1st Report – Safeguarding Vulnerable Claimants

DWP provides essential services that act as a lifeline to millions of people each year, many of whom are vulnerable and require additional support to access them. For this reason, when mistakes are made, it is possible that the severest consequences can arise. Over several years there are known to have been hundreds of serious harms and deaths of claimants, many of which could have been prevented had DWP discharged its responsibilities more effectively. It is imperative that DWP learns from these mistakes so that opportunities to prevent deaths of and serious harm to people are not missed in the future. (Conclusion, Paragraph 17)

We note that in April 2022, the Equality and Human Rights Commission (EHRC) and DWP were working to improve DWP’s treatment of disabled benefit claimants in accordance with a legally binding section 23 agreement. We further note that the EHRC launched a formal investigation into DWP in May 2024, which is considering if DWP failed to make reasonable adjustments for disabled people with learning disabilities or long-term mental health conditions during health assessment determinations, and that as of April 2025, this investigation is ongoing. It is essential that the investigation be allowed to run its course, and at this point we do not wish to make any conclusions and recommendations that anticipate findings of that investigation. However, once those findings have been made, this may be an issue that the Committee wishes to scrutinise further. (Conclusion, Paragraph 18)

It is striking that despite being engaged with safeguarding on a daily basis, the Department has never had a clear and coherent, public facing safeguarding policy or strategy. For example, that when making an internet search for “DWP safeguarding policy” or “strategy”, there are no clear results from Government webpages. Whilst it is encouraging that DWP has said it now intends to review and publish its approach to safeguarding, bold action is required if DWP is to rebuild the trust of claimants. (Conclusion, Paragraph 23) 93

To signal a step-change to the public in the culture of the Department, and to improve accountability directly to Parliament, we recommend the Secretary of State for Work and Pensions make a statement to the House, setting out DWP’s new approach to safeguarding, at the conclusion of its current review. This should include a statement of intent relating to cultural change at all levels of the Department, and a new commitment to safeguarding. It should also include clear and specific actions by Ministers and the Senior Leadership Team to demonstrate to all staff that supporting claimants is an important part of DWP’s mission. (Recommendation, Paragraph 24)

The Department has said that whilst it does not have a statutory duty to safeguard vulnerable claimants, it recognises it has a responsibility to support them and does so through other means. We remain concerned, however, that current practice is insufficient, and that public trust is sorely damaged. We received no evidence from outside of the Department that introducing a statutory safeguarding duty was an unreasonable request. When we raised this with the previous Government, we were told that improvement could be achieved through investment in training, guidance, development and links to other Government Departments and organisations that have that duty. We welcome the new Secretary of State’s view that while laws alone do not change behaviour, they can help. We recognise that the introduction of a statutory duty would be a significant undertaking for the DWP, however, we are not convinced that the Government’s current approach is achieving its desired outcomes. For example, in 2023- 24 there were 75 IPR referrals for internal investigations into cases that have been mishandled by DWP. This number remains stubbornly high, and if this is on the basis of addressing this issue through improved training, guidance and joint-working, then it is time for a new approach. A statutory safeguarding duty would help to drive and embed culture change in the Department, support the consistent delivery of safeguarding practices, and improve accountability should failures occur. The introduction of a duty, underpinned by practical actions, would also signal a change in the Government’s approach to safeguarding and help to rebuild the trust of claimants. (Conclusion, Paragraph 30)

We recommend DWP introduce a statutory duty to safeguard vulnerable claimants that applies to the whole Department, and for which the Secretary of State is ultimately accountable. The duty should have regard to factors such as the wellbeing of vulnerable claimants and preventing harm, when exercising its functions. It should apply when developing, implementing and reviewing policy, and also cover specified duties that contain clear criteria and definitions, including: • a responsibility to proactively conduct a safeguarding assessment or identify if a claimant needs additional support; 94 • an obligation to both inform and proactively offer additional support measures to all claimants who might need such support; and • a duty to refer vulnerable claimants to other agencies, including those which have a duty of care, to ensure their additional needs are supported (Recommendation, Paragraph 31). Systems-based policymaking

