Year 5 Independent Review of the Work Capability Assessment

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Year 5 Independent Review of the Work Capability Assessment

1. Year 5 Independent Review of the Work Capability Assessment RNIB Group response

About RNIB group

As the largest organisation of blind and partially sighted people in the UK, RNIB is pleased to have the opportunity to respond to this consultation.

We are a membership organisation with over 12,000 members who are blind, partially sighted or the friends and family of people with sight loss, and more than 80 per cent of our Board of Trustees are blind or partially sighted. We encourage them to be involved in our work and regularly consult with them on government policy and their ideas for change.

As a campaigning organisation of blind and partially sighted people, we fight for the rights of people with sight loss in each of the UK’s countries. Our priorities are to:

 stop people losing their sight unnecessarily  support independent living for blind and partially sighted people  create a society that is inclusive of blind and partially sighted people's interests and needs.

Finally the RNIB Group comprises of, Action for Blind People, Cardiff Institute of the Blind, certain local societies and RNIB itself.

The RNIB group is presently, and historically, been a provider of Government funded employment support via Work Choice, NDDP, Workstep, Work Preparation Residential Training and Access to Work.

RNIB is also a member of the Disability Benefits Consortium (DBC) and fully support the consortium’s response to this review. Introduction We are pleased to have the opportunity to submit evidence to this review. In its current form the Work Capability Assessment (WCA) is failing to assess blind and partially sighted people adequately and unfairly denying them the correct level of support through Employment Support Allowance (ESA).

Whilst we realise that people with visual impairments are not alone in finding criticism with the WCA, there are specific factors that we believe treat blind and partially sighted people particularly unfairly, and could be swiftly addressed by the Department for Work and Pensions (DWP).

We have set out our evidence thematically and are only responding to the questions we have expertise in. We will indicate which questions in the call for evidence our comments relate to. The current Work Capability Assessment and blind and partially sighted people In preparing this evidence RNIB undertook a Freedom of Information request to the Department of Work and Pensions to obtain up to date figures for those who have undergone the WCA who have vision impairment. The full data tables and analysis is provided in Appendix 1 of this submission.

Between October 2008 and September 2013, 10,300 blind and partially sighted claimants have completed their initial Work Capability Assessment.

Incorrect decision making (Question 15) Up until March 2013 an incredible 4,400 people with sight loss have appealed against their fit for work decisions and although at this date we don’t know the outcomes of around three fifths of those appeals, the results that we have show that over a third of the appeals had their initial decision overturned. As a snapshot of those claimants, this year alone RNIB’s legal advice service have resolved 22 cases concerned with the WCA on behalf of blind and partially sighted clients. These cases are the result of either appealing or reviewing initial decisions and all but one resulted in a change in the group the claimant was placed into. In 2013 RNIB’s legal rights service were involved with 77 cases at appeal, with a over 80 percent resulting in a change of group assignment and the Independent Living Advisors in Action for Blind People were involved in 44 appeal cases in which the tribunal overturned the original decision.

Indeed, the figures that we have obtained from the DWP show that before appeal 43.3 percent of blind and partially sighted claimants are being found fit for work, but after the appeals process this percentage drops by almost 6 percent to just 37.5 percent, leaving over 1 in 20 of the applicants found fit for work unfairly cut off from vital support unless they appeal their decision.

For those claimants whose initial decision entitled them to contribution based ESA in the Work Related Activity Group (WRAG), claimants can be left without support once the 365 day time limit has passed yet still be undergoing the lengthy appeal process. RNIB has provided support to clients who during the appeals process have been left without ESA financial support for 8 months whilst they wait to find out if their appeal is successful. As well as the emotional uncertainty that this brings to someone who may have recently lost their sight, it is worth noting that two in five people with sight loss face some or great difficulty making ends meet so can ill afford this withdrawal of financial and specialist employment support.1

Furthermore, it would be incorrect to assume that the high percentage of successful appeals relates to an anomalous small proportion of incorrectly assessed claimants. Out of the 4,500 blind and partially sighted claimants who have been found fit for work since October 2008, 4,400 appealed their decision.

This trend for decisions being overturned at appeal stage or during mandatory reconsideration is consistent with data that we have reported to previous independent reviews and continues to show that the WCA’s improvements over the years have failed to address the needs of blind and partially sighted people. It is therefore vital that the year 5 independent review takes specific steps to address the treatment of this group by the WCA.

Appeals Process Case Study RNIB Legal Rights Service client – appeal from Fit for Work to support group

1 McManus S and Lord C, (2012) Circumstances of people with sight loss 2 RNIB legal rights advisors were approached by a 54 year old woman, certified partially sighted. She does not read braille and in addition to her sight loss the client has arthritis.

She had been in receipt of Incapacity Benefit on the grounds of incapacity and was assessed under the Work Capability Assessment as part of the migration to Employment and Support Allowance.

Following this assessment the client received a decision stating that she had scored 9 points and therefore did not qualify for ESA from 16 January 2014.

The client appealed the decision and approached us for assistance. Jobcentre Plus reviewed her case but did not change their original decision. The matter progressed firstly to a first-tier tribunal and our Legal Rights Service submitted the case on activity 7 that it can be satisfied based on sight loss alone. The new DWP guidance on the sensory activity that was issued in March 2014 was submitted as evidence. This guidance clarified that a claimant could satisfy activity 7 based on sight loss alone if they were unable to read 16 point print and braille.

Upon receipt of the submission the tribunal judge made a direction notice. This notice requested the Secretary of State to revisit the matter before the appeal was to be listed for an oral hearing. Despite the clarification provided by the new guidance in March 2014, the Secretary of State felt unable to revise the decision and reverted to the tribunal judge.

The case was heard before the tribunal on 9 June 2014 and the appeal was upheld. The client was awarded ESA with the support group component from 16 January 2014. An unfair test (Questions 13 and 15) The current structure of the WCA makes it difficult for blind and partially sighted people to earn enough points against the descriptors to enable them to qualify for the ESA. Indeed the descriptors are not appropriate for the majority of blind and partially sighted people, who have a range of difficulties associated with their sight loss (communication, navigation, safety, awareness of hazards, etc.), which cannot reasonably be covered by only one or two descriptors.

Only one descriptor in schedule 3 relates to sensory impairment - that of understanding communication. This does not adequately cover the most disabling effects of visual impairment, nor does it represent the most significant barriers to employment most blind and partially sighted people face.

Consequently, people are losing their benefits and being told that they are now job-seekers or must attend "work-related activities" to try to improve their employability. For most this is irrelevant and unhelpful.

The flaws in the assessment originate from a lack of understanding of sight loss, both within the descriptors and amongst health care professionals (HCPs) carrying out the face to face assessments.

HCPs are tasked with carrying out assessments on claimants with a wide range of impairments and we do not blame them for failing to have specialist knowledge in sight loss. However it is essential that guidance and descriptors reflect the specialist needs of those with sensory impairment in order to mitigate that risk.

“It is obvious that achieving an appropriate WCA outcome for claimants, in terms of being found fit for work or placed in the WRAG or Support Group, is very heavily dependent on whether the 3 assessment criteria are the right ones, and whether they are being applied properly”. Work and Pensions Select Committee2

“Work capability should be based on how you get about when you go to places that are unfamiliar, can you relay a message non verbally to someone or do you have to do it verbally, is reading Braille your only option, what kind of support is needed to look for work, and what kind of support is needed at work. What kind of assistive technology do you need.” Kelly, appealed ESA claimant, West Sussex

Of the ten activities covering physical functions, the two that are most relevant to claimants with sight impairment are:  activity 7: 'understanding communication'  activity 8: navigation and maintaining safety. Therefore, for someone whose only disability is sight loss, they will almost certainly need to score 15 points from those descriptors in order to qualify for ESA.

One major flaw in the test for activity 7 is the emphasis placed on the use of braille as a communication medium. The descriptor is intended to take into account the communication needs of the claimant, however the WCA states that the ability to understand a basic message in braille is enough to discount a person from accessing the support group.

