Managed migration: the risks of DWP’s approach

Z2K’s Jamie Thunder explains why DWP needs to take responsibility for moving people on to Universal Credit, rather than putting claimants at risk

Over the next five-and-a-half years, the Department for Work and Pensions (DWP) wants to move everyone who currently receives a ‘legacy benefit’ like Tax Credits, Income Support, and Employment Support Allowance, onto Universal Credit, in a process known as ‘managed migration’. It’s already been moving small groups over, and now it’s starting to roll this out more widely.

There are a lot of serious problems with Universal Credit and the way it works, or doesn’t work, for many people who need it, as our 2020 report Blunt, Bureaucratic, and Broken set out.

But even if all of those problems with ongoing Universal Credit claims were resolved, managed migration would come with its own risks.

DWP’s approach to managed migration is to send people receiving legacy benefits a Migration Notice. This gives a 3-month deadline to make a new Universal Credit claim.

The big question in all of this is: what happens if someone just doesn’t respond to the Migration Notice?

We’ve repeatedly pressed DWP officials about this. In response, they tell us that people can request an extension (or someone can do so on their behalf). They’re also testing the design of the Migration Notice to see if they can encourage more people to take action, and in some cases will take other action like making a home visit.

This, bluntly, isn’t good enough. It’s DWP that has decided to move people over onto Universal Credit, and it’s DWP that should take responsibility for ensuring no-one loses out. Trying harder and harder to get someone to do what they ‘should’ is all very well, but eventually, if someone doesn’t engage or can’t be contacted, their benefits will be stopped. That has several very serious consequences as it stands:

  • That person will be without any means-tested benefits until they claim Universal Credit. If and when they eventually claim, the claim won’t be backdated
  • They will lose any Transitional Protection they might have been entitled to
  • They might have to go through another Work Capability Assessment

This is a completely unacceptable outcome that DWP should publicly confirm won’t be allowed to happen. Instead, it just says that regrettably, this will happen if someone continually doesn’t engage.

And once people do move on to Universal Credit, the default design of the system looks very different from what they are used to: it’s a monthly payment, which comes per household (not per person), and your help with housing costs comes to you rather than your landlord. The apparent reason for this is to mirror payment patterns in work, so moving into work is less of a change. But many jobs, and especially lower-paid jobs, pay weekly or fortnightly anyway. And many of the people moving to Universal Credit in the coming years are not well enough to work – so even if Universal Credit did mirror work payment patterns, what would be the point?

Universal Credit is able to provide more regular payments, the payment of rent directly to a landlord, or payments split between members of a couple, but you have to request this. There’s no good reason why, at the start of a claim, someone couldn’t be asked to decide how they want to receive their payment. That would be far more empowering than DWP setting its own default for how these payments work.

As the roll-out of managed migration picks up pace, we’ll keep a close eye on how it’s working – and continue to push DWP to make sure no-one loses out.

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