DWP is more likely to prevent vulnerable claimants from experiencing harm if it first engages them in decision-making that affects them: their needs, the potential risks of proposals, and how those risks might be mitigated. We welcome the intention to introduce a trauma-informed policy framework and the work reviewing policy changes from a clinical perspective, predominantly in the disability service area. Disability, however, is not the only characteristic that makes claimants vulnerable, and we are concerned about the lack of focus on claimants with other vulnerabilities in the policymaking process. (Conclusion, Paragraph 38)

We recommend that as a part of a systems-based approach to safeguarding, the Department introduce an explicit requirement that all significant new policies and policy changes, including those that fall outside the disability service area, are assessed by the Chief Medical Advisor’s team to understand their potential health impact on claimants. This should be accompanied by an appropriate expansion in resources for the team if needed. In light of the Government’s commitment to improve safeguarding practices, to accompany the safe implementation of health and disability benefit reforms, we suggest it would be appropriate for the Department to consider reinvesting a portion of the estimated savings to fund this work. (Recommendation, Paragraph 39)

The Chief Medical Adviser (CMA) told us her team provided clinical advice to Ministers and was involved in assessing any potential policy changes put forward within White Papers or Green Papers; however, these assessments were not usually published, to enable Ministers to make decisions in a safe space. The Pathways to Work Green Paper proposes sweeping changes to health and disability benefits and will have a significant effect on claimants. Given the potential impact of these reforms, we believe it would be appropriate for Ministers to approve the publication of the CMA assessment of proposals, to aid Parliamentary and public scrutiny. (Conclusion, Paragraph 40)

In response to this report, we ask that DWP confirm that planned changes to health and disability benefits, set out in the Pathways to Work Green Paper, were prospectively assessed with respect to possible physical and mental 95 health impacts on claimants. We recommend DWP publish the Chief Medical Adviser’s team’s assessment of proposals, and place a copy in the House’s library. (Recommendation, Paragraph 41)

DWP is undertaking a major programme of reform via its green and white papers and several long-term strategies and programmes. This work presents a significant opportunity to improve safeguarding for claimants across the social security system. However, DWP must be alert to unintended consequences that could put claimants at risk, as has happened too many times in the past. The Department must make sure it centres the wellbeing of vulnerable claimants in its policymaking, including by ensuring that the voices of people with lived experience are incorporated in design, planning, and implementation. (Conclusion, Paragraph 46)

We recommend the Department introduce a systems-based approach to safeguarding, at all levels of DWP and in all policies. A systems- based approach should consist of developing mechanisms to ensure that safeguarding is explicitly considered at each point in the development, implementation, monitoring and evaluation stages of all policies. This work would ensure that safeguarding is everybody’s business, at all levels of the Department. It should include gathering data on the number of claimants it has identified as vulnerable and the needs of these claimants, defining measurable objectives relating to improved safeguarding across all its key strategies and policies, monitoring progress and reporting outcomes in its Annual Report and Accounts. (Recommendation, Paragraph 47)

To ensure that it incorporates the expertise of people with lived experience of the benefit system, DWP should set up a reference group similar to the Greater Manchester Disabled People’s Panel to help shape safeguarding policy. (Recommendation, Paragraph 51) Defining ‘vulnerability’ and identifying additional needs

DWP’s existing description, or definition, of vulnerability in internal documentation encourages an open, flexible approach to determine when a claimant has additional support needs. However, the lack of a clear, consistent and public-facing definition of vulnerability could act as a barrier to understanding if and when individuals are entitled to additional support and to having that support put in place. (Conclusion, Paragraph 60)

DWP should formalise its definition of vulnerability and undertake work to ensure it is clearly and consistently communicated in key public facing documents, including its ‘Advanced Customer Support: Delivering support and transformation to help DWP customers with additional support needs’ document, and its new approach to safeguarding, when published. The Department should also develop and publish guidance on how to 96 understand and apply its definition of vulnerability to make it easier for support organisations to engage with it. In doing this, the Department could draw on the approach taken by the Financial Conduct Authority as well as other public sector agencies to define vulnerability; and its own work to highlight additional support needs within the ‘Additional Support Area’ in Universal Credit. (Recommendation, Paragraph 61)