Activity 7 is underpinned by an assumption that an employer will be able to provide braille communications in an emergency situation to an employee with severe sight impairment. Whilst the Equality Act 2010 requires the provision of accessible formats, it is in reality very rare that employers have the means to provide braille without ordering it from specialist transcription service (a typical braille embosser costs around £3,500).

Of the roughly 80,000 working age registered blind and partially sighted people in the UK, RNIB estimates that only about 23 per cent have tried braille, with far fewer being literate in it as a preferred communications format. Therefore it is an anomaly that this small percentage of people with severe sight impairment is unable to progress towards accessing vital ESA support because of a theoretical entitlement to braille in the workplace.

Additionally, due to the assessment being split into descriptors designed to recognise the needs of physical disabilities and those designed for mental, cognitive and intellectual function, blind and partially sighted claimants are falling between gaps. Of the seven activities covering mental, cognitive and intellectual functions (which therefore excludes blind and partially sighted people) the one that would be particularly relevant to sight loss is activity 12: awareness of everyday hazards. However, only people who have a learning difficulty are able to be assessed against this criterion.

In effect this results in a situation where although someone with a sight condition may understand that there is a risk, this information in isolation is as useless as it is to someone with a severe cognitive condition yet they will score no points: knowing there is a protruding sharp edged object in a workplace does a person no good if they have no way of determining where it is. The inflexibility of the WCA descriptors to read across impairment models means that the descriptor highlights a major issue around perception of hazards and subsequently fails to address it through the scoring mechanism, denying people with sight loss the support of ESA.

2 Work and Pensions Select Committee (July 2014) 1st Report - Employment and Support Allowance and Work Capability Assessments 4 In relation to the face to face assessment process, a regular criticism we have reported back to us is a lack of understanding of sight loss leading to inaccurate conclusions about a claimant. This lack of understanding is exemplified through the observable behaviour assessment.

The DWP assessment handbook highlights the following as the observed behaviours for daily living:

 Ask the claimant how they got to the examination centre, and how they found their way around the centre. Note whether the claimant needed to be accompanied by another person.  Note any observed ability to manipulate belts and buttons – inability to do so would indicate very severe sight loss.  Observe whether the claimant manages to read their medication labels or repeat prescription sheet.

These behaviours in the controlled environment of the assessment centre should not form the basis of assumptions about a claimant’s ability to access the labour market. For example people with very severe sight loss are as able to use buttons on familiar clothing without looking at them as a sighted person would be. This concept is known as proprioception and allows functional behaviour without the need for sight such as touch-typing or using pedals whilst driving a car. Similarly it means that an ability to manipulate belts and buttons does not equate to being able to manipulate unfamiliar clothing or complete manual tasks that would require sight.

Furthermore, a person who is registered as partially sighted can read at 6 metres what an average sighted person can read at 60 (6 over 60). Someone with a certificate of visual impairment (CVI) of severe visual impairment are at best 3 over 60 and are measured as "best performance" in the best eye. For observable behaviour in a brief assessment by someone without sight loss expertise to refute evidence supplied by an ophthalmologist on a person’s eye sight is both unreasonable and unjust.

“I was crying and sobbing after 10 minutes, all way through. The report did not say this at all, but said I “maintained good eye contact and held a good conversation”. How can you do that whilst crying?” Anonymous claimant with sight loss

Inaccessible communications (Question 10) Whilst we have heard anecdotally that the previous contractor for the WCA, Atos, had systematic procedures in place to provide communications in a claimant’s accessible format, we do not believe that this is happening routinely due to the procedures of the DWP.

“I asked for large print and was told my details had been altered to confirm that. The next letter came in large print but anything after that was back to standard print.” Anonymous survey respondent talking about DWP’s provision of accessible formats

“When I went to the local job centre to ask about claiming ESA I was given a very faintly tiny printed bit of paper and told to call the number from their phones in the office I said I was registered blind and couldn't read it, but the person just shrugged, so I had to take it home and get my mom to help me” Anonymous survey respondent talking about DWP’s provision of accessible formats

Where the preferred format requirements of blind and partially sighted claimants are not being recorded at points of contact and then shared between agencies, there is a lack of consistency on 5 format provision. This leads to claimants being excluded from vital elements of the assessment process and could result in the sanctioning of benefit. Improving the WCA for blind and partially sighted people (Questions 10, 13 and 15) We believe there are measures that the DWP should undertake as a matter of urgency to improve the WCA for blind and partially sighted people. We have outlined below practical improvements that could be made. We would welcome the opportunity discuss these further with either the review team or the DWP.

The assessment (Question 13 and 15) 1. Add greater weight to navigating around unfamiliar surroundings. Activity 8 in schedule 2 assesses a person's ability to navigate and maintain safety in familiar and unfamiliar surroundings.

Evidence suggests that problems with navigation and mobility skills are one of the main barriers to blind people gaining employment. Yet very few people, even those registered blind with minimal sight, would need another person to walk them around their own home, or to a familiar destination. Activity 8A is therefore misleading. Does this refer to the person’s own living room or the streets around their home? Depending on the interpretation of this descriptor, the potential to not score anything is quite high.

The workplace however, particularly in a new job, is by definition an unfamiliar and constantly changing surroundings, yet it is only possible to score 9 points against activity 8C. We would like to see this increased to 15 points, in order to make activity 8 meaningful to a work-related setting.

We therefore propose that the number of points scored against descriptor 8C (schedule 2) be increased from 9 to 15. More clarity should be offered around activity 8A, relating to navigation around familiar surroundings, or be combined with 8C.

2. Include navigation and maintaining safety in schedule 3. There is no descriptor around navigation and maintaining safety in schedule 3.

Navigation, mobility and maintaining safety are among the primary barriers to employment for blind and partially sighted people. We would like to see descriptors around navigating and maintaining safety, such as those in activity 8 in schedule 2, included in schedule 3.

We therefore propose an additional descriptor around navigation, mobility and maintaining safety included in schedule 3.

3. Awareness of everyday hazards in schedule 2 to encompass sight loss It is unfair that only people with mental, cognitive and intellectual conditions (not people with sight loss) can score points against activity 12: awareness of everyday hazards, in schedule 2. Sight loss can also mean you have a lack of awareness of hazards and can present the same or greater level of risk. At best, a person with sever sight impairment may be only aware of a hazard over the distance of a mobility aid such as a white cane, whereas a sighted person may be able to detect it at 10, 50 or even 100 meter distance.

Someone with severe sight impairment could not alert others of a hazard which they are unable to see in the first place.

6 We therefore propose that activity 12 in schedule 2 be included in the physical functions section, or extended to people with sensory impairment (specifically sight loss)

4. Awareness of hazard in schedule 3 to encompass sight loss Similarly, it is unfair that only people with cognitive impairment or mental disorder (not people with sight loss) can score points against activity 10: awareness of hazard, in schedule 3. Sight loss can also mean you have a lack of awareness of hazard and can present the same or greater level of risk of injury to self and other, or damage to property or possessions.

The "awareness of hazard" descriptor is very relevant for blind or partially sighted people. By widening this to include people with sensory impairment or sight loss, it is likely that more claimants with severe vision impairment could be properly assessed into the correct group for their need and therefore avoid lengthy appeals procedures.

We therefore propose that activity 10 in schedule 3 be extended to people with sensory impairment.

5. Remove braille literacy as a reasonable adaptation of communication We would like to point out that braille is usually irrelevant in the context of communication at work and the WCA interpretation in activity 7 (schedule 2) is leading to unjust decisions. Use of braille cannot be substituted for ability to read print.

The ability to read braille, which currently counts towards a blind or partially sighted person's fitness for work, should not be interpreted as an adaptation of communication in the workplace, as typical workplaces almost exclusively lack the means to produce information in braille and typical workforces are unfamiliar in using braille as a means of communication.

