Managed migration is an opportunity for the government to show that Universal Credit is an improvement on the legacy system.
In this blog post, we argue that the DWP can deliver effective support that improves the lives of claimants and supports people toward independence.
Managed migration is a massive exercise with over two million households moving onto Universal Credit over four years, on top of the natural migration caseload. The risk is not only that vulnerable claimants are left without the support they need to make and manage a Universal Credit claim, but also that the opportunity to kick start individual journeys toward greater independence is lost.
Departmental resources will be stretched and the DWP will need to make use of all of its strengths, including its data and its partnerships with local support providers, to make managed migration a success. Quite rightly, Managed Migration is seen first and foremost as a risk management exercise, helping to ensure the smooth transition of over 69,000 households each month from the legacy system onto Universal Credit.
Through our work and engagement with local welfare providers and our experience of supporting people through natural migration to Universal Credit, we have been confronted with some of the most salient issues related to both policy and practice. Equally, we have witnessed a number of success stories. Reflecting upon this experience, we have formulated a series of key lessons learnt and recommendations for managed migration.
Policy in Practice uses administrative data to help local organisations to:
- identify the impact of Universal Credit on households before they migrate across
- track the outcomes of households as they move onto Universal Credit, and
- engage households through clear calculations, explanations and advice that help people to take control of their situation.
Our work with administrative data on legacy claims, and our analytical engine that factors in complexities including council tax support, free school meals and advice on actions people can take, can be used by the Department to plan for migration and target individual households with tailored support.
We know from our analysis we’ve done for local councils that nine in ten applications for a Discretionary Housing Payment (DHP) are successful, yet only one in five households that need a DHP apply. Councils use our analysis to target DHPs more effectively, and we believe the DWP can do the same to better target Universal Support.
Our three core recommendations:
- The rollout of managed migration should be delivered on a geographical basis, with detailed analysis on each geography prior to managed migration to help the DWP and their partners resource and co-ordinate support effectively.
- A geographical migration should be supplemented with targeted and tailored communications to every household before they are asked to migrate, and a personalised support offer as they move onto Universal Credit.
- A more comprehensive support offer could help people not only move onto Universal Credit, but also take practical steps to increase their income, reduce expenditure and move towards financial independence.
Our three recommendations to the Universal Credit managed migration inquiry will help ensure vulnerable people are offered and can access the support they need. At the same time, they ensure that more able claimants can make an efficient online claim and understand the financial benefits of Universal Credit, as they move into and progress in work.
In addition, our recommendations will focus departmental resources on where they can be most effective, deliver long term benefits through the managed migration process, and ensure the first experience that millions of households will have of Universal Credit is a positive one.
Background and context to managed migration
Managed migration describes the transfer of existing legacy benefit claims to Universal Credit, where there has not been a change of circumstances that has resulted in a ‘natural’ transfer to Universal Credit.
When the managed migration takes place, claimants will receive transitional protection if their entitlement to Universal Credit is lower than their entitlement to existing legacy benefits. On current plans, the managed migration exercise is due to begin in January 2019 with some early, small-scale testing, and then is due to continue in earnest from July 2019, lasting until 2023.
DWP estimate that approximately 2.09 million households (2.87 million people) will migrate from existing benefits to Universal Credit. This equates to 69,000 households (95,000 peoples) each month when ‘migrating at pace’. Of those being ‘managed migrated’, most people currently receive tax credits (54% or .12m households) or ESA (36% or 745,000 households). More than half (55%) of the tax credit recipients also receive Housing Benefit. Many will have been receiving benefits for some time and, in respect of ESA claimants, will be among the most vulnerable claimants.
This is a massive exercise for DWP and its partners. Our briefing note focuses first on regulation changes we think ought to be considered, and then looks at how best the significant administrative challenges can be met.
Below we focus on how to tackle the administrative challenges, and the opportunities this creates to deliver more effective support to people as they transition onto Universal Credit.
How will managed migration be implemented?
We do not yet know how the rollout of managed migration will be organised. For example, it could be by case type, perhaps starting with the simplest, across all areas, or it could be geographical by Jobcentre area.
We think geographical rollout will work best, as in the rollout of Universal Credit full service. This approach will facilitate the use of advanced analytical techniques to target individual households in specific areas, with tailored support based on their specific circumstances. This information will be vital for all organisations involved in supporting claimants through the migration, particularly local authorities, and a lot of support will be needed.
Policy in Practice can model the impact of the Universal Credit transition for each individual claimant, based on the latest claim information held within their Housing Benefit records or within the Customer Information System. Knowing this information about a cohort of claimants can inform the order in which they are migrated. It can help third parties involved in providing support by giving them data broken down by council, JCP area, or ward and neighbourhood level, so that they can understand how migration will affect service in their area. Such a planned approach would promote positive engagement, inform resource planning and facilitate partnership discussion, ensuring support is available while effort is not duplicated.
What information will be given to claimants, and is it enough?
DWP intends to provide claimants with general information about the ending of existing benefit claims and the need to make a UC claim first. It will give advice about support and preparation, such as how to open a bank account.
Next, claimants will receive a second notification telling them what date they need to make a UC claim by. They will normally have a month to make the UC claim but this can be extended, either at the outset or during the notification period, where there is good reason to, for example in cases where people have complex needs, are vulnerabile or in a domestic emergency. Two reminders will be issued during the notification period.
However, the notifications the Department intends to send will not be tailored to claimants’ specific circumstances. We know from behavioural experiments that messages tailored to the individual are more likely drive engagement and action, and this seems like too good an opportunity to miss.
Policy in Practice’s modelling can show the most effective way to communicate with different types of claimant. We can identify potentially vulnerable claimants by assessing their financial resilience and advise them of their eligibility for low cost utility tariffs, for example. More self-sufficient claimants can be directed to self-serve, and also be offered advice on taking a job or increasing hours.