We heard in evidence that when using the ‘Additional Support Area’ in Universal Credit, DWP officials are able to record support needs under the following eight categories: care leavers; armed forces; ex-offender; homeless or risk of homelessness; limited digital ability or accessibility; difficulties with English; drug and alcohol misuse; and an ‘other’ box. It is our view that the category of ‘victims of domestic abuse’ is a glaring omission from this list. Unfortunately, there will be many people dealing with DWP who fall into this category. And they will have particular vulnerabilities and need specialised support that cannot be covered by the other categories and seem more significant than being put into the ‘other’ box. We recommend that the category of ‘victims of domestic abuse’ be added to the ‘Additional Support Area’ in Universal Credit to ensure that this set of vulnerabilities is being looked out for and to signal to DWP officials that people falling within that category will need the offer of additional support. (Conclusion, Paragraph 62)

When it comes to identifying vulnerable claimants, the Department places too great an onus on self-disclosure. The nature of some vulnerabilities can make disclosure difficult. A lack of trust in the Department can further deter people from sharing their personal circumstances. Whilst DWP has sought to train staff to recognise signs of vulnerability, claimants’ experiences can change over time, and their level of vulnerability may vary. And some claimants in receipt of health and disability benefits will not have regular contact with Work Coaches. It is therefore essential that there are proactive and ongoing opportunities for DWP to identify if a claimant requires additional support. (Conclusion, Paragraph 69)

DWP should add a question to all benefit application forms that asks claimants if they would like to disclose anything about their personal circumstances, including medical or mental health concerns, that means they might need additional support, now or in the future. Forms should also include a simple tick-box, through which a claimant could indicate they would like DWP to reach out to them and initiate a conversation about their circumstances. (Recommendation, Paragraph 70)

DWP should also implement a new policy making clear that staff have a responsibility to check proactively for vulnerabilities and engage claimants in regular conversations where they can share any difficulties they may be experiencing. For example, if a claimant attended meetings with a support 97 worker advocating on their behalf, this should act as a clear indication of a possible vulnerability. DWP should also consider how to introduce semi- regular moments to check on claimants who do not have regular contact with Work Coaches, to understand if their needs have changed. This would require an emphasis on building trust with claimants, to ensure they do not feel DWP is monitoring or policing them. Staff training must reflect these new approaches to identifying and supporting vulnerable claimants. (Recommendation, Paragraph 71) Ensuring accessibility and supporting claimants

Ensuring vulnerable people have support to access the benefits they are entitled to is an essential part of delivering equitable welfare provision and an effective safety net. Since the removal of Help to Claim’s face-to-face service in 2022 it has become more difficult for some individuals to apply for Universal Credit. We are not convinced that DWP’s safeguards - referring claimants to Jobcentres, or to the DWP visiting team - offer an adequate solution. (Conclusion, Paragraph 79)

DWP must ensure that Jobcentres can provide as thorough a service as used to be offered through Help to Claim. We recommend that, in its response to this report, DWP sets out where the support offered in Jobcentres and through home visits differs from that provided by Help to Claim. If it identifies a shortfall, DWP must set out how it intends to provide equivalent support to claimants who require it. (Recommendation, Paragraph 80)

Some vulnerable claimants require reasonable adjustments and additional support throughout their benefit claim. These adjustments are crucial to ensuring that claimants can successfully engage with the system, receive the support they are entitled to, and reduce the risk of unmet needs escalating to serious harms. However, many claimants do not know that additional support exists and it can be even be difficult for experts to know what is available. DWP has said it intends to set out the support available to those who require it and how to access that support, and we welcome this measure. (Conclusion, Paragraph 92)

Upon first applying to benefits, and at each review point, we recommend DWP staff provide claimants with detailed information about the additional support available to them, which must include an indicative list of possible reasons which might lead to an individual requiring this support. Frontline staff should also be trained to offer additional support measures proactively when they become aware of a claimant’s circumstances. DWP should also add to its Additional Support Area a mechanism through which DWP staff can record that they have provided claimants with such information. (Recommendation, Paragraph 93) 98

