Dr. Joanne McCarthy:

I thank the committee for the invitation to discuss this important issue. The Disability Federation of Ireland, DFI, represents the rights and expectations of those who live with disabilities to be fully included in Irish society. We are an umbrella organisation that supports more than 130 member organisations and these support and provide services to all people with disabilities whether they are hidden, physical, intellectual, mental health, sensory, neurological or emotional.

This issue has been high on the DFI agenda for some time. We have an internal network of interests. The membership is drawn from people with disabilities and interested organisations around social protection and the issue we are here to discuss has come up through that

We participate on the Department's disability consultative forum and, along with other disability organisations, brought this issue to the Department and we acknowledge that the Department ran with an initiative to address it. For all of us here, this has been an ongoing issue.

To epitomise some of the challenges we are facing, and I will refer only to the disability allowance because I do not want to go into all the payments to which this relates, we know from the Department's own statistics for 2014 that there were over 111,000 people on disability allowance. In that same period, 27,000 decisions were made on disability allowance eligibility and over half of those were refused on the first application. We know that during the same period almost 6,000 disability allowance appeals were heard and that two thirds of those were granted. It is clear from that snapshot of the Department's own statistics that a disproportionate number of people are being refused disability allowance on the first application, which highlights to us that there are procedural questions that must be asked about protocols and the way systems are operated. Members will appreciate the stress that is causing for the people with disabilities and their families who are involved in submitting these applications.

Drawing on our own work, which Ms Joan O'Donnell chairs, in terms of our network of interests and also the work that has taken place through the initiative of the Department of Social Protection we are using that as our raw data to support what we see as some of the core issues facing us when we talk about this issue. First, we believe the decisions are made largely on a medical assessment. In most cases, that is a desk-based analysis. It does not give persons with disabilities or, as we heard earlier, carers the opportunity to describe the impact the disability is having on their capacity to work or otherwise. It does not provide the opportunity to perform a holistic assessment on that person. The members might use slightly different terms but we are looking for the opportunity of a much more holistic assessment that will examine not just the medical issue around disability but how that has an impact in terms of someone's physical or mental well-being. I refer also to the family circumstances that person may be in or the other inter-relations that take place. For example, if someone who wants to go to work it will vary depending on the educational capital that person has at hand. That is the first issue that is arising repeatedly through our engagement on this issue.

Second, there is evidence to suggest that for the Department, the medical assessor's opinion is taking precedent. This was substantiated significantly in recent case law in the case of a personal application for a domiciliary care allowance where it was found that the assessment did not give what they called due weight to the professional reports from other professionals or multidiciplinary teams that work with the claimant on an ongoing basis. It found that the Department's mindset was that these professional reports were coloured in some way in favour of the applicant. In their findings they said they felt that this was not an isolated case and an issue that was persistent.

What we are saying is that equal regard to all forms of assessment reports must be put on the table, not just the medical assessor's report but also other reports that support people to live with a disability on a daily or weekly basis. Also, we need to highlight the fact that the way decisions are being made is inappropriate. The concept of that desk-based analysis is inappropriate.

The third issue that arises repeatedly in this regard is the wide perception not just among people with disabilities but among general practitioners and other allied health professionals that, typically, people are refused at the initial application stage. People often expect that their application will be refused so they withhold information to substantiate any appeals process. There is also the sense, and we got this from our discussions with people with disabilities, that they believe the appeals officers operate more independently in their decision making, and that is fuelling a particular take within the system.

There are other concerns that interweave with what we would see as the three main areas. For some people it would be the cost of the appeals process. Often people are asked to get independent consultant reports which they have to fund themselves. There is also widespread misunderstanding about the types of payments, how one can apply and the level of information required on the application form, and that is having an impact.

There is a much wider issue, which the OECD stated in 2008, that people with disabilities get parked on these payments. They are not able to access activation measures, similar to people on the live register. The members will be aware of the level of rejections of appeals. Many people with disabilities are almost too frightened to take the risk and investigate whether they could go back to work or further education.

We have spoken a good deal about high level policy issues we believe must be addressed when discussing this topic but we are anxious that the members do not lose sight of who it is we are talking about in terms of the people making applications. We know from the census of population that there are almost 600,000 people with disabilities in Ireland. We also know that in 2014, just over 111,000 of those were on disability allowance. This is a particular cohort of people who are seeking this support and resource from the Department. They need to understand that those people probably feature in the statistics to which I am about to refer.

We know that in 2010, 40% of people with disabilities did not go past first level education, as opposed to 50% of the general population. Some 21% of people with disabilities aged between 15 to 65 are in work, compared to 50% of the population. We know also that 53% of people with disabilities are living in deprivation. That figure has risen significantly since 2009 when the figure was 36%. Those people are bearing the brunt of the recession and are significantly dependent on social welfare payments to ease some of that burden.

In summary, the Disability Federation of Ireland believes there is strong evidence to show that it is time to review the medical eligibility criteria for illness and disability payments and that these claims are substantiated by a number of sources. We know from our internal working group in the DFI, our network of interests, that there is an ongoing issue. The Department's statistics bear fruit in that regard. We also know, and it is now supported in case law, that if we are to be honest-----