We therefore propose that the inclusion of braille as a reasonable aid is removed from the wording in activity 7 (schedule 2).

Communications (Question 10) Poor and inaccessible communications can not only cause increased distress and confusion for claimants, but can be unreadable if they’re not provided in the claimant’s preferred format, disenfranchising claimant’s from making their own decisions around the WCA.

Therefore the Department of Work and Pensions should routinely record the format requirements of blind and partially sighted claimants on a database that attaches this information to the claimant’s record. This recommendation is repeated in the Social Security Advisory Committee’s occasional paper on Communications in the benefits system from September 2013.

“A critical aspect of personalised communications is ensuring that people receive information from the Department using their preferred channel or format. However, evidence provided by stakeholders and the literature shows that this is not happening consistently because communications preferences are not routinely recorded by the Department….

Recommendation 5 The Department must ensure both that its staff routinely record the communication preferences of its customers and that communications are then provided through the requested channel or by using the appropriate format.” Social Security Advisory Committee report on Communications in the benefits system

7 Ensuring format information is prominent on a claimant’s application notes would also help ensure the WCA process is in line with the requirements of the Equality Act 2010. A longer term vision for the WCA As outlined above the WCA is failing to meet the needs of blind and partially sighted people in fundamental ways. Whilst we believe that there are steps that could and should be taken in the short term to improve the assessment for people with visual impairments, there is a longer term need to deliver a new assessment which works for all disability groups.

The WCA in its current form is more aligned to a medical model of disability than a social model, and is not a genuinely functional assessment of a blind or partially sighted person's ability to find and sustain employment.

Blind and partially sighted people need specialist support on their journey towards employment. In addition to barriers common with anyone out of work for a long period, blind and partially sighted jobseekers have specific needs related to their sight loss, and require intensive support and specialist interventions in key areas. This can only be addressed with an assessment process that addresses those needs.

If a blind or partially sighted person is found Fit for Work or placed into the Work Related Activity Group, there is little in the way of meaningful support offered to help them find work, or develop the skills required to help them move closer to the labour market.

The Work Programme is the Government’s main programme to support long-term unemployed people back to work in England, Scotland and Wales. Of the 690 blind or partially sighted people enrolled on the programme between 1 June 2011 and 31 March 2013, it helped just 20 (approx 2 per cent) into paid employment. Early analysis of the latest 2014 statistics suggests this situation has not improved.

A Work and Pensions Select Committee report entitled “Can the Work Programme work for all user groups?”, concludes that the Work Programme is not providing incentives to contracted providers to support those with more challenging barriers to employment (for example blind and partially sighted people).

Another recent Work and Pensions Select Committee report entitled, "The role of Jobcentre Plus in the reformed welfare system" indicates access to specialist support is limited – with an estimated ratio of one specialist DEA to more than 600 ESA WRAG claimants (compared to Jobseeker’s Allowance caseloads of around 140 claimants per adviser).

In their recently published research report (Fit For Purpose), which looks at transforming employment support for disabled people, the Centre for Social and Economic Inclusion (CESI) recommends aligning the WCA assessment process with a proper assessment of support needs, so that a person being assessed as capable of "work related activity" becomes a meaningful outcome.

Although we appreciate that no test is a perfect form of assessment, we believe these longer term ideas could be incorporated to help meet the needs of blind and partially sighted people.

We would be pleased to discuss this further with the independent review team.

For clarifications or if we can be of any assistance to the independent review team please contact Andy Pike in the RNIB policy and campaigns team: [email protected] or on 0207 391 2026

8 Andy Pike Policy and Campaigns, RNIB August 2014

9 2. Appendix 1.

3. Initial Work Capability Assessments: comparison between blind and partially sighted people and all ESA claimants: Great Britain

1. Introduction This briefing contains the most recent statistics on the outcomes of the initial Work Capability Assessments (WCA) for blind and partially sighted (BPS) Employment and Support Allowance (ESA) claimants in Great Britain. The statistics presented apply to claims for the periods from October 2008 to March, September or December 2013 (depending upon the individual table).

The statistics were provided by DWP following a Freedom of Information Act (FOI) request for an ad hoc analysis relating to ESA claimants who are blind or partially sighted. Equivalent tables for all claimants are in the Official Statistics publication, released on 24 June 2014 (DWP, 2014).

1.1 Definition of blind and partially sighted DWP administrative data has a category 'Diseases of the Eye and Adnexa'. As this includes some acute medical conditions that do not cause vision impairment ESA claimants with these acute conditions are excluded from the tables in this briefing. The tables are broken down by each of the 10 non-acute conditions in Diseases of the Eye and Adnexa detailed in appendix A.

Throughout this document, claimants with Diseases of the Eye and Adnexa with conditions that are associated with vision impairment (as detailed in appendix A) will be referred to as the BPS group.

1.2 Notes on the tables The figures provided by DWP are rounded to the nearest 100. The sum of the numbers in the tables may therefore not tally exactly with the totals given. They also exclude any numbers under ten (which are denoted as “ – “ meaning ‘nil or negligible’). All the percentages are therefore based on the DWP totals and for this reason may not add up to 100%.

10 2. Key findings

2.1 BPS claimants put forward for WCA

 Between October 2008 and September 2013 a total of 17,400 blind and partially sighted ESA claimants had undertaken or were in the process of undertaking an initial Work Capability Assessment, or had closed their claim before the assessment had been completed. o 39% of BPS claimants (6,800) were in the 'blindness and low vision' sub-group o 30.5% of BPS claimants (5,300) had their claim closed before assessment had taken place

2.2 Initial WCA outcomes

 Between October 2008 and December 2013 a total of 10,300 blind and partially sighted claimants completed their initial Work Capability Assessment. The outcomes were:

 Work Related Activity Group (WRAG): o 25% all claimants o 35% BPS claimants o 50% of BPS claimants in the WRAG group had 'Blindness and Low Vision' (this was the largest of all the BPS sub-groups)  41% of claimants with ‘blindness and low vision’ were allocated to the WRAG group

 Support Group: o 22% all claimants o 20.4% BPS claimants o 66.7% of BPS claimants in the Support Group had 'blindness and low vision' (this was the largest of all the BPS sub-groups)  32% of claimants with ‘blindness and low vision’ were allocated to the Support Group

 Fit for Work: o 54.0% all claimants o 44.7% BPS claimants o 26.1% BPS claimants found Fit for Work had 'blindness and low vision' (this was the largest of all the BPS sub-groups)  27.0% of claimants with ‘blindness and low vision’ were found Fit for Work 2.3 Fit for Work (FFW) appeals

 Between October 2008 and March 2013 a total of 4,400 blind and partially sighted claimants appealed their initial Fit for Work decision. Information on the appeal outcome was available for 38.6% of them (1,700). The outcomes were:

 Initial FFW decision overturned: o 37.0% of all claimants o 35.3% BPS claimants o 40% BPS claimants with 'blindness and low vision' 11 2.3 New claims - outcomes of initial WCA adjusted to account for the outcome of appeal

 Between October 2008 and September 2013, when the outcomes of FFW appeal decisions are taken into account the WCA outcomes for BPS claimants are:

 Fit for Work: o 37.5% BPS claimants o 20% BPS claimants with 'blindness and low vision'

 Work Related Activity Group (WRAG): o 32% of all claimants o 39.4% BPS claimants o 44.4% BPS claimants with 'blindness and low vision'

 Support Group: o 23% of all claimants o 23.1% BPS claimants o 35.6% BPS claimants with 'blindness and low vision'

2.4 New claims: reasons for assignment to Support Group

 When comparing the reasons claimants were assigned to the Support Group for new claims starting between October 2008 and September 2013 the reasons are:

 Severe functional disability: o 38% of all claimants o 74% BPS claimants o 75% BPS claimants with 'blindness and low vision'

 Physical or mental health risk: o 34.0% of all claimants o 13.0% BPS claimants o 12.5% BPS claimants with 'blindness and low vision'