DWP must ensure its new ‘approach to safeguarding’ publication is easy to use, signposts relevant support organisations, and is available in a range of languages and alternative formats. DWP should also develop an additional support toolkit to accompany this publication, to ensure information relating to available support is not lost within a lengthy policy document. This should include both a toolkit aimed at claimants and a toolkit aimed at organisations supporting claimants. (Recommendation, Paragraph 94) Preventing harm and responding to risk

Incorrectly applied, policies intended to drive claimant behaviour and deliver value for money, such as sanctions and deductions, can create and exacerbate vulnerabilities. While DWP has checks in place that are supposed to ensure this doesn’t happen, the application of these checks is inconsistent. This can leave claimants facing substantial hardship, putting them at risk of harm. (Conclusion, Paragraph 110)

The effectiveness of DWP policies that are supposed to protect claimants from harm is in large part contingent on Work Coaches applying discretion correctly and consistently. Discretion can be a valuable tool in the benefit system, but we are concerned that overreliance on discretion is placing an unreasonable burden on time-poor Work Coaches and increasing the risk of safeguarding policies and procedures not being followed properly. Furthermore, we are mindful that for discretion to be applied effectively, frontline staff must feel confident in applying safeguarding measures. Our survey results suggested that a sizeable minority of DWP staff do not feel they received adequate safeguarding training to enable them to deal with safeguarding issues. (Conclusion, Paragraph 111)

We recommend DWP commissions or undertakes a series of surveys to understand how staff feel about the Department’s safeguarding policies, practices and their overall workload. The surveys should include questions relating to views on training and guidance; familiarity and confidence with safeguarding policies; and culture relating to safeguarding, both within the individual’s service area, and across DWP more generally. We recommend DWP undertake an initial round of any such survey as soon as possible, and a second round after one year. Within three months of each survey, DWP should also report to us how it will continue to improve its approach to safeguarding and ensure that where discretion is used, it is consistently applied. DWP should use the survey as an opportunity to understand which areas of training DWP staff would most benefit from, and develop an improved training programme accordingly. (Recommendation, Paragraph 112)

Advanced Customer Support Senior Leaders (ACSSLs) form a core part of DWP’s safeguarding strategy and undertake significant public facing and operational roles. Despite ACSSLs playing a critical role in DWP’s approach 99 to safeguarding, there remains a lack of understanding, including amongst organisations that support claimants, about the work ACSSLs undertake. This inhibits their effectiveness. Furthermore, there are currently only 37 ACSSLs who work on a regional basis across England, Scotland and Wales. As the Department reviews and improves its approach to safeguarding, it is likely that the expertise of ACSSLs will be drawn on more heavily, and that limits on capacity will hinder the Department’s ability to discharge its safeguarding responsibilities effectively. (Conclusion, Paragraph 118)

We recommend DWP work to improve awareness of the work that Advanced Customer Support Senior Leaders undertake, including by setting out a full description of their role when publishing their new approach to safeguarding, and by promoting case studies. As part of its review into safeguarding, the Department should also assess ACSSL capacity against demand, including considering unmet need, and undertake work to understand the likely impact of any changes it makes to its approach on ACSSLs. If necessary, DWP should expand the number of ACSSLs working across Great Britain. (Recommendation, Paragraph 119)

The Department should also develop a more systematic route through which benefit advisers can contact ACSSLs directly, when and if they have a serious concern about a claimant. DWP should consider creating an external equivalent of the internal system it uses to allow DWP colleagues to refer cases for ACSSL consideration. (Recommendation, Paragraph 120)

Effective collaboration between partners is essential to understand the complex needs of some claimants, to understand if they are at risk, and to identify if any interventions are required to assure their safety. The Department has taken some steps to improve the way it works with other agencies, led by Advanced Customer Support Senior Leader (ACSSL), who now sit on 80% of Safeguarding Adults Boards. However, the department still does not consistently refer vulnerable claimants to appropriate agencies. (Conclusion, Paragraph 127)

