Dr. Ray Griffin:

Good morning and thank you for the kind invitation to this meeting. I wish to thank my South East Technological University, SETU, research team and colleagues for reviewing my observations and Science Foundation Ireland's National Challenge Fund for supporting my current work on digital welfare and digital social policy.

Our work in the Waterford Un/Employment Research Collaborative, WUERC, is orientated towards ethnographic studies of the experience of unemployment, including the institutional and administrative infrastructure. We have very limited data on the experience of Means-testing, and nothing as rich as what TDs get in their clinics. TDs are probably world experts on the ins and outs of our welfare system at the client experience level. Indeed, the Department of Social Protection is something of a black box for all Irish social policy researchers, so we tend to focus on input,output research and public reporting. There is very limited understanding of the lived experience of Means-testing and of the actual internal administrative machinery and how it all works. As a result, my observations are more akin to open questions on the systematic and organisational approach to Means-testing.

Like other witnesses, I note that a unique feature of social welfare is how much of our system relies on Means-testing and the high percentage of total disbursements made using means-tested payments. Our welfare system is a perpetual calibration, an automatic stabiliser against the extremes of poverty. At the moment it is altering, with varied success, to the dramatic rise in the cost of living and housing. Informing this calibration, like all previous calibrations, is an earnest effort to statistically identify and target specific anti-poverty interventions. In response to Ireland’s peculiarly high level of income inequality before taxes and government transfers, governments prefer to respond to with highly-targeted measures so Means-testing is somewhat overused in our system. The collective effect of this is that we are left with a very complex, unwieldy and administratively problematic means-testing system. Each version of the means test has its own particular internal logic, rules, thresholds and disregards and it is really difficult to access and navigate those rules. There is also a long waiting time for determinations, with a considerable volume of paperwork being produced, reviewed and examined, including the date thresholds of different elements. All of this can be counterproductive to the original goal of welfare. I certainly would hate to be tested here today on the finer points of the operation of any of the Means-testing schemes.

The specific problems of means-testing are reasonably well known. There is significant concern over the disincentive to apply and the rate of under claiming and non-claiming that happens on foot of means-testing. We have no data on this. Means-testing takes time, is complex, invasive, unpredictable and can be humiliating for those subject to it. It favours the organised, knowledgeable and capable claimant. Indeed, I tested the guidelines on the Department of Social Protection website, which indicate a literacy level of around 50, which means that a university- or college-level education is needed to understand the means-testing guidelines. It is also unclear whether means-testing is objective, flexible and fair and being caught on the wrong side of a threshold can have a disproportionate effect. A person could have €1 of extra income per week, or €52 per year and could lose out on an entire payment. It is very hard to know how means-testing assesses volatile income, which is a particular issue for seasonal workers, farmers, self-employed people and those with flexible work contracts. We do not know how the difference in costs, income and asset ownership thresholds and disregard rates are assessed in different parts of Ireland. The value of a house or an income, for example, as well as spending patterns, are very different in different parts of our country. The more complex the rules, the more open they are to different interpretations. Things like date thresholds and other minutiae become critical and can be interpreted favourably or negatively. I also note that there is a reasonably high rate of appeal on means tested payments and this is perpetually reported as a source of discussion in the formal dialogue between the chief appeals officer and the head of the decisions advisory office in the Department.

I really welcome this committee’s exploration of means-testing and the Department's exploration of same and have a number of recommendations. We need high quality econometric analysis on the trade-off between universal benefits, direct services and targeted means-testing payments. That analysis should take account of the cost and time of administering means-testing, their targeting accuracy, the impact on non-claiming and under-claiming, and the potential deadweight effects of over-payments to the nearly poor enough, that is, those who fall just outside the bands and thresholds. We do not have that data. That work is not done so we are flying blind, so to speak. We need to get serious about capturing data that analyses under-claiming and poverty in particular. We might also consider if the concept of an adult dependant is still socially, culturally and economically appropriate. The patriarchal vestiges in our welfare system work to reduce the autonomy of poorer people in our society. This is particularly true with things like the cohabiting rules, which bring the Department into very strange places in examining people's lives.

Beyond this, so much more could be done to make people aware of their entitlements. We really need to simplify claimant pathways but that does not mean that we simplify our anti-poverty schemes. We need to make the system more sensible and intuitive for users who interact with it. This is particularly true where whole-of-government linkages between Revenue, the Department and health and local authorities are essential to service provision. The Department's first message to claimants should be hopeful and kind. The touch points of our welfare State should be graceful. This is vital in the context of ever more centralised, complicated system where people no longer have the ability to drop in to a local office and meet somebody who will help them to navigate it. Despite the use of the term "client" from time to time by the Department, experiential data on user experience shows that attention to the user's experience of application forms and digital systems is very low. Claimants do not have consumer agency or choice interacting with the Department. They need to be treated as people with entitlements and rights.