So while the intention to provide clear and helpful information is welcomed, we believe that this should be supplemented with targeted and tailored communications to every household before they are asked to migrate, and a personalised support offer as they move onto Universal Credit.
What support will be available to claimants to make and manage their claim?
If possible, it would be preferable to pre-populate initial UC claims with data from the existing benefit claim(s) which the claimant could then agree and update within, say, 3 months. This has been done before; in 1988, recipients of Supplementary Benefit were deemed to have made an automatic claim for Income Support. If this is a step too far, DWP should allow maximum flexibility to extend the deadline day for making a claim and allow backdating in any reasonable circumstances. Evidence suggests that claimants find it difficult to make and manage online claims and will need as much help as possible. Decision-makers must be trained to exercise maximum flexibility and not just stick by a set script.
The new provisions announced by the government in late 2017 will all apply. These include no waiting periods, easier advance payments and the two-week housing benefit run-on if the claimant is receiving housing benefit immediately before making a new UC claim and has complied with the managed migration process. These are positive steps which should help claimants through the claim process.
What wider support will be available to claimants, and how will it be funded?
Many claimants will need support, either from DWP or from a third party, both to interpret and to act on the notifications they receive. Some of the most vulnerable claimants will be involved. They will need good telephone back up and expert help from well-trained DWP staff. Local authorities and others will need clear guidance, with very good communications. We believe that additional funding will be required to make this support fully effective. We absolutely must make best use of existing resources and we firmly believe we can help with targeting help to where it is needed most.
Our work can also inform the type of support claimants are offered to help them through the transition. We can offer help to make households more financially resilient, for example helping them to claim help with council tax, reduce their fuel and water bills or show how to cope with existing arrears. If appropriate, this could also include help with better off in work calculations which could include the availability of and eligibility for childcare. This could be loaded into a calculation for face-to-face support, as part of a verification visit.
Successful local interventions often involve a multi-agency approach to the delivery of local support. In this context, reliable information that can be easily accessed is an essential condition. Through our work we have found that this condition is not always met in Universal Credit full service areas due to a lack of a systematic sharing of information on Universal Credit claimants between the local Jobcentre Plus office and local authorities. Because of this, there is a concern that households on Universal Credit are more likely to fall through the net of support available to them.
New national regulations and guidelines on the accessibility of Universal Credit data could help overcome this barrier. Alternatively, guidance built into frontline advice, and data sharing to identify affected households and provide relevant guidance in advance, can help advisers and frontline organisations to deliver on the government’s commitment to Universal Support.
How will DWP evaluate the success of the migration exercise?
The DWP should monitor, in a systematic way, families affected by managed migration in the months following the reform. This must go beyond what is currently envisaged under the current monitoring and evaluation plan.
Policy in Practice is currently tracking the living standards of more than half a million households to find out how factors such as housing, jobs, childcare and financial resilience affect their living standards. As part of this we will be able to track households moving onto Universal Credit through managed migration and understand who moves into work and who moves into financial hardship, incurring additional costs. We believe that a similar initiative involving the rigorous monitoring and scrutiny of policy outcomes should be embedded in the way managed migration is implemented and delivered at a national scale.
Only through this type of analysis will it be possible to fully assess the extent to which the policy has been successful in migrating people across and, crucially, in achieving its broader objective of changing behaviour. This represents a key pillar of an outcome-based approach, allowing full accountability of the government’s role in considering what outcomes are achieved.
How will anomalies between claims on legacy benefits and Universal Credit be handled?
The managed migration exercise is likely to uncover cases where household circumstances have changed but the local authority has not been informed. These changes will be recorded as people move onto UC and have to verify their claim. At this point, it will become clear that the existing payment of Housing Benefit is incorrect.
The local authority will then trigger an overpayment calculation which will end up being recovered by DWP, potentially at 20% of the standard allowance. This will have a doubly negative impact on the perceived UC award, first through the overpayment itself, and then through its recovery. The Department should consider ignoring small-value overpayments as part of the migration exercise or at least be flexible with the level of recovery enforced.
Local authorities are implementing similar approaches to those outlined in this briefing note. This is helping them to identify, engage and track the outcomes of people migrating naturally onto Universal Credit, in order to better target Universal Support.
Managed migration should be supported by data-led analysis
The applications for data-led analysis to support managed migration are powerful and myriad. We believe rollout should occur by geography, be that by JCP or by local authority, and mixed caseloads migrated in a staggered way to ensure resources are available to deliver tailored support.
Rolling out Universal Credit local area by local area will help both the DWP and local support organisations, including local authorities, to plan and resource their support. These plans can help to ensure local support is adequately funded and resourced.
Migrating a mixed caseload in a staggered way over the four years helps to avoid an unnecessary focus on ‘winners’ and ‘losers’ moving onto Universal Credit at particular times, and avoids debates around who should be migrated first.
- Migrate people who stand to lose out onto Universal Credit quickly, to ensure they receive transitional protection
- Alternatively, move people who will be better off on Universal Credit first so that Universal Credit is more likely to be well received locally
Beware of missed opportunities
While the DWP will no doubt be modelling income under legacy benefits alongside Universal Credit in order to calculate the transitional protection award, we understand that the scope of this won’t include modelling eligibility for other support. We feel this is a missed opportunity to help ensure people are aware of the ability to access childcare and move into work faster, or apply for utility discounts, to help with low financial resilience.
Ultimately, the choice is between delivering a generic managed migration process to all households, versus a much more tailored, personalised approach. We believe this opportunity to engage households should be seized, with the ambition not only to help people onto Universal Credit, but also to help people take steps toward independence.