We recommend the Government make it a statutory requirement for all Safeguarding Adult Boards to include DWP representation. As part of its statutory safeguarding duty, DWP should also have a specified duty to refer vulnerable claimants to other agencies, including those which have a duty of care, to ensure their additional needs are supported. We also recommend DWP publish the Memorandum of Understanding it developed with the National Network for Chairs of Safeguarding Adults, so that it is in the public domain and to improve understanding among external partners of DWP’s responsibilities. (Recommendation, Paragraph 128) 100 Reviewing harm and learning from mistakes

Many of the people making a complaint against DWP are likely to be in a vulnerable situation. Having a robust, clear and accessible complaints procedure is therefore crucial to prevent failures from reoccurring and to provide those affected with a means of redress. We are concerned that some vulnerable claimants, after pressing their cases through different layers of complaints, will be deterred from making a complaint against DWP to the Parliamentary and Health Service Ombudsman (PHSO) because of the ‘MP filter’. This risks preventing these claimants from having their complaints heard and reduces opportunities for the Department to learn from mistakes and failures. (Conclusion, Paragraph 136)

We agree with the PHSO that the MP filter should be removed, and that the PHSO should be granted the power of initiative so that it can investigate known and systemic issues, more effectively support public services and extend access to justice to those least likely to complain, without a specific complaint having to be raised. This would extend PHSO’s powers in line with many equivalent Ombudsmen, including those in Wales and Northern Ireland. (Recommendation, Paragraph 137)

We remain concerned that the true scale of deaths and serious harms of vulnerable claimants is currently unknown. As set out by the Chief Medical Advisor, we recognise the complexity of these cases and that being in receipt of benefits does not automatically imply culpability of the Department. However, we believe there is more work to be done to learn from serious cases. (Conclusion, Paragraph 151)

We recommend the Department work with its Chief Medical Advisor, DWP’s Caldicott Guardian, and coroners to devise a way to record more systematically all cases of serious harms and deaths where the individual affected was in receipt of working-age benefits. The Department should then commit to publishing this information annually to aid transparency. (Recommendation, Paragraph 152)

We welcome the action taken by the Chief Medical Advisor to appoint a Caldicott Guardian in order to aid transparency and to ensure DWP handles claimants’ data safely and ethically. However, we are concerns that due to other organisations, the protections offered by a Caldicott Guardian will not be seen throughout DWP’s range of services. In response to this report, we seek reassurance that the Caldicott Guardian be included in any future service procurement process. (Recommendation, Paragraph 153)

If all other layers of safeguarding fail, and claimants experience harm as a consequence, it is essential that DWP learns from these cases. Furthermore, it is right that learning mechanisms are transparent, so that claimants and their families can understand what the Department is doing to prevent 101 these same failures from recurring. We welcome the Department’s plans to publish anonymised Internal Process Review (IPR) data, and the detailed information it provided to us about Internal Process Reviews and the Serious Case Panel. Whilst this has aided our own understanding of the processes DWP uses to learn from cases of serious harm and death, we remain concerned that the system remains opaque, diminishing the Department’s accountability. (Conclusion, Paragraph 160)

DWP should work with the PHSO in the next six months to improve the transparency of the processes it uses to learn from serious mistakes and failures, including Internal Process Reviews, the Independent Case Examiner, and the Serious Case Panel. Greater transparency would improve accountability and drive learning. This would help to ensure that claimants, their loved ones, and relevant stakeholders have a better understanding of the entire system, and drive learning within a systems-based approach to safeguarding. (Recommendation, Paragraph 161)

However, even if the Department improves transparency, we are still concerned that the process in DWP amount to it marking its own homework. Therefore, in the longer term, we recommend DWP introduce an independent body to investigate serious harms, to improve scrutiny and ensure appropriate action is taken when cases are mishandled. DWP must ensure that it consults with relevant stakeholders, including Disabled Peoples Organisations, when setting up this body. (Recommendation, Paragraph 162) 102