On Wednesday night, the co-chairs of the Timms Review of personal independence payment (PIP) published draft recommendations. These are not the Review’s final recommendations – only ‘emerging’ recommendations that will be tested and refined through workshops with disabled people starting next week – but they give a very clear indication of the Review’s thinking.
The Review’s steering group should be commended for its transparency. By taking the unusual step of publishing the draft recommendations, and agreeing to consult and test the proposals with disabled people before finalising them, the Review is making a clear effort to honour its commitment to openness and working with disabled people to get reform of PIP right. But what about the proposals themselves?
The published recommendations are in two sections. The first section covers recommendations that aim to deliver ‘improvements to the current benefit’. The second section sets out not precise recommendations but higher-level ‘principles for a reformed benefit’. The document does not explicitly set out how the two different sets of proposals interact with each other. However, the implication seems to be that the Review is looking to make recommendations for a two-stage process of reform. The initial stage seems to involve more immediate reforms to PIP, presumably delivered through secondary legislation and changes to policies and process. The second stage seems to consist of a subsequent, more fundamental whole redesign of PIP, which will take considerably longer and require primary legislation.
This blog explores the merits and risks of the draft recommendations and principles set out in the letter from the co-chairs.
The draft recommendations reflect disabled people’s concerns
Let’s start with the positives, and there are a lot of them. Particularly around the recommendations relating to improving the current benefit, there are clear signs that across a number of areas the Review steering group has listened to what Z2K, disabled people and many other organisations have been saying is needed for effective reform of PIP.
The first draft recommendation is a very clear call for the government to ‘reduce unnecessary award reviews for people with lifelong or degenerative conditions’. This is hugely welcome: as we set out in our recent report, Prove It Again: The Cost of Unnecessary PIP Reassessments, ending this sort of unnecessary award review will improve the mental wellbeing and financial security of disabled people and allow Department for Work and Pensions (DWP) resources to be better focused on cases where needs are genuinely likely to change. That this has made its way into the draft recommendations is a testament to all the campaigners who have been raising this issue for so many years.
It’s also really positive to see such a strong focus on addressing the poor quality of PIP decision-making, which is forcing so many disabled people to navigate a complex, lengthy and highly stressful appeals process just to access basic support. Strengthening quality assurance and improving feedback mechanisms from mandatory reconsideration and appeal stage are important steps towards ensuring the DWP gets more decisions right the first time. Alongside this, the Review’s emphasis on improving assessments for people with fluctuating conditions, making greater use of paper-based assessments, and introducing a fast-track pathway for disabled people with the most serious and straightforwardly-evidenced conditions reflects the kinds of interventions called for in previous Z2K research and should help make the process fairer and less distressing.
There are a number of areas where these recommendations could be deepened. Reforms to the award review process should go further by proposing to streamline the process for all disabled people whose needs have not changed, not just those whose primary health condition is always lifelong or degenerative. We would also like to see a stronger explicit focus on improving how medical evidence is used in decision-making, as recommended in our Ending the Culture of Fear report. However, it’s clear that a number of these recommendations suggest that the steering group has heard many of the concerns raised by disabled people and campaigners.
The Review’s vision for a reformed PIP carries significant risks
While the shorter-term changes that the Review is proposing are positive, some of the principles set out for a longer-term reformed version of PIP pose significant concerns.
Setting out the principles for a future reformed benefit, the draft recommendations say that awards for this benefit will be determined by ‘cost categories’, giving the examples of ‘equipment and aids’ or ‘mobility and transport’. Though not made explicit by this document, the implication seems to be that under this reformed version of PIP, the daily living and mobility components and the activities and descriptors that govern eligibility for them would be removed entirely, and would replaced by a more flexible system more directly aligned to specific extra costs. This is a direction of travel that was hinted at in the Review’s interim report, which criticised PIP’s use of task-based descriptors. Suffice to say, it would mean a very radical change to the way PIP works.
On one level, there is an obvious logic to this kind of proposal. If PIP exists to meet the extra costs of disability, then why shouldn’t the criteria for the benefit much more directly align with these actual extra costs? Doesn’t this make more sense than the current system, which is based on twelve activities and descriptors that do not explicitly link directly to the extra costs that the system is designed to cover?
There are two problems with this approach. The first is that it threatens to make an already complex system even more complicated. PIP’s eligibility criteria were designed based on the principle that, in the interests of simplicity, a fixed number of descriptors could act as broad proxies for the many kinds of functional difficulties that were likely to lead to extra costs. While changing the eligibility criteria so that they instead align more directly to each possible extra cost might lead to more nuanced awards that better mirror each individual’s extra costs, the cost of that nuance could well be a more complicated, lengthier and more difficult assessment for each disabled person – something the Review has rightly identified as already a significant problem with the present assessment process.
