Mark Willis examines official research and analysis on managed migration to universal credit (UC).
DWP research
In August, the DWP published its latest research and analysis on managed migration,
Completing the Move to Universal Credit: Learning from initial Tax Credit migrations.
1 The report covers the ‘operational phase’ from November 2022 to May 2023, when managed migration began to expand in selected areas to claimants receiving tax credits only. The DWP’s report, based on analysis of migration data and in-depth interviews with claimants and staff, is divided into four areas.
The migration notice and reminders
The DWP recognises the importance of the migration notice providing clear, relevant and essential information. As a result of research, feedback and stakeholder engagement, it has made several changes to the wording of the migration notice including making it clearer that:
•moving to UC does not happen automatically;
•claimants need to apply for UC and also renew tax credits;
•UC can be claimed if claimants have capital over £16,000;
•UC is for people in work as well as people who are out of work.
It has added signposts to Citizens Advice’s ‘Help to Claim’ service and Advicelocal. The HMRC logo is placed on migration notices for tax credits claimants.
The DWP also acknowledges the effectiveness of the reminder notice, currently sent at week seven, in encouraging people to claim UC.
Support and contact for claimants
Approximately one in five claimants contacted the dedicated managed migration helpline. The DWP concludes from this that ‘tax credit claimants are more likely to be able to self-serve through the digital application system and make their transition to Universal Credit independently’. The migration notice directs people to the specific page for people who have received a migration notice (), but DWP research found claimants used search instead, directing them to generic UC pages or online benefit calculators, which could be misleading as regards transitional protection. The DWP intends to improve its managed migration-specific content (so that it is easier to find by searching), amend the general content to include managed migration and, with stakeholders, provide online benefit calculators.
Outbound calls were made to claimants nearing their deadline, but the DWP attributed the low response rate to claimants being more likely to be in work and unavailable and also less likely to answer unknown calls.
The claim process
The DWP observed the trend of some claims being made rapidly at the outset and a large number being made immediately before the deadline. Some claimants made active decisions to delay claims until after their next tax credits payment or to save up in case of a delay, because of a recent or imminent change of circumstances, or were waiting for support with the application. The majority claimed and verified identity online, which the DWP found supported its assumption that most tax credits claimants are comfortable with the online service, with a low number of telephone claims and face-to-face appointments. Those who did not use the online service were more likely to be frustrated with the process, mainly because most were employed and unable to make appointments.
The DWP’s analysis also reveals that ‘there is some evidence to suggest that claimants do not fully understand how transitional protection is calculated’. This may come as no surprise to advisers who have been struggling with what the DWP calls ‘its inherent complexity’, and the fact that decision notices do not explain how the transitional element is calculated. The report commits to going further to improve claimants’ understanding.
Extensions and terminating legacy benefits
The report notes ‘a consistent, if relatively small, proportion of tax credit claimants not making a claim to Universal Credit’ and identifies emerging themes as to why.
•Some claimants made a conscious decision not to claim as it was not worthwhile for a small amount given the time they perceived needed to apply and comply with subsequent requirements.
•Some claimants believed they were not eligible for UC, as their circumstances had recently changed and their tax credits had already stopped, in some cases, due to an increase in income.
•Some claimants felt a stigma attached to claiming UC as it combined in and out of work benefits, and that they did not need it as their income was sufficient, and they believed that benefits should only be for those who really need them.
The DWP says that it is continually testing, learning and adapting its approach for managed migration and will be undertaking further analysis to understand claimants’ experience and work closely with stakeholders to ‘inform further improvements’. It aims to notify over half a million households claiming tax credits only by the end of 2023/24. The report confirms plans for the remaining tax credits claimants, including those on employment and support allowance (ESA) and tax credits, and those on housing benefit (HB), income support and income-based jobseeker’s allowance to be notified by the end of 2024/25, with the remaining 800,000 on ESA only, or ESA and HB, delayed until 2028/29.
CPAG comment
CPAG suggests the reasons identified by the DWP for people not claiming UC demonstrate the importance of independent advice to make informed decisions. Those who failed to claim may have been unaware that even a small amount of UC is a passport to other help, such as cost of living payments. Opting out may seem like the easier option when faced with the intricacies of how changes in income affect tax credits, transitional protection and in-work conditionality under UC. The perceived stigma attached to claiming UC also reflects one positive aspect of tax credits: they were often seen as a tax advantage rather than a benefit, and originally designed with a view to progressive universalism, which is lost in the move to UC.
Of further concern is the DWP’s apparent assumption that most tax credits claimants can manage this process independently, and it is only a ‘relatively small’ proportion at the higher end of the income scale who drop out. Closer analysis by CPAG of the statistics on completed cases between November 2022 and March 2023 indicates that 28 per cent did not claim UC at all and had their legacy benefit payments terminated. Over a quarter of claimants receiving working tax credit without children are disabled workers,
2 including those with learning disabilities, sensory impairments and mental health issues, some of whom may be in low-paid work and may have managed the stability of tax credits for several years but may find the move to UC challenging.
CPAG briefing
CPAG’s managed migration project has produced a more detailed analysis of the statistics accompanying the report and advisers’ experience of managed migration so far, as informed by our Early Warning System, advice lines and training.
3 The briefing covers the following topics.
•Face-to-face ID appointments.
•Insufficient communication with claimants.
•The importance of deadline extensions.
•Lack of information for self-employed claimants.
•Difficulty getting help from a third party.
•Improving telephone claims.
Our research highlights why a sizable minority is falling through the gaps and recommends what the DWP can do to ensure that everyone sent a migration notice understands the letter’s implications and can make and manage a UC claim.