireland (MEAI) aims to highlight these inadequacies in the hope that the situation is improved in favour of the person with M.E. associated illness and disabilities. 

We have responded to the recently published government Green Paper on Disability Reform with our submission by email on behalf of members of the M.E. community in Ireland.

We think that the Goverment's proposal is a reductive, regressive, brutal way to frame the lived experience and reality of life for our disabled citizens, and vehemently oppose the proposal by the Irish Government to categorize disabled people for the purposes of allocating social welfare payments. Please see our reasons as outlined in our submission.

Our completed submission is available here .

The full email details re the submission made by ME Advocates Ireland (MEAI) on 07/11/23 including the response from Government and any other updates on the matter are at the bottom of this page.

Continue below for sample submissions by us and others.

We encourage as many people as possible to support those in the M.E. community with a submission, whether you are a carer, family member or friend of someone with M.E., or part of our M.E. community.

Thank you for your support.

Making your own submission

For anyone interested in writing a personal submission

The Government invited submissions from individuals and stakeholder organisations, particularly people with disabilities, Disabled Persons’ Organisations and Disabled Persons’ Representative Organisations, to share their views. During the consultation process you can share your views with the Government at one of their public consultation events, or through a written or video submission, more information here.

Where to make your submission

You may make your submission by email or post:

• Email: DCPolicyConsultation@welfare.ie
• Postal Address: Disability and Carers’ Policy Unit, Áras Mhic Dhiarmada, Department of Social Protection, Store Street, Dublin 1, D01 WY03.

Submission Templates

ME Advocates Ireland (MEAI) put together two template submissions regarding the Green Paper for Welfare Reform announced in September 2023 for anyone interested in responding by sending a submission.

There are two links to templates included below for anyone in the ME community who (i) is receiving a disability payment (Disability Allowance/Invalidity Pension), or (ii) for anyone who wishes to support those on disability payments.

Here are the links to the template submissions:

(i) For anyone who is receiving a disability payment (Disability Allowance/Invalidity Pension) see our template submission

(ii) For anyone who wishes to support those on disability payments see our template submission

How to edit the submission

You can edit the template that concerns you as you wish by removing or adding details. If you are not up to making edits you may send the template document as it is.

• Step 1. Please open this link if you are a person on disability payments, or this link if you would like to support those on disability payments

• Download or copy the relevant template to your PC/laptop

• Edit, then save to your device

How to send your submission

You may make your submission by email or post:

Email: DCPolicyConsultation@welfare.ie

Postal Address: Disability and Carers’ Policy Unit, Áras Mhic Dhiarmada, Department of Social Protection, Store Street, Dublin 1, D01 WY03.

The closing date for submissions is 15th December 2023 15th March, 2024 the 31st July, 2024 - Responses received after this date will not be considered.

Important Notes!

• Please look after yourself when putting a submission together. Try not to stress too much about it and try not to stress over what a submission should look like; please write in a way that suits you. Stress is not good for a person with ME, a may cause a post exertional response/relapse/crash.

• We suggest that you write your submission in sections over time if you are able to compose a submission, or get a family member, friend or carer to write one on your behalf.

• A submission can be as long or as short as you want it to be.

 

• At the beginning of your submission please state:

- Your contact details

- State whether you are contributing as an individual or as an organisation,

- State if you are disabled or not

- State if you avail of the payments affected or not

Other sample submissions from members of the ME community are included at the bottom of the page.

Political Representative Support

It may be a good idea to get onto your local TDs to ask them to inform the Government re your concerns. You could send a copy of your submission to your local representatives (TDs/others) and ask them to call on the Minister for Social Protection and other members of Government to:

- immediately stop the proposals listed in the Green Paper on Disability Reform;

- forthwith ensure that the Disability Allowance be made a universal, non-means-tested payment;

- raise the Disability Allowance to the level of the PUP payment to take over 100,000 disabled citizens out of abject poverty;

- ratify all protocols of the UN Convention on the Rights of Persons with Disabilities within the lifetime of this Government.

 

Please use our template letter to make contact with your local TD and encourage them to raise matters with Minister Humphries and the Government. You can edit the template as you wish or use it as it is. 

LOBBY YOUR TD LETTER

 

How to edit the TD Letter

You can edit the template as you wish by removing or adding details. If you are not up to making edits you may send the template letter as it is.