The second and more fundamental problem is that PIP does much more for disabled people than cover the extra costs of disability. As the DWP’s own research has shown, many disabled people receiving PIP use this money to cover essentials like food, bills and rent. Indeed, the reality for clients of Z2K’s advice services is that PIP is not primarily about the extra costs of disability, but basic survival. As Roxie, a member of Z2K’s disability benefits expert by experience group put it: ‘PIP is what keeps us safe, housed, warm, and able to cope.’
Disabled people are in this position largely because the means-tested part of the working-age social security system – universal credit (UC) – has become increasingly inadequate over recent years. The standard allowance of universal credit sits close to its lowest ever level in real terms at just £98/week, with research by the Joseph Rowntree Foundation showing that it sits well below the amount needed to afford even the most basic day-to-day essentials. What’s more, last year the previous government approved a £3 billion cut to the support for disabled people under universal credit, which has started to take effect from this April. All of this piles more pressure on PIP, stretching it further and further beyond its intended purpose.
The result is that, while focusing PIP awards more precisely on the extra costs of disability might make sense in isolation, it is fraught with huge risks of deepening poverty when considering how PIP is really used by disabled people. We saw how this played out last year, when the previous government tried to reform the rules governing PIP eligibility: impact assessments revealed that these changes would have pushed hundreds of thousands of disabled people into poverty or even deeper into poverty. A more nuanced system based more precisely on specifically extra costs would likely mean some disabled people receiving less support than they do now. When the basic social safety net intended to cover these essential costs is so threadbare, this could have very severe consequences for disabled people’s living standards.
That does not mean a more directly cost-based system could never work. But it can only succeed if it is accompanied by further investment in the means-tested social security system to mitigate its potential impact on disability poverty. That investment would need to be substantial: at a minimum, it would mean implementing the Joseph Rowntree Foundation and Trussell Trust’s proposed Essentials Guarantee in full, and reversing the reduction in the rate of UC-Health introduced by the Universal Credit Act 2025. If the steering group wishes to pursue a more explicitly cost-based model, it should be clear that it will fail unless the inadequacies of universal credit are addressed at the same time.
Any further policy development must also be co-produced with disabled people
While the recommended improvements to the current system set out by the Review’s steering group are relatively precise and granular, the principles for further reform are much more high-level. The draft recommendations imply that any future benefit will not be designed by the steering group as part of the Review but will instead be developed through a subsequent design process.
Principles are important, but when it comes to social security reform, the devil is in the detail. The draft recommendations set out that the reformed benefit will be ‘designed with’ disabled people, but they stop short of recommending that it be co-produced with them in a similar manner to the Review itself.
The government was right to commit to co-produce the Timms Review with disabled people. Co-production leads to more effective, just and workable policies – particularly for disabled people and people living in poverty, who are too often left out of decisions that directly affect their lives. The evidence so far suggests that the co-production of the Review has led to deeper engagement with decision-making and richer insights than a purely DWP-led process.
The next stage of policy development will be high-stakes, and getting it right will be essential if the DWP is to continue rebuilding trust with disabled people. Like the Review, it will be put under careful scrutiny by stakeholders and parliamentarians. The steering group, therefore, should be minded to go further and explicitly recommend that any reformed benefit is co-produced with disabled people, using a similar steering group structure with majority-vote decision-making power as the Timms Review.
The next two months will be critical
The draft recommendations leave a number of questions unanswered. Is the government still planning to abolish the work capability assessment? It isn’t mentioned at all in these draft recommendations, and it’s extremely difficult to see how moving to a more nuanced cost-based eligibility criteria is in any way compatible with PIP becoming the gateway to UC-Health. Will the substitution of in-kind support for some cash elements alluded to in the recommendations, which has been the focus of much of the initial reaction, be mandatory or optional? That, no doubt, will be the subject of much concern for many disabled people as these proposals develop. As the Review finalises its recommendations ahead of its expected final report in the autumn, the next two months will be critical.
It is easy for the dominant public discourse around disability benefits reform to lead those who are fighting for a better system to despair. But last week provided two small reasons for hope. First, a new report found that the majority of the British public supports increasing spending on disability benefits: not what you might have thought if you’ve picked up a newspaper recently. Then, during a skirmish between Andy Burnham and Kemi Badenoch at Prime Minister’s Questions, the prime minister made headlines for saying that ‘national security can’t come at the expense of social security’. It was striking to hear a government minister talk about the social security system in such straightforwardly positive terms. Time will tell if ministers are truly serious about making the positive case for our social security system: but if they are, that must mean designing reforms that genuinely improve disabled people’s lives, rather than pushing them deeper into poverty.
