The DWP has revealed more details of what now seems to be a shambolic system for assessing claimants for the Severe Disability Group. According to the latest DWP update, membership will be based on a confused, ad hoc collection of criteria.
Depending on the claimant’s diagnosis, entry may be based on:
- medically precise definitions that have no connection with the benefits system at all; or
- on information that only the claimant or carer will know, but a specialist will still have to provide; or
- the availability of specialist services where the claimant lives; or
- even on no clear criteria at all.
There is also a lack of clarity on the overlap between the Severe Disability Group and the light-touch review system for PIP.
And some claimants are voicing the suspicion that the creation of separate group of severely disabled claimants could be aimed at reducing future payments for allegedly less severely disabled people.
What is the Severe Disability Group?
The purpose of the Severe Disability Group, according to the DWP, is to improve the assessment process for claimants who have conditions which are severely disabling, lifelong and with no realistic prospect of recovery.
Claimants who fit the criteria will not need to complete a detailed application form or go through a face-to-face assessment for PIP or the WCA.
There’s more details about the scheme here.
But, in essence, claimants will need to show that they have a condition that will not improve, that it is managed or was diagnosed by a specialist, that they need help from another person with at least two daily living activities and that they would qualify for the support group or for at least one enhanced PIP component.
There are then different criteria for different conditions, which also need to be met.
Medically precise definitions
It has long been a basic principle of disability benefits that it is not the condition that matters, it is how it affects your everyday activities.
Yet, for entry to the Severe Disability Group, it is very much the condition that counts. In some cases, only those who meet specific medical assessment criteria will qualify. For example (please note, the links are provided by Benefits and Work, not the DWP):
for autism you need to meet DSM 5 level 2 or 3;
for heart failure, New York Heart Association (NYHA) 3 or 4;
for multiple sclerosis you need to score more than 6 on the Expanded Disability Status Scale;
for Parkinson’s Disease, you must score 21 to 30 on the UPDRS.
Very often, scores like this will not appear anywhere in NHS records, so new evidence will have to be provided by a specialist.
In addition, many claimants who do not meet these scores will still be in receipt of PIP at the enhanced levels for both components and have no possibility of their condition improving. Yet they will not be eligible for the Severe Disability Group.
Only the claimant will know
For some conditions the criteria are not only less precisely defined, but they are also ones that a specialist will not be able to give first-hand give evidence on.
For epilepsy, you need to have “incapacitating seizures at least once per week despite optimal medical therapy”. But probably the only person who can give detailed evidence on the frequency of seizures will be the claimant themselves or a carer, if they have one. A consultant’s evidence will be hearsay at best.
The only criteria given for strokes is that the claimant “requires assistance from another person to mobilise, dress and feed themselves”. But this is something that would probably be better judged by an occupational therapist than a specialist and, ultimately, only the claimant or their carer will have first-hand, daily knowledge about this.
Availability of services
For some conditions, access to the Severe Disability Group will depend on having services available in your area.
For example, for bipolar disorder or depression, you will need to show that you are “under the care of specialist psychiatric services” and have a “history of recurrent admissions or crisis team treatment”. If the NHS in your area is too overstretched to provide these services in your case, then you will be unlikely to qualify.
For OCD, you will need to show that you have failed to “respond to treatment by intensive specialist treatment services”. This assumes that such services exist in your area and are available to you.
For ME/CFS, you will have to show that “all treatment options provided by specialist pain and fatigue services have been exhausted”. Again, such services may not even exist where you live, may have a very long waiting list or may not be accessible to you because of the travel time involved.
No clear criteria at all
For people with multiple conditions – and that would include a huge proportion of claimants – the DWP explains that entry to the Severe Disability Group may be available:
multiple impairments, for example combinations of COPD, coronary artery disease, diabetes and obesity that would not meet the criteria as single conditions but may do so if present in combination.
But there is no explanation of how this would work in practice. If you don’t meet the criteria for any single condition, what do you have to prove in order to meet the unexplained criteria for multiple impairments?
And which health professional would be the one required to provide the evidence?
All of this remains unexplained.
Overlap with light-touch reviews
Oner of the questions that has yet to be answered is how the Severe Disability Group will overlap with the light-touch review system for PIP.