• Step 1. Please open the link above, i.e., 'Lobby Your TD Letter'

• Download or copy the template to your PC/laptop

• Edit, then save to your device

TD Email Contact Information

Here is a link to your TDs and their respective email addresses (hit the ‘constituency’ button, then ‘all constituencies’)

Deadline - The public consultation is open until 31st July 2024, you must make your submission before then.

Email Details re Submission made by ME Advocates Ireland (MEAI) on 07/11/23

MEAI's Emailed Submission to DCPolicyConsultation@welfare.ie

 

Re: Submission re Green Paper on Disability Reform 2023

 

To Whom It Concerns,

ME Advocates Ireland (MEAI) is concerned about the adequate provision of state services, resources and welfare entitlements for people with Myalgic Encephalomyelitis (ME).  

Where services, resources and welfare entitlements are unavailable, inaccessible, or under threat of being taken away, ME Advocates Ireland (MEAI) aims to highlight these inadequacies in the hope that the situation is improved in favour of the person with M.E. associated illness and disabilities.  

We are responding to the recently published government  Green Paper on Disability Reform with our submission on behalf of members of the M.E. community in Ireland. In so doing we are contributing to the public consultation process re the Green Paper on Disability Reform, as a patient advocacy organisation with lived experience of disability, particularly of people among the Myalgic Encephalomyelitis (M.E.) community in Ireland.

 

Please consider our submission which is attached in pdf format.

 

 

Yours Sincerely,

 

XXXX

 

 

 

Response to our Emailed Submission from DCPolicyConsultation@welfare.ie

Thank you for your email.

Your submission will be considered as part of the public consultation process.

Some important things to note

· None of the proposals in the Green Paper are being implemented at this time, they are just proposals. Nothing is going to change for now.

· The Green Paper is not a final reform design. The proposals in it are intended to provoke discussion, debate and suggestions.

· Depending on the feedback, the model presented for Government approval may closely resemble the Green Paper or could be completely different.

· The feedback and submissions received will help to design and develop a new model of income supports for Government to consider.

Meet us at one of our public consultation events

Public consultation events are taking place in Dublin, Cork and Athlone. Register now at the links below.

·       Dublin Castle, 9 November, hybrid event https://DisabilityReformDublin.eventbrite.com

·       Cork, 14 November, in-person event https://DisabilityReformCork.eventbrite.com

·       Athlone, 23 November, in-person event https://DisabilityReformAthlone.eventbrite.com

You can read more at www.gov.ie/DisabilityPaymentsReform

 

Disability and Carers' Policy Unit

Department of Social Protection

Updates

24/11/23

Thank you for your support & patience during the Green Paper campaign that is currently taking place

We are aware that there is currently a lot being posted across social media in general re the Green Paper on Disability Reform; we thank you for your support and patience around this important subject.

We will continue with our campaign until we feel that we have done enough in the public consultation process and in other areas.

Reply to our recent email from Minister Humphrey's office

Please see the reply to our recent email to Minister Humphrey'ss office in the attached PDF. It is clear that we are up against deaf ears and likely that the proposals to bring reform to disability payments will go ahead even if the decision makers are insisting that the Green Paper is not definitive. Now more than ever we need as many people as possible in the M.E. community to support the submission process and other areas of the campaign. Please see more about that below.

How can I take part in this campaign?

There are various ways you can take part in the campaign to scrap the Green Paper proposals, we would encourage as many people in the M.E. community to make a submission.

- You or your family/friend/carer can make a submission by Friday Decemeber 15th. March 15th 2024. You are welcome to use one of our templates or to use parts of MEAI's longer submission, also included. Of course you can write your own submission, all details here.

Another submission template below

Disabled People demand the Irish Government:

SCRAP THE GREEN PAPER on Disability Reform

The Government's Green Paper on Disability Reform, written without disabled people & our DPOs, but currently under public consultation, is fundamentally ableist. It suggests that the government can know everything it needs to about the lives and experiences of disabled people in order to categorise us by our ability to work, when a diagnosis worthy of any assistance is often expensive and can often only be acquired through the private system or by going abroad.

The Green Paper may force as many as half the people currently on disability off their payments and into work, and another third pressured into finding and entering into part time work.

The Green Paper will waste HSE money. The process to receive disability payments right now is long and difficult. The government assumes the limited things they can know about disabled people through medical assessments are the only things they need to know. Forcing us to prove every aspect of our lives as disabled people in order to be left alone to care for our conditions puts us back through the process of gathering even more diagnoses and documents and scans in order to be categorised by our capacity to work. This is an ableist idea.