 Other reason: o 12.0% of all claimants o 13.0% BPS claimants o 12.5% BPS claimants with 'blindness and low vision'

2.5 New claims: reason for assignment to WRAG

 When comparing the reasons claimants were assigned to the WRAG group for new claims starting between October 2008 and September 2013 the reasons are:

 15 points or more at assessment: o 50.0% of all claimants o 69.0% BPS claimants o 76.2% BPS claimants with 'blindness and low vision' 12  After appeal: o 22.0% of all claimants o 14.3% BPS claimants o 9.5% BPS claimants with 'blindness and low vision'

 At reconsideration: o 17.0% of all claimants o 11.9% BPS claimants o 9.5% BPS claimants with 'blindness and low vision'

 Clerical assessment: o 2.0% of all claimants o 2.4% BPS claimants o 4.8% BPS claimants with 'blindness and low vision'

 Medical reasons: o 8.0% of all claimants o 2.4% BPS claimants o For BPS claimants with 'blindness and low vision' the number was ‘nil or negligible’

2.6 New claims - WRAG (15 points or more) at functional assessment split into functional impairments Because some claimants have multiple impairments, the total figure provided by DWP over- represents the number of claimants. We have therefore based the percentages on the number of BPS claimants (2,900) and BPS claimants with blindness and low vision (1,600) that we know were allocated to the WRAG during the period October 2008 to September 2013 because they scored 15 points or more at assessment.

The percentages in this section are therefore indicative only and should be treated with some caution

 Between October 2008 and September 2013, at initial functional assessment the indicative proportions of BPS claimants assigned to the WRAG because they scored 15 points or more on specific functional impairment categories were:

 15 points or more in sensory functional impairment category: o 5.0% of all claimants o 89.7% BPS claimants o 93.8% BPS claimants with 'blindness and low vision'

 15 points or more in adapting to change category: o 46.0% of all claimants o 10.3% BPS claimants o 6.3% BPS claimants with 'blindness and low vision'

 15 points or more in understanding and focus category: o 32.0% of all claimants o 6.9% BPS claimants 13 o 6.3% BPS claimants with 'blindness and low vision'

 15 points or more in social interaction category: o 35.0% of all claimants o 6.9% BPS claimants o 6.3% BPS claimants with 'blindness and low vision'

 Blind and partially sighted people also scored15 points or more in the following categories:

o Lower limb: 10.3% o Upper limb: 3.4% o Consciousness: 3.4 %

2.7 Incapacity Benefits reassessments: outcomes of Work Capability Assessments adjusted to account for the outcome of appeal

 Since the start of the reassessment process in April 2011 and September 2013, a total of 9,600 BPS people on Incapacity Benefit (IB) were referred for reassessment. o 65.6% of BPS claimants (6,300) were in the 'blindness and low vision' sub-group o 7.3% of BPS claimants were still undergoing assessment o 3.1% of BPS claimants had their claim closed before assessment had taken place

 After adjusting for the outcome of appeals, the outcomes for completed assessments were:

 Work Related Activity Group (WRAG): o 38.0% all claimants o 32.6% BPS claimants o 60.7% of BPS claimants in the WRAG group had 'Blindness and Low Vision' (this was the largest of all the BPS sub-groups)  30.4% of claimants with ‘blindness and low vision’ were allocated to the WRAG group

 Support Group: o 42.0% all claimants o 58.1% BPS claimants o 72.0% of BPS claimants in the Support Group had 'blindness and low vision' (this was the largest of all the BPS sub-groups)  64.3% of claimants with ‘blindness and low vision’ were allocated to the Support Group

 Fit for Work: o 20.0% all claimants o 9.3% BPS claimants o 37.5% BPS claimants found Fit for Work had 'blindness and low vision' (this was the largest of all the BPS sub-groups)  5.4% of claimants with ‘blindness and low vision’ were found Fit for Work

14 3. WCA outcomes for blind and partially sighted ESA claimants in Great Britain

3.1 New claims – ESA claimants put forward for a Work Capability Assessment (WCA) Tables RNIB 1 and RNIB 2 correspond to the whole of the period in tables 1a and 7 in the DWP report. During the period October 2008 to September 2013, a total of 17,400 blind and partially sighted ESA claimants were put forward for an initial Work Capability Assessment. Of these, nearly a third (5,300 claimants representing 30.5%) had closed their claim before the assessment was complete. Just under one in ten (9.8%) were still being assessed. The initial assessment was completed for the remaining 60% (10,400).

For claimants whose claim was closed before the assessment was completed, looking at each sub-group in turn, we see that the proportion varies from virtually all claimants with Iridocyclitis and three-quarters with Disorders of the Globe, to only one in five with Blindness and Low Vision.

3.2 New claims – Outcomes of initial functional assessments Tables RNIB 3 and RNIB 4 correspond to table 2a in the DWP report. They cover the period October 2008 to December 2013.

3.2.1 Initial WCA outcomes for BPS claimants Between October 2008 and December 2013, initial WCA assessments were completed for over 10,000 (10,300) BPS claimants. More than two in five (44.7%) were found Fit for Work, just over a third (35%) were allocated to the Work Related Activity Group (WRAG) and the remaining one in five (20.4%) were allocated to the Support Group.

3.2.2 Comparison with all ESA claimants Comparing these outcomes with those for all ESA claimants, around one in five in both groups were allocated to the Support Group. For claimants with blindness and low vision the proportion was higher: 32% compared to 22% for all claimants overall.

A higher proportion of BPS claimants were allocated to the WRAG (just over a third compared to a quarter of all claimants), while a smaller proportion (over two in five) of BPS claimants were found Fit for Work compared to over half (54%) of all claimants. Again, there were differences for the blindness and low vision group, with a higher proportion allocated to the WRAG (41% compared to 25% overall) and fewer found Fit for Work (27% compared to 54% overall).

3.2.3 Comparisons between BPS sub-groups The largest sub-group of the 10,300 BPS claimants (4,400) were those with blindness and low vision representing 43% of the total. The second largest sub-group (2,900) were claimants with 'Other Disorders of the Eye and Adnexa' representing 28%. The third and fourth largest sub- groups were claimants with 'Other Cataract' (1,200) and 'Glaucoma' (800) representing 12% and 8% respectively (percentages are rounded).

Claimants in the blindness and low vision group were much less likely than BPS claimants in any of the other sub-groups to be found Fit for Work. Only 27% of this group were assessed as Fit for Work. They were also the sub-group with the highest proportion assigned to the Support Group (32%).

15 Between one half and two thirds of claimants in the other sub-groups were found Fit for Work. There doesn't seem to be any obvious reason why this may be the case, although it is important to note that the numbers in some of the groups (Keratitis, Iridocyclitis, Disorders of the Globe, Other Disorders of the Optic Nerve and Visual Pathways, and Nystagmus and Other Irregular Eye Movement) were very small, ranging from ‘nil or negligible’ to 100 claimants in total over the entire period.

The sub-groups most likely to be found Fit for Work were people with Keratitis and with Disorders of the Globe. Virtually all claimants in these sub-groups were assessed as Fit for Work (from the table it appears to be 100% but figures were rounded and there may have been very small numbers – under ten – allocated to the other groups). Two thirds (67%) of people with Other Cataract and with Retinal Detachment and Breaks were found Fit for Work.

3.3 New claims - outcomes of appeals heard on Fit for Work decisions in initial functional assessment Tables RNIB 5 and RNIB 6 correspond to the whole of the period October 2008 to March 2013 detailed in table 3 of the DWP report.

3.3.1 Outcomes of appeals for BPS claimants During the period October 2008 to March 2013 a total of 4,400 BPS claimants appealed against their Fit for Work decision. Appeal outcomes information is available for only 1,700 of these claimants, representing just under two fifths (39%). For the remaining 2,700 there is 'no completed appeals information at this date'.

Of the 1,700 claimants whose appeal outcome is known, just under two thirds (65%) had their initial decision upheld and just over one third (35%) had the initial decision overturned.