In July 2023 the DWP began sending out the PIP AR2 light-touch review form to claimants who have:
- very stable needs which are unlikely to change over time
- high level needs which will either stay the same or get worse
- a planned award review date due on or at State Pension age
The AR2 form is very much shorter, is unlikely to result in a face-to-face assessment and has to be completed only once every ten years.
On the face of it, this seems to be similar to the Severe Disability Group, at least for PIP claimants. And it has the advantage that it does not require any medical evidence in order to qualify.
But what isn’t clear is whether the Severe Disability Group will replace the light-touch system, run parallel with it or whether a claimant could be subject to both systems.
Lower payments for non-severe claimants?
Government voices have been issuing warnings about the cost of disability and incapacity benefits for some time. They claim that far too many people are being placed in the support group and that the cost of PIP is spiralling out of control.
This has led some claimants to suspect that the Severe Disability Group is the first step towards cutting the cost of these benefits in the future.
The theory is that, if you divide disabled claimants in to severe and non-severe groups, you can argue that claimants who are not severely disabled should not be entitled to as high a rate of support as those who are.
This is exactly what was done with the WCA, when new claimants in the limited capability for work category were deprived of the additional amount that had previously been awarded. For new claims now, only those with limited capability for work-related activity get an additional amount.
It is very unlikely that any government would try to reduce current PIP claimants’ awards, because of the unquestionably enormous backlash.
But an altered payments system for new PIP claimants in the future is not hard to imagine and would cause much less controversy, though we should stress that the DWP have made no suggestion that this is their intention.
Specific condition criteria
Below, we’ve listed some of the more detailed criteria that the DWP have now published for different conditions. There’s more on this DWP page.
We’d really like to hear from claimants with experience of any of these conditions as to whether you think the criteria are reasonable and whether you think you would qualify. Please use the comments section to let us know.
Please note, the links are provided by Benefits and \Work, not the DWP.
Arthritis
Late or poorly controlled inflammatory arthritis
Autism
Autism spectrum disorders - meet the DSM 5 level 2 or level 3 criteria - requiring substantial or very substantial support (annex 2)
Bipolar disorder/depression
Long term severe depression or bipolar disorder failing to significantly respond to treatment, under the care of specialist psychiatric services, indicators of unstable mood and worsening functioning requiring ongoing high levels of care or supervision including history of recurrent admissions or crisis team treatment, decreasing intervals between episodes of relapse or rapid cycling
COPD
Severe chronic respiratory condition (e.g. chronic obstructive pulmonary disease (COPD), fibrotic interstitial lung disease, diffuse pleural thickening) with grade 5 MRC breathlessness (too breathless to leave the house or breathless when dressing or undressing)
Epilepsy
Intractable epilepsy with associated cognitive impairment and incapacitating seizures at least once per week despite optimal medical therapy
Heart failure
Heart failure with reduced ejection fraction on maximal possible tolerated medical therapy and cardiac resynchronisation therapy if indicated, with ongoing limiting symptoms, New York Heart Association (NYHA) 3 or 4 and not a candidate for cardiac transplant
IBD
Treatment resistant inflammatory bowel disease
OCD
Longstanding obsessive-compulsive disorder (OCD), failing to respond to treatment by intensive specialist treatment services, with severe ongoing symptoms resulting in significant difficulties with ADLs
ME/CFS
Syndromes characterised by chronic pain and fatigue where symptoms are longstanding, affect multiple activities of daily living (ADLs) and confirmation that all treatment options provided by specialist pain and fatigue services have been exhausted
MS
Advanced multiple sclerosis scoring more than 6 on the Expanded Disability Status Scale (EDSS)
Multiple physical conditions
Multiple impairments, for example combinations of COPD, coronary artery disease, diabetes and obesity that would not meet the criteria as single conditions but may do so if present in combination
Parkinson’s disease
Advanced Parkinson’s disease with bilateral symptoms of tremor, rigidity and bradykinesia and impairment of balance, a Unified Parkinson’s Disease Rating Scale (UPDRS) score of 21 to 30 and requiring assistance from another person with most activities of daily living
Schizophrenia
Longstanding schizophrenia, failing to significantly respond to all treatment or rehabilitative options, under the care of specialist psychiatric or support services, significant continuing symptoms and poor self-care requiring ongoing high levels of care and or supervision
Stroke
Stroke, for example where the person requires assistance from another person to mobilise, dress and feed themselves
