Charity demands transparency in digital universal credit system
The digital universal credit system needs overhauling to ensure greater transparency over benefit claims and more effective means of redress when things go wrong, says child poverty charity
The design of the digital universal credit (UC) system means claimants are “routinely” left without basic information about their own benefit claims, making it difficult to challenge decisions and leading to incorrect payments, Child Poverty Action Group (CPAG) research has found.
Following a three-year investigation into how well the implementation of UC aligns with its underpinning social security legislation, CPAG found the architecture of the UK’s first digital-by-design benefit does not permit certain features of the social security system to operate as intended, and that the design of the digital claim process is leaving people without the basic information needed to manage their benefits.
Sophie Howes, head of policy and research at CPAG, told Computer Weekly that while the negative role of algorithms and automated decision-making in benefits claims has received a fair amount of attention in recent years, the charity’s research shows the Department for Work and Pensions’ (DWP’s) digital design choices can also cause problems for claimants.
She added that although there are clear benefits of moving benefits such as UC to a digital platform for both administrators and claimants, from CPAG’s perspective, the benefits have so far largely accrued to the former.
“The DWP has created the system through the lens of what’s easiest for it to administrate, rather than thinking about where this digital system can support claimants and make their lives easier,” said Howes, adding that, for example, the automated feeding of earnings information from HMRC to the DWP shows how digitising benefits can reduce the administrative burden for claimants.
“It does feel like DWP have designed a system that works well for them, but they maybe need to put a bit more thought into how it works for claimants,” she said.
For instance, while the social security legislation allows certain groups of people to be able to submit a UC claim up to a month in advance, CPAG claims in its report that the DWP has designed a digital system that does not permit any UC claims to be accepted early, and that it has provided no adequate workaround outside the digital system. It added that the digital claims process also does not allow a claim to be submitted until all the questions have been answered, even though the law itself does not require answers to these questions to make a valid claim.
Specific circumstances
On top of this, CPAG found the digital claims process does not gather all the information needed to correctly calculate claimants’ awards, with the onus being placed on individuals to navigate a complex benefit landscape and identify whether specific circumstances apply to them. They are also expected to raise this to DWP themselves without any prompting.
CPAG claims this is all leading to delays in claims being submitted, in turn causing people to miss out on benefits they are entitled to and breaching legal principles around procedural fairness.
Howes said that while most people can claim UC without experiencing problems, the fact that nearly six million people are claiming means a significant number of people will be affected by these issues.
In his foreword to CPAG’s report, former judge John Mesher similarly noted that while millions are effectively supported by UC, “the sheer cumulation of problems reported means that they cannot be dismissed as mere unfortunate unintended consequences of a fundamentally sound system”.
He said the evidence gathered by CPAG demonstrates the “systemic issues that have been built into the design of the UC digital system and not corrected since”, adding that “even claimants paid accurately and on time will often have difficulty in working out how their entitlement has been calculated”.
Challenging DWP decisions
CPAG said the lack of transparency around UC claims also limits people’s ability to challenge DWP decisions about their benefits, especially given the fact that when a UC award is changed, claimants are only able to see the new decision information and have no oversight of previous decisions.
“Without being able to compare the original with the new payment decision, claimants have insufficient information to identify whether any overpayments or underpayments have been calculated correctly,” it said.
“Similarly, claimants who previously received UC and then make a new claim lose all access to their previous online journal because it is overwritten by a new one. This is a problem for claimants who want to challenge a termination of their award and for those looking to resolve outstanding issues on the original award.”
It added that claimants in this position can only access their previous online journal information by querying the information available via the UC helpline, applying for a subject access request or waiting for the information to be reproduced in the paperwork prepared for a challenge of the decision at a Tribunal.
Howes said that while UC’s digitisation is therefore leading to payment errors on the one hand, on the other it is not allowing people to effectively appeal DWP decisions. “The combination of the two is quite concerning,” she said, adding that CPAG’s goal is to have “universal credit as accurate as it possibly can be, so that people get the money they’re entitled to in a timely manner … and then if mistakes are made, people need a quick resolution to that”.
Recommendations for change
To help alleviate the issues faced by UC claimants, CPAG has made a number of recommendations based on its findings, most of which revolve around increasing transparency around the system.
Howes said that while some of the recommendations involve bigger changes that might require more resources, most are smaller changes that could be actioned quickly and have a big impact.
The recommended changes include updating the digital claim process to ensure all relevant questions are asked; providing claimants with more expansive information about how their benefits are calculated; stopping the practice of overwriting information about previous decisions and allowing original material to be seen for comparisons; and amending the digital process to allow for advanced claims to be made.
Other recommendations include amending the appeals notice to accurately reflect claimants’ appeal rights, and making the source code for the UC system publicly available.
“At a system-wide level, the DWP has not made the source code for UC publicly available, despite this being a requirement of the service standards of the Government Digital Service, with the UC digital system having been paid for by the public via their taxes,” it said, adding that the DWP has already committed to publishing the source code for its personal independence payment and pension credit systems.
“If the UC digital system source code was made public, there could be increased scrutiny; interested parties could check whether there are errors, suggest fixes and solutions to improve the system, and understand if there are legitimate technical reasons why some changes are difficult for the DWP to make,” it continued.
“When the DWP asserts that changes to the UC digital system would be too costly or too damaging to the internal architecture, these assertions cannot be substantiated or fairly challenged due to a lack of information in the public domain.”
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Howes added that although the DWP has been open to dialogue with CPAG, “ultimately we need to see actual changes to the universal credit system”.
“The department has told us that the digital design team are aware of the issues we’ve raised and looking at solutions, but they have lots of competing priorities – we just feel like there’s only so much patience, these issues do actually affect claimants’ lives and they need to prioritise it,” she said.
Responding to the findings of the CPAG research and the claims detailed, a DWP spokesperson said: “Our welfare system helps millions of people every year and it is vital that it can be accessed by all who need it.
“We are aware of the research conducted by Child Poverty Action Group and will be meeting them in the coming weeks to discuss their findings in more detail.”
As part of its investigation, CPAG reviewed roughly 2,500 cases from its Early Warning System (a bank of more than 6,500 case studies from welfare rights advisers that details problems they are seeing in the social security system); sent around 50 freedom of information requests for operational guidance, training materials and administrative data; and conducted interviews with 13 welfare rights advisers and 28 UC claimants.
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