3.3.2 Comparison with all ESA claimants on appeal outcomes Comparing BPS claimants with all ESA claimants whose appeal decision details are available, there was very little difference between BPS claimants compared with all claimants overall; 37% of all claimants and 35% of BPS claimants had their initial FFW decision overturned at appeal.

Neither was there a great difference between the proportion of claimants in the blindness and low vision sub-group who had their initial decision overturned when compared with all claimants; 40% versus 37%.

3.3.3 Comparisons between BPS sub-groups on appeal outcomes Because the numbers in some of the sub-groups are so small, it is not possible to detect any meaningful differences in terms of appeal outcomes. We only have figures for four BPS sub- groups: Blindness and Low Vision, Other Cataract, Glaucoma and Other Disorders of the Eye and Adnexa.

The sub-group that made the largest number of appeals (1,600) was the Other Disorders of the Eye and Adnexa group, followed by 1,100 claimants with blindness and low vision and 800 with Other Cataract. These were also the sub-groups with the largest numbers of ESA claimants undergoing a WCA represented in tables RNIB 1 and RNIB 3.

16 3.4 New claims - outcomes of initial functional assessment adjusted to account for the outcome of appeal Tables RNIB 7 and RNIB 8 correspond to the whole of the period from October 2008 to September 2013 detailed in table 4 of the DWP report. These tables give the WCA outcome figures for BPS claimants adjusted to take into account the FFW appeal decisions.

3.4.1 Adjusted outcomes for BPS claimants Of the 10,400 BPS claimants whose claim had been completed, and taking into account the decision following appeals that had been made against the Fit for Work decision, 37% had been found Fit for Work, 39% allocated to the WRAG and 23% to the Support Group.

As a proportion of the initial FFW decisions were overturned following appeal we would expect to see a higher proportion of claimants allocated to the WRAG and Support Group. This is in fact what we do see. If we compare the outcomes for the completed assessments in RNIB tables 1 and 2 for the same period, the proportion of BPS claimants in the WRAG has increased when adjusted for the appeal outcome (from 34.6% to 39.4%) and the proportion found Fit for Work has decreased (43.3% to 37.5%). Those allocated to the Support Group has also increased slightly (22.1% to 23.1%).

See also RNIB table 16 for a comparison of outcomes before and after appeal for ESA claimants and for IB claimants following reassessment.

3.4.2 Comparisons between BPS sub-groups on adjusted outcomes When looking at WCA outcomes for BPS claimants in the different sub-groups when FFW appeal decisions have been taken into account the sub-group that stands out most from the other BPS claimant sub-groups is the blindness and low vision group. Following adjustments for appeal decisions, only a fifth (20%) of claimants in this group were found Fit for Work, compared to 37.5% of BPS claimants overall.

A higher proportion of claimants in the blindness and low vision sub-group was also allocated to the WRAG (44.4% compared to 39.4%) and the Support Group (35.5% compared to 23.1% of BPS claimants overall).

A higher proportion of claimants in the blindness and low vision group had also been allocated to the WRAG and Support Group following the overturning of their initial FFW decision (comparing RNIB tables 1 and 7). Before the appeals process 25% of claimants with blindness and low vision were found Fit for Work. If we look at the adjusted outcomes following appeal this figure has dropped to 20%. Before appeal, 41% were allocated to the WRAG and after adjusting for appeals the proportion was 44.4%. For the Support Group the proportions were 34% and 35.5% respectively.

Again, see also RNIB table 16 for a comparison of outcomes before and after appeal for ESA claimants and for IB claimants following reassessment.

3.5 New claims: Support Group at functional assessment initially or after appeal split into reasons for assignment Tables RNIB 9 and RNIB 10 correspond to the whole period from October 2008 to September 2013 detailed in table 5 of the DWP report. This gives reasons for assigning claimants to the Support Group, from the following list: 1. Chemotherapy/radiotherapy 2. Physical or mental health risk 17 3. Pregnancy risk 4. Severe functional disability 5. Terminally ill 6. Other reason

3.5.1 Reasons for assigning BPS claimants to the Support Group BPS claimants were assigned to the Support Group for one of only three reasons: Physical or Mental Health Risk, Severe Functional Disability, or Other Reason. The total number of BPS claimants assigned to the Support Group for any of the other reasons was under ten in each of those groups.

For the majority of the 2,300 BPS claimants who were assigned to the Support Group in this period, the reason give was Severe Functional Disability. Nearly three-quarters (74%) were assigned for this reason. The remaining quarter of claimants were divided equally between Physical or Mental Health Risk (13%) and Other Reason (13%).

Out of the 1,600 claimants with blindness and low vision, the same proportion (75%) as for all BPS claimants was assigned to the Support Group because of Severe Functional Disability.

3.5.2 Comparison with all claimants assigned to the Support Group A far higher proportion of BPS claimants was assigned to the Support Group due to Severe Functional Disability compared to all claimants assigned to this group (74% compared to 38%). For a smaller proportion of BPS claimants the reason was Physical or Mental Health Risk (13% compared to 34% of all claimants). Similar proportions were assigned to the Support Group for Other Reasons (13% compared to 12% of all claimants).

3.6 New claims: Work Related Activity Group at functional assessment initially or after appeal split into reasons for assignment Tables RNIB 11 and RNIB 12 correspond to the whole period from October 2008 to September 2013 detailed in table 6 of the DWP report. This gives reasons for assigning claimants to the WRAG, from the following list: 1. 15 points or more at assessment 2. Medical reasons 3. Clerical assessment 4. After appeal 5. At reconsideration

3.6.1 Reasons for assigning BPS claimants to the WRAG Of the 4,200 BPS claimants assigned to the WRAG, for the majority (69%) the reason given was that they scored 15 points or more at assessment. The next most common reasons given were After Appeal (14%) and At Reconsideration (12%). Just over one in 50 (2.4%) were assigned to the WRAG for Medical Reasons and the same proportion, following Clerical Assessment.

Of the 2,100 BPS claimants with blindness and low vision, over three quarters (76%) were assigned to the WRAG because they scored 15 points or more at assessment. Just under one in ten (9.5%) were assigned to the WRAG After Appeal and the same proportion, At Reconsideration.

18 3.6.2 Comparison with all claimants assigned to the WRAG The reason for assigning BPS claimants to the WRAG was more likely than for all claimants to be because they scored more than 15 points at assessment (69% BPS compared to 50% all claimants). BPS claimants were less likely than all other claimants to be assigned to any of the other groups, although the rank order for the reasons was the same as detailed in 3.6.1.

3.7 New claims - Work Related Activity Group (15 points or more) at functional assessment split into functional impairments Table RNIB 13 corresponds to the whole of the period from October 2008 to September 2013 detailed in table 8 of the DWP report. The functional impairment categories are: 1. Lower limb 2. Upper limb 3. Sensory 4. Continence 5. Consciousness 6. Understanding and focus 7. Adapting to change 8. Social interaction

3.7.1 All BPS claimants The figures in RNIB table 13 apply to BPS claimants who were assigned to the WRAG because they scored 15 points or more at functional assessment. However, the sum of the row totals (3,800) does not represent the total number of BPS claimants as some may have multiple impairments and will therefore have been allocated to more than one category. For this reason, the figures in table RNIB 13 have not been presented as percentages in a separate table.

Nevertheless, because we know from RNIB table 11 that the number of BPS claimants allocated to the WRAG during the period October 2008 to September 2013 was 2,900, this total has been used to calculate the indicative proportion of BPS people in each category. The percentages below should therefore be regarded as indicative only and treated with some caution. If we assume a base of 2,900 BPS claimants, we see that the majority (89.7%) were assigned to the WRAG because they scored 15 points or more on the sensory functional impairment category. The actual number of BPS claimants in this category was 2,600.

Three hundred (10.3%) BPS claimants scored 15 points or more on the adapting to change category. Two hundred (6.9%) scored 15 points or more on understanding and focus, and also on social interaction.