The government's proposals will not lift most disabled people out of poverty, only endanger the mental and physical health of disabled people by increasing demands on us to go through a job seeker process not intended for us, which international evidence suggests will not work.

This paper makes false assumptions about access to workplaces.

Instead of starting with making workplaces more accessible, they propose threatening the payments of some of our most vulnerable, though the government denies anybody will lose their payments, contrary to he implication of the Green Paper.

The Green Paper wants to dump 84% of disabled people into the Intreo system with no mention of training for Intreo officers to deal with the special circumstances that come from trying to seek work or education while being disabled.

The Green Paper seeks to value disabled people only in terms of our ability to earn and forces us to prove in detail our inability to fit into a society which does not make adaptations for us. It is contrary to our UNCPD human rights. The Government must scrap the Green Paper now.

 

 

- You or you family/friend/carer can sign the petition to stop proposed categorising of disabled people for disability payments.

- You or your family/friend/carer could attend an online consultation and workshop on Thursday November 30th at 11am, all details here. Please remember to sign up for this event via eventrbrite.

- You could ask your family/friend/carer to attend the 'Scrap the Green Paper' protest event at the Dáil Kildare Street on Thursday Decemeber 7th at 12pm to 2pm, details here.

Please keep an eye on futher actions we may share over the nexts weeks/months.

_________________________________________________________________________

Sample Submissions from Members of the ME Community & Others

• A member of the ME community in Ireland has very kindly shared their Green Paper submission with us in case it is of any help to someone in the ME community who is planning to write their own submission. please see their submission email and attached submission document here

• Short submission samples from the Oppose Reform Of Disability Allowance Facebook page here

Updates

27/11/23

Extension to the Green Paper Submission Deadline!!



There has been an extension made to the public consultation around the Green Paper on Disability Reform.


The closing date for submissions is now set to 15th March 2024. Responses received after this date will not be considered.


See more on Gov.ie pages under the heading Submissions: https://www.gov.ie/en/consultation/3b001-green-paper-on-disability-reform-a-public-consultation-to-reform-disability-payments-in-ireland/#public-consultation-events



The introduction part to the Gov.ie page about the public consultation has not been updated yet so we have sought confirmation, however, other people have received emails from the Disability and Carers' Policy Unit of the Dept of Social Protection confirming the extension to March 15th 2024.

30/01/2023

We have resubmitted our Green Paper Submission with a new email to highlight the fact that the Green Paper proposals conflate two different issues – the extra Cost of Disability and the question of ‘capacity to work’; these should be tackled separately.

'To Whom It Concerns,

Our position is that the Green Paper on Disability Reform as it stands will not deliver on its stated aim of tacking poverty and low employment rates.

The overall problem with the Green Paper, as we see it, is that it conflates two different issues – the extra Cost of Disability and the question of ‘capacity to work’; these should be tackled separately.

Currently the fear among disabled citizens who CANNOT work is palpable; surely there should be a separate focus on those who can work and a focus on getting the systems in place to accommodate a return to work for those who can work. Separately there needs to be a focus on the cost of disability, i.e., on the cost of what it is to be disabled and totally incapacitated in Ireland.

The focus of consultation should be on the voice of disabled citizens and carers, and it is that what is most important in a public process. We are not entirely sure that our voice has been heard, or that other disability groups are being listened to.

We hope that the many concerns being articulated strongly through the public consultation process will be heard by the Department of Social Protection, and by the Government, and that a change in approach occurs.

We are concerned that the Minister is not supporting disabled people on this matter, moreover, we are very worried about disabled communities, in particular about those with M.E., a chronic multi-systemic neurological illness.

We responded to the Government Green Paper on Disability Reform with our submission on behalf of members of the M.E. community in Ireland in November 2023. In so doing we are contributing to the public consultation process re the Green Paper on Disability Reform, as a patient advocacy organisation with lived experience of disability, particularly of people among the Myalgic Encephalomyelitis (M.E.) community in Ireland.

Please reconsider our submission which is attached in pdf format.

Yours sincerely,

11/03/24

Submission deadline has been extended to 31st July 2024

26/03/24

Model of Assessment received by FOI from the Department of Social Protection here

Thank you all for your support on this important matter.