Other categories in which BPS claimants assigned to the WRAG scored 15 points or more were the lower limb (10.3%) upper limb and consciousness (100 claimants, or 3.4%, in the latter two groups), which have no specific relationship to vision impairment. As previously noted some BPS claimants may have been allocated to more than one reason such as sensory and upper lower limb or adapting to change and social interaction.

3.7.2 BPS claimants in the blindness and low vision sub-groups Overall, 1,500 claimants with blindness and low vision scored 15 points or more on the sensory functional impairment category. Using the same method as in 3.7.1 and using as our base the total of 1,600 in RNIB table 11, this means that over nine in ten (93.8%) of claimants with blindness and low vision were assigned to the WRAG because they scored 15 points or more on the sensory functional impairment category. 19 For the adapting to change, understanding and focus and social interaction categories the proportion was 6.3%. One in ten (10.3%) scored 15 points or more on the lower limb category and 3.4% on the lower limb and consciousness categories.

3.7.3 Comparisons between BPS and all claimants assigned to WRAG While 89.7% of BPS claimants were assigned to the WRAG because they scored 15 points or more in the sensory functional impairment category, for all claimants overall the percentage was only 5%.

Forty-six per cent of all claimants scored 15 points or more on adapting to change compared to 10.3% of BPS claimants and for social interaction the percentages were 35% overall and 6.9% for BPS claimants.

3.8 Incapacity Benefits (IB) Reassessments - Outcomes of Work Capability Assessments adjusted to account for the outcome of appeal RNIB tables 14 and 15 correspond to table 10 in the DWP report. Since the start of the reassessment process in April 2011 and September 2013, a total of 9,600 BPS people on Incapacity Benefit (IB) were referred for reassessment. The outcomes detailed below are adjusted to account for the outcomes of appeals.

3.8.1 Adjusted outcomes for BPS IB reassessments Of the 9,600 BPS IB claimants who underwent a reassessment, outcomes are known for 8,600 representing nine in ten (89.6%). Three hundred people (3.1%) had their claim closed before the assessment was completed and the assessment was still in progress for a further 700 (7.3%).

For the 9,600 IB claimants whose reassessment outcomes were known, almost three in five (58.1%) were allocated to the Support Group. One in three (32.6%) were assigned to the WRAG while just under one in ten (9.3%) were found Fit for Work.

3.8.2 Comparison with all IB reassessments on adjusted outcomes If we compare outcomes of completed reassessments for BPS claimants with all claimants we see that BPS claimants were more likely to be assigned to the Support Group (58.1% compared to 42.0%). They were less likely to be assigned to the WRAG (32.6% compared to 38.0%) or found Fit for Work (9.3% compared to 20.0%).

3.8.3 Comparisons between BPS sub-groups’ IB reassessments on adjusted outcomes By far the largest BPS sub-group of IB claimants who were put forward for reassessment was the blindness and low vision group: 6,300 claimants in total representing two thirds (65.6%) of all BPS reassessments. The second largest group was people with other disorders of the eye and adnexa: 1,600 or 16.7% of BPS IB reassessments. Ranked third in size was the glaucoma sub- group: 500 people in total representing only 5% of the BPS group.

While the small numbers of most of the BPS sub-groups makes comparison between the groups difficult, it is worth noting that the blindness and low vision group does appear to stand out as having different outcomes from the other BPS sub-groups.

Claimants with blindness and low vision were more likely than any other group – and more likely than the BPS group as a whole – to be assigned to the Support Group and far less likely to be found Fit for Work.

20 Of the 5,600 claimants with blindness and low vision whose outcomes were known, nearly two thirds (64.3%) were assigned to the Support Group. This compares to 58.1% of BPS claimants overall, and 42.9% in the next largest sub-group, people with other disorders of the eye and adnexa. For the other, much smaller BPS sub-groups the proportions ranged from 33.3% to 50%.

Only one in 20 claimants with blindness and low vision was found Fit for Work (5.4%). This is a much smaller proportion than the 21.4% of claimants with other disorders of the eye and adnexa and the 9.3% of BPS claimants overall.

The differences were less in relation to allocation to the WRAG. For the blindness and low vision sub-group the proportion allocated to the WRAG was 30.4% compared to 35.7% with other disorders of the eye and adnexa and 32.6% of BPS claimants overall.

The fact that most claimants with chronic conditions affecting their vision who were on Incapacity Benefit were in the blindness and low vision sub-group indicates that most were indeed sight impaired. The finding that nearly two thirds of this group were, on reassessment assigned to the Support Group and only one in 20 found Fit for Work indicates that the vast majority had been correctly assessed as entitled to IB originally.

Sue Keil National research officer (education, transition and employment) Evidence and Service Impact 28 July 2014 References

DWP (2014) Employment and Support Allowance: outcomes of Work Capability Assessments, Great Britain. Quarterly Official Statistics Bulletin. 24 June 2014

21 Appendix 1a

Diseases of the Eye and Adnexa (ICD10): Conditions that are associated with vision impairment

The list below is taken from the DWP category 'Diseases of the Eye and Adnexa'. Because this includes some acute medical conditions that do not cause vision impairment, we have removed the acute conditions from the Diseases of the Eye and Adnexa category and would like analysis of DWP data to include only those people with the following 10 conditions:

 H16 - Keratitis (inflammation of the cornea)  H20 - Iridocyclitis (acute inflammatory disease of the anterior segment)  H26 - Other cataract  H33 - Retinal detachment and breaks  H40 - Glaucoma  H44 - Disorders of the globe  H47 - Other disorders of the optic (2nd) nerve and visual pathways  H54 - Visual impairment including blindness (binocular or monocular) (Blindness and low vision)  H55 - Nystagmus and other irregular eye movement  H57 - Other disorders of the eye and adnexa

Acute conditions that have been removed from the Diseases of the Eye and Adnexa category  Hordeolum and chalazion (these are inflammatory eye disorders)  Other inflammation of the eyelid  Conjunctivitis  Foreign body on external Eye  Other Inflammation of Eyelid

22 Appendix 1b

Table RNIB 1: New Claims - Outcome of initial functional assessment that were completed between October 2008 and September 2013, Great Britain: number of BPS claimants (corresponds to tables 1a and 7 in DWP report) Support Work Related Fit for Claim closed Assessment still Health Condition Group Activity Group Work before assessment in progress complete Keratitis - - 100 100 - Iridocyclitis - - - 100 - Other cataract 100 300 800 1,100 100 Retinal detachment and breaks - 100 200 300 - Glaucoma 100 300 400 300 100 Disorders of the Globe - - 100 300 - Other disorders of the optic (2nd) nerve and visual pathways - - - - - Blindness and low vision 1,500 1,800 1,100 1,300 1,100 Nystagmus and other irregular eye movement - - - - - Other disorders of the eye and adnexa 400 900 1,700 1,800 400 All 2,300 3,600 4,500 5,300 1,700 Notes: 1. Figures are rounded to the nearest 100 and totals may not sum due to the rounding used. 2. “ – “ denotes nil or negligible Table RNIB 2: New Claims - Outcome of initial functional assessment that were completed between October 2008 and September 2013, Great Britain: percentage of BPS claimants (corresponds to tables 1a and 7 in DWP report) Support Group Work Related Fit for Claim closed Assessment still in Health Condition Activity Group Work before assessment progress complete Keratitis - - 2.2% 1.9% - Iridocyclitis - - - 1.9% - Other cataract 4.3% 8.3% 17.8% 20.8% 5.9% Retinal detachment and breaks - 2.8% 4.4% 5.7% - Glaucoma 4.3% 8.3% 8.9% 5.7% 5.9% Disorders of the Globe - - 2.2% 5.7% - Other disorders of the optic (2nd) nerve and visual pathways - - - - - Blindness and low vision 65.2% 50.0% 24.4% 24.5% 64.7% Nystagmus and other irregular eye movement - - - - - Other disorders of the eye and adnexa 17.4% 25.0% 37.8% 33.9% 23.5% Base 2,300 3,600 4,500 5,300 1,700

Proportion allocated to each group 13.2% 20.7% 25.9% 30.5% 9.8%

Notes: 1. Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum 2. “ – “ denotes nil or negligible Table RNIB 3: New Claims – Outcomes of initial functional assessments that were completed between October 2008 and December 2013, Great Britain: number of BPS claimants (corresponds to table 2a in DWP report) Support Group Work Related Fit for Work Health Condition Activity Group Keratitis - - 100 Iridocyclitis - - - Other cataract 100 300 800 Retinal detachment and breaks - 100 200 Glaucoma 100 300 400 Disorders of the Globe - - 100 Other disorders of the optic (2nd) nerve and visual pathways - - - Blindness and low vision 1,400 1,800 1,200 Nystagmus and other irregular eye movement - - - Other disorders of the eye and adnexa 400 900 1,600 All 2,100 3,600 4,600 Notes: 1. Figures are rounded to the nearest 100 and totals may not sum due to the rounding used. 2. “ – “ denotes nil or negligible Table RNIB 4: New Claims – Outcomes of initial functional assessments that were completed between October 2008 and December 2013, Great Britain: percentage of BPS claimants (corresponds to table 2a in DWP report) Support Group Work Related Fit for Work All * Health Condition Activity Group Keratitis - - 2.2% 1.0% Iridocyclitis - - - - Other cataract 4.8% 8.3% 17.4% 11.7% Retinal detachment and breaks - 2.8% 4.3% 2.9% Glaucoma 4.8% 8.3% 8.7% 7.8% Disorders of the Globe - - 2.2% 1.0% Other disorders of the optic (2nd) nerve and visual - pathways - - - Blindness and low vision 66.7% 50.0% 26.1% 42.7% Nystagmus and other irregular eye movement - - - - Other disorders of the eye and adnexa 19.0% 25.0% 34.8% 28.2% Base 2,100 3,600 4,600 10,300

Proportion allocated to each group 20.4% 35.0% 44.7% 100%

Total population (from DWP table 2a) 22.0% 25.0% 54.0% 100% Notes: 1. Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum 2. “ – “ denotes nil or negligible *Totals are slightly under-represented as they are based on the figures provided and do not include nil or negligible figures “ – “ Table RNIB 5: New Claims - Outcome of appeals heard on Fit for Work (FFW) decisions in initial functional assessment for claims starting between October 2008 and March 2013, Great Britain: number of BPS claimants (corresponds to table 3 of DWP report) Initial decision Initial decision upheld No completed appeals Health condition overturned information at this date Keratitis - - - Iridocyclitis - - - Other cataract 100 200 500 Retinal detachment and breaks - - 100 Glaucoma 100 100 200 Disorders of the Globe - - 100 Other disorders of the optic (2nd) nerve and visual pathways - - - Blindness and low vision 200 300 600 Nystagmus and other irregular eye movement - - - Other disorders of the eye and adnexa 200 400 1,000 All 600 1,100 2,700 Notes: 1. Figures are rounded to the nearest 100 and totals may not sum due to the rounding used. 2. “ – “ denotes nil or negligible Table RNIB 6: New Claims - Outcome of appeals heard on Fit for Work (FFW) decisions in initial functional assessment for claims starting between October 2008 and March 2013, Great Britain: percentage of BPS claimants (corresponds to table 3 of DWP report) Initial decision Initial decision upheld No completed appeals All* Health condition overturned information at this date Keratitis - - - - Iridocyclitis - - - - Other cataract 16.7% 18.2% 18.5% 18.2% Retinal detachment and 2.3% breaks - - 3.7% Glaucoma 16.7% 9.1% 7.4% 9.1% Disorders of the Globe - - 3.7% 2.3% Other disorders of the - optic (2nd) nerve and visual pathways - - - Blindness and low vision 33.3% 27.3% 22.2% 25.0% Nystagmus and other irregular eye movement - - - - Other disorders of the eye and adnexa 33.3% 36.4% 37.0% 36.4% Base 600 1,100 2,700 4,400

Proportion allocated to 100% each group 13.6% 25.0% 61.4%

Proportion allocated to 100% each group where appeal outcome is known 35.3% 64.7%

Total population where 100% appeal outcome is known (from DWP table 3) 37.0% 63.0% Notes: Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum. “ – “ denotes nil or negligible *Totals are slightly under-represented as they are based on the figures provided and do not include nil or negligible figures “ – “ Table RNIB 7: New Claims - Outcome of initial functional assessment adjusted to account for the outcome of appeal for claims starting between October 2008 and September 2013, Great Britain: number of BPS claimants (corresponds to table 4 in DWP report) Support Group Work Related Fit for Work Claim closed Assessment still in Activity Group before progress Health condition assessment complete Keratitis - 100 100 100 - Iridocyclitis - - - 100 - Other cataract 100 400 700 1,100 100 Retinal detachment and breaks - 100 200 300 - Glaucoma 100 300 400 300 100 Disorders of the Globe - 100 100 300 - Other disorders of the optic (2nd) nerve and vis pathways - - - - - Blindness and low vision 1,600 2,000 900 1,300 1,100 Nystagmus and other irregular eye movement - - - - - Other disorders of the eye and adnexa 400 1,100 1,500 1,800 400 All 2,400 4,100 3,900 5,300 1,700 Notes: 1. Figures are rounded to the nearest 100 and totals may not sum due to the rounding used. 2. “ – “ denotes nil or negligible Table RNIB 8: New Claims - Outcome of initial functional assessment adjusted to account for the outcome of appeal for claims starting between October 2008 and September 2013, Great Britain: percentage of BPS claimants (corresponds to table 4 in DWP report) Support Group Work Related Fit for Claim closed before Assessm All* Health Activity Group Work assessment complete ent still in condition progress Keratitis - 2.4% 2.6% 1.9% - 1.7% Iridocyclitis - - - 1.9% - 0.6% Other cataract 4.2% 9.8% 17.9% 20.8% 5.9% 13.8% Retinal 3.4% detachment and breaks - 2.4% 5.1% 5.7% - Glaucoma 4.2% 7.3% 10.3% 5.7% 5.9% 6.9% Disorders of the 2.9% Globe - 2.4% 2.6% 5.7% - Other disorders - of the optic (2nd) nerve and vis pathways - - - - - Blindness and 39.7% low vision 66.7% 48.8% 23.1% 24.5% 64.7% Nystagmus and - other irregular eye movement - - - - - Other disorders 29.9% of the eye and adnexa 16.7% 26.8% 38.5% 33.9% 23.5% Base 2,400 4,100 3,900 5,300 1,700 17,400

% allocated to 100% each group 13.8% 23.6% 22.4% 30.5% 9.8%

% allocated to 23.1% 39.4% 37.5% each group where WCA outcome is known Notes: Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum. “ – “ denotes nil or negligible *Totals are slightly under-represented as they are based on the figures provided and do not include nil or negligible figures “ – “ Table RNIB 9: Support Group at functional assessment initially or after appeal split into reasons for assignment for new claims starting between October 2008 and September 2013, Great Britain: number of BPS claimants (corresponds to table 5 in DWP report) Chemotherapy/radiotherapy Physical or Pregnancy Severe Terminally Other reason Health condition mental health risk functional ill risk disability Keratitis ------Iridocyclitis ------Other cataract - - - 100 - - Retinal detachment and breaks ------Glaucoma - - - 100 - - Disorders of the Globe ------Other disorders of the optic (2nd) nerve and vis pathways ------Blindness and low vision - 200 - 1,200 - 200 Nystagmus and other irregular eye movement ------Other disorders of the eye and adnexa - 100 - 300 - 100 All - 300 - 1,700 - 300 Notes: 1. Figures are rounded to the nearest 100 and totals may not sum due to the rounding used. 2. “ – “ denotes nil or negligible Table RNIB 10: Support Group at functional assessment initially or after appeal split into reasons for assignment for new claims starting between October 2008 and September 2013, Great Britain: percentage of BPS claimants (corresponds to table 5 in DWP report) Chemo-therapy Physical or Pregnancy Severe Termi Other reason All* Health /radio-therapy mental health risk functional nally condition risk disability ill Keratitis ------Iridocyclitis ------Other cataract - - - 5.9% - - 4.3% Retinal - detachment and breaks ------Glaucoma - - - 5.9% - - 4.3% Disorders of - the Globe ------Other - disorders of the optic (2nd) nerve and vis pathways ------Blindness and 69.6% low vision - 66.7% - 70.6% - 66.7% Nystagmus - and other irregular eye movement ------Other 21.7% disorders of the eye and adnexa - 33.3% - 17.6% - 33.3% Base - 300 - 1,700 - 300 2,300

% allocated - 13.0% - 74.0% - 13.0% to each 100% reason

% total population allocated to 100% each reason (from DWP table 5) 10.0% 34.0% 1.0% 38.0% 5.0% 12.0% Notes: Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum. “ – “ denotes nil or negligible *Totals are slightly under-represented as they are based on the figures provided and do not include nil or negligible figures “ – “ Table RNIB 11: Work Related Activity Group at functional assessment initially or after appeal split into reasons for assignment for new claims starting between October 2008 and September 2013, Great Britain: number of BPS claimants (corresponds to table 6 in DWP report) 15 Medical reasons Clerical After appeal At reconsideration points or assessment Health condition more at assessm ent Keratitis - - - - - Iridocyclitis - - - - - Other cataract 200 - - 100 100 Retinal detachment and breaks 100 - - - - Glaucoma 200 - - - - Disorders of the Globe - - - - - Other disorders of the optic (2nd) nerve and vis pathways - - - - - Blindness and low vision 1,600 - 100 200 200 Nystagmus and other irregular eye movement - - - - - Other disorders of the eye and adnexa 700 - - 200 200 All 2,900 100 100 600 500 Notes: 1. Figures are rounded to the nearest 100 and totals may not sum due to the rounding used. 2. “ – “ denotes nil or negligible Table RNIB 12: Work Related Activity Group at functional assessment initially or after appeal split into reasons for assignment for new claims starting between October 2008 and September 2013, Great Britain: proportion of BPS claimants (corresponds to table 6 in DWP report) 15 points or more at Medical Clerical After appeal At All* Health assessment reasons assessment reconsid- condition eration Keratitis ------Iridocyclitis ------Other cataract 6.9% - - 16.7% 20.0% 9.5% Retinal detachment and breaks 3.4% - - - - 2.4% Glaucoma 6.9% - - - - 4.8% Disorders of the Globe ------Other disorders of the optic (2nd) nerve and vis pathways ------Blindness and low vision 55.2% - 100% 33.3% 40.0% 50.0% Nystagmus and other irregular eye movement ------Other disorders of the eye and adnexa 24.1% - - 33.3% 40.0% 26.2% Base 2,900 100 100 600 500 4,200

% allocated to each reason 69.0% 2.4% 2.4% 14.3% 11.9% 100%

% total 50.0% 8.0% 2.0% 22.0% 17.0% 100% population allocated to each reason (from DWP table 6) Notes: Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum. “ – “ denotes nil or negligible *Totals are slightly under-represented as they are based on the figures provided and do not include nil or negligible figures “ – “ Table RNIB 13: New Claims - Work Related Activity Group (15 points or more) at initial functional assessment split into functional impairments and health condition for claims starting between October 2008 and September 2013, Great Britain: number of BPS claimants (corresponds to table 8 in DWP report) Lower Limb Upper Limb Sensory Continence Conscious- Understand- Adapting to Social ness ing and Change Interaction Focus Keratitis ------Iridocyclitis ------Other cataract - - 200 - - - - - Retinal detachment and breaks - - 100 - - - - - Glaucoma - - 200 - - - - - Disorders of the Globe ------Other disorders of the optic (2nd) nerve and vis pathways ------Blindness and low vision 100 - 1,500 - - 100 100 100 Nystagmus and other irregular eye movement ------Other disorders of the eye and adnexa 100 - 600 - - - 100 - All 300 100 2,600 - 100 200 300 200

Base of 10.3% 3.4% 89.7% - 3.4% 6.9% 10.3% 6.9% 2,900 * *Because some claimants had multiple impairment s the overall total is an over- representat ion. The base is an estimate, taken from RNIB table 11 Table RNIB 14: Incapacity Benefits Reassessments - Outcomes of Work Capability Assessments adjusted to account for the outcome of appeal for claims starting between April 2011 to September 2013, Great Britain: number of BPS claimants (corresponds to table 10 in DWP report) Support Group Work Related Fit for Work Claim closed Assessment still in Activity Group before progress assessment complete Keratitis - - - - - Iridocyclitis - - - - - Other cataract 100 100 100 - - Retinal detachment and breaks 100 100 - - - Glaucoma 200 200 100 - - Disorders of the Globe - - - - - Other disorders of the optic (2nd) nerve and vis pathways 100 100 - - - Blindness and low vision 3,600 1,700 300 200 500 Nystagmus and other irregular eye movement - - - - - Other disorders of the eye and adnexa 600 500 300 100 100 All 5,000 2,800 800 300 700 Table RNIB 15: Incapacity Benefits Reassessments - Outcomes of Work Capability Assessments adjusted to account for the outcome of appeal for claims starting between April 2011 to September 2013, Great Britain: percentage of BPS claimants (corresponds to table 10 in DWP report) Support Group Work Related Fit for Work Claim closed Assessment still Activity Group before in progress assessment complete Keratitis - - - - - Iridocyclitis - - - - - Other cataract 2.0% 3.6% 12.5% - - Retinal detachment and breaks 2.0% 3.6% - - - Glaucoma 4.0% 7.1% 12.5% - - Disorders of the Globe - - - - - Other disorders of the optic (2nd) nerve and vis pathways 2.0% 3.6% - - - Blindness and low vision 72.0% 60.7% 37.5% 66.7% 71.4% Nystagmus and other irregular eye movement - - - - - Other disorders of the eye and adnexa 12.0% 17.9% 37.5% 33.3% 14.3% Base 5,000 2,800 800 300 700

Proportion allocated to each group 52.1% 29.2% 8.3% 3.1% 7.3%

Proportion allocated to each group where assessment completed 58.1% 32.6% 9.3%

Total population outcomes where assessment completed 42.0% 38.0% 20.0%

41 Notes: Percentages are based on totals in DWP table; some totals in the original table were subject to rounding and totals did not sum. “ – “ denotes nil or negligible Table RNIB 16: Outcomes before and after appeal for BPS ESA claimants and IB reassessments ESA claimants – initial ESA claimants – initial ESA claimants - IB reassessments - outcomes before appeal outcomes before appeal outcomes adjusted to outcomes adjusted to account for outcome of account for outcome of (RNIB tables 1 & 2) (RNIB tables 3 & 4) appeal appeal (RNIB tables 7 & 8) (RNIB tables 14 & 15) Oct 08 – Sept 13 Oct 08 – Dec 13 Oct 08 – Sept 13 April 11 – Sept 13 Support Group BPS: 22.1% BPS: 20.4% BPS: 23.1% BPS: 58.1%

B&LV: 34.0% B&LV: 32.0% B&LV: 35.6% B&LV: 64.3% WRAG BPS: 34.6% BPS: 35.0% BPS: 39.4% BPS: 32.6%

B&LV: 41.0% B&LV: 41.0% B&LV: 44.4% B&LV: 30.4% Fit for Work BPS: 43.3% BPS: 44.7% BPS: 37.5% BPS: 9.3%

B&LV: 25.0% B&LV: 27.0% B&LV: 20.0% B&LV: 5.4% BPS: blind and partially sighted claimants B&LV: BPS claimants in the blindness and low vision sub